CORRESP Filing
COMMERCE BANCSHARES INC /MO/
Date: Sept. 8, 2025 · CIK: 0000022356 · Accession: 0001104659-25-088320
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-289873
Letter
Commerce Bancshares, Inc.
1000 Walnut Street
Kansas City, Missouri 64106
September 8, 2025
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporate Finance
100 F Street, NE
Washington, DC, 20549
Attn: Robert Arzonetti
Re: Commerce Bancshares, Inc.
Acceleration Request
Registration Statement on Form S-4/A
File No. 333-289873
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, and in connection with the above-referenced Registration Statement (the " Registration Statement "), Commerce Bancshares, Inc., a Missouri corporation (the " Company "), hereby respectfully requests that the U.S. Securities and Exchange Commission (the " Commission ") declare the Registration Statement effective on Wednesday, September 10, 2025, at 4:30 p.m., Eastern Time, or as soon thereafter as practicable.
The Company hereby authorizes Paul M. Aguggia of Holland & Knight LLP, attorney for the Company, to orally modify or withdraw this request for acceleration.
Please provide a copy of the Commission's order declaring the Registration Statement effective to Paul M. Aguggia, Holland & Knight LLP, 800 17th Street N.W., Suite 1100, Washington, DC 20006.
If you have any questions regarding this request, please telephone Paul M. Aguggia at (202) 469-5422 or, in his absence, Shawn M. Turner at (303) 974-6645 at the law firm of Holland & Knight LLP.
Very truly yours,
/s/
John W. Kemper.
Show Raw Text
CORRESP 1 filename1.htm Commerce Bancshares, Inc. 1000 Walnut Street Kansas City, Missouri 64106 September 8, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporate Finance 100 F Street, NE Washington, DC, 20549 Attn: Robert Arzonetti Re: Commerce Bancshares, Inc. Acceleration Request Registration Statement on Form S-4/A File No. 333-289873 Ladies and Gentlemen: Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, and in connection with the above-referenced Registration Statement (the " Registration Statement "), Commerce Bancshares, Inc., a Missouri corporation (the " Company "), hereby respectfully requests that the U.S. Securities and Exchange Commission (the " Commission ") declare the Registration Statement effective on Wednesday, September 10, 2025, at 4:30 p.m., Eastern Time, or as soon thereafter as practicable. The Company hereby authorizes Paul M. Aguggia of Holland & Knight LLP, attorney for the Company, to orally modify or withdraw this request for acceleration. Please provide a copy of the Commission's order declaring the Registration Statement effective to Paul M. Aguggia, Holland & Knight LLP, 800 17th Street N.W., Suite 1100, Washington, DC 20006. If you have any questions regarding this request, please telephone Paul M. Aguggia at (202) 469-5422 or, in his absence, Shawn M. Turner at (303) 974-6645 at the law firm of Holland & Knight LLP. Very truly yours, /s/ John W. Kemper. John W. Kemper Chief Executive Officer cc: Margaret M. Rowe (Commerce Bancshares, Inc.) Paul M. Aguggia (Holland & Knight LLP) Shawn M. Turner (Holland & Knight LLP) 1