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: KEMPER JONATHAN M (Director, Vice Chairman)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-12-13	Common Stock	A	156	$49.04	Acquired	35260	Indirect

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	858830	Direct
Common Stock	16638	Indirect
Common Stock	19031	Indirect
Common Stock	23641	Indirect
Common Stock	112447	Indirect
Common Stock	39897	Indirect
Common Stock	212858	Indirect
Common Stock	19013	Indirect
Common Stock	143533	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.