COMMERCE BANCSHARES INC /MO/ — Director's Dealing 2005

Dec 15, 2005

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMMERCE BANCSHARES INC /MO/ (CBSH)
CIK: 0000022356
Period of Report: 2005-12-14

Reporting Person: KEMPER JONATHAN M (Director, Vice Chairman)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2005-12-14	Common Stock	A	161	$53.26	Acquired	37724	Indirect

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	913001	Direct
Common Stock	18067	Indirect
Common Stock	19982	Indirect
Common Stock	24823	Indirect
Common Stock	118069	Indirect
Common Stock	41891	Indirect
Common Stock	220875	Indirect
Common Stock	19963	Indirect
Common Stock	150709	Indirect

Footnotes

F1: Stock holdings adjusted to include 5% stock dividend - record date 11/29/05; payable 12/13/05.