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

Nov 4, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMMERCE BANCSHARES INC /MO/ (CBSH)
CIK: 0000022356
Period of Report: 2004-11-03

Reporting Person: KEMPER DAVID W (Director, Chairman of the Board, CEO)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-11-03	Common Stock	S	3150	$49.04	Disposed	983231	Direct
2004-11-03	Common Stock	S	650	$49.02	Disposed	982581	Direct
2004-11-03	Common Stock	S	1640	$48.95	Disposed	980941	Direct
2004-11-03	Common Stock	S	300	$49.01	Disposed	980641	Direct
2004-11-03	Common Stock	S	2093	$49	Disposed	978548	Direct
2004-11-03	Common Stock	S	1300	$48.98	Disposed	977248	Direct
2004-11-03	Common Stock	S	867	$48.96	Disposed	976381	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	10747	Indirect
Common Stock	1461	Indirect
Common Stock	18125	Indirect
Common Stock	18129	Indirect
Common Stock	5680	Indirect
Common Stock	18129	Indirect
Common Stock	1907208	Indirect
Common Stock	37998	Indirect
Common Stock	136699	Indirect
Common Stock	18117	Indirect