Commerce Funds NCSRS Certified semi-annual shareholder report (management investment company)

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM N-CSR

CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT

INVESTMENT COMPANIES

Investment Company Act file number 811-8598

The Commerce Funds

(Exact name of registrant as specified in charter)

922 Walnut St., Fourth Floor, Mail Code = TB4-1, Kansas City, Missouri 64106

(Address of principal executive offices) (Zip code)

Diana E. McCarthy, Esq.,

Drinker Biddle & Reath LLP

One Logan Square, Suite 2000

Philadelphia, PA 19103

(Name and address of agent for service)

Registrant’s telephone number, including area code:1-800-995-6365

Date of fiscal year end 10/31

Date of reporting period: 4/30/11

ITEM 1.

REPORTS TO SHAREHOLDERS

The Semi-Annual Report to Shareholders pursuant to Rule 30e-1 under the Investment Company Act of 1940 (17 CFR 270.30e-1) is filed herewith.

LOGO

The Commerce Funds

Semi-Annual Report

April 30, 2011

LOGO

For Your Life’s Direction

At The Commerce Funds, we’re committed to providing sound investment choices to help you realize your most important financial goals, no matter where life takes you.

We offer a full range of mutual funds managed by Commerce Investment Advisors, Inc., a subsidiary of Commerce Bank. With a choice of 8 portfolios—each targeting a specific investment goal—we make it easy for you to invest with confidence not

just today, but throughout all the stages of your life.

Behind each of our Funds is a carefully defined investment philosophy and a commitment to the highest investment standards. This means, whether you are building a nest egg for retirement, planning for your child’s education, or saving for a special need, you can find investment options at The Commerce Funds.

Risk/Reward

The Commerce Funds

Risk

MidCap Growth

Growth

Value

Kansas Tax-Free

Intermediate Bond

Missouri Tax-Free

Intermediate Bond

National Tax-Free

Intermediate Bond

Bond

Short-Term Government

Potential

Return

In general, greater returns are associated with greater risks and increased risks create the potential for greater losses.

COMMERCE FUNDS

Table of Contents


Performance and Expense Ratio Information			2

Schedules of Investments

Growth			3

Value			5

MidCap Growth			7

Bond			9

Short-Term Government			18

National Tax-Free Intermediate Bond			22

Missouri Tax-Free Intermediate Bond			29

Kansas Tax-Free Intermediate Bond			37

Statements of Assets and Liabilities			42

Statements of Operations			44

Statements of Changes in Net Assets			46

Financial Highlights			50

Notes to Financial Statements			58

Other Information			70

Please note:

The information in this semi-annual report is as of April 30, 2011 and is unaudited. To view more recent information about each Commerce Fund’s performance and portfolio or to obtain a prospectus, please visit our website at www.commercefunds.com. This report is not authorized for distribution to prospective shareholders unless accompanied or preceded by a prospectus, which contains more complete information about the Commerce Funds’ investment policies, management and expenses. Investors should read the prospectus carefully before investing.

You may also receive Commerce Funds information by calling toll free 1-800-995-6365 or by writing to P.O. Box 219525, Kansas City, Missouri, 64121-9525, or you may contact your investment professional. The Commerce Funds publish performance and portfolio information for each Commerce Fund at the end of every calendar quarter. Investors should read the prospectus carefully before investing or sending money.

COMMERCE FUNDS

Performance and Expense Ratio Information

April 30, 2011 (Unaudited)


PERFORMANCE REVIEW
November 1, 2010 - April 30, 2011	Fund Total Return^(a)			Index Total Return			Index
Equity Funds:
Growth		13.68	%		16.96	%	Russell 1000® Growth^(b)
Value		18.88			17.29		Russell 1000® Value^(c)
Mid Cap Growth		19.33			22.62		Russell Midcap® Growth^(d)
Fixed Income Funds:
Bond		1.13			0.02		Barclays Capital U.S. Aggregate Bond^(e)
Short-Term Government		0.10			-0.26		Citigroup 1-5 Year Treasury/Government Sponsored^(f)
National Tax-Free Intermediate Bond		-1.03			-0.33		Barclays Capital 3-15 Year Blend^(g)
Missouri Tax-Free Intermediate Bond		-0.51			-0.33		Barclays Capital 3-15 Year Blend^(g)
Kansas Tax-Free Intermediate Bond		-0.49			-0.33		Barclays Capital 3-15 Year Blend^(g)

^(a)

Returns assume expense reimbursements and are not annualized. Returns do not reflect the deduction of taxes that a shareholder would pay on capital gains or other taxable distributions or the redemption of Fund shares.

^(b)

The Russell 1000® Growth Index, an unmanaged index, is a market capitalization weighted index of those 1,000 Russell companies with higher price-to-book ratios and higher forecasted growth values. The Index figures do not reflect the deduction of any fees, expenses or taxes.

^(c)

The Russell 1000® Value Index is an unmanaged market capitalization weighted index of those 1,000 Russell companies with lower price-to-book ratios and lower forecasted growth values. The Index figures do not reflect the deduction of any fees, expenses or taxes.

^(d)

The Russell Midcap® Growth Index, an unmanaged index, measures the performance of those Russell midcap companies with higher price-to-book ratios and higher forecasted growth values. The Index figures do not reflect the deduction of any fees, expenses or taxes.

^(e)

The Barclays Capital U.S. Aggregate Bond Index is an unmanaged index comprised of the Barclays Capital Government Corporate Bond Index, Mortgage-Backed Securities Index and Asset-Backed Securities Index. The Index figures do not reflect the deduction of any fees, expenses or taxes.

^(f)

The Citigroup 1-5 Year Treasury/Government Sponsored Index is an unmanaged index comprised of Treasury securities with a minimum principal amount of $1 billion and U.S. Government securities with a minimum principal amount of $100 million. The securities range in maturity from one to five years. The Index figures do not reflect the deduction of any fees, expenses or taxes.

^(g)

The Barclays Capital 3-15 Year Blend Index is an unmanaged index composed of investment grade municipal securities ranging from 2 to 17 years in maturity. The Index figures do not reflect the deduction of any fees, expenses or taxes.


STANDARDIZED AVERAGE ANNUAL TOTAL RETURNS^(h)
For the period ended 03/31/2011	One Year			Five Years			Ten Years			Since Inception			Inception Date
Equity Funds:
Growth		13.64	%		2.73	%		2.32	%		7.15	%		12/12/94
Value		15.34			0.75			2.80			4.32			3/3/97
Mid Cap Growth		28.62			4.42			5.20			7.95			12/12/94
Fixed Income Funds:
Bond		8.05			7.37			5.68			6.54			12/12/94
Short-Term Government		3.14			4.82			3.91			5.08			12/12/94
National Tax-Free Intermediate Bond		2.18			3.93			4.09			4.62			2/21/95
Missouri Tax-Free Intermediate Bond		1.99			3.81			3.93			4.47			2/21/95
Kansas Tax-Free Intermediate Bond		1.78			3.84			3.95			4.16			12/26/00

^(h)

The Standardized Average Annual Total Returns are average annual total returns as of the most recent calendar quarter-end. They assume reinvestment of all distributions at NAV.

These returns represent past performance. Past performance does not guarantee future results. The investment return and principal value of an investment will fluctuate and, therefore, an investor’s shares, when redeemed, may be worth more or less than their original cost. Current performance may be lower or higher than the total return figures in the above charts.

Returns assume fee waivers and expense reductions. Absent these waivers and reductions, returns would have been lower. Returns do not reflect the deduction of taxes that a shareholder would pay on capital gains or other taxable distributions or the redemption of Fund shares.


EXPENSE RATIOS⁽ⁱ⁾
	Net Expense Ratio (Current)			Gross Expense Ratio (Before Reimbursement)
Equity Funds:
Growth		1.13	%		1.25	%
Value		0.70			0.95
Mid Cap Growth		1.34			1.34
Fixed Income Funds:
Bond		0.84			0.84
Short-Term Government		0.68			0.90
National Tax-Free Intermediate Bond		0.70			0.87
Missouri Tax-Free Intermediate Bond		0.70			0.86
Kansas Tax-Free Intermediate Bond		0.70			0.96

⁽ⁱ⁾

The expense ratios of the Funds, both current (net of applicable fee waivers and/or expense limitations) and before waivers (gross of applicable fee waivers and/or expense limitations), are as set forth above according to the most recent publicly available Prospectus for the Funds and may differ from the expense ratios disclosed in the Financial Highlights in this report. Applicable waivers and expense limitations may be modified or terminated in the future, consistent with the terms of any arrangements in place. If this occurs, the expense ratios may change without shareholder approval.

COMMERCE GROWTH FUND

Schedule of Investments

April 30, 2011 (Unaudited)



Shares		Description	Value
	Common Stocks – 94.7%
	Commercial Services – 1.0%
	33,200	Thomson Reuters Corp.		$ 1,343,604

	*Communications – 1.0%**
	34,000	SBA Communications Corp. Class A		1,313,420

	Consumer Durables – 2.4%
	142,100	Ford Motor Co.*		2,198,287
	44,300	Leggett & Platt, Inc.		1,164,647

				3,362,934

	Consumer Non-Durables – 5.4%
	22,500	Coach, Inc.		1,345,725
	8,600	Colgate-Palmolive Co.		725,410
	29,400	PepsiCo, Inc.		2,025,366
	22,400	Philip Morris International, Inc.		1,555,456
	9,700	Polo Ralph Lauren Corp.		1,268,469
	7,800	The Coca-Cola Co.		526,188

				7,446,614

	Consumer Services – 5.3%
	40,800	DIRECTV Class A*		1,982,472
	20,700	eBay, Inc.*		712,080
	28,900	Expedia, Inc.		723,367
	41,400	Las Vegas Sands Corp.*		1,946,214
	5,100	McDonald’s Corp.		399,381
	42,800	Starbucks Corp.		1,548,932

				7,312,446

	Electronic Technology – 19.0%
	15,700	Apple, Inc.*		5,467,211
	83,100	Cadence Design Systems, Inc.*		862,578
	84,300	Cisco Systems, Inc.		1,480,308
	95,200	Dell, Inc.*		1,476,552
	7,900	F5 Networks, Inc.*		800,744
	16,400	Harris Corp.		871,332
	74,400	Hewlett-Packard Co.		3,003,528
	119,000	Intel Corp.		2,759,610
	50,600	Linear Technology Corp.		1,760,880
	11,600	Lockheed Martin Corp.		919,300
	33,600	Novellus Systems, Inc.*		1,078,560
	81,300	QLogic Corp.*		1,461,774
	23,300	QUALCOMM, Inc.		1,324,372
	61,800	Texas Instruments, Inc.		2,195,754
	16,400	Zebra Technologies Corp. Class A*		644,356

				26,106,859

	Energy Minerals – 10.8%
	44,300	Arch Coal, Inc.		1,519,490
	18,700	Chevron Corp.		2,046,528
	8,000	Cimarex Energy Co.		884,720
	19,300	ConocoPhillips		1,523,349
	72,500	Exxon Mobil Corp.		6,380,000
	22,200	Occidental Petroleum Corp.		2,537,238

				14,891,325

	Finance – 2.3%
	46,400	Morgan Stanley & Co.		1,213,360



Shares		Description	Value
	Common Stocks – (continued)
	Finance – (continued)
	15,800	Prudential Financial, Inc.		$ 1,002,036
	51,400	The Charles Schwab Corp.		941,134

				3,156,530

	*Health Services – 1.5%**
	35,000	Medco Health Solutions, Inc.		2,076,550

	Health Technology – 6.5%
	13,000	Abbott Laboratories		676,520
	22,400	Allergan, Inc.		1,782,144
	19,600	C. R. Bard, Inc.		2,092,300
	48,700	Gilead Sciences, Inc.*		1,891,508
	6,500	Johnson & Johnson		427,180
	26,200	Medtronic, Inc.		1,093,850
	15,500	Stryker Corp.		914,500

				8,878,002

	Industrial Services – 2.2%
	8,900	Diamond Offshore Drilling, Inc.		675,243
	26,100	Schlumberger Ltd.		2,342,475

				3,017,718

	Non-Energy Minerals – 3.5%
	17,100	Cliffs Natural Resources, Inc.		1,602,612
	26,000	Freeport-McMoRan Copper & Gold, Inc.		1,430,780
	9,600	Newmont Mining Corp.		562,656
	31,500	Southern Copper Corp.		1,179,990

				4,776,038

	Process Industries – 1.1%
	49,300	International Paper Co.		1,522,384

	Producer Manufacturing – 7.9%
	6,200	Cummins, Inc.		745,116
	16,800	Eaton Corp.		899,304
	64,100	General Electric Co.		1,310,845
	22,300	The Timken Co.		1,257,497
	23,900	TRW Automotive Holdings Corp.*		1,363,734
	40,600	United Technologies Corp.		3,636,948
	23,200	WABCO Holdings, Inc.*		1,713,320

				10,926,764

	Retail Trade – 5.7%
	6,400	AutoZone, Inc.*		1,807,232
	12,900	Dollar Tree, Inc.*		741,750
	81,700	Lowe’s Cos., Inc.		2,144,625
	4,400	Netflix, Inc.*		1,023,748
	14,900	Target Corp.		731,590
	58,800	The Gap, Inc.		1,366,512

				7,815,457

	Technology Services – 15.6%
	26,700	Adobe Systems, Inc.*		895,785
	33,800	BMC Software, Inc.*		1,697,774
	7,400	Google, Inc. Class A*		4,026,340
	39,100	International Business Machines Corp.		6,669,678


The accompanying notes are an integral part of these financial statements.		3

COMMERCE GROWTH FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)



Shares		Description	Value
	Common Stocks – (continued)
	Technology Services – (continued)
	120,800	Microsoft Corp.		$ 3,143,216
	86,700	Oracle Corp.		3,125,535
	17,700	Rovi Corp.*		859,512
	26,200	VeriSign, Inc.		968,352

				21,386,192

	Transportation – 3.5%
	52,000	Frontline Ltd.		1,149,720
	15,500	Union Pacific Corp.		1,603,785
	62,450	United Continental Holdings, Inc.*		1,425,109
	8,800	United Parcel Service, Inc. Class B		659,736

				4,838,350

	TOTAL COMMON STOCKS
	(Cost $109,224,033)			$130,171,187


	Exchange Traded Fund – 3.6%
	78,400	iShares Russell 1000 Growth Index Fund
	(Cost $4,679,877)			$ 4,896,080


Principal Amount	Interest Rate			Maturity Date		Value
Short-term Investment^(a) – 1.8%
Repurchase Agreement – 1.8%
State Street Bank & Trust Co.
$2,509,000		0.010	%		05/02/11	$	2,509,000
Maturity Value: $2,509,002
(Cost $2,509,000)

TOTAL INVESTMENTS – 100.1%
(Cost $116,412,910)						$	137,576,267

LIABILITIES IN EXCESS OF OTHER ASSETS – (0.1)%							(69,890)

NET ASSETS – 100.0%						$	137,506,377


The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets.
*		Non-income producing security.
^(a)		Repurchase agreement was entered into on April 29, 2011. This agreement was fully collateralized by $2,530,000 U.S. Treasury Note, 1.000%, due 04/30/12 with a market value of $2,561,160.

PORTFOLIO COMPOSITION


	AS OF 4/30/11			AS OF 10/31/10

Electronic Technology		19.0	%		20.6	%
Technology Services		15.6			16.0
Energy Minerals		10.8			7.8
Producer Manufacturing		7.9			7.0
Health Technology		6.5			10.6
Retail Trade		5.7			4.9
Consumer Non-Durables		5.4			8.3
Consumer Services		5.3			5.0
Exchange Traded Fund		3.6			—
Transportation		3.5			2.9
Non-Energy Minerals		3.5			1.5
Consumer Durables		2.4			2.7
Finance		2.3			3.0
Industrial Services		2.2			2.0
Health Services		1.5			2.5
Process Industries		1.1			2.4
Communications		1.0			1.1
Commercial Services		1.0			—
Distribution Services		—			1.2
Short-term Investment		1.8			0.6

TOTAL INVESTMENTS		100.1	%		100.1	%

The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets. Underlying investment categories of exchange traded funds (“ETFs”) held by the Fund are not reflected in the table above. Consequently, the Fund’s overall investment category allocations may differ from the percentages contained in the table above.

The Fund is actively managed and, as such, its composition may differ over time.


