[Commerce Bancshares, Inc. Letterhead]

July 30, 2013

Via EDGAR Transmission

Securities and Exchange Commission

Division of Corporation Finance

Attention: Suzanne Hayes

100 F Street, N.E.

Washington, D.C. 20549-4561

Re:	Commerce Bancshares, Inc.
	Registration Statement on Form S-4
	File No. 333-189535

Dear Ms. Hayes:

Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, Commerce Bancshares, Inc. (the “Company”) hereby requests acceleration of the effective date of the above-referenced registration statement so that the Registration Statement will become effective as of 4:30 p.m. Eastern Time, July 30, 2013, or as soon thereafter as practicable.

Very truly yours,

/s/ Thomas J. Noack

Thomas J. Noack, Vice President and Secretary