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

Feb 1, 2005

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMMERCE BANCSHARES INC /MO/ (CBSH)
CIK: 0000022356
Period of Report: 2005-01-28

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

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2005-01-28	Common Stock	A	1452	—	Acquired	879496	Direct

Derivative Transactions

Date	Security	Exercise Price	Code	Shares	A/D	Expiration	Underlying	Ownership
2005-01-28	Non-Qualified Stock Option (right to buy)	$47.16	A	36000	Acquired	2015-01-28	Common Stock (36000)	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	16801	Indirect
Common Stock	19031	Indirect
Common Stock	23641	Indirect
Common Stock	35260	Indirect
Common Stock	112447	Indirect
Common Stock	39897	Indirect
Common Stock	212858	Indirect
Common Stock	19013	Indirect
Common Stock	143533	Indirect

Footnotes

F1: Award of stock pursuant to Commerce Bancshares, Inc. Restricted Stock Plan.

F2: The option vests in four equal annual installments beginning on January 28, 2005.