4		The accompanying notes are an integral part of these financial statements.

COMMERCE VALUE FUND

Schedule of Investments

April 30, 2011 (Unaudited)



Shares		Description	Value
	Common Stocks – 94.9%
	Commercial Services – 0.4%
	11,000	R.R. Donnelley & Sons Co.		$ 207,460

	Communications – 4.9%
	55,000	AT&T, Inc.		1,711,600
	6,656	CenturyLink, Inc.		271,432
	22,000	Verizon Communications, Inc.		831,160

				2,814,192

	Consumer Non-Durables – 18.6%
	41,500	Altria Group, Inc.		1,113,860
	40,000	Avon Products, Inc.		1,175,200
	23,000	ConAgra Foods, Inc.		562,350
	12,000	General Mills, Inc.		462,960
	17,000	Kimberly-Clark Corp.		1,123,020
	17,000	PepsiCo, Inc.		1,171,130
	17,500	Procter & Gamble Co.		1,135,750
	31,000	Reynolds American, Inc.		1,150,410
	16,000	The Coca-Cola Co.		1,079,360
	10,000	The Hershey Co.		577,100
	11,000	V.F. Corp.		1,106,160

				10,657,300

	Consumer Services – 0.9%
	11,000	Darden Restaurants, Inc.		516,670

	Distribution Services – 1.9%
	20,000	Genuine Parts Co.		1,074,000

	Electronic Technology – 8.2%
	3,000	General Dynamics Corp.		218,460
	25,000	Intel Corp.		579,750
	20,000	Intersil Corp. Class A		295,400
	32,500	Linear Technology Corp.		1,131,000
	14,000	Lockheed Martin Corp.		1,109,500
	29,000	Microchip Technology, Inc.		1,190,160
	4,000	Raytheon Co.		194,200

				4,718,470

	Energy Minerals – 8.6%
	25,500	Chevron Corp.		2,790,720
	27,500	ConocoPhillips		2,170,575

				4,961,295

	Finance – 11.3%
	3,500	Bank of Hawaii Corp.		170,765
	1,500	BlackRock, Inc.		293,910
	21,000	Federated Investors, Inc. Class B		541,380
	30,000	GATX Corp.		1,268,100
	6,000	HCP, Inc.		237,720
	58,500	Kimco Realty Corp.		1,143,090
	16,000	Liberty Property Trust		562,720
	3,000	M&T Bank Corp.		265,110
	8,000	Senior Housing Properties Trust		189,760
	2,000	Simon Property Group, Inc.		229,080
	4,000	Taubman Centers, Inc.		232,600
	6,000	The Chubb Corp.		391,140
	8,500	The Travelers Cos., Inc.		537,880



Shares		Description	Value
	Common Stocks – (continued)
	Finance – (continued)
	2,000	Vornado Realty Trust		$ 193,360
	10,000	Weyerhaeuser Co.		230,100

				6,486,715

	Health Technology – 8.6%
	16,000	Abbott Laboratories		832,640
	8,000	Eli Lilly & Co.		296,080
	20,000	Johnson & Johnson		1,314,400
	22,000	Merck & Co., Inc.		790,900
	80,000	Pfizer, Inc.		1,676,800

				4,910,820

	Industrial Services – 0.9%
	13,000	Waste Management, Inc.		512,980

	Process Industries – 4.2%
	17,000	Greif, Inc. Class A		1,055,700
	9,000	MeadWestvaco Corp.		303,210
	30,000	Sonoco Products Co.		1,036,800

				2,395,710

	Producer Manufacturing – 6.5%
	5,000	Eaton Corp.		267,650
	90,000	General Electric Co.		1,840,500
	19,000	Illinois Tool Works, Inc.		1,109,790
	22,000	Pitney Bowes, Inc.		540,320

				3,758,260

	Retail Trade – 3.0%
	60,000	SUPERVALU, Inc.		675,600
	28,000	The Home Depot, Inc.		1,039,920

				1,715,520

	Technology Services – 5.6%
	21,000	Automatic Data Processing, Inc.		1,141,350
	40,000	Microsoft Corp.		1,040,800
	31,000	Paychex, Inc.		1,014,010

				3,196,160

	Utilities – 11.3%
	6,000	Alliant Energy Corp.		237,240
	6,000	DTE Energy Co.		303,180
	20,000	Duke Energy Corp.		373,000
	8,000	Edison International		314,160
	5,000	Exelon Corp.		210,750
	47,500	MDU Resources Group, Inc.		1,134,775
	21,000	OGE Energy Corp.		1,116,570
	16,000	ONEOK, Inc.		1,119,040
	5,000	PG&E Corp.		230,400
	4,500	Progress Energy, Inc.		213,525
	8,000	Questar Corp.		140,560
	7,000	The Southern Co.		273,280
	17,000	UGI Corp.		566,100
	10,000	Xcel Energy, Inc.		243,300

				6,475,880

	TOTAL COMMON STOCKS
	(Cost $49,708,979)			$54,401,432


The accompanying notes are an integral part of these financial statements.		5

COMMERCE VALUE FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)



Shares		Description	Value
	Exchange Traded Fund – 2.1%
	17,500	iShares Russell 1000 Value Index Fund
	(Cost $1,162,996)			$ 1,232,875


Principal Amount	Interest Rate			Maturity Date		Value
Short-term Investment^(a) – 2.9%
Repurchase Agreement – 2.9%
State Street Bank & Trust Co.
$1,657,000		0.010	%		05/02/11	$	1,657,000
Maturity Value: $1,657,001
(Cost $1,657,000)

TOTAL INVESTMENTS – 99.9%
(Cost $52,528,975)						$	57,291,307

OTHER ASSETS IN EXCESS OF LIABILITIES – 0.1%							56,149

NET ASSETS – 100.0%						$	57,347,456


The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets.
^(a)		Repurchase agreement was entered into on April 29, 2011. This agreement was fully collateralized by $1,670,000 U.S. Treasury Note, 1.000%, due 04/30/12 with a market value of $1,690,568.

PORTFOLIO COMPOSITION


	AS OF 4/30/11			AS OF 10/31/10

Consumer Non-Durables		18.6	%		5.7	%
Finance		11.3			26.4
Utilities		11.3			5.1
Energy Minerals		8.6			9.8
Health Technology		8.6			9.9
Electronic Technology		8.2			3.9
Producer Manufacturing		6.5			6.3
Technology Services		5.6			4.2
Communications		4.9			5.2
Process Industries		4.2			3.0
Retail Trade		3.0			1.6
Exchange Traded Fund		2.1			3.0
Distribution Services		1.9			0.8
Consumer Services		0.9			7.5
Industrial Services		0.9			3.4
Commercial Services		0.4			0.9
Transportation		—			0.9
Consumer Durables		—			0.8
Health Services		—			0.7
Non-Energy Minerals		—			0.3
Short-term Investment		2.9			0.7

TOTAL INVESTMENTS		99.9	%		100.1	%

The Fund is actively managed and, as such, its composition may differ over time.


6		The accompanying notes are an integral part of these financial statements.

COMMERCE MIDCAP GROWTH FUND

Schedule of Investments

April 30, 2011 (Unaudited)



Shares		Description	Value
	Common Stocks – 94.9%
	Commercial Services – 3.7%
	4,900	FactSet Research Systems, Inc.		$ 536,109
	16,700	FTI Consulting, Inc.*		666,330
	13,400	Lender Processing Services, Inc.		394,362
	8,800	The Brink’s Co.		290,488
	18,100	The McGraw-Hill Cos., Inc.		732,507

				2,619,796

	*Communications – 1.7%**
	16,400	SBA Communications Corp. Class A		633,532
	27,100	TW Telecom, Inc.		583,734

				1,217,266

	*Consumer Durables – 1.3%**
	14,100	Tempur-Pedic International, Inc.		885,198

	Consumer Non-Durables – 4.3%
	11,200	Brown-Forman Corp., Class B		804,832
	26,500	Coach, Inc.		1,584,965
	9,100	The Clorox Co.		633,906

				3,023,703

	Consumer Services – 5.6%
	1,900	Chipotle Mexican Grill, Inc. Class A*		506,901
	31,800	Expedia, Inc.		795,954
	28,900	Marriott International, Inc. Class A		1,020,170
	1,700	Priceline.com, Inc.*		929,917
	4,400	Wynn Resorts Ltd.		647,460

				3,900,402

	Electronic Technology – 16.9%
	116,000	Advanced Micro Devices, Inc.*		1,055,600
	16,700	Altera Corp.		813,290
	65,400	Cadence Design Systems, Inc.*		678,852
	6,800	Dolby Laboratories, Inc. Class A*		340,408
	19,800	Harris Corp.		1,051,974
	32,400	JDS Uniphase Corp.*		675,216
	26,200	Juniper Networks, Inc.*		1,004,246
	31,400	Linear Technology Corp.		1,092,720
	24,700	Marvell Technology Group Ltd.*		381,121
	19,700	Novellus Systems, Inc.*		632,370
	37,000	NVIDIA Corp.*		740,000
	32,400	ON Semiconductor Corp.*		340,524
	19,400	SanDisk Corp.*		953,316
	33,800	Xilinx, Inc.		1,178,268
	23,300	Zebra Technologies Corp. Class A*		915,457

				11,853,362

	Energy Minerals – 6.0%
	19,500	Arch Coal, Inc.		668,850
	6,400	Cimarex Energy Co.		707,776
	9,500	CONSOL Energy, Inc.		513,855
	15,400	SM Energy Co.		1,168,244
	10,100	Ultra Petroleum Corp.*		512,979
	4,500	Walter Energy, Inc.		621,990

				4,193,694



Shares		Description	Value
	Common Stocks – (continued)
	Finance – 7.2%
	7,995	Eaton Vance Corp.		$ 269,991
	8,800	Endurance Specialty Holdings Ltd.		390,192
	7,800	Federal Realty Investment Trust		682,968
	18,300	Genworth Financial, Inc. Class A*		223,077
	4,200	IntercontinentalExchange, Inc.*		505,470
	11,800	Jefferies Group, Inc.		285,206
	10,600	Principal Financial Group, Inc.		357,750
	7,600	Rayonier, Inc.		504,336
	18,800	T. Rowe Price Group, Inc.		1,207,900
	29,000	TD Ameritrade Holding Corp.		624,660

				5,051,550

	*Health Services – 2.7%**
	6,680	Cerner Corp.		802,802
	11,000	Laboratory Corporation of America Holdings		1,061,170

				1,863,972

	Health Technology – 7.0%
	6,540	Allergan, Inc.		520,323
	11,080	C. R. Bard, Inc.		1,182,790
	15,500	DENTSPLY International, Inc.		581,870
	18,100	Hill-Rom Holdings, Inc.		814,681
	11,500	Illumina, Inc.*		816,270
	5,200	Life Technologies Corp.*		287,040
	9,900	Varian Medical Systems, Inc.*		694,980

				4,897,954

	Industrial Services – 1.7%
	7,800	Core Laboratories NV		748,644
	10,000	FMC Technologies, Inc.*		464,800

				1,213,444

	Non-Energy Minerals – 1.7%
	6,100	Cliffs Natural Resources, Inc.		571,692
	29,400	Titanium Metals Corp.*		588,882

				1,160,574

	Process Industries – 7.0%
	24,200	Crown Holdings, Inc.*		905,080
	34,000	International Paper Co.		1,049,920
	13,400	Nalco Holding Co.		391,414
	10,400	PPG Industries, Inc.		984,568
	15,336	Sigma-Aldrich Corp.		1,082,415
	5,700	The Sherwin-Williams Co.		469,053

				4,882,450

	Producer Manufacturing – 9.0%
	9,000	Avery Dennison Corp.		375,660
	6,200	Cummins, Inc.		745,116
	5,700	Dover Corp.		387,828
	5,400	Joy Global, Inc.		545,130
	5,800	Lincoln Electric Holdings, Inc.		455,764
	25,900	Masco Corp.		347,578
	10,550	Parker Hannifin Corp.		995,076


The accompanying notes are an integral part of these financial statements.		7

COMMERCE MIDCAP GROWTH FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)



Shares		Description	Value
	Common Stocks – (continued)
	Producer Manufacturing – (continued)
	16,900	The Timken Co.		$ 952,991
	9,200	The Toro Co.		624,772
	15,600	TRW Automotive Holdings Corp.*		890,136

				6,320,051

	Retail Trade – 5.1%
	3,800	AutoZone, Inc.*		1,073,044
	21,900	Chico’s FAS, Inc.		320,397
	4,000	Netflix, Inc.*		930,680
	6,260	Nordstrom, Inc.		297,663
	12,000	PetSmart, Inc.		506,040
	5,700	Ross Stores, Inc.		420,033

				3,547,857

	Technology Services – 10.6%
	14,100	Akamai Technologies, Inc.*		485,604
	6,200	Alliance Data Systems Corp.*		589,000
	13,300	Autodesk, Inc.*		598,234
	22,700	BMC Software, Inc.*		1,140,221
	55,100	Compuware Corp.*		624,283
	15,500	MICROS Systems, Inc.*		806,310
	14,400	Red Hat, Inc.*		683,568
	15,600	Rovi Corp.*		757,536
	10,200	Teradata Corp.*		570,384
	18,400	VeriSign, Inc.		680,064
	24,400	Western Union Co.		518,500

				7,453,704

	Transportation – 2.5%
	8,500	Con-way, Inc.		330,820
	33,600	Delta Air Lines, Inc.*		348,768
	22,100	Frontline Ltd.		488,631
	24,990	United Continental Holdings, Inc.*		570,272

				1,738,491

	Utilities – 0.9%
	35,300	CenterPoint Energy, Inc.		656,580

	TOTAL COMMON STOCKS
	(Cost $47,831,542)			$66,480,048


	Exchange Traded Fund – 4.8%
	53,400	iShares Russell Midcap Growth Index Fund
	(Cost $3,025,509)			$ 3,368,472


Principal Amount	Interest Rate			Maturity Date		Value
Short-term Investment^(a) – 0.5%
Repurchase Agreement – 0.5%
State Street Bank & Trust Co.
$338,000		0.010	%		05/02/11	$	338,000
Maturity Value: $338,000
(Cost $338,000)

TOTAL INVESTMENTS – 100.2%
(Cost $51,195,051)						$	70,186,520

LIABILITIES IN EXCESS OF OTHER ASSETS – (0.2)%							(141,208)

NET ASSETS – 100.0%						$	70,045,312


The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets.
*		Non-income producing security.
^(a)		Repurchase agreement was entered into on April 29, 2011. This agreement was fully collateralized by $345,000 U.S. Treasury Note, 1.000%, due 04/30/12 with a market value of $349,249.

PORTFOLIO COMPOSITION


	AS OF 4/30/11			AS OF 10/31/10

Electronic Technology		16.9	%		14.1	%
Technology Services		10.6			12.6
Producer Manufacturing		9.0			9.3
Finance		7.2			7.5
Health Technology		7.0			8.9
Process Industries		7.0			7.0
Energy Minerals		6.0			2.5
Consumer Services		5.6			6.6
Retail Trade		5.1			8.0
Exchange Traded Fund		4.8			—
Consumer Non-Durables		4.3			5.1
Commercial Services		3.7			2.5
Health Services		2.7			4.6
Transportation		2.5			4.1
Communications		1.7			1.2
Industrial Services		1.7			2.3
Non-Energy Minerals		1.7			0.8
Consumer Durables		1.3			1.5
Utilities		0.9			1.1
Short-term Investment		0.5			0.5

TOTAL INVESTMENTS		100.2	%		100.2	%

The Fund is actively managed and, as such, its composition may differ over time.


8		The accompanying notes are an integral part of these financial statements.

COMMERCE BOND FUND

Schedule of Investments

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date		Value
Asset-Backed Securities – 8.9%
Auto^(a) – 0.3%
Citifinancial Auto Issuance Trust Series 2009-1, Class A2
$ 1,696,419		1.830	%		11/15/12	$	1,699,733

Commercial – 1.4%
LB-UBS Commercial Mortgage Trust Series 2002-C1, Class A4
6,164,836		6.462			03/15/31		6,332,224
Small Business Administration Series 2006-P10B, Class 1
2,377,915		5.681			08/10/16		2,574,075

							8,906,299

Credit Card – 0.6%
Citibank Credit Card Issuance Trust Series 2004, Class A8
3,600,000		4.900			12/12/16		3,979,782

Equipment^(a) – 0.1%
CIT Equipment Collateral Series 2010-VT1A, Class A2
728,909		1.510			05/15/12		730,024

Home Equity – 3.5%
Ameriquest Mortgage Securities, Inc. Series 2004-FR1W, Class A6^(b)
2,000,000		5.440			05/25/34		1,860,000
Carrington Mortgage Loan Trust Series 2006-NC5, Class A1^(b)
617,306		0.263			01/25/37		607,933
Chase Funding Mortgage Loan Asset-Backed Certificates Series 2002-3, Class 1A5
3,185,995		5.407			06/25/32		3,151,395
Countrywide Asset-Backed Certificates Series 2007-QH1, Class A1^(a)(b)
1,277,985		0.413			02/25/37		846,380
Equifirst Mortgage Loan Trust Series 2003-2, Class 2A2
1,068,223		3.750			09/25/33		1,040,013
Equity One ABS, Inc. Series 2004-2, Class AF5
450,000		5.199			07/25/34		432,726
Lehman XS Trust Series 2005-1, Class 1A4^(b)
903,636		0.553			07/25/35		756,723
Renaissance Home Equity Loan Trust Series 2005-3, Class AF3
682,586		4.814			11/25/35		657,795
Renaissance Home Equity Loan Trust Series 2005-3, Class AF4
1,125,000		5.140			11/25/35		979,230
Residential Asset Mortgage Products, Inc. Series 2003-RZ3, Class A6
2,176,540		3.400			03/25/33		2,168,626
Residential Asset Mortgage Products, Inc. Series 2003-RZ4, Class A6
3,971,280		5.490			10/25/33		3,165,070
Residential Funding Mortgage Securities I, Inc. Series 2000-HI2, Class AI5
804,558		8.850			03/25/25		791,716
Residential Funding Mortgage Securities I, Inc. Series 2000-HI4, Class AI7
818,916		8.480			09/25/30		809,243
SACO I Trust Series 2005-7 Class A^(b)
274,674		0.773			09/25/35		239,580


Principal Amount	Interest Rate			Maturity Date	Value
Asset-Backed Securities – (continued)
Home Equity – (continued)
Soundview Home Equity Loan Trust Series 2006-EQ1, Class A2^(b)
$ 280,331		0.323	%	10/25/36	$	274,118
Southern Pacific Secured Asset Corp. Series 1998-2, Class A7
4,049,538		6.740		07/25/29		1,895,054
Structured Asset Securities Corp. Series 2005-9XS, Class 1A3A
2,290,430		5.250		06/25/35		2,098,778
Terwin Mortgage Trust Series 2005-16HE, Class AF2
426,357		4.429		09/25/36		422,436
Wells Fargo Home Equity Trust Series 2004-2, Class AI5^(b)
554,054		4.890		05/25/34		558,931

						22,755,747

Manufactured Housing – 2.2%
Green Tree Financial Corp. Series 1993-4, Class A5
1,571,138		7.050		01/15/19		1,608,830
Green Tree Financial Corp. Series 1995-5, Class M1^(b)
642,952		7.650		09/15/26		655,230
Green Tree Financial Corp. Series 1996-4, Class A7^(b)
955,517		7.900		06/15/27		984,321
Green Tree Financial Corp. Series 1996-6, Class A6
219,169		7.950		09/15/27		231,421
Green Tree Financial Corp. Series 1997-3, Class A6
77,697		7.320		03/15/28		84,498
Green Tree Financial Corp. Series 1998-3, Class A5
3,872,815		6.220		03/01/30		4,122,805
Green Tree Financial Corp. Series 1998-3, Class A6^(b)
483,725		6.760		03/01/30		511,830
Lehman Manufactured Housing Contract Series 2001-B, Class A3
416,822		4.350		05/15/14		418,267
Mid-State Trust Series 11, Class A1
367,330		4.864		07/15/38		356,200
Newcastle Investment Trust Series 2011-MH1, Class A^(a)
4,000,000		2.450		12/10/33		3,999,489
Oakwood Mortgage Investors, Inc. Series 1996-C, Class A6
1,362,489		7.650		04/15/27		1,362,583

						14,335,474

Student Loans – 0.8%
Northstar Education Finance, Inc. Series 2005-1, Class A5^(b)
2,019,600		1.023		10/30/45		1,940,553
SLM Student Loan Trust Series 2011-A, Class A2^(a)
2,900,000		4.370		04/17/28		2,950,637

						4,891,190

TOTAL ASSET-BACKED SECURITIES
(Cost $54,010,585)					$	57,298,249


The accompanying notes are an integral part of these financial statements.		9

COMMERCE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date		Value
Taxable Municipal Bond Obligations – 12.3%
Alabama – 0.2%
Montgomery Alabama Taxable GO Warrants Series 2005 (AGM)
$ 1,295,000		4.790	%		04/01/15	$	1,402,226

Alaska – 0.1%
Providence Alaska Health System Direct Obligation Series 2005
500,000		4.790			10/01/11		508,840

California – 3.0%
Anaheim California Public Financing Authority Revenue Bonds Build America Bonds
4,000,000		5.685			10/01/40		3,826,680
Hillsborough School District GO Bonds Capital Appreciation Election 2002 C^(c)
10,590,000		0.000			09/01/42		1,186,716
11,420,000		0.000			09/01/43		1,180,371
Industry California Sales Tax Revenue Bonds Taxable Series 2005 (NATL-RE)
3,045,000		5.000			01/01/13		3,110,924
Napa Valley Unified School District GO Bonds (Build America Bonds-Taxable) Series B
3,000,000		6.507			08/01/43		3,054,120
San Francisco City & County Airports Commission Revenue Bonds Refunding Second Series C
3,000,000		5.000			05/01/17		3,312,960
Santa Clara County CA Fremont Union High School District GO Bonds Capital Appreciation Election 2008 B^(c)
11,005,000		0.000			08/01/37		1,711,938
12,290,000		0.000			08/01/39		1,624,615

