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

Dec 14, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMMERCE BANCSHARES INC /MO/ (CBSH)
CIK: 0000022356
Period of Report: 2004-12-13

Reporting Person: KIM CHARLES G (Executive Vice President)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-12-13	Common Stock	M	7570	$11.869	Acquired	18041	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2004-12-13	Stock Option (right to buy)	$11.869	M	7570	Disposed	2005-02-02	Common Stock (7570)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	7567	Indirect