SecProbe.io

July 8, 2013

Via E -Mail
Jeffrey D. Aberdeen
Controller
Commerce Bancshares, Inc.
1000 Walnut
Kansas City, Missouri 64106

Re: Commerce Bancshares, Inc.
  Registration Statement on Form S-4
Filed  June 21, 2013
  File No.  333-189535

Dear Mr. Aberdeen :

We have limited our review of your registration statement to the issue we have addressed
in our comment below.  In our comment, we ask you to provide us with information so we may
better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information.   Where you do not believe our comment applies to your facts and
circumstances or do not  believe an amendment is appropriate, please  tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments.

The Merger, page 14

Background of Negotiations, page 15

1. We note the references to D.A. Davidson’s presentations to the Boards of Directors of
Summit and Summit Bank.  Information about any reports, opinions or appraisals that are
materially related to the transaction and refe rred to in the registration statement are
required to be disclosed in the registration statement and filed as exhibits.  To the extent
not already provided, please revise your disclosure to provide the information required by
Item 1015(b) of Regulation M -A.  Please note that oral reports, if material, should be
summarized and disclosed in the registration statement or filed as exhibits.  Further,
please provide us a copy of any board books or similar materials for our review.  Please
refer to Items 4(b) and  21(c) of Form S -4.

Jeffrey D. Aberdeen
Commerce Bancshares, Inc.
July 8, 2013
Page 2

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the  disclosures they have made.

Notwithstanding our comments, in the event you request acceleratio n of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not for eclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding reques ts for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities  Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective  date of  the
registration statement.

Please contact  Ramin Olson  at (202) 551 -3331 , Laura Crotty at (202) 551 -3563,  or me at
(202) 551 -3675 w ith any questions you may have.

Sincerely,

        /s/ Laura Crotty for

Suzanne Hayes
Assistant Director