[Commerce Bancshares, Inc. Letterhead]
July 30, 2013
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 |
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 | |
