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SEC Company Response from COMMERCE BANCSHARES (CBSH) — Jul 30, 2013

COMMERCE BANCSHARES INC /MO/ (CBSH) (CIK 0000022356)
Date: July 30, 2013 · CIK: 0000022356 · Accession: 0000922907-13-000310

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File numbers found in text: 333-189535

Date
July 30, 2013
Author
/s/ Thomas J. Noack
Form
CORRESP
Company
COMMERCE BANCSHARES INC /MO/ (CBSH) (CIK 0000022356)

Letter

Via EDGAR Transmission Securities and Exchange Commission Division of Corporation Finance Attention: Suzanne Hayes Re: Commerce Bancshares, Inc. Registration Statement on Form S-4 File No. 333-189535

Dear Ms. Hayes:

Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, Commerce Bancshares, Inc. (the “Company”) hereby requests acceleration of the effective date of the above-referenced registration statement so that the Registration Statement will become effective as of 4:30 p.m. Eastern Time, July 30, 2013, or as soon thereafter as practicable.

Very truly yours,
/s/ Thomas J. Noack

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CORRESP
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    correspondence_073013.htm

[Commerce Bancshares, Inc. Letterhead]

July 30, 2013

Via EDGAR Transmission

Securities and Exchange Commission

Division of Corporation Finance

Attention: Suzanne Hayes

100 F Street, N.E.

Washington, D.C. 20549-4561

Re:

Commerce Bancshares, Inc.

Registration Statement on Form S-4

File No. 333-189535

Dear Ms. Hayes:

Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, Commerce Bancshares, Inc. (the “Company”) hereby requests acceleration of the effective date of the above-referenced registration statement so that the Registration Statement will become effective as of 4:30 p.m. Eastern Time, July 30, 2013, or as soon thereafter as practicable.

Very truly yours,

/s/ Thomas J. Noack

Thomas J. Noack, Vice President and Secretary