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: MATTHEWS ROBERT C JR (Executive Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-12-01	Common Stock	M	7570	$11.869	Acquired	22054	Direct
2004-12-01	Common Stock	M	14898	$11.869	Acquired	36952	Direct
2004-12-01	Common Stock	F	1804	$49.8	Disposed	35148	Direct
2004-12-01	Common Stock	S	786	$49.44	Disposed	34362	Direct
2004-12-01	Common Stock	S	640	$49.4	Disposed	33722	Direct
2004-12-01	Common Stock	S	5360	$49.39	Disposed	28362	Direct
2004-12-01	Common Stock	S	1000	$49.38	Disposed	27362	Direct
2004-12-01	Common Stock	S	700	$49.37	Disposed	26662	Direct
2004-12-01	Common Stock	S	300	$49.36	Disposed	26362	Direct
2004-12-01	Common Stock	S	1000	$49.31	Disposed	25362	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2004-12-01	Stock Option (right to buy)	$11.869	M	7570	Disposed	2005-02-03	Common Stock (7570)	Direct
2004-12-01	Stock Option (right to buy)	$11.869	M	14898	Disposed	2005-02-03	Common Stock (14898)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	16305	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.