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

Dec 22, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMMERCE BANCSHARES INC /MO/ (CBSH)
CIK: 0000022356
Period of Report: 2004-12-20

Reporting Person: KEMPER JONATHAN M (Director, Vice Chairman)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-12-20	Common Stock	F	5056	$48.61	Disposed	853774	Direct
2004-12-20	Common Stock	F	4883	$48.61	Disposed	848891	Direct
2004-12-20	Common Stock	M	20000	$11.869	Acquired	868891	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2004-12-20	Stock Option (right to buy)	$11.869	M	20000	Disposed	2005-02-02	Common Stock (20000)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	16638	Indirect
Common Stock	19031	Indirect
Common Stock	23641	Indirect
Common Stock	35260	Indirect
Common Stock	112447	Indirect
Common Stock	39897	Indirect
Common Stock	212858	Indirect
Common Stock	19013	Indirect
Common Stock	143533	Indirect