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

Dec 3, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMMERCE BANCSHARES INC /MO/ (CBSH)
CIK: 0000022356
Period of Report: 2004-12-01

Reporting Person: KIM CHARLES G (Executive Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-12-01	Common Stock	S	3701	$49.68	Disposed	11771	Direct
2004-12-01	Common Stock	S	1300	$49.75	Disposed	10471	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	7567	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.