COMMERCE BANCSHARES INC /MO/ — Director's Dealing 2004

Dec 29, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMMERCE BANCSHARES INC /MO/ (CBSH)
CIK: 0000022356
Period of Report: 2004-12-28

Reporting Person: BARTH KEVIN G (Senior Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-12-28	Common Stock	M	6104	$11.869	Acquired	20063	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2004-12-28	Stock Option (right to buy)	$11.869	M	6104	Disposed	2005-02-03	Common Stock (6104)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	8996	Indirect
Common Stock	4447	Indirect