SEC FORM 4

SEC Form 4

FORM 4

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

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Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

1. Name and Address of Reporting Person^*

ANDERSON ANDREW F

(Last)

(First)

(Middle)

P O BOX 13686

(Street)

KANSAS CITY

64199-3686

(City)

(State)

(Zip)

2. Issuer Name and Ticker or Trading Symbol
COMMERCE BANCSHARES INC /MO/ [ CBSH ]

5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

	Director	10% Owner
X	Officer (give title below)	Other (specify below)
	Senior Vice President

3. Date of Earliest Transaction (Month/Day/Year)
04/15/2004

4. If Amendment, Date of Original Filed (Month/Day/Year)

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	3. Transaction Code (Instr. 8)		4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5)			5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4)	6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	Code	V	Amount	(A) or (D)	Price		6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
Common Stock	04/15/2004		M		7,846	A	$29.9699	101,342	D
Common Stock	04/15/2004		M		3,535	A	$33.4553	104,877	D
Common Stock	04/15/2004		M		7,524	A	$34.1756	112,401	D
Common Stock	04/15/2004		M		3,150	A	$35.4476	115,551	D
Common Stock	04/15/2004		M		4,962	A	$38.458	120,513	D
Common Stock	04/15/2004		M		276	A	$35.3742	120,789	D
Common Stock	04/15/2004		S		8,000	D	$44.75	112,789	D
Common Stock	04/15/2004		S		450	D	$44.48	112,339	D
Common Stock	04/15/2004		S		1,550	D	$44.47	110,789	D
Common Stock	04/15/2004		S		2,300	D	$44.42	108,489	D
Common Stock	04/15/2004		S		696	D	$44.4	107,793	D
Common Stock	04/15/2004		S		200	D	$44.39	107,593	D
Common Stock	04/15/2004		S		300	D	$44.37	107,293	D
Common Stock	04/15/2004		S		2,250	D	$44.36	105,043	D
Common Stock	04/15/2004		S		1,547	D	$44.35	103,496	D
Common Stock	04/15/2004		S		2,000	D	$44.32	101,496	D
Common Stock	04/15/2004		S		1,150	D	$44.2	100,346	D
Common Stock	04/15/2004		S		373	D	$44.3	99,973	D
Common Stock	04/15/2004		S		1,000	D	$44.29	98,973	D
Common Stock	04/15/2004		S		843	D	$44.26	98,130	D
Common Stock	04/15/2004		S		2,050	D	$44.25	96,080	D
Common Stock	04/15/2004		S		100	D	$44.24	95,980	D
Common Stock	04/15/2004		S		484	D	$44.21	95,496	D
Common Stock	04/15/2004		S		1,400	D	$44.19	94,096	D
Common Stock	04/15/2004		S		100	D	$44.18	93,996	D
Common Stock	04/15/2004		S		500	D	$44.16	93,496	D
Common Stock								256	I	By Daughter
Common Stock								239	I	By Son
Common Stock								198	I	By Wife

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	4. Transaction Code (Instr. 8)		5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5)		6. Date Exercisable and Expiration Date (Month/Day/Year)		7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4)		8. Price of Derivative Security (Instr. 5)	9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4)	10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	Code	V	(A)	(D)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares	8. Price of Derivative Security (Instr. 5)		10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
Non-Qualified Stock Option (right to buy)	$35.4476	04/15/2004		M			3,150	03/06/2003	03/05/2013	Common Stock	3,150	$0	3,150	D
Stock Option (right to buy)	$29.9699	04/15/2004		M			7,846	02/01/1999	02/01/2009	Common Stock	7,846	$0	0	D
Stock Option (right to buy)	$33.4553	04/15/2004		M			3,535	02/05/1998	02/05/2008	Common Stock	3,535	$0	0	D
Stock Option (right to buy)	$34.1756	04/15/2004		M			7,524	03/06/2001	03/05/2011	Common Stock	7,524	$0	0	D
Stock Option (right to buy)	$35.3742	04/15/2004		M			276	09/30/2002	09/30/2012	Common Stock	276	$0	275	D
Stock Option (right to buy)	$38.458	04/15/2004		M			4,962	03/07/2002	03/06/2012	Common Stock	4,962	$0	1,653	D

Explanation of Responses:

	By: Jeffery D. Aberdeen For: Andrew F. Anderson	04/16/2004
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 4 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.