							19,008,324

District of Columbia – 0.8%
Metropolitan Washington D.C. Airport Authority System Revenue Bonds Series B
5,000,000		5.250			10/01/25		5,368,500

Florida – 0.3%
Inland Protection Financing Corp. Florida Revenue Bonds Build America Bonds Series 2010
2,000,000		4.700			07/01/19		2,069,760

Illinois – 0.3%
Will County Community Consolidated School District No. 30-C Troy Township Taxable GO Series 2007 (AGM)
1,100,000		5.650			10/01/18		1,198,417
Will County Forest Preservation District GO Bonds Build America Bonds Direct Payment Series 2009
1,000,000		5.700			12/15/27		1,039,260

							2,237,677

Indiana – 1.0%
Indiana Bond Bank Revenue Bonds Taxable School Severance Funding Series 2006-11 (XLCA)
2,190,000		5.650			07/15/13		2,403,678


Principal Amount	Interest Rate			Maturity Date	Value
Taxable Municipal Bond Obligations – (continued)
Indiana – (continued)
Indianapolis Multi-School Building Corp. Revenue Bonds (Refunding First Mortgage)
$ 5,000,000		3.000	%	01/15/26	$	4,040,150

						6,443,828

Iowa – 0.6%
Iowa Higher Education Loan Authority Revenue Bonds Refunding Private College Facility (Grinnell College Project)
2,500,000		5.000		12/01/19		2,908,375

Maryland – 0.2%
Baltimore County Maryland GO Bonds Build America Bonds Consolidated Public Improvement Series 2009 B
1,000,000		5.000		11/01/23		1,044,290

Massachusetts – 0.0%
University of Massachusetts Building Authority Revenue Bonds Refunding Taxable Series 2006-2 (AMBAC)
255,000		5.360		05/01/11		255,000

Michigan – 0.2%
Utica Community Schools GO Bonds (Taxable-Qualified School Construction-Direct Payment)
1,500,000		5.875		05/01/22		1,544,505

Missouri – 1.9%
Curators University of Missouri System Facilities Revenue Bonds Build America Bonds
2,500,000		5.792		11/01/41		2,674,625
Missouri Joint Municipal Electric Utility Commission Power Project Revenue Bonds Build America Bonds Series 2009
2,000,000		5.078		01/01/17		2,067,160
Missouri Joint Municipal Electric Utility Commission Power Project Revenue Bonds Taxable Series 2009 B
1,570,000		4.693		01/01/16		1,619,110
Missouri State Highways & Transit Commission State Road Revenue Bonds Build America Bonds Series 2010
2,800,000		4.820		05/01/23		2,921,940
New Liberty Hospital District Revenue Bonds Build America Bonds Series 2010 B
1,345,000		5.704		12/01/19		1,407,448
St. Louis Package Revenue Bonds Series 2006 B (NATL-RE)
1,560,000		5.020		12/15/12		1,618,750

						12,309,033

Nevada – 0.4%
Clark County Nevada Sales & Excise Tax Revenue Bonds Build America Bonds Series 2010 C
2,525,000		5.100		07/01/21		2,533,989

New Jersey – 0.2%
New Jersey Economic Development Authority Revenue Bonds Taxable Designated Industry Series 2004-A
1,000,000		5.200		03/01/14		1,070,060


10		The accompanying notes are an integral part of these financial statements.

COMMERCE BOND FUND


Principal Amount	Interest Rate			Maturity Date	Value
Taxable Municipal Bond Obligations – (continued)
New York – 1.2%
New York GO Build America Bonds Series 2010
$ 2,000,000		4.908	%	06/01/21	$	2,068,720
1,055,000		5.008		06/01/22		1,098,497
New York State Housing Finance Agency Personal Income Tax Revenue Bonds Taxable Economic Development & Housing Series 2006 B
3,925,000		5.220		09/15/15		4,287,160

						7,454,377

Ohio – 0.7%
Ohio State GO Build America Bonds Series 2010
2,500,000		3.000		11/01/18		2,386,400
Ohio State GO Build America Bonds Taxable Conservation Project Direct Payment Series 2009 C
1,960,000		4.471		03/01/19		2,057,686

						4,444,086

Oregon – 0.1%
Multnomah County Oregon School District 1J Portland GO Bonds Refunding Taxable Series 2004
785,000		5.165		06/15/11		788,729

Pennsylvania – 0.5%
State Public School Building Authority Revenue Bonds (Qualified School Construction Bonds)
3,000,000		6.495		09/15/28		3,185,310

Rhode Island – 0.5%
Providence Rhode Island GO Bonds Refunding Taxable Series 2004 B (AGM)
710,000		4.960		07/15/14		750,761
Rhode Island Convention Center Authority Revenue Bonds Taxable Civic Center Series 2006 A (AGM)
2,155,000		5.810		05/15/16		2,336,214

						3,086,975

South Carolina – 0.2%
South Carolina State Public Service Authority Revenue Bonds Santee Cooper Taxable Series 2008 B
1,150,000		7.308		01/01/14		1,307,861

TOTAL TAXABLE MUNICIPAL BOND OBLIGATIONS
(Cost $75,726,345)					$	78,971,745


Mortgage-Backed Obligations – 31.3%
Collateralized Mortgage Obligations – 27.0%
ABN Amro Mortgage Corp. Series 2003-13, Class A2
$ 20,964		5.500	%	02/25/18	$	20,962
Banc of America Alternative Loan Trust Series 2004-1, Class 1A1
4,294,761		6.000		02/25/34		4,513,871
Banc of America Alternative Loan Trust Series 2005-10, Class 6A1
2,965,359		5.500		11/25/20		2,901,942


Principal Amount	Interest Rate			Maturity Date	Value
Mortgage-Backed Obligations – (continued)
Collateralized Mortgage Obligations – (continued)
Banc of America Alternative Loan Trust Series 2006-3, Class 6A1
$ 634,503		6.000	%	04/25/36	$	625,181
Bear Stearns Alt-A Trust Series 2005-9, Class 25A1^(b)
3,436,065		5.518		11/25/35		2,580,412
Bear Stearns Asset Backed Securities Trust Series 2003-AC7, Class A2
1,107,473		5.750		01/25/34		1,130,862
Chase Mortgage Finance Corp. Series 2003-S13, Class A1
1,321,176		5.500		11/25/33		1,366,655
Citicorp Mortgage Securities, Inc. Series 2006-4, Class 3A1
271,668		5.500		08/25/21		273,702
Citigroup Mortgage Loan Trust, Inc. Series 2004-NCM2, Class 1CB2
2,164,369		6.750		08/25/34		2,186,214
Citigroup Mortgage Loan Trust, Inc. Series 2005-10, Class 1A5A^(b)
1,800,191		5.593		12/25/35		1,372,286
Citigroup Mortgage Loan Trust, Inc. Series 2007-AR5, Class 1A3A^(b)
902,531		5.567		04/25/37		614,490
Citigroup Mortgage Loan Trust, Inc. Series 2009-3, Class 2A1^(a)
3,363,668		5.750		09/25/21		3,430,942
Citimortgage Alternative Loan Trust Series 2006-A3, Class 2A1
575,579		5.500		07/25/36		533,124
Countrywide Alternative Loan Trust Series 2004-18CB, Class 3A1
1,197,250		5.250		09/25/19		1,220,524
Countrywide Alternative Loan Trust Series 2005-5R, Class A2
926,953		4.750		12/25/18		935,136
Countrywide Alternative Loan Trust Series 2005-J1, Class 3A1
347,353		6.500		08/25/32		338,496
Countrywide Alternative Loan Trust Series 2007-J2, Class 2A1
877,559		6.000		07/25/37		716,370
Countrywide Home Loans Trust Series 2003-J6, Class 1A1
2,828,181		5.500		08/25/33		3,007,343
Countrywide Home Loans Trust Series 2004-J1, Class 2A4
1,226,108		4.750		01/25/19		1,255,736
Countrywide Home Loans Trust Series 2005-27, Class 2A1
3,449,884		5.500		12/25/35		3,133,236
Countrywide Home Loans Trust Series 2005-6, Class 2A1
816,084		5.500		04/25/35		753,120
CS First Boston Mortgage Securities Corp. Series 2003-19, Class 1A4
1,118,426		5.250		07/25/33		1,154,116
CS First Boston Mortgage Securities Corp. Series 2005-5, Class 2A9
9,000,000		5.500		07/25/35		8,817,903
FHLMC REMIC PAC Series 1579, Class PM
425,076		6.700		09/15/23		476,398
FHLMC REMIC PAC Series 2103, Class TE
368,002		6.000		12/15/28		396,625


The accompanying notes are an integral part of these financial statements.		11

COMMERCE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Mortgage-Backed Obligations – (continued)
Collateralized Mortgage Obligations – (continued)
FHLMC REMIC PAC Series 2110, Class PG
$ 1,887,542		6.000	%	01/15/29	$	2,077,004
FHLMC REMIC PAC Series 2640, Class DR
1,316,014		4.000		08/15/17		1,336,877
FHLMC REMIC PAC Series 2716, Class DT
495,192		5.000		02/15/30		509,054
FHLMC REMIC PAC Series 2760, Class EC
4,050,000		4.500		04/15/17		4,185,884
FHLMC REMIC PAC Series 2836, Class XQ
183,910		4.500		09/15/27		185,520
FHLMC REMIC PAC Series 2907, Class HC
951,340		5.000		06/15/27		960,254
FHLMC REMIC Series 2391, Class Z
4,633,210		6.000		12/15/31		5,129,289
FHLMC REMIC Series 2508, Class OY
1,183,040		4.500		10/15/17		1,254,852
FHLMC REMIC Series 2603, Class C
2,620,000		5.500		04/15/23		2,889,777
FHLMC REMIC Series 2677, Class BC
800,000		4.000		09/15/18		845,390
FHLMC REMIC Series 2840, Class JL
1,087,820		4.500		06/15/23		1,127,258
FHLMC REMIC Series 2866, Class DH
2,628,956		4.000		09/15/34		2,779,397
FHLMC REMIC Series 2890, Class KB
3,115,000		4.500		02/15/19		3,317,513
FHLMC REMIC TAC Series 2658, Class A
1,069,486		4.500		08/15/18		1,101,657
First Horizon Alternative Mortgage Securities Series 2004-FA2, Class 1A1
1,451,950		6.000		01/25/35		1,445,196
First Horizon Alternative Mortgage Securities Series 2006-RE1, Class A1
4,980,989		5.500		05/25/35		4,396,878
FNMA REMIC FNIC PAC Series 2001-45, Class WG
697,283		6.500		09/25/31		787,383
FNMA REMIC PAC Series 2003-1, Class PG
1,316,231		5.500		09/25/31		1,375,444
FNMA REMIC PAC Series 2003-117, Class KB
3,000,000		6.000		12/25/33		3,384,835
FNMA REMIC PAC Series 2003-14, Class AP
308,338		4.000		03/25/33		323,763
FNMA REMIC PAC Series 2004-53, Class NC
3,344,635		5.500		07/25/24		3,552,902
FNMA REMIC Series 2002-73, Class OE
3,775,405		5.000		11/25/17		4,068,589
FNMA REMIC Series 2002-82, Class XE
3,205,000		5.000		12/25/17		3,452,312
FNMA REMIC Series 2003-83, Class PG
700,000		5.000		06/25/23		756,432


Principal Amount	Interest Rate			Maturity Date	Value
Mortgage-Backed Obligations – (continued)
Collateralized Mortgage Obligations – (continued)
FNMA REMIC Series 2003-84, Class PG
$ 540,000		5.000	%	03/25/32	$	580,047
FNMA Series 2003-W6, Class 2A32
442,050		6.500		09/25/42		494,495
GNMA Series 1998-12, Class EB
675,491		6.500		05/20/28		705,479
Impac CMB Trust Series 2004-4, Class 1A1^(b)
3,374,927		0.853		09/25/34		2,603,948
Impac CMB Trust Series 2004-4, Class 2A2
5,316,246		4.857		09/25/34		5,213,674
Impac Secured Assets Corp. Series 2004-2, Class A6
1,503,004		5.181		08/25/34		1,455,077
JPMorgan Alternative Loan Trust Series 2006-S1, Class 1A16
3,350,245		6.000		03/25/36		2,862,298
JPMorgan Mortgage Trust Series 2005-S3, Class 1A20
5,000,000		5.500		01/25/36		4,931,560
JPMorgan Mortgage Trust Series 2007-A2, Class 4A2^(b)
1,000,000		5.900		04/25/37		894,068
Master Alternative Loans Trust Series 2004-4, Class 1A1
657,802		5.500		05/25/34		674,016
Master Alternative Loans Trust Series 2004-4, Class 8A1
2,341,150		6.500		05/25/34		2,429,350
Master Asset Securitization Trust Series 2003-10, Class 3A1
590,940		5.500		11/25/33		621,910
Master Asset Securitization Trust Series 2003-7, Class 1A1
1,076,921		5.500		09/25/33		1,122,529
Master Asset Securitization Trust Series 2004-3, Class 5A1
113,567		6.250		01/25/32		114,716
Merrill Lynch Mortgage Investors Trust Series 2005-A8, Class A1C1^(b)
488,251		5.250		08/25/36		495,263
Morgan Stanley Mortgage Loan Trust Series 2005-7, Class 2A1^(b)
3,738,536		5.586		11/25/35		3,639,371
Morgan Stanley Mortgage Loan Trust Series 2007-12, Class 3A22
3,731,795		6.000		08/25/37		3,296,279
RBSGC Mortgage Pass-Through Certificates Series 2007-B, Class 2A1^(b)
4,728,774		5.997		11/25/21		4,020,886
RBSGC Mortgage Pass-Through Certificates Series 2007-B, Class 3A1^(b)
340,471		5.332		07/25/35		335,238
Residential Accredit Loans, Inc. Series 2003-QS7, Class A2
2,583,947		4.750		04/25/33		2,626,236
Residential Accredit Loans, Inc. Series 2004-QS2, Class CB
4,574,273		5.750		02/25/34		4,610,071
Residential Accredit Loans, Inc. Series 2005-QS11, Class A2^(b)
741,111		0.713		07/25/35		609,012


12		The accompanying notes are an integral part of these financial statements.

COMMERCE BOND FUND


Principal Amount	Interest Rate			Maturity Date	Value
Mortgage-Backed Obligations – (continued)
Collateralized Mortgage Obligations – (continued)
Residential Asset Mortgage Products, Inc. Series 2004-SL4, Class A2
$ 1,525,670		6.000	%	07/25/32	$	1,539,565
Residential Asset Securitization Trust Series 2004-A6, Class A1
3,297,128		5.000		08/25/19		3,289,640
Residential Funding Mortgage Securities Corp. Series 2003-RM2, Class AIII
751,539		6.000		05/25/33		781,670
Residential Funding Mortgage Securities I, Inc. Series 2003-S8, Class A1
499,982		5.000		05/25/18		514,277
Residential Funding Mortgage Securities I, Inc. Series 2005-S7, Class A5
1,375,788		5.500		11/25/35		1,316,426
Residential Funding Mortgage Securities I, Inc. Series 2005-S9, Class A5
2,983,695		5.750		12/25/35		2,815,534
Residential Funding Mortgage Securities I, Inc. Series 2006-S12, Class 1A1
2,678,669		5.500		12/25/21		2,672,283
Sequoia Mortgage Trust Series 2004-10, Class A1A^(b)
1,035,790		0.523		11/20/34		962,539
Structured Asset Securities Corp. Series 2003-20, Class 1A1
3,107,103		5.500		07/25/33		3,220,696
Structured Asset Securities Corp. Series 2003-31A, Class 2A7^(b)
1,262,717		2.561		10/25/33		1,201,335
Structured Asset Securities Corp. Series 2003-34A, Class 3A3^(b)
1,843,596		2.574		11/25/33		1,763,803
Structured Asset Securities Corp. Series 2004-11XS, Class 1A4B
3,220,006		5.710		06/25/34		2,957,286
Structured Asset Securities Corp. Series 2005-6, Class 5A2
610,043		5.000		05/25/35		612,498
Washington Mutual Alternative Mortgage Pass-Through Certificates Series 2005-4, Class 4A1
2,328,903		5.500		06/25/20		2,325,398
Washington Mutual MSC Mortgage Pass-Through Series 2002-MS2, Class 3A1
165,763		6.500		05/25/32		165,724
Wells Fargo Mortgage Backed Securities Trust Series 2003-6, Class 1A1
696,847		5.000		06/25/18		722,148
Wells Fargo Mortgage Backed Securities Trust Series 2005-1, Class 3A1
469,785		5.250		01/25/20		483,920
Wells Fargo Mortgage Backed Securities Trust Series 2005-AR15, Class 1A2^(b)
1,300,171		5.048		09/25/35		1,252,738
Wells Fargo Mortgage Backed Securities Trust Series 2006-12, Class A5
500,000		6.000		10/25/36		200,138


Principal Amount	Interest Rate			Maturity Date		Value
Mortgage-Backed Obligations – (continued)
Collateralized Mortgage Obligations – (continued)
Wells Fargo Mortgage Backed Securities Trust Series 2007-2, Class 3A5
$ 1,000,000		5.250	%		03/25/37	$	963,210
WF-RBS Commercial Mortgage Trust Series 2011-C2, Class A1^(a)
3,943,631		2.501			02/15/44		4,003,921

TOTAL COLLATERALIZED MORTGAGE OBLIGATIONS
(Cost $152,710,571)						$	173,099,378

Commercial Mortgage Obligations – 1.4%
GNMA Series 2003-16, Class B
$3,580,000		4.490	%		08/16/25	$	3,748,556
GNMA Series 2003-38, Class JC^(b)
93,174		7.321			08/16/42		105,247
GNMA Series 2004-60, Class C^(b)
5,000,000		5.240			03/16/28		5,259,779

TOTAL COMMERCIAL MORTGAGE OBLIGATIONS
(Cost $8,711,766)						$	9,113,582

Mortgage-Backed Pass-Through Obligations – 2.9%
FHLMC
$ 57,425		8.500	%		02/01/19	$	63,042
105,802		8.500			03/01/21		119,405
616,249		7.000			05/01/26		708,143
37,428		7.000			10/01/30		43,155
91,047		7.500			12/01/30		105,869
171,888		7.500			01/01/31		199,871
324,994		7.000			08/01/31		374,967
3,960,038		5.000			05/01/33		4,205,428
697,863		2.604	^(b)		05/01/34		723,813
1,377,689		5.269	^(b)		01/01/36		1,474,013
FNMA
55,226		6.000			12/01/13		57,870
28,440		6.500			07/01/14		31,258
51,752		9.000			11/01/21		58,374
84,622		9.000			02/01/25		99,358
17,040		6.500			03/01/26		19,277
29,984		8.000			07/01/28		34,968
134,151		6.500			10/01/28		151,760
93,207		2.455	^(b)		12/01/28		94,251
55,772		6.500			01/01/29		63,093
79,110		6.000			07/01/29		87,466
103,725		7.500			09/01/29		120,807
76,371		7.000			03/01/31		87,990
35,470		7.500			03/01/31		41,346
195,707		7.000			11/01/31		225,473
322,969		7.000			01/01/32		372,091
1,163,331		6.000			12/01/32		1,286,221
313,093		5.310	^(b)		02/01/33		334,278
1,274,582		5.000			07/01/33		1,354,360
662,951		5.219	^(b)		10/01/34		697,234
1,492,601		5.078	^(b)		02/01/35		1,583,630


