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

Dec 8, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMMERCE BANCSHARES INC /MO/ (CBSH)
CIK: 0000022356
Period of Report: 2004-12-06

Reporting Person: RAUSCHER ROBERT (Senior Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-12-06	Common Stock	M	575	$15.3094	Acquired	5390	Direct
2004-12-06	Common Stock	F	177	$49.52	Disposed	5213	Direct
2004-12-06	Common Stock	M	1950	$11.869	Acquired	7163	Direct
2004-12-06	Common Stock	F	467	$49.52	Disposed	6696	Direct
2004-12-06	Common Stock	M	2602	$21.1371	Acquired	9298	Direct
2004-12-06	Common Stock	F	1110	$49.52	Disposed	8188	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2004-12-06	Stock Option (right to buy)	$11.869	M	1950	Disposed	2005-02-03	Common Stock (1950)	Direct
2004-12-06	Stock Option (right to buy)	$15.3094	M	575	Disposed	2006-02-08	Common Stock (575)	Direct
2004-12-06	Stock Option (right to buy)	$21.1371	M	2602	Disposed	2007-02-05	Common Stock (2602)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	5374	Indirect

Footnotes

F1: All holdings reported in column 5 of this form have been restated for a 5% stock dividend, ex-date 11/24/2004.