The accompanying notes are an integral part of these financial statements.		13

COMMERCE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date		Value
Mortgage-Backed Obligations – (continued)
Mortgage-Backed Pass-Through Obligations – (continued)
GNMA
$ 210,279		8.000	%		02/15/22	$	245,699
83,728		7.500			08/20/25		97,067
386,736		7.500			07/20/26		448,172
460,817		6.500			04/15/31		522,312
345,641		6.500			05/15/31		391,767
1,819,472		5.500			04/15/33		1,993,378

TOTAL MORTGAGE-BACKED PASS-THROUGH OBLIGATIONS
(Cost $17,114,791)						$	18,517,206

TOTAL MORTGAGE-BACKED OBLIGATIONS
(Cost $178,537,128)						$	200,730,166


Corporate Obligations – 27.4%
Aerospace/Defense – 0.8%
Goodrich Corp.
$ 1,000,000		4.875	%		03/01/20	$	1,050,798
Lockheed Martin Corp.
1,972,000		6.150			09/01/36		2,163,085
United Technologies Corp.
2,000,000		5.700			04/15/40		2,158,174

							5,372,057

Beverages – 0.7%
Anheuser-Busch Cos., Inc.
1,500,000		5.600			03/01/17		1,691,634
PepsiCo, Inc.
2,500,000		4.500			01/15/20		2,638,737

							4,330,371

Cable TV – 1.3%
Comcast Corp.
1,500,000		5.700			07/01/19		1,648,860
1,250,000		6.400			05/15/38		1,325,300
DIRECTV Holdings LLC/DIRECTV Financing Co, Inc.
3,000,000		3.500			03/01/16		3,045,894
Time Warner Cable, Inc.
2,000,000		6.200			07/01/13		2,202,318

							8,222,372

Chemicals – 0.5%
E.I. du Pont de Nemours and Co.
1,000,000		3.250			01/15/15		1,045,408
Sigma-Aldrich Corp.
2,000,000		3.375			11/01/20		1,894,484

							2,939,892

Commercial Banks – 2.4%
Barclays Bank PLC
2,000,000		5.125			01/08/20		2,057,744


Principal Amount	Interest Rate			Maturity Date	Value
Corporate Obligations – (continued)
Commercial Banks – (continued)
Credit Suisse AG
$3,000,000		5.400	%	01/14/20	$	3,094,251
Credit Suisse New York
1,500,000		5.000		05/15/13		1,607,731
KeyBank NA
2,540,000		5.800		07/01/14		2,792,268
Wachovia Bank NA
2,000,000		5.000		08/15/15		2,158,994
Wells Fargo Bank NA
3,125,000		4.750		02/09/15		3,360,800

						15,071,788

Communications Equipment – 0.4%
Cisco Systems, Inc.
2,500,000		4.450		01/15/20		2,600,468

Computers – 0.3%
Hewlett-Packard Co.
2,000,000		2.125		09/13/15		1,986,362

Consumer Services – 0.3%
eBay, Inc.
2,000,000		1.625		10/15/15		1,933,334

Diversified Manufacturing – 1.1%
GE Capital Trust I^(b)
3,525,000		6.375		11/15/67		3,657,187
Ingersoll-Rand Global Holding Co. Ltd.
1,000,000		9.500		04/15/14		1,204,123
Parker-Hannifin Corp.
2,000,000		3.500		09/15/22		1,883,504

						6,744,814

Electric – 2.2%
Columbus Southern Power Co.
2,870,000		5.850		10/01/35		2,976,750
Connecticut Light & Power Co.
415,000		5.650		05/01/18		465,892
Duke Energy Corp.
1,525,000		5.300		10/01/15		1,716,741
Exelon Generation Co. LLC
1,470,000		5.350		01/15/14		1,592,377
PacifiCorp
2,400,000		5.650		07/15/18		2,709,857
San Diego Gas & Electric Co.
1,585,000		5.300		11/15/15		1,780,836
Southern California Edison Co.
3,000,000		5.500		03/15/40		3,102,000

						14,344,453

Financial – 6.3%
Bank One Corp.
1,000,000		8.530		03/01/19		1,230,037


14		The accompanying notes are an integral part of these financial statements.

COMMERCE BOND FUND


Principal Amount	Interest Rate			Maturity Date	Value
Corporate Obligations – (continued)
Financial – (continued)
Bear Stearns Companies, Inc.
$1,000,000		7.250	%	02/01/18	$	1,174,944
Blackstone Holdings Finance Co. LLC^(a)
3,000,000		5.875		03/15/21		2,972,127
Citigroup, Inc.
2,750,000		6.010		01/15/15		3,048,169
Equitable Life Assurance Society of the United States^(a)
6,220,000		7.700		12/01/15		7,233,897
General Electric Capital Corp.
2,000,000		5.900		05/13/14		2,229,934
Jefferies Group, Inc.
1,600,000		3.875		11/09/15		1,621,150
JPMorgan Chase & Co.
1,250,000		6.000		01/15/18		1,391,035
Merrill Lynch & Co., Inc.
1,270,000		6.875		04/25/18		1,441,126
Metropolitan Life Insurance Co.^(a)
6,770,000		7.700		11/01/15		7,946,958
Morgan Stanley & Co.
2,600,000		6.625		04/01/18		2,902,593
National Rural Utilities Cooperative Finance Corp.
1,550,000		5.450		04/10/17		1,733,963
SunTrust Capital VIII^(b)
2,670,000		6.100		12/15/36		2,616,600
TD Ameritrade Holding Corp.
2,750,000		4.150		12/01/14		2,901,575

						40,444,108

Food – 0.2%
Kraft Foods, Inc.
1,000,000		6.875		02/01/38		1,152,566

Health Care Equipment & Supplies – 0.5%
Baxter International, Inc.
2,650,000		5.375		06/01/18		2,983,834

Health Technology – 0.3%
Becton, Dickinson & Co.
2,000,000		3.250		11/12/20		1,885,208

Industrial – 0.3%
Receipts on Corporate Securities Trust NSC-1998-1
2,016,781		6.375		05/15/17		2,078,515

Insurance – 0.9%
Aegon NV
2,650,000		4.625		12/01/15		2,790,667
American International Group, Inc.
1,000,000		3.650		01/15/14		1,024,918
Reinsurance Group of America, Inc.
2,000,000		6.450		11/15/19		2,193,260

						6,008,845


Principal Amount	Interest Rate			Maturity Date	Value
Corporate Obligations – (continued)
Metals & Mining – 0.5%
Rio Tinto Finance USA Ltd.
$3,000,000		5.200	%	11/02/40	$	2,929,686

Multimedia – 0.6%
CBS Corp.
2,600,000		8.200		05/15/14		3,056,095
The McGraw-Hill Companies, Inc.
1,000,000		5.375		11/15/12		1,060,772

						4,116,867

Oil & Gas – 1.6%
Apache Corp.
1,360,000		7.375		08/15/47		1,660,972
BP Capital Markets PLC
3,530,000		3.875		03/10/15		3,702,423
Tosco Corp.
2,095,000		8.125		02/15/30		2,757,317
Valero Energy Corp.
2,000,000		6.875		04/15/12		2,105,816

						10,226,528

Real Estate – 1.4%
AMB Property LP
2,000,000		6.125		12/01/16		2,212,252
Hospitality Properties Trust
1,240,000		6.300		06/15/16		1,371,725
Kimco Realty Corp.
2,000,000		4.300		02/01/18		2,042,296
Simon Property Group LP
1,000,000		6.750		05/15/14		1,129,607
2,000,000		4.200		02/01/15		2,128,994

						8,884,874

Retail – 0.2%
Wal-Mart Stores, Inc.
1,250,000		6.200		04/15/38		1,381,578

Software – 0.4%
Adobe Systems, Inc.
2,700,000		4.750		02/01/20		2,773,713

Sovereign Agency – 0.3%
Resolution Funding Corp.
1,500,000		8.125		10/15/19		2,047,746

Telecommunications – 0.8%
AT&T, Inc.
2,320,000		2.500		08/15/15		2,326,051
Telefonica Emisiones SAU
2,635,000		3.729		04/27/15		2,703,067

						5,029,118

Utilities – 1.3%
GTE Corp.
5,310,000		6.840		04/15/18		6,182,746


The accompanying notes are an integral part of these financial statements.		15

COMMERCE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Corporate Obligations – (continued)
Utilities – (continued)
Pacific Gas & Electric Co.
$ 2,000,000		6.350	%	02/15/38	$	2,200,982

						8,383,728

Yankee – 1.8%
BHP Billiton Finance USA Ltd.
750,000		6.750		11/01/13		847,463
955,000		5.250		12/15/15		1,073,937
Canadian National Railway Co.
1,190,000		6.200		06/01/36		1,339,547
Swiss Bank Corp.
7,335,000		7.375		06/15/17		8,304,166

						11,565,113

TOTAL CORPORATE OBLIGATIONS
(Cost $164,488,844)					$	175,437,938


U.S. Government Agency Obligations – 14.3%
FFCB
$ 5,000,000		2.625	%	04/17/14	$	5,214,410
6,135,000		4.500		05/06/14		6,737,647
6,460,000		3.000		06/17/16		6,481,156
2,860,000		5.190		04/22/21		3,205,720
FHLB
5,000,000		1.750		08/22/12		5,085,555
5,000,000		4.500		09/16/13		5,420,440
7,000,000		3.625		10/18/13		7,448,616
2,050,000		5.625		06/13/16		2,267,300
1,915,000		5.375		08/15/24		2,144,331
2,650,000		7.125		02/15/30		3,430,867
FHLMC
5,000,000		1.625		04/15/13		5,093,710
29,488		6.000		12/01/13		32,000
2,860,000		2.875		02/09/15		2,993,562
2,500,000		5.000		02/16/17		2,831,400
2,500,000		6.750		03/15/31		3,214,102
FNMA
4,000,000		1.300		05/25/12		4,002,360
5,000,000		1.750		02/22/13		5,098,635
3,000,000		1.750		05/07/13		3,060,849
4,500,000		5.000		02/13/17		5,103,792
3,000,000		5.000		05/11/17		3,407,718
2,000,000		5.375		04/11/22		2,081,518
Tennessee Valley Authority
2,456,999		4.929		01/15/21		2,684,272
1,485,096		5.131		01/15/21		1,642,888
2,500,000		5.880		04/01/36		2,886,980

TOTAL U.S. GOVERNMENT AGENCY OBLIGATIONS
(Cost $88,795,558)					$	91,569,828


Principal Amount	Interest Rate			Maturity Date		Value
Government Guarantee Obligations^(d) – 0.5%
Oriental Bank & Trust
$ 3,000,000		2.750	%		03/16/12	$	3,062,910
(Cost $3,000,000)


U.S. Treasury Obligations – 2.4%
United States Treasury Bonds
$ 2,150,000		5.375	%		02/15/31	$	2,498,031
5,000,000		4.500			02/15/36		5,124,220
3,000,000		3.500			02/15/39		2,558,436
United States Treasury Notes
5,000,000		2.750			11/30/16		5,142,190

TOTAL U.S. TREASURY OBLIGATIONS
(Cost $15,022,192)						$	15,322,877


Shares	Description	Rate			Value
Investment Company – 0.7%
Vanguard Long-Term Investment Grade Fund Admiral Shares
506,527			5.600	%	$	4,776,552
(Cost $3,961,043)


Principal Amount	Interest Rate			Maturity Date	Value
Short-term Investment^(e) – 2.1%
Repurchase Agreement – 2.1%
State Street Bank & Trust Co.
$13,594,000		0.010	%	05/02/11	$	13,594,000
Maturity Value: $13,594,011
(Cost $13,594,000)

TOTAL INVESTMENTS – 99.9%
(Cost $597,135,695)					$	640,764,265

OTHER ASSETS IN EXCESS OF LIABILITIES – 0.1%						807,286

NET ASSETS – 100.0%					$	641,571,551


The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets.
^(a)		Exempt from registration under Rule 144A of the Securities Act of 1933. Under procedures approved by the Board of Trustees, such securities have been determined to be liquid by the Investment Adviser and may be resold, normally to qualified institutional buyers in transactions exempt from registration. Total market value of Rule 144A securities amounted to $35,814,108, which represents approximately 5.6% of net assets as of April 30, 2011.
^(b)		Variable rate security. The interest rate shown reflects the rate as of April 30, 2011.
^(c)		Issued with a zero coupon. Income is recognized through the accretion of discount.


16		The accompanying notes are an integral part of these financial statements.

COMMERCE BOND FUND


^(d)		Guaranteed under the Federal Deposit Insurance Corporation’s (“FDIC”) Temporary Liquidity Guarantee Program and is backed by the full faith and credit of the United States. The expiration date of the FDIC’s guarantee is the earlier of the maturity date of the debt or June 30, 2012.
^(e)		Repurchase agreement was entered into on April 29, 2011. This agreement was fully collateralized by $13,700,000 U.S. Treasury Note, 1.000%, due 04/30/12 with a market value of $13,868,731.



Investment Abbreviations:
AGM		—Insured by Assured Guaranty Municipal Corp.
AMBAC		—Insured by American Municipal Bond Assurance Corp.
FFCB		—Federal Farm Credit Bank
FHLB		—Federal Home Loan Bank
FHLMC		—Federal Home Loan Mortgage Corp.
FNIC		—Financial Network Investment Corporation
FNMA		—Federal National Mortgage Association
GNMA		—Government National Mortgage Association
GO		—General Obligation
MSC		—Mortgage Securities Corp.
NATL-RE		—Insured by National Reinsurance Corp.
PAC		—Planned Amortization Class
REMIC		—Real Estate Mortgage Investment Conduit
TAC		—Targeted Amortization Class
XLCA		—Insured by XL Capital Assurance, Inc.

PORTFOLIO COMPOSITION


	AS OF 4/30/11			AS OF 10/31/10

Corporate Obligations		27.4	%		28.1	%
Collateralized Mortgage Obligations		27.0			28.1
U.S.Government Agency Obligations		14.3			14.5
Asset-Backed Securities		8.9			8.2
Taxable Municipal Bond Obligations		12.3			8.0
Mortgage-Backed Pass-Through Obligations		2.9			3.3
U.S. Treasury Obligations		2.4			3.5
Commercial Mortgage Obligations		1.4			1.7
Investment Companies		0.7			0.7
Government Guarantee Obligations		0.5			2.0
Short-term Investment		2.1			1.4

TOTAL INVESTMENTS		99.9	%		99.5	%

The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets. Underlying investment categories of investment companies held by the Fund are not reflected in the table above. Consequently, the Fund’s overall investment category allocations may differ from the percentages contained in the table above.

The Fund is actively managed and, as such its composition may differ over time.


The accompanying notes are an integral part of these financial statements.		17

COMMERCE SHORT-TERM GOVERNMENT FUND

Schedule of Investments

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Asset-Backed Securities – 1.6%
Commercial – 0.9%
Small Business Administration Series 2006-P10B, Class 1
$ 951,166		5.681	%	08/10/16	$	1,029,630

Home Equity^(a) – 0.7%
Argent Securities, Inc. Series 2004-W5, Class AV3B
778,639		0.663		04/25/34		666,737
Lehman XS Trust Series 2005-7N, Class 1A1A
336,483		0.483		12/25/35		238,362

						905,099

TOTAL ASSET-BACKED SECURITIES
(Cost $1,572,919)					$	1,934,729


Mortgage-Backed Obligations – 27.0%
Collateralized Mortgage Obligations – 22.5%
ABN Amro Mortgage Corp. Series 2003-11, Class A9
$ 216,901		6.000	%	10/25/33	$	220,189
American Home Mortgage Investment Trust Series 2004-3, Class 6A4
396,935		5.010		10/25/34		397,491
Banc of America Alternative Loan Trust Series 2004-1, Class 1A1
468,351		6.000		02/25/34		492,245
Bank of America Funding Corp. Series 2004-A, Class 1A3^(a)
94,212		4.946		09/20/34		95,674
Chase Mortgage Finance Corp. Series 2003-S13, Class A1
512,963		5.500		11/25/33		530,621
Citicorp Mortgage Securities, Inc. Series 2004-3, Class A11
104,785		5.250		05/25/34		104,717
Citicorp Mortgage Securities, Inc. Series 2004-5, Class 2A3
147,500		4.750		08/25/34		153,072
Citigroup Mortgage Loan Trust, Inc. Series 2004-HYB3, Class 1A^(a)
259,321		2.984		09/25/34		249,371
Countrywide Alternative Loan Trust Series 2003-21T1, Class A2
999,367		5.250		12/25/33		1,011,628
Countrywide Alternative Loan Trust Series 2004-29CB, Class A7
490,016		5.375		01/25/35		487,399
Countrywide Alternative Loan Trust Series 2005-5R, Class A2
555,296		4.750		12/25/18		560,197
Countrywide Home Loans Trust Series 2003-J6, Class 1A1
138,358		5.500		08/25/33		147,123
Countrywide Home Loans, Inc. Series 2002-35, Class 3A1
373,348		5.000		02/25/18		385,911
Countrywide Home Loans, Inc. Series 2003-HYB3, Class 7A1^(a)
435,155		2.961		11/19/33		434,917
FHLMC REMIC PAC Series 023, Class PK
384,229		6.000		11/25/23		413,516


Principal Amount	Interest Rate			Maturity Date	Value
Mortgage-Backed Obligations – (continued)
Collateralized Mortgage Obligations – (continued)
FHLMC REMIC PAC Series 041, Class F
$ 63,625		10.000	%	05/15/20	$	71,686
FHLMC REMIC PAC Series 159, Class H
27,587		4.500		09/15/21		28,931
FHLMC REMIC PAC Series 2022, Class PE
91,795		6.500		01/15/28		103,489
FHLMC REMIC PAC Series 2109, Class PE
270,420		6.000		12/15/28		298,251
FHLMC REMIC PAC Series 2345, Class PQ
38,334		6.500		08/15/16		40,835
FHLMC REMIC PAC Series 2522, Class PE
281,154		5.500		03/15/22		292,244
FHLMC REMIC PAC Series 2524, Class PD
231,693		5.500		12/15/31		243,409
FHLMC REMIC PAC Series 2594, Class OR
35,861		4.250		06/15/32		36,257
FHLMC REMIC PAC Series 2668, Class OE
573,031		5.000		10/15/28		584,523
FHLMC REMIC PAC Series 2760, Class EC
1,000,000		4.500		04/15/17		1,033,551
FHLMC REMIC PAC Series 2836, Class PX
716,003		4.000		05/15/18		745,280
FHLMC REMIC PAC Series 3028, Class MC
1,510,586		5.000		06/15/29		1,544,795
FHLMC REMIC PAC Series 3059, Class CD
945,000		5.000		04/15/31		1,018,505
FHLMC REMIC PAC Series 3117, Class PC
517,883		5.000		06/15/31		541,204
FHLMC REMIC Series 2534, Class HB
341,396		5.000		10/15/16		344,751
FHLMC REMIC Series 2584, Class LX
52,074		5.500		12/15/13		52,577
FHLMC REMIC Series 2642, Class DA
464,245		5.000		05/15/22		486,201
FHLMC REMIC Series 2664, Class MA
287,993		5.000		04/15/30		294,541
FHLMC REMIC Series 2830, Class DA
360,245		5.000		07/15/19		373,456
FHLMC REMIC Series 2972, Class CA
430,082		4.500		05/15/20		457,329
FHLMC REMIC Series 3131, Class BA
223,652		5.500		11/15/24		237,189
FHLMC REMIC Series 3146, Class GA
254,427		5.500		11/15/24		270,545
FNMA REMIC PAC Series 1992, Class 89 Principal-Only Stripped Security^(b)
32,140		0.000		06/25/22		28,952
FNMA REMIC PAC Series 1992-129, Class L
197,236		6.000		07/25/22		218,623


18		The accompanying notes are an integral part of these financial statements.

COMMERCE SHORT-TERM GOVERNMENT FUND


Principal Amount	Interest Rate			Maturity Date	Value
Mortgage-Backed Obligations – (continued)
Collateralized Mortgage Obligations – (continued)
FNMA REMIC PAC Series 1993-132, Class A Principal-Only Stripped Security^(b)
$ 9,683		0.000	%	10/25/22	$	9,649
FNMA REMIC PAC Series 1998-36, Class J
97,437		6.000		07/18/28		105,487
FNMA REMIC PAC Series 2001-71, Class MB
218,748		6.000		12/25/16		235,740
FNMA REMIC PAC Series 2003-117, Class KB
556,000		6.000		12/25/33		627,323
FNMA REMIC PAC Series 2003-14, Class AP
414,572		4.000		03/25/33		435,311
FNMA REMIC Series 1991-137, Class H
85,418		7.000		10/25/21		95,752
FNMA REMIC Series 1993-182, Class FA^(a)
31,216		2.860		09/25/23		32,426
FNMA REMIC Series 2003-33, Class LD
1,225,846		4.250		09/25/22		1,267,681
FNMA Series 2003-W17, Class 1A6
73,394		5.310		08/25/33		77,023
GNMA Series 1998-12, Class EB
168,873		6.500		05/20/28		176,370
GNMA Series 2001-53, Class F^(a)
30,098		0.563		10/20/31		30,064
GSR Mortgage Loan Trust Series 2003-6F, Class A1
356,817		3.000		09/25/32		351,966
GSR Mortgage Loan Trust Series 2004-6F, Class 5A1
1,068,879		5.500		03/25/19		1,109,865
GSR Mortgage Loan Trust Series 2006-AR1, Class 2A4^(a)
1,070,000		2.809		01/25/36		754,660
Indymac Index Mortgage Loan Trust Series 2004-AR6, Class 6A1^(a)
430,683		5.508		10/25/34		409,461
Master Adjustable Rate Mortgages Trust Series 2004-13, Class 2A1^(a)
721,034		2.796		04/21/34		717,163
Master Asset Securitization Trust Series 2003-6, Class 9A1
29,830		4.250		07/25/33		29,846
Master Asset Securitization Trust Series 2004-3, Class 5A1
54,006		6.250		01/25/32		54,552
Residential Accredit Loans, Inc. Series 2004-QA4, Class NB21^(a)
97,976		3.686		09/25/34		95,257
Residential Accredit Loans, Inc. Series 2004-QS5, Class A5
389,306		4.750		04/25/34		390,826
Residential Funding Mortgage Securities Corp. Series 2003-RM2, Class AII
139,572		5.000		05/25/18		143,109
Residential Funding Mortgage Securities I, Inc. Series 2003-S8, Class A1
194,222		5.000		05/25/18		199,775


Principal Amount	Interest Rate			Maturity Date	Value
Mortgage-Backed Obligations – (continued)
Collateralized Mortgage Obligations – (continued)
Securitized Asset Sales, Inc. Series 1993-7, Class TA6
$ 23,934		6.250	%	12/25/23	$	24,950
Sequoia Mortgage Trust Series 10, Class 1A^(a)
188,192		1.013		10/20/27		178,545
Sequoia Mortgage Trust Series 2003-2, Class A1^(a)
333,902		0.873		06/20/33		301,164
Structured Asset Securities Corp. Series 2003-20, Class 1A1
812,084		5.500		07/25/33		841,773
Structured Asset Securities Corp. Series 2003-31A, Class 2A7^(a)
1,145,503		2.561		10/25/33		1,089,819
Vendee Mortgage Trust Series 1996-2, Class 1Z
225,250		6.750		06/15/26		254,968
Washington Mutual MSC Mortgage Pass-Through Series 2002-MS8, Class 4A5
196,370		5.750		12/25/32		203,989
Washington Mutual MSC Mortgage Pass-Through Series 2003-MS8, Class 2A1
1,202,557		5.000		05/25/18		1,233,250
Wells Fargo Alternative Loan Trust Series 2003-1, Class 2A1
749,846		5.750		09/25/18		761,098
Wells Fargo Mortgage Backed Securities Trust Series 2003-6, Class 1A1
125,433		5.000		06/25/18		129,987

TOTAL COLLATERALIZED MORTGAGE OBLIGATIONS
(Cost $26,209,459)					$	27,400,044

Commercial Mortgage Obligations – 1.3%
GNMA Series 2004-20, Class C
$ 398,977		4.430	%	04/16/34	$	406,745
GNMA Series 2004-60, Class C^(a)
1,150,000		5.240		03/16/28		1,209,749

TOTAL COMMERCIAL MORTGAGE OBLIGATIONS
(Cost $1,559,051)					$	1,616,494

Mortgage-Backed Pass-Through Obligations – 3.2%
FHLMC
$ 103,060		5.500	%	08/01/17	$	111,811
245,813		5.500		09/01/21		266,839
84,506		6.000		10/01/23		92,672
358,943		5.000		05/01/27		381,466
FNMA
39,565		6.500		09/01/13		43,486
118,034		10.500		11/01/15		128,185
90,374		6.000		07/01/16		98,749
422,692		5.500		05/01/19		459,176
421,699		5.500		06/01/20		458,098
4,992		4.195	^(a)	08/01/23		5,243
3,425		9.000		07/01/24		3,444
11,030		2.455	^(a)	12/01/28		11,154
59,305		7.000		11/01/31		68,325
638,978		6.000		07/01/33		706,477
585,654		2.603	^(a)	02/01/34		614,633
309,130		5.219	^(a)	10/01/34		325,116


The accompanying notes are an integral part of these financial statements.		19

COMMERCE SHORT-TERM GOVERNMENT FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Mortgage-Backed Obligations – (continued)
Mortgage-Backed Pass-Through Obligations – (continued)
GNMA
$ 7,976		8.000	%	07/15/17	$	9,095
1,398		3.000	^(a)	12/20/24		1,448
15,105		3.375	^(a)	04/20/26		15,741
14,032		2.625	^(a)	08/20/26		14,493
16,018		3.375	^(a)	01/20/28		16,697

TOTAL MORTGAGE-BACKED PASS-THROUGH OBLIGATIONS
(Cost $3,674,750)					$	3,832,348

TOTAL MORTGAGE-BACKED OBLIGATIONS
(Cost $31,443,260)					$	32,848,886


Government Guarantee Obligations^(c) – 6.2%
GMAC, Inc.
$1,000,000		2.200	%	12/19/12	$	1,027,427
JPMorgan Chase & Co.
800,000		3.125		12/01/11		813,370
Keybank National Association
400,000		3.200		06/15/12		412,944
Morgan Stanley & Co.
750,000		2.250		03/13/12		762,338
Regions Bank
1,000,000		3.250		12/09/11		1,018,510
U.S. Bancorp
750,000		2.250		03/13/12		762,794
1,000,000		1.800		05/15/12		1,014,651
U.S. Central Credit Union
900,000		1.900		10/19/12		918,431
Wells Fargo & Co.
800,000		3.000		12/09/11		813,567

TOTAL GOVERNMENT GUARANTEE OBLIGATIONS
(Cost $7,392,254)					$	7,544,032


U.S. Government Agency Obligations – 51.2%
FFCB
$1,000,000		3.875	%	10/07/13	$	1,071,921
2,600,000		2.625		04/17/14		2,711,493
1,170,000		3.000		09/22/14		1,233,002
150,000		4.700		08/10/15		167,295
250,000		7.000		09/01/15		301,048
500,000		6.125		12/29/15		590,864
FHLB
1,250,000		4.750		12/09/11		1,282,903
1,000,000		3.500		03/08/13		1,052,849
1,500,000		5.125		08/14/13		1,646,029
1,000,000		3.625		10/18/13		1,064,088
1,560,000		5.250		06/18/14		1,751,424
1,000,000		5.250		09/12/14		1,124,319
2,500,000		5.000		12/21/15		2,822,487
1,000,000		4.000		03/04/16		1,047,023
250,000		5.375		05/15/19		287,467


Principal Amount	Interest Rate			Maturity Date	Value
U.S. Government Agency Obligations – (continued)
FHLMC
$1,575,000		2.125	%	09/21/12	$	1,611,108
1,500,000		4.625		10/25/12		1,591,911
1,800,000		1.625		04/15/13		1,833,736
1,500,000		4.000		06/12/13		1,602,132
2,000,000		1.500		07/12/13		2,003,724
1,000,000		1.250		07/29/13		1,002,265
1,560,000		2.500		01/07/14		1,621,080
1,600,000		2.500		04/23/14		1,662,846
790,000		5.000		07/15/14		881,725
1,000,000		4.500		01/15/15		1,106,262
1,200,000		2.875		02/09/15		1,256,040
1,300,000		1.750		09/10/15		1,294,046
1,300,000		5.300		12/01/15		1,485,037
1,500,000		1.000		08/26/16		1,502,290
FNMA
1,000,000		6.125		03/15/12		1,050,216
2,000,000		3.625		02/12/13		2,104,266
1,500,000		4.375		03/15/13		1,603,977
1,200,000		0.875		03/21/14		1,202,603
1,600,000		2.500		05/15/14		1,660,347
1,000,000		3.000		07/28/14		1,005,479
2,000,000		3.000		09/16/14		2,111,354
1,250,000		4.625		10/15/14		1,386,161
2,000,000		2.625		11/20/14		2,083,602
1,800,000		5.000		04/15/15		2,031,340
1,250,000		2.375		07/28/15		1,281,468
1,000,000		4.375		10/15/15		1,103,500
2,000,000		1.625		10/26/15		1,974,630
1,800,000		5.000		03/15/16		2,040,998
Tennessee Valley Authority
900,000		6.790		05/23/12		961,596

TOTAL U.S. GOVERNMENT AGENCY OBLIGATIONS
(Cost $60,549,257)					$	62,209,951


U.S. Treasury Obligations – 13.1%
United States Treasury Inflation Protected Securities
$1,230,660		3.000	%	07/15/12	$	1,316,037
1,197,530		2.000		01/15/14		1,317,189
1,173,880		2.000		07/15/14		1,303,924
United States Treasury Notes
435,000		4.500		04/30/12		453,233
1,800,000		1.375		09/15/12		1,825,101
2,400,000		1.375		11/15/12		2,435,155
1,200,000		1.750		04/15/13		1,226,856
1,200,000		1.750		03/31/14		1,226,156
1,700,000		2.375		10/31/14		1,764,148
1,200,000		2.250		01/31/15		1,237,219
1,800,000		2.125		05/31/15		1,840,356

TOTAL U.S. TREASURY OBLIGATIONS
(Cost $15,255,026)					$	15,945,374


20		The accompanying notes are an integral part of these financial statements.

COMMERCE SHORT-TERM GOVERNMENT FUND


Principal Amount	Interest Rate			Maturity Date		Value
Short-term Investment^(d) – 0.7%
Repurchase Agreement – 0.7%
State Street Bank & Trust Co.
$ 825,000		0.010	%		05/02/11	$	825,000
Maturity Value: $825,001
(Cost $825,000)

TOTAL INVESTMENTS – 99.8%
(Cost $117,037,716)						$	121,307,972

OTHER ASSETS IN EXCESS OF LIABILITIES – 0.2%							192,928

NET ASSETS – 100.0%						$	121,500,900


The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets.
^(a)		Variable rate security. The interest rate shown reflects the rate as of April 30, 2011.
^(b)		Issued with a zero coupon. Income is recognized through the accretion of discount.
^(c)		Guaranteed under the Federal Deposit Insurance Corporation’s (“FDIC”) Temporary Liquidity Guarantee Program and is backed by the full faith and credit of the United States. The expiration date of the FDIC’s guarantee is the earlier of the maturity date of the debt or June 30, 2012.
^(d)		Repurchase agreement was entered into on April 29, 2011. This agreement was fully collateralized by $835,000 U.S. Treasury Note, 1.000%, due 04/30/12 with a market value of $845,284.



Investment Abbreviations:
FFCB		—Federal Farm Credit Bank
FHLB		—Federal Home Loan Bank
FHLMC		—Federal Home Loan Mortgage Corp.
FNMA		—Federal National Mortgage Association
GNMA		—Government National Mortgage Association
MSC		—Mortgage Securities Corp.
PAC		—Planned Amortization Class
REMIC		—Real Estate Mortgage Investment Conduit

PORTFOLIO COMPOSITION


	AS OF 4/30/11			AS OF 10/31/10

U.S. Government Agency Obligations		51.2	%		46.1	%
Collateralized Mortgage Obligations		22.5			21.6
U.S. Treasury Obligations		13.1			13.6
Government Guarantee Obligations		6.2			7.0
Mortgage-Backed Pass-Through Obligations		3.2			3.3
Asset-Backed Securities		1.6			1.6
Commercial Mortgage Obligations		1.3			2.5
Short-term Investment		0.7			3.7

TOTAL INVESTMENTS		99.8	%		99.4	%

The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets.

The Fund is actively managed and, as such, its composition may differ over time.


The accompanying notes are an integral part of these financial statements.		21

COMMERCE NATIONAL TAX-FREE INTERMEDIATE BOND FUND

Schedule of Investments

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – 98.8%
Alabama – 0.6%
Birmingham AL Special Care Facilities Financing Authority Revenue Bonds (Children’s Hospital) Series B (AMBAC) (A/A3)
$1,005,000		5.000	%	06/01/16	$	1,050,868
Cullman AL GO Bonds (Warrants) Series 2007 (AGM) (AA+/Aa3)
65,000		4.500		07/01/23		65,953

						1,116,821

Alaska – 0.6%
Alaska Industrial Development & Export Authority Revenue Bonds (Refunding-Greater Fairbanks) Series C (A/NR)
1,050,000		4.500		04/01/18		1,062,401

Arizona – 9.7%
Arizona Health Facilities Authority Healthcare & Education Facilities Revenue Bonds (Kirksville College) (A-/NR)
700,000		4.700		01/01/21		707,406
750,000		4.750		01/01/22		752,070
1,000,000		5.000		01/01/25		999,930
Arizona School Facilities Board Certificates of Participation (A+/A1)
2,810,000		5.125		09/01/21		2,945,189
Arizona State University Energy Management LLC Revenue Bonds (Tempe Campus II) Series 2009 (AA-/A1)
2,000,000		5.000		07/01/14		2,158,460
Glendale AZ Industrial Development Authority Revenue Bonds (Midwestern University) (A-/NR)
1,500,000		5.000		05/15/30		1,472,880
Glendale AZ Industrial Development Authority Revenue Bonds (Refunding-Midwestern University) (A-/NR)
1,200,000		5.250		05/15/19		1,307,304
Pinal County AZ Unified School District No. 1 Florence GO Bonds (School Improvement Project of 2006) Series C (A/NR)
860,000		5.000		07/01/17		950,928
335,000		5.000		07/01/18		368,343
350,000		5.000		07/01/19		378,367
1,100,000		5.125		07/01/22		1,165,076
Queen Creek AZ Excise Tax & State Shared Revenue Bonds (NATL-RE) (A+/Baa1)
1,070,000		5.000		08/01/27		1,060,530
Yuma County AZ Library District GO Bonds Series 2007 (XLCA) (A+/Aa3)
1,000,000		5.000		07/01/19		1,070,390
500,000		5.000		07/01/20		530,670
1,000,000		5.000		07/01/21		1,054,610

						16,922,153

Arkansas – 0.3%
Arkansas State Development Finance Authority Economic Development Revenue Bonds (Taxable) (A/NR)
535,000		5.480		09/01/17		553,158


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
California – 3.2%
Burbank CA Unified School District GO Bonds Capital Appreciation Election of 1997 Series C (NATL-RE) (FGIC) (AA-/NR)^(a)
$1,500,000		0.000	%	07/01/27	$	519,045
California Educational Facilities Authority Revenue Bonds for Loyola Marymount University Series 2010 A (NR/A2)
500,000		5.125		10/01/40		458,385
Long Beach CA Pension Obligation Revenue Bonds Series A (AA+/Aa3)
100,000		4.960		09/01/11		101,141
Pajaro Valley CA Unified School District GO Bonds Capital Appreciation Election of 2002 Series B (AGM) (AA+/Aa2)^(a)
3,855,000		0.000		08/01/26		1,475,771
Port Oakland CA Revenue Bonds Series C (A-/A3)
600,000		5.000		11/01/16		659,064
Sacramento County CA Airport System Revenue Bonds (A/A2)
1,000,000		5.000		07/01/27		1,008,710
San Mateo CA Unified High School District GO Bonds (Capital Appreciation) Series C (NATL-RE) (AA/Aa1)^(a)
880,000		0.000		09/01/23		438,847
Santa Clara County CA East Side Union High School District GO Bonds (Refunding) Series B (A/Baa1)
800,000		5.250		02/01/23		823,272

						5,484,235

Colorado – 1.8%
Colorado Educational & Cultural Facilities Authority Revenue Bonds (Charter School-High Point Academy) (A/NR)
1,000,000		4.500		03/01/20		992,040
Colorado Educational & Cultural Facilities Authority Revenue Bonds (Charter School-University Laboratory School Project) (ETM) (NR/NR)
60,000		5.250		06/01/11		60,215
Colorado Educational & Cultural Facilities Authority Revenue Bonds (Pinnacle Charter High School) (NR/NR)
1,000,000		5.000		12/01/29		917,160
Colorado Housing & Finance Authority Revenue Bonds (Single Family Mortgage) Series A (FHA) (AAA/Aaa)
430,000		4.350		11/01/19		437,555
450,000		4.600		11/01/20		463,964
Westminster CO Certificates of Participation (Refunding) (NATL-RE) (AA-/Baa1)
250,000		4.500		12/01/23		253,935

						3,124,869

District of Columbia – 0.7%
District of Columbia Revenue Bonds (Deed Tax) Series B (NR/A1)
1,165,000		5.000		06/01/25		1,165,792

Florida – 8.5%
Brevard County FL Health Facilities Authority Revenue Bonds (Health First, Inc. Project) Series 2005 (A-/A3)
875,000		5.000		04/01/18		899,859


22		The accompanying notes are an integral part of these financial statements.

COMMERCE NATIONAL TAX-FREE INTERMEDIATE BOND FUND


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Florida – (continued)
Broward County FL Airport System Revenue Bonds (Refunding) Series O (A+/A1)
$1,395,000		5.375	%	10/01/29	$	1,422,802
Florida Municipal Loan Council Revenue Bonds Series A (NATL-RE) (A-/Baa1)
1,000,000		5.000		10/01/20		994,770
Gulf Breeze FL Revenue Bonds (Local Government Loan) Series J (A+/Aa3)
1,000,000		4.500		12/01/20		1,067,310
Jupiter County FL (Community Center Project) GO Bonds Series 2001 (AAA/Aa1)
50,000		5.500		07/01/21		58,625
Lake County FL School Board Certificates of Participation Series A (AMBAC) (A/NR)
1,500,000		5.000		06/01/24		1,510,935
Miami-Dade County FL Aviation Revenue Bonds (Miami International Airport) Series A (A-/A2)
1,000,000		5.000		10/01/22		1,048,920
1,000,000		5.250		10/01/23		1,054,620
1,000,000		5.500		10/01/25		1,052,450
Miami-Dade County FL Educational Facilities Authority Revenue Bonds (Refunding-University of Miami) Series B (AMBAC) (A-/A3)
685,000		5.250		04/01/21		745,677
Miami-Dade County FL Expressway Authority Toll Systems Revenue Bonds Series B (FGIC) (A/A3)
1,000,000		5.250		07/01/14		1,094,460
Miami-Dade County FL Special Obligation Revenue Bonds (Capital Asset Acquisition) Series A (AGM) (AA+/Aa3)
1,805,000		4.000		04/01/18		1,893,824
1,260,000		4.000		04/01/19		1,292,634
Osceola County FL School Board Certificates of Participation Series A (FGIC) (A/Aa3)
465,000		5.000		06/01/15		495,318
Port St. Lucie FL Lease Revenue Bonds (Taxable-Wyndcrest Project) Series A (A/Aa3)
200,000		6.090		09/01/20		208,648

						14,840,852

Georgia – 0.4%
Brunswick GA Water & Sewer Revenue Bonds (Refunding & Improvement) Series 1992 (NATL-RE) (BBB/Baa1)
90,000		6.100		10/01/19		109,422
Cherokee County GA Water & Sewer Authority Revenue Bonds (Refunding & Improvement) Series 1993 (NATL-RE) (BBB/Aa2)
55,000		5.500		08/01/23		64,124
Gainesville & Hall County Hospital Authority Revenue Bonds (Northeast Georgia Healthcare System) Series B (A+/NR)
500,000		4.000		02/15/20		489,460

						663,006


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Illinois – 14.3%
Chicago IL GO Bonds (Project & Refunding) Series A (AGM) (AA+/Aa3)
$1,500,000		5.000	%	01/01/28	$	1,471,650
Chicago IL Metropolitan Water Reclamation District Greater Chicago GO Bonds (Refunding) Series C (AAA/Aaa)
500,000		5.250		12/01/26		570,665
Chicago IL Public Building Commission Revenue Bonds (Refunding-Chicago School Reform) Series B (FGIC) (BBB/Aa2)
1,000,000		5.250		12/01/18		1,068,160
De Kalb County IL Community Unit School District No. 428 GO Bonds (Capital Appreciation-School Building) (AA-/Aa2)^(a)
1,500,000		0.000		01/01/20		985,485
Dekalb Kane & Lasalle Counties Community College District No. 523 GO Bonds Series A (AA/NR)
455,000		4.625		02/01/21		463,013
400,000		5.000		02/01/23		408,324
Illinois Educational Facilities Authority Revenue Bonds (Columbia College Chicago) (NATL-RE) (BBB+/Baa1)
1,000,000		5.000		12/01/20		999,940
Illinois Finance Authority Revenue Bonds (Columbia College) (NATL-RE) (BBB+/Baa1)
2,000,000		5.250		12/01/22		2,002,120
Illinois Finance Authority Revenue Bonds (Poetry Foundation Project) (A+/A1)
470,000		4.850		01/01/26		472,280
490,000		4.900		01/01/27		489,971
1,625,000		5.000		01/01/30		1,590,160
Illinois Finance Authority Revenue Bonds (Refunding-Swedish Covenant) Series A (BBB+/NR)
1,210,000		5.500		08/15/24		1,176,592
Illinois Finance Authority Revenue Bonds (Roosevelt University) (NR/Baa2)
100,000		5.250		04/01/22		96,141
Illinois Finance Authority Revenue Bonds (Roosevelt University) Series 2007 (NR/Baa2)
650,000		5.125		04/01/19		648,089
Illinois Housing Development Authority Revenue Bonds Homeowner Mortgage Series C-1 (AA/Aa3)
235,000		3.700		02/01/13		239,810
Illinois State GO Bonds (A+/A1)
1,000,000		4.000		04/01/19		953,700
Illinois State GO Bonds (First Series) (NATL-RE) (A+/A1)
2,000,000		5.500		08/01/17		2,200,060
Illinois State GO Bonds (Refunding) Series B (A+/A1)
1,100,000		5.000		01/01/14		1,165,890
Illinois State GO Bonds Series A (A+/A1)
2,000,000		5.000		03/01/17		2,073,920
Macon & De Witt Counties IL Community Unit School District No. 001 GO Bonds (NATL-RE) (FGIC) (NR/NR)
435,000		6.150		12/01/12		461,378


The accompanying notes are an integral part of these financial statements.		23

COMMERCE NATIONAL TAX-FREE INTERMEDIATE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Illinois – (continued)
Northern IL Municipal Power Agency Project Revenue Bonds (Prairie State Project) Series A (NATL-RE) (NR/A2)
$1,750,000		5.000	%	01/01/42	$	1,495,533
Peoria County IL Community Unit School District No. 309 GO Bonds (Capital Appreciation-Brimfield School District) Series A (AGM) (AA+/NR)^(a)
540,000		0.000		04/01/18		417,193
Regional Transportation Authority IL Revenue Bonds Series A (NATL-RE) (AA/Aa3)
2,345,000		6.000		07/01/29		2,461,804
University of Illinois Board of Trustees Certificates of Participation Series A (AA-/Aa2)
1,000,000		5.000		10/01/20		1,029,210

						24,941,088

Indiana – 6.1%
Allen County IN War Memorial Revenue Bonds (Refunding-Coliseum Additions Building Corp.) Series A (NR/Aa3)
600,000		5.000		05/01/16		677,190
615,000		5.000		11/01/16		697,152
Evansville IN Redevelopment Authority Revenue Bonds (Build America Bonds-Taxable) Series B (A/Aa3)
250,000		4.930		02/01/17		254,990
675,000		6.050		02/01/23		688,318
3,000,000		6.860		02/01/29		3,096,870
Indiana Bond Bank Revenue Bonds (Special Project-Hendricks Regional Health) Series A (AA/NR)
390,000		5.000		02/01/13		412,191
120,000		5.000		08/01/14		130,768
Indiana Health & Educational Facilities Financing Authority Revenue Bonds (Refunding-University of Indianapolis Educational Facilities) (A-/NR)
1,090,000		5.000		10/01/15		1,184,056
Indiana State Finance Authority Lease Revenue Bonds (Refunding) Series A-1 (AA+/Aa2)
500,000		5.000		11/01/13		539,195
Indiana State University Revenue Bonds (Build America Bonds) (NR/A1)
530,000		5.310		04/01/25		531,092
Indianapolis IN Multi-School Building Corp. Revenue Bonds (Refunding-First Mortgage) (AA/Baa1)
920,000		3.000		01/15/26		743,387
Mun-Del Building Corp. Delaware County IN Revenue Bonds (Refunding-First Mortgage) (A/NR)
830,000		3.000		07/05/13		840,624
750,000		3.000		01/05/14		762,330

						10,558,163

Iowa – 0.1%
Iowa Finance Authority Revenue Bonds (Single Family Mortgage) Series A (GNMA/FNMA) (AAA/Aaa)
125,000		4.300		07/01/16		126,330


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Kansas – 0.0%
Neosho County KS Sales Tax Revenue Bonds (NATL-RE) (ETM) (BBB/NR)
$ 55,000		5.500	%	08/15/11	$	55,642

Kentucky – 1.7%
Ashland KY Medical Center Revenue Bonds (Ashland Hospital Corp.) Series B (A+/A1)
1,000,000		5.000		02/01/23		1,014,780
Kentucky Economic Development Finance Authority Medical Center Revenue Bonds (Ashland Hospital Corp. Kings) Series C (A+/A1)
1,900,000		6.000		02/01/33		1,951,642

						2,966,422

Louisiana – 4.3%
East Baton Rouge LA Mortgage Finance Authority Revenue Bonds (Mortgage Backed Securities Program) Series A-2 (GNMA/FNMA/FHLMC) (NR/Aaa)
315,000		4.750		10/01/29		314,112
Louisiana Local Government Environmental Facilities Community Development Authority Revenue Bonds (Woman’s Hospital Foundation) Series A (BBB+/A3)
5,000,000		5.500		10/01/25		4,892,750
Tangipahoa Parish LA Hospital Service District No. 1 Revenue Bonds (Refunding-North Oaks Medical Center Project) Series A (BBB+/NR)
1,100,000		5.375		02/01/18		1,124,376
1,245,000		5.000		02/01/30		1,094,442

						7,425,680

Massachusetts – 4.5%
Massachusetts Educational Financing Authority Education Loan Revenue Bonds (Issue I) Series A (AA/NR)
1,945,000		5.100		01/01/25		1,972,055
Massachusetts State Health & Educational Facilities Authority Revenue Bonds (UMass Memorial Health Care, Inc.) Series G (BBB+/Baa1)
960,000		5.000		07/01/20		961,334
1,415,000		5.000		07/01/21		1,396,082
Massachusetts State Housing Finance Agency Multi Family Housing Revenue Bonds Series A (FHA) (NR/Aaa)
2,500,000		5.300		12/01/38		2,471,300
Massachusetts State Housing Finance Agency Revenue Bonds (Single Family) Series 152 (AA/Aa2)
1,000,000		4.150		12/01/28		909,650
Massachusetts State Water Resources Authority Revenue Bonds Series A (ETM) (AA+/Aa1)
60,000		6.500		07/15/19		72,429

						7,782,850

Michigan – 3.5%
Grand Valley MI State University Revenue Bonds (FGIC) (A+/NR)
1,500,000		5.300		12/01/24		1,578,165


24		The accompanying notes are an integral part of these financial statements.

COMMERCE NATIONAL TAX-FREE INTERMEDIATE BOND FUND


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Michigan – (continued)
Grand Valley MI State University Revenue Bonds Series 1998 (FGIC) (A+/NR)
$1,080,000		5.500	%	02/01/18	$	1,172,880
Ingham County MI GO Bonds Series 1998 (AGM) (AA+/Aa3)
265,000		5.125		11/01/12		265,779
Lake Superior University of Michigan Revenue Bonds (Unrefunded) Series 1997 (NATL-RE) (BBB/Baa1)
355,000		5.000		11/15/12		355,937
Michigan State Housing Development Authority Rental Housing Revenue Bonds Series B (Go of Authority) (AA/NR)
690,000		4.500		10/01/19		702,013
Michigan State Housing Development Authority Single Family Home Ownership Revenue Bonds (Non AMT) Series A (Go of Auth) (AA/NR)
2,000,000		4.750		12/01/25		1,957,520

						6,032,294

Minnesota – 1.5%
Minnesota State Housing Finance Agency Revenue Bonds (Residential) Series A (AA+/Aa1)
605,000		3.800		07/01/17		619,339
Ortonville MN Independent School District No. 062 GO Bonds (Refunding-School Buildings) Series A (AAA/NR)
800,000		5.000		04/01/15		899,080
St. Paul MN Housing & Redevelopment Authority Health Care Revenue Bonds (Allina Health System) Series A-2 (A+/A1)
1,000,000		5.000		11/15/19		1,075,400

						2,593,819

Missouri – 0.7%
Kansas City MO Special Obligation Revenue Bonds (Capital Appreciation) Series E (AA-/A1)^(a)
110,000		0.000		02/01/14		101,926
125,000		0.000		02/01/15		111,615
305,000		0.000		02/01/17		246,964
Raytown MO Sewer Revenue Bonds (NR/NR)
275,000		4.625		07/01/24		276,697
St. Louis County MO Industrial Development Authority Health Facilities Revenue Bonds (Refunding-Ranken Jordan Project) (NR/NR)
500,000		5.000		11/15/17		484,035

						1,221,237

Montana – 0.3%
Montana State Board Housing Revenue Bonds (Single Family Mortgage) Series A-2 (AMT) (AA+/Aa1)
220,000		4.350		06/01/16		221,188
230,000		4.350		12/01/16		231,242

						452,430

Nebraska – 1.1%
Douglas County NE Hospital Authority No. 002 Revenue Bonds (Refunding) (Health Facilities-Children’s Hospital) (NR/A2)
500,000		6.000		08/15/22		538,050


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Nebraska – (continued)
Nebraska Investment Finance Authority Revenue Bonds Series F (GNMA/FNMA/FHLMC) (AAA/NR)
$ 110,000		4.300	%	09/01/14	$	112,944
145,000		4.350		03/01/15		146,879
95,000		4.350		09/01/15		96,417
20,000		4.400		09/01/16		20,282
Nebraska Investment Finance Authority Single Family Housing Revenue Bonds Series A (GNMA/FNMA/FHLMC) (AAA/NR)
1,000,000		6.100		09/01/45		1,045,450

						1,960,022

Nevada – 0.6%
Las Vegas NV Convention & Visitors Authority Revenue Bonds (AMBAC) (A+/A1)
1,020,000		5.000		07/01/28		1,010,657
Nye County NV School District GO Bonds (Refunding) Series A (PSF-GTD) (NR/Aaa)
100,000		4.375		05/01/25		98,712

						1,109,369

New Hampshire – 1.2%
New Hampshire State Housing Finance Authority Revenue Bonds (Non AMT) Series A (NR/Aa3)
1,375,000		3.800		07/01/25		1,290,713
New Hampshire State Housing Finance Authority Single Family Mortgage Revenue Bonds (Non AMT) (NR/Aa2)
690,000		5.300		07/01/28		710,603

						2,001,316

New Jersey – 1.2%
New Jersey State Higher Education Assistance Authority Student Loan Revenue Bonds (Refunding) Series 1A (AA/Aa2)
2,000,000		4.750		12/01/23		1,951,840
Passaic County NJ GO Bonds (Refunding-Taxable Pension) Series 2003 (AGM) (NR/Aa3)
100,000		5.750		02/15/21		101,554

						2,053,394

New Mexico – 0.3%
Albuquerque NM Apartment Revenue Bonds (Refunding) (AMT) (AMBAC) (A+/Aa3)
500,000		5.375		07/01/13		503,030

New York – 0.3%
Metropolitan Transportation Authority NY Revenue Bonds Series 2008C (A/A2)
150,000		5.500		11/15/18		166,425
New York State Dormitory Authority Revenue Bonds (Consolidated City University System) Series A (AA-/Aa3)
260,000		5.750		07/01/13		272,025

						438,450

North Dakota – 0.9%
North Dakota State Housing Finance Agency Revenue Bonds (Home Mortgage Finance Program) Series A (NR/Aa1)
285,000		4.100		07/01/19		288,355


The accompanying notes are an integral part of these financial statements.		25

COMMERCE NATIONAL TAX-FREE INTERMEDIATE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
North Dakota – (continued)
North Dakota State Housing Finance Agency Revenue Bonds (Housing Finance Project) Series B (AMT) (NR/Aa1)
$ 550,000		4.400	%	07/01/16	$	569,646
635,000		4.450		07/01/17		647,814

						1,505,815

Ohio – 2.1%
Akron OH Certificates of Participation (Parking Facilities Project) Series A (AMBAC) (A+/NR)
1,250,000		5.000		12/01/16		1,356,662
Ohio State Higher Educational Facility Commission Revenue Bonds (Cleveland Hospital) Clinic Health Series A (AA-/Aa2)
750,000		5.250		01/01/33		748,020
Ohio State Higher Educational Facility Commission Revenue Bonds (Xavier University) Series C (A-/A3)
430,000		4.250		05/01/14		454,876
1,000,000		5.000		05/01/18		1,103,400

						3,662,958

Oklahoma – 3.2%
McClain County OK Economic Development Authority Educational Facilities Lease Revenue Bonds (Blanchard Public Schools Project) (A-/NR)
1,000,000		4.000		09/01/13		1,035,710
1,000,000		4.850		09/01/18		1,061,280
1,000,000		5.000		09/01/19		1,067,970
Oklahoma County OK Finance Authority Educational Facilities Lease Revenue Bonds (Jones Public School Project) (A-/NR)
2,000,000		5.000		09/01/18		2,161,400
Tulsa OK Industrial Authority Student Housing Revenue Bonds (University of Tulsa) Series 2006 (NR/A2)
150,000		5.250		10/01/26		154,326

						5,480,686

Oregon – 0.2%
Oregon State Housing & Community Services Department Revenue Bonds (Single Family Mortgage) Series E (AMT) (NR/Aa2)
370,000		5.050		07/01/17		377,826

Pennsylvania – 5.1%
Delaware County PA Authority University Revenue Bonds (Neumann University) (BBB/NR)
785,000		3.000		10/01/14		774,465
1,025,000		5.000		10/01/19		1,029,141
1,250,000		5.250		10/01/31		1,134,975
Pennsylvania Housing Finance Agency Single Family Mortgage Revenue Bonds (Non AMT) Series 103C (AA+/Aa2)
1,050,000		5.000		10/01/23		1,085,396
Pennsylvania Housing Finance Agency Single Family Mortgage Revenue Bonds Series 110B (AA+/Aa2)
2,000,000		4.125		10/01/25		1,913,260
Pennsylvania State Higher Education Facilities Authority Revenue Bonds (University of Scranton) Series 2008 (A/NR)
1,140,000		4.500		05/01/14		1,212,447


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Pennsylvania – (continued)
Philadelphia PA Authority for Industrial Development Revenue Bonds (Mathematics Science & Technology Charter School) (BBB+/NR)
$ 460,000		5.000	%	08/01/20	$	449,323
St. Mary’s PA Area Water Authority Revenue Bonds (BBB+/NR)
1,350,000		4.750		02/01/25		1,335,150

						8,934,157

Puerto Rico – 0.0%
Puerto Rico Electric Power Authority Revenue Bonds (Refunding) (NATL-RE) (BBB+/A3)
10,000		5.000		07/01/20		10,409

Rhode Island – 0.9%
Rhode Island Housing & Mortgage Finance Corp. Revenue Bonds (Multi Family Development) Series 1 (NR/Aa2)
460,000		5.125		10/01/30		452,479
Rhode Island Housing & Mortgage Finance Corp. Revenue Bonds (Multi Family Funding) Series A (NR/Aaa)
500,000		5.250		04/01/35		493,940
Rhode Island State Student Loan Authority Revenue Bonds Series 3 (AMBAC) (AMT) (NR/A3)
180,000		5.700		12/01/12		180,173
205,000		5.800		12/01/14		205,119
125,000		5.900		12/01/15		125,077
Rhode Island State Student Loan Authority Revenue Bonds Series 3 (AMBAC) (AMT) (NR/NR)
190,000		5.750		12/01/13		190,148

						1,646,936

South Carolina – 3.9%
Berkeley County SC School District Installment Lease Revenue Bonds (Securing Assets for Education) (A/A1)
2,500,000		5.250		12/01/24		2,554,775
Fort Mill SC School Facilities Corp. Revenue Bonds (Installment Purchase Revenue) Series 2006 (NR/Aa3)
550,000		5.250		12/01/22		575,635
Greenville County SC Public Facilities Corp. Certificates of Participation (Refunding-University Center Project) (AMBAC) (AA+/Aa1)
700,000		5.000		04/01/16		781,074
Kershaw County SC Public School Foundation Installment Power Revenue Bonds (School District Project) (CIFG) (BBB+/NR)
1,000,000		5.000		12/01/22		995,620
1,500,000		5.000		12/01/28		1,440,600
Scago Educational Facilities Corp. for Beaufort School District SC Installment Revenue Bonds (AGM) (AA+/Aa2)
175,000		5.500		12/01/15		200,659
Scago Educational Facilities Corp. for Sumter County School District 17 SC Revenue Bonds (AGM) (AA+/Aa3)
255,000		5.500		12/01/15		290,238

						6,838,601


26		The accompanying notes are an integral part of these financial statements.

COMMERCE NATIONAL TAX-FREE INTERMEDIATE BOND FUND


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
South Dakota – 0.1%
South Dakota Housing Development Authority Revenue Bonds (Homeowner Mortgage) Series E-1 (AMT) (NR/NR)
$ 185,000		5.150	%	05/01/11	$	185,000

Tennessee – 0.1%
Tennessee Housing Development Agency Revenue Bonds (Homeownership Program) (AMT) (AA+/Aa1)
220,000		4.250		01/01/14		224,818

Texas – 4.5%
Canyon TX Regional Water Authority Contract Revenue Bonds (Refunding-Mid Cities Project) (AMBAC) (A/NR)
500,000		5.000		08/01/22		522,680
Cash Special Utility District TX Revenue Bonds (Refunding & Improvement) (NATL-RE) (A/Baa1)
500,000		5.250		09/01/22		525,130
Corpus Christi TX Utility System Revenue Bonds (Refunding) (AGM) (AA+/Aa3)
375,000		5.000		07/15/12		393,862
Dallas Fort Worth TX International Airport Revenue Bonds (Refunding & Improvement) Series A (FGIC) (A+/A1)
130,000		5.750		11/01/15		132,774
Houston County TX GO Bonds (Certificates of Obligation) (A/NR)
235,000		5.000		02/15/20		255,067
590,000		5.000		02/15/24		620,049
Lower Colorado River Authority TX Revenue Bonds (Refunding) (A/A1)
800,000		5.625		05/15/39		823,664
North Texas Tollway Authority Revenue Bonds (Refunding-System First Tier) (A-/A2)
3,000,000		6.000		01/01/34		3,068,100
San Jacinto TX River Authority Special Project Revenue Bonds (The Woodlands Water Supply Systems) Series 2007 (AMBAC) (A+/NR)
330,000		5.250		10/01/21		343,665
Texas State Department of Housing & Community Affairs Single Family Mortgage Revenue Bonds (Refunding) Series G (AMT) (FHA/VA Mortgages) (AAA/Aa1)
85,000		4.600		09/01/19		85,434
Texas Woman’s University Financing Systems Revenue Bonds Series 2008 (A/Aa3)
675,000		5.500		07/01/24		743,627
Weslaco TX Independent School District GO Bonds (Maintenance Tax Notes) Series A (NR/A1)
300,000		4.500		02/15/16		326,586

						7,840,638

Utah – 1.6%
Tooele County UT Hazardous Waste Treatment Revenue Bonds (Union Pacific Project) Series A (BBB+/Baa2)
2,000,000		5.700		11/01/26		2,001,480


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Utah – (continued)
Utah Housing Corporation Single Family Mortgage Revenue Bonds (Refunding) Series A (AAA/Aaa)
$ 380,000		3.600	%	07/01/15	$	380,536
350,000		3.850		07/01/16		351,088

						2,733,104

Vermont – 0.8%
Vermont Economic Development Authority Revenue Bonds (Central Vermont Public Service Corp.-Recovery Zone Facility) (NR/Baa1)
1,375,000		5.000		12/15/20		1,351,268

Virginia – 0.6%
Richmond VA Metropolitan Authority Expressway Revenue Bonds (Refunding) (FGIC) (BBB/NR)
1,000,000		5.250		07/15/17		1,104,150

Washington – 4.4%
Everett WA Public Facilities District Sales Tax & Interlocal Revenue Bonds Series A (A-/NR)
1,000,000		5.000		12/01/24		1,005,520
FYI Properties WA Lease Revenue Bonds (Washington State District Project) (AA/NR)
1,000,000		5.000		06/01/27		1,021,280
Puyallup WA Combined Utility Revenue Bonds Series A (AA/NR)
160,000		4.000		11/01/15		172,395
Vancouver WA GO Bonds (Refunding-Limited Tax) (AA/Aa3)
1,160,000		5.125		12/01/35		1,225,099
Washington State Health Care Facilities Authority Revenue Bonds (Catholic Health Initiatives) Series D (AA/Aa2)
500,000		6.000		10/01/23		547,440
Washington State Health Care Facilities Authority Revenue Bonds (Overlake Hospital Medical Center) (A-/A3)
2,000,000		4.375		07/01/18		2,017,660
1,750,000		5.250		07/01/25		1,702,190

						7,691,584

West Virginia – 0.6%
West Virginia State Hospital Finance Authority Revenue Bonds (Refunding & Improvement-Charleston) Series A (NR/A3)
1,000,000		5.500		09/01/28		971,650

Wisconsin – 1.8%
Central Brown County WI Water Authority System Revenue Bonds (AMBAC) (A+/NR)
1,500,000		5.000		12/01/35		1,426,650
Milwaukee County WI Airport Revenue Bonds (Refunding) Series B (NATL-RE) (NR/A1)
115,000		5.000		12/01/14		123,628
350,000		5.000		12/01/15		378,466
Plymouth WI Combined Utility Revenue Bonds (XLCA) (NR/A2)
100,000		4.375		05/01/12		103,181


The accompanying notes are an integral part of these financial statements.		27

COMMERCE NATIONAL TAX-FREE INTERMEDIATE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date		Value
Municipal Bond Obligations – (continued)
Wisconsin – (continued)
Wisconsin State Health & Educational Facilities Authority Revenue Bonds (Children’s Hospital of Wisconsin) (AA-/Aa3)
$1,000,000		5.000	%		08/15/21	$	1,060,620

							3,092,545

Wyoming – 0.5%
Wyoming Community Development Authority Housing Revenue Bonds Series 8 (AMT) (AA+/Aa1)
165,000		4.250			06/01/14		169,642
280,000		4.250			12/01/14		289,086
385,000		4.300			12/01/15		390,097

							848,825

TOTAL MUNICIPAL BOND OBLIGATIONS
(Cost $170,224,744)						$	171,655,793


Short-term Investment^(b) – 1.1%
Repurchase Agreement – 1.1%
State Street Bank & Trust Co.
$1,939,000		0.010	%		05/02/11	$	1,939,000
Maturity Value: $1,939,002
(Cost $1,939,000)

TOTAL INVESTMENTS – 99.9%
(Cost $172,163,744)						$	173,594,793

OTHER ASSETS IN EXCESS OF LIABILITIES – 0.1%							249,182

NET ASSETS – 100.0%						$	173,843,975


The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets.
^(a)		Issued with a zero coupon. Income is recognized through the accretion of discount.
^(b)		Repurchase agreement was entered into on April 29, 2011. This agreement was fully collateralized by $1,955,000 U.S. Treasury Note, 1.000%, due 04/30/12 with a market value of $1,979,078.
Security ratings disclosed, if any, are issued by Standard & Poor’s Ratings Services/Moody’s Investors Service and are unaudited. A description of the ratings is available in the Fund’s Statement of Additional Information.



Investment Abbreviations:
AGM		—Insured by Assured Guaranty Municipal Corp.
AMBAC		—Insured by American Municipal Bond Assurance Corp.
AMT		—Alternative Minimum Tax
CIFG		—Insured by CIFG Assurance North America, Inc.
ETM		—Escrow to Maturity
FGIC		—Insured by Financial Guaranty Insurance Co.
FHA		—Insured by Federal Housing Administration
FHLMC		—Federal Home Loan Mortgage Corp.
FNMA		—Federal National Mortgage Association
GNMA		—Government National Mortgage Association
GO		—General Obligation
NATL-RE		—Insured by National Reinsurance Corp.
NR		—Not Rated
PSF-GTD		—Guaranteed by Permanent School Fund
VA		—Veterans Administration
XLCA		—Insured by XL Capital Assurance, Inc.

PORTFOLIO COMPOSITION


Sector Allocation	AS OF 4/30/11			AS OF 10/31/10

Education		15.5	%		14.4	%
Lease		15.0			19.1
Hospital		14.9			17.2
General Obligations		14.7			12.4
Single Family Housing		9.5			10.6
Transportation		8.8			6.8
General		8.7			9.0
Water/Sewer		2.9			4.6
Student		2.7			3.2
Power		2.2			1.9
Multi Family Housing		2.0			0.0
Industrial Development Revenue		1.1			0.0
Crossover		0.6			0.0
Prerefunded/Escrow to Maturity		0.2			0.1
Short-term Investment		1.1			0.5

TOTAL INVESTMENTS		99.9	%		99.8	%

The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets.

The Fund is actively managed and, as such its composition may differ over time.


28		The accompanying notes are an integral part of these financial statements.

COMMERCE MISSOURI TAX-FREE INTERMEDIATE BOND FUND

Schedule of Investments

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – 97.4%
Arizona – 2.5%
Arizona Healthcare & Education Facilities Authority Revenue Bonds (Kirksville College) (A-/NR)
$1,000,000		5.000	%	01/01/25	$	999,930
Arizona School Facilities Board Certificates of Participation (A+/A1)
3,000,000		5.250		09/01/23		3,104,820
Pinal City Arizona Unified School District No. 1 Florence School Improvement Project of 2006 GO Bonds Series C (A/NR)
1,155,000		5.125		07/01/23		1,215,291
1,215,000		5.150		07/01/24		1,270,368

						6,590,409

California – 1.0%
Burbank CA Unified School District GO Bonds Capital Appreciation Election of 1997 Series C (NATL-RE) (FGIC) (AA-/WR)^(a)
2,000,000		0.000		07/01/27		692,060
Sacramento County CA Airport System Revenue Bonds (A/A2)
2,000,000		5.000		07/01/27		2,017,420

						2,709,480

Colorado – 0.3%
Colorado Housing & Finance Authority Revenue Bonds (Single Family Mortgage) Series A (FHA) (AAA/Aaa)
650,000		4.350		11/01/19		661,421

Florida – 1.2%
Gulf Breeze FL Revenue Bonds (Local Government Loan) Series J (A+/Aa3)
1,000,000		4.500		12/01/20		1,067,310
Tampa FL Revenue Bonds (Health System-Catholic East) (A/A1)
1,875,000		5.000		11/15/16		2,033,925

						3,101,235

Georgia – 0.4%
Georgia Housing & Finance Authority Revenue Bonds (Single Family Mortgage) (Non AMT) Series A (AAA/NR)
1,000,000		4.500		12/01/25		1,006,160

Idaho – 0.4%
Idaho Housing & Finance Association Revenue Bonds (Single Family Mortgage) Series B Class I (NR/Aaa)
895,000		5.250		07/01/29		909,776

Illinois – 1.7%
Grundy Kendall & Will Counties IL Community School District No. 201 GO Bonds (Refunding) Series A (AA/NR)
1,500,000		5.250		10/15/27		1,564,365
Illinois Finance Authority Revenue Bonds (Poetry Foundation Project) (A+/A1)
1,000,000		5.300		01/01/40		935,750
Illinois Finance Authority Revenue Bonds (Refunding-Resurrection Health) (BBB+/Baa1)
1,000,000		5.250		05/15/15		1,038,920


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Illinois – (continued)
Illinois Finance Authority Revenue Bonds (Refunding-Swedish Covenant) Series A (BBB+/NR)
$1,000,000		5.500	%	08/15/24	$	972,390

						4,511,425

Indiana – 1.5%
Evansville IN Redevelopment Authority Revenue Bonds (Build America Bonds-Taxable) Series B (A/Aa3)
2,000,000		6.860		02/01/29		2,064,580
Indiana Bond Bank Revenue Bonds (Special Program-Hendricks Regional Health) Series A (AA/NR)
500,000		5.500		02/01/29		523,685
Indiana State Finance Authority Revenue Bonds (Educational Facilities for Indiana Historical Society, Inc.) (NR/A3)
1,435,000		5.000		07/01/35		1,276,145

						3,864,410

Iowa – 0.8%
Iowa Finance Authority Revenue Bonds (Single Family Mortgage) Series E (GNMA/FNMA) (Go of Authority) (AAA/Aaa)
710,000		5.000		07/01/23		721,388
Waterloo Community School District Infrastructure Sales & Services Tax Revenue Bonds (Refunding) Series 2011 A (A/NR)
1,245,000		5.250		01/01/30		1,266,788

						1,988,176

Kentucky – 0.2%
Kentucky Housing Corp. Revenue Bonds Series A (FHA) (AAA/Aaa)
445,000		5.750		07/01/39		454,096

Louisiana – 3.3%
Louisiana Local Government Environmental Facilities & Community Development Authority Revenue Bonds (Refunding-Independence Stadium Project) (A/NR)
1,525,000		5.000		03/01/21		1,597,575
Louisiana Local Government Environmental Facilities & Community Development Authority Revenue Bonds (Woman’s Hospital Foundation) Series A (BBB+/A3)
7,000,000		5.500		10/01/25		6,849,850

						8,447,425

Michigan – 0.4%
River Rouge MI School District GO Bonds (Refunding) (NATL-RE) (FGIC) (AA-/Aa2)
1,000,000		5.000		05/01/19		1,031,330

Missouri – 79.4%
Arnold MO Certificates of Participation (A+/NR)
200,000		3.000		11/01/17		198,716
230,000		3.000		11/01/18		222,111
210,000		3.000		11/01/19		199,939
225,000		3.625		11/01/22		217,487


The accompanying notes are an integral part of these financial statements.		29

COMMERCE MISSOURI TAX-FREE INTERMEDIATE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Missouri – (continued)
Arnold MO Certificates of Participation (A+/NR) (continued)
$ 470,000		3.700	%	11/01/23	$	449,546
225,000		3.800		11/01/24		214,461
480,000		3.875		11/01/25		446,429
250,000		4.000		11/01/26		232,743
Belton MO Certificates of Participation (A/NR)
500,000		5.125		03/01/25		507,875
500,000		5.250		03/01/29		501,670
Belton MO School District No. 124 Direct Deposit Program GO Bonds (Refunding) Series A (AA+/Aa1)
150,000		4.000		03/01/17		157,817
Belton MO School District No. 124 Direct Deposit Program GO Bonds (Refunding) Series B (AA+/Aa1)
150,000		4.000		03/01/21		157,770
Bi-State Development Agency MO Metro District Revenue Bonds (Refunding-St. Clair County Metrolink Project) (AGM) (AA+/Aa3)
2,000,000		5.250		07/01/20		2,212,640
Boone County MO Hospital Revenue Bonds (NR/A3)
2,350,000		5.750		08/01/28		2,380,268
Branson MO Reorganized School District No. R-4 GO Bonds (AGM) (AA+/Aa3)
1,000,000		5.000		03/01/18		1,076,980
1,250,000		5.000		03/01/19		1,338,250
Branson MO Reorganized School District No. R-4 GO Bonds School District Direct Deposit Program (AMBAC) (A+/NR)
300,000		5.500		03/01/14		333,417
Bridgeton MO Certificates of Participation (NR/Aa3)
250,000		1.700		08/01/11		250,480
Camdenton MO Reorganized School District No. RIII GO Bonds (Refunding & Improvement) (AGM) (AA+/Aa3)
500,000		5.250		03/01/17		578,490
1,000,000		5.250		03/01/21		1,077,690
Campbell MO Reorganized School District No. 2 Direct Deposit Program GO Bonds (Refunding) (AA+/NR)
215,000		1.600		03/01/13		216,215
215,000		1.900		03/01/14		216,071
220,000		2.250		03/01/15		220,895
Cape Girardeau County MO Industrial Development Authority Health Care Facilities Revenue Bonds (St. Francis Medical Center) Series A (A+/NR)
930,000		5.250		06/01/11		932,939
400,000		5.250		06/01/12		415,364
1,000,000		5.250		06/01/13		1,061,310
1,550,000		5.500		06/01/16		1,620,029
Cass County MO Reorganized School District No. R-2 Raymore-Peculiar Direct Deposit Program GO Bonds (AA+/NR)
1,000,000		5.000		03/01/18		1,118,730
Clay County MO Public School District No. 53 Liberty Direct Deposit Program GO Bonds (Refunding) Series A (AGM) (AA+/Aa3)
1,000,000		5.000		03/01/18		1,032,850


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Missouri – (continued)
Clay County MO Public School District No. 53 Liberty Direct Deposit Program GO Bonds Series B (AGM) (AA+/Aa3)
$1,000,000		5.000	%	03/01/18	$	1,033,020
Clay County MO Public School District No. 53 Liberty School Building Direct Deposit Program GO Bonds (AA+/NR)
1,280,000		5.000		03/01/25		1,370,714
2,435,000		5.000		03/01/28		2,553,828
Clay County MO Reorganized School District No. R-1 Kearney School Building Direct Deposit Program GO Bonds Series B (AA+/Aa1)
695,000		5.000		03/01/21		748,237
650,000		5.000		03/01/22		696,618
Clayton MO Special Obligation Revenue Bonds (Build America Bonds) Series B (AA+/NR)
810,000		5.200		12/01/23		845,842
Clinton MO Certificates of Participation (Refunding & Improvement) (NR/NR)
400,000		5.000		12/01/12		418,892
Cole County MO Certificates of Participation (Jail Project) (NR/Aa3)
660,000		4.300		12/01/19		675,675
1,000,000		4.500		12/01/20		1,027,420
Des Peres MO Certificates of Participation (Refunding) (AA+/NR)
390,000		3.000		08/01/14		402,921
Fenton MO Certificates of Participation (Refunding) (AA-/NR)
565,000		2.000		01/01/13		572,023
Florissant MO Certificates of Participation (FGIC) (NR/A1)
330,000		5.000		08/01/11		333,498
560,000		5.000		08/01/12		589,926
485,000		5.000		08/01/15		500,079
500,000		5.000		08/01/16		513,930
450,000		5.000		08/01/17		460,926
Fort Zumwalt MO School District Direct Deposit Program GO Bonds Series A (AA+/Aa1)
1,080,000		5.000		03/01/19		1,201,446
Fort Zumwalt MO School District GO Bonds Direct Deposit Program (Refunding) Series A (AA+/Aa1)
700,000		5.000		03/01/17		778,582
935,000		5.000		03/01/18		1,034,129
945,000		5.000		03/01/19		1,032,441
Franklin County MO Public Water Supply District No. 3 Certificates of Participation (NR/NR)
610,000		5.875		12/01/30		572,564
1,455,000		6.250		12/01/35		1,342,107
Franklin County MO Public Water Supply District No. 3 Certificates of Participation (Refunding) Series C (FGIC) (NR/NR)
395,000		5.000		12/01/15		409,342
Gladstone MO Certificates of Participation Series A (XLCA) (NR/A1)
475,000		5.000		06/01/23		493,729


30		The accompanying notes are an integral part of these financial statements.

COMMERCE MISSOURI TAX-FREE INTERMEDIATE BOND FUND


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Missouri – (continued)
Greene County MO Certificates of Participation (Refunding-Law Enforcement) (NR/Aa2)
$ 100,000		2.000	%	07/01/11	$	100,171
425,000		2.500		07/01/15		430,542
Greene County MO Special Obligation Revenue Bonds (Refunding) (NR/Aa2)
450,000		2.000		03/01/13		456,151
280,000		2.500		03/01/15		283,368
Greenwood MO GO Build America Bonds Taxable Series B (A-/NR)
500,000		5.625		03/01/25		491,710
Hannibal MO Industrial Development Authority Health Facilities Revenue Bonds (Refunding-Hannibal Regional Hospital) (BBB+/NR)
650,000		3.500		09/01/12		655,694
Harrisonville MO Annual Appropriation Supported Tax Revenue Bonds (Refunding-Harrisonville Towne Center Project) (A+/NR)
1,610,000		4.625		11/01/28		1,487,415
Hickman Mills MO School District No. C-1 Direct Deposit Program GO Bonds (AGM) (AA+/Aa3)
2,300,000		5.000		03/01/19		2,381,834
Higginsville MO Sewage Systems Revenue Bonds (Build America Bonds-Taxable Direct Payment to Issuer) (A-/NR)
500,000		5.924		10/01/30		479,620
I-470 & 350 Transportation Development District MO Sales Tax Revenue Bonds (Refunding & Improvement) (Radian) (NR/NR)
420,000		4.600		06/01/29		389,840
Independence MO School District (Direct Deposit Program) Series A (AA+/NR)
2,000,000		5.250		03/01/30		2,160,820
1,700,000		5.250		03/01/31		1,826,786
Jackson County MO Consolidated School District Direct Deposit Program GO Bonds (AA+/NR)
2,365,000		5.000		03/01/25		2,537,030
Jackson County MO Consolidated School District No. 2 Direct Deposit Program GO Bonds (NATL-RE) (AA+/Baa1)
1,250,000		5.000		03/01/22		1,342,287
Jackson County MO Public Building Corp. Leasehold Revenue Bonds (Capital Improvements Project) Series B (NR/Aa3)
530,000		4.500		12/01/19		551,984
555,000		4.500		12/01/20		572,088
Jackson County MO Public Building Corp. Leasehold Revenue Bonds Series A (NATL-RE) (NR/Aa3)
500,000		5.000		12/01/20		527,820
Jackson County MO Reorganized School District No. 4 Blue Springs GO Bonds (Refunding & Improvement) Series A (AA/NR)
2,000,000		5.000		03/01/29		2,082,620
Jackson County MO School District No. C-1 Hickman School Building Direct Deposit Program GO Bonds (AA+/NR)
500,000		5.000		03/01/24		541,370


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Missouri – (continued)
Jackson County MO Special Obligation Revenue Bonds (Harry S. Truman Sports Complex) (AMBAC) (A+/Aa3)
$1,360,000		5.000	%	12/01/22	$	1,436,364
Jackson County MO Special Obligation Revenue Bonds Series A (NATL-RE) (NR/Aa3)
1,735,000		5.500		12/01/12		1,806,187
Jefferson County MO Consolidated Public Water Supply District No. C-1 Revenue Bonds (AMBAC) (NR/NR)
1,000,000		5.250		12/01/15		1,048,850
Jefferson County MO Consolidated Public Water Supply District No. C-1 Waterworks Revenue Bonds (Refunding) (AA-/NR)
290,000		4.000		12/01/20		301,208
435,000		4.000		12/01/21		448,698
425,000		4.000		12/01/22		436,118
Jefferson County MO Library District Lease Certificates of Participation (Refunding) Series A (A+/NR)
455,000		5.000		03/01/29		460,014
Jefferson County MO Library District Lease Certificates of Participation (Refunding) Series B (A+/NR)
1,270,000		5.000		03/01/29		1,270,787
Joplin MO Industrial Development Authority Health Facilities Revenue Bonds (Freeman Health System Project) (BBB+/NR)
820,000		5.500		02/15/12		831,013
555,000		5.500		02/15/14		572,827
2,570,000		5.500		02/15/29		2,393,261
1,500,000		5.750		02/15/35		1,384,980
Kansas City MO Land Clearance Revenue Bonds (Refunding & Improvement) Series E (XCLA) (AA-/A1)
1,000,000		5.000		12/01/15		1,112,460
Kansas City MO Metropolitan Community Leasehold Jr. College Revenue Bonds (Refunding & Improvement) (FGIC) (NR/Aa2)
1,075,000		5.000		07/01/17		1,181,855
Kansas City MO Special Obligation Revenue Bonds (Arena Project) (Refunding & Improvement) Series C (AA-/A1)
1,575,000		5.500		04/01/23		1,761,637
Kansas City MO Special Obligation Revenue Bonds (Arena Project) (Refunding & Improvement) Series D (AA-/A1)
280,000		6.431		04/01/18		286,972
Kansas City MO Special Obligation Revenue Bonds (Capital Appreciation) Series E (AA-/A1)^(a)
4,465,000		0.000		02/01/18		3,423,226
Kansas City MO Special Obligation Tax Allocation (East Village Project) Series A (AA-/A1)
500,000		5.000		04/15/31		492,540
Kansas City MO Special Obligation Tax Allocation (Refunding-Kansas City Project) Series B (AA-/A1)
500,000		3.000		01/01/15		514,335
Kirkwood MO Certificates of Participation (Build America Bonds-Taxable Direct Payment) (NR/Aa2)
500,000		6.050		09/01/30		502,220


The accompanying notes are an integral part of these financial statements.		31

COMMERCE MISSOURI TAX-FREE INTERMEDIATE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Missouri – (continued)
Kirkwood MO School District Educational Facilities Authority Leasehold Revenue Bonds for Kirkwood School District R-7 Project Series B (NATL-RE) (NR/Aa2)
$ 750,000		5.000	%	02/15/19	$	800,430
Ladue MO School District GO Bonds (Refunding & Improvement) (AAA/NR)
500,000		5.000		03/01/20		560,725
545,000		5.000		03/01/22		606,220
500,000		5.000		03/01/23		552,780
Lee’s Summit MO Water & Sewer Revenue Bonds (Refunding) (AMBAC) (NR/Aa2)
1,000,000		5.250		07/01/12		1,006,930
1,135,000		5.250		07/01/15		1,140,062
Lee’s Summit MO Water & Sewer Revenue Bonds Combination Series A (AMBAC) (NR/Aa2)
480,000		5.000		07/01/20		490,829
Mehlville MO School District No. R-9 Certificates of Participation (AGM) (AA+/Aa3)
1,620,000		4.750		03/01/16		1,721,056
850,000		4.750		03/01/17		896,818
Missouri Development Finance Board Cultural Facilities Revenue Bonds (Nelson Gallery Foundation) Series A (AA-/NR)
1,000,000		5.000		12/01/20		1,116,810
Missouri Development Finance Board Cultural Facilities Revenue Bonds (Nelson Gallery Foundation) Series A (NATL-RE) (AA-/Aa3)^(b)
1,410,000		5.250		12/01/11		1,450,481
Missouri School Board Association Lease Certificates of Participation for Liberty Public School District No. 53 (AGM) (AA+/Aa3)
830,000		5.250		03/01/21		916,021
700,000		5.250		03/01/22		769,041
Missouri State Board of Public Buildings Special Obligation Revenue Bonds Series A (AA+/Aa1)
1,000,000		5.000		10/15/20		1,053,370
Missouri State Development Finance Board Infrastructure Facilities Revenue Bonds (Independence Parks Facilities Project) Series D (A-/NR)
590,000		4.250		04/01/12		602,797
Missouri State Development Finance Board Infrastructure Facilities Revenue Bonds (Independence-Events Center) Series F (A-/NR)
1,000,000		6.125		04/01/29		1,011,180
Missouri State Development Finance Board Infrastructure Facilities Revenue Bonds (Water System) (Refunding) Series E (A-/NR)
700,000		4.000		11/01/13		735,434
Missouri State Development Finance Board Infrastructure Facilities Tax Allocation (Eastland Center Project) Series A (A-/NR)
150,000		4.500		04/01/22		150,612


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Missouri – (continued)
Missouri State Development Finance Board Infrastructure Facilities Tax Allocation (Hartman Heritage Center Phase II) (AMBAC) (A-/NR)
$ 300,000		5.000	%	04/01/13	$	309,849
1,070,000		5.000		04/01/19		1,087,655
1,240,000		5.000		04/01/21		1,258,786
Missouri State Development Finance Board Infrastructure Facilities Tax Allocation (Independence-Centerpoint Project) (A-/NR)
935,000		4.750		04/01/28		893,075
Missouri State Environmental Improvement & Energy Resources Authority Water Pollution Control Revenue Bonds (Prerefunded-State Revolving Funds Program) Series B (NR/Aaa)^(b)
705,000		5.000		01/01/13		757,812
715,000		5.125		01/01/13		770,034
Missouri State Environmental Improvement & Energy Resources Authority Water Pollution Control Revenue Bonds (State Revolving Funds Program) Series A (NR/Aaa)
400,000		5.500		01/01/23		463,208
Missouri State Environmental Improvement & Energy Resources Authority Water Pollution Control Revenue Bonds (State Revolving Funds Program) Series B (NR/Aaa)
1,115,000		5.000		07/01/17		1,270,509
Missouri State Environmental Improvement & Energy Resources Authority Water Pollution Control Revenue Bonds (Unrefunded Balance-State Revolving Funds Program) Series A (NR/Aaa)
185,000		5.125		07/01/11		185,622
435,000		5.200		07/01/12		436,501
Missouri State Environmental Improvement & Energy Resources Authority Water Pollution Control Revenue Bonds (Unrefunded Balance-State Revolving Funds Program) Series B (NR/Aaa)
415,000		5.125		01/01/18		436,455
20,000		5.000		01/01/22		20,790
Missouri State Health & Educational Facilities Authority Revenue Bonds (Barnes-Jewish, Inc.) (AA/Aa2)
150,000		6.000		05/15/11		150,222
Missouri State Health & Educational Facilities Authority Revenue Bonds (Barnes-Jewish, Inc.) Series A (AA/Aa2)
3,035,000		5.250		05/15/14		3,244,020
Missouri State Health & Educational Facilities Authority Revenue Bonds (BJC Health System) Series 2003 (AA/Aa2)
2,180,000		5.250		05/15/17		2,288,651
Missouri State Health & Educational Facilities Authority Revenue Bonds (BJC Health System) Series A (AA/Aa2)
1,225,000		5.000		05/15/18		1,289,741
Missouri State Health & Educational Facilities Authority Revenue Bonds (Children’s Mercy Hospital) (A+/NR)
1,000,000		5.000		05/15/23		1,015,850
Missouri State Health & Educational Facilities Authority Revenue Bonds (Cox Health System) (NR/A2)
2,350,000		5.125		11/15/23		2,385,884


32		The accompanying notes are an integral part of these financial statements.

COMMERCE MISSOURI TAX-FREE INTERMEDIATE BOND FUND


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Missouri – (continued)
Missouri State Health & Educational Facilities Authority Revenue Bonds (Lake Regional Health System Project) (BBB+/NR)
$ 510,000		5.000	%	02/15/14	$	525,570
Missouri State Health & Educational Facilities Authority Revenue Bonds (Refunding-Lake Regional Health System) (BBB+/NR)
2,000,000		5.000		02/15/19		2,019,100
Missouri State Health & Educational Facilities Authority Revenue Bonds (SSM Health Care) Series B (AA-/NR)
1,000,000		4.500		06/01/25		943,840
Missouri State Health & Educational Facilities Authority Revenue Bonds (St. Louis University) (AA-/A1)
1,000,000		5.500		10/01/12		1,059,280
Missouri State Health & Educational Facilities Authority Revenue Bonds (St. Lukes Health System) Series A (AGM) (AA+/Aa3)
2,000,000		5.000		11/15/14		2,172,880
1,000,000		5.000		11/15/19		1,082,930
Missouri State Health & Educational Facilities Authority Revenue Bonds (University of Missouri-Columbia Arena Project) (AA+/Aa1)
500,000		5.000		11/01/17		509,710
Missouri State Health & Educational Facilities Authority Revenue Bonds (Washington University) Series A (AAA/Aaa)
1,050,000		5.000		02/15/17		1,173,060
1,545,000		5.000		02/15/20		1,688,716
120,000		4.750		11/15/37		119,104
Missouri State Highways & Transit Commission Road Revenue Bonds (Second Lien) (AAA/Aa1)
1,165,000		5.250		05/01/18		1,362,724
Missouri State Housing Development Commission Multi Family Housing Revenue Bonds (Samantha Heights Apartments Project) Series 2 (FHA) (AA/NR)
500,000		4.375		07/01/30		459,030
3,420,000		4.750		07/01/42		3,146,366
Missouri State Housing Development Commission Revenue Bonds (Single Family Homeowner Loan) Series A-1 (AMT) (FNMA/GNMA) (AAA/NR)
25,000		5.800		09/01/11		25,001
20,000		5.900		09/01/12		20,001
20,000		6.000		09/01/13		20,001
Missouri State Housing Development Commission Single Family Mortgage Revenue Bonds (Special Homeownership Loan Program Market Bonds) Series E-1 (FHLMC) (AAA/NR)
1,030,000		3.950		05/01/21		1,014,941
1,205,000		3.950		11/01/21		1,186,684
Missouri State Regional Convention & Sports Complex Authority Revenue Bonds (Refunding-Convention & Sports Facilities Project) Series A-1 (AMBAC) (AA+/Aa2)
2,000,000		5.250		08/15/12		2,105,220


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Missouri – (continued)
Missouri State Stormwater Control GO Bonds Series A (AAA/Aaa)^(b)
$ 300,000		5.250	%	08/01/12	$	318,429
Monarch-Chesterfield MO Levee District Special Tax (A-/NR)
3,425,000		4.000		03/01/19		3,465,723
Monarch-Chesterfield MO Levee District Special Tax (NATL-RE) (BBB/Baa1)
770,000		5.450		03/01/14		772,194
Neosho MO Reorganized School District No. R-5 GO Bonds (Building-Direct Deposit Program) (AGM) (AA+/Aa3)
1,430,000		5.250		03/01/21		1,579,564
Nixa MO Electric System Revenue Bonds (XLCA) (NR/NR)
1,000,000		4.750		04/01/15		1,042,990
North Kansas City MO Hospital Revenue Bonds (North Kansas City Hospital) Series A (AGM) (AA+/Aa3)
1,000,000		5.000		11/15/18		1,033,320
1,000,000		5.000		11/15/19		1,029,170
North Kansas City MO School District No. 74 Direct Deposit Program GO Bonds (AA+/Aa1)
3,000,000		5.500		03/01/28		3,337,950
Northwest Missouri State University Revenue Bonds (Housing System) (NATL-RE) (NR/A3)
2,875,000		5.000		06/01/20		2,965,160
O’ Fallon MO Certificates of Participation (NATL-RE) (NR/Aa3)
1,000,000		5.000		02/01/22		1,035,020
O’ Fallon MO Certificates of Participation (NR/Aa3)
2,130,000		5.250		11/01/17		2,347,388
1,000,000		5.250		11/01/18		1,101,980
2,000,000		5.250		11/01/19		2,202,700
OTC Public Building Corp. MO Leasehold Revenue Bonds (Refunding-Ozarks Technical Community College) (AGM) (AA+/NR)
1,500,000		5.000		03/01/19		1,737,240
Ozark MO Reorganized School District No. R-6 GO Bonds (Direct Deposit Program) (AGM) (AA+/Aa3)
440,000		5.000		03/01/22		480,058
Platte County MO GO Bonds for Parkville Neighborhood Improvement Series B (NATL-RE) (NR/Aa2)
2,720,000		5.000		02/01/22		2,889,266
Platte County MO Industrial Development Authority Transportation Revenue Bonds (Refunding & Improvement-Zona Rosa Retail Project) (AA-/NR)
435,000		5.000		12/01/18		485,456
850,000		5.000		12/01/20		933,708
Raytown MO Annual Appropriation-Supported Tax Revenue Bonds (Live Redevelopment Plan Project 1) (A+/NR)
150,000		5.000		12/01/12		155,541
Raytown MO Sewer Revenue Bonds (NR/NR)
100,000		4.625		07/01/24		100,617
100,000		4.700		07/01/27		100,116


The accompanying notes are an integral part of these financial statements.		33

COMMERCE MISSOURI TAX-FREE INTERMEDIATE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Missouri – (continued)
Republic MO Special Obligation Revenue Bonds (A/NR)
$ 380,000		2.000	%	05/01/14	$	377,070
175,000		2.500		05/01/15		175,464
150,000		2.650		05/01/16		148,751
125,000		3.000		05/01/17		123,579
150,000		3.150		05/01/18		144,608
150,000		3.300		05/01/19		145,157
250,000		3.500		05/01/20		240,562
300,000		3.750		05/01/21		288,864
325,000		3.875		05/01/22		313,150
Ritenour MO School District Direct Deposit Program GO Bonds (AA+/NR)
1,740,000		4.500		03/01/17		1,933,157
Riverside MO Tax Increment Revenue Tax Allocation (L-385 Levee Project) (A/NR)
1,000,000		5.250		05/01/20		1,020,170
Riverside-Quindaro MO Bend Levee District Project Revenue Bonds Series L (Radian) (BBB/NR)
450,000		5.500		03/01/14		465,525
500,000		5.500		03/01/15		516,645
Sikeston MO Electric Revenue Bonds (Refunding) (BBB/Baa1)
530,000		5.000		06/01/22		531,124
Southeast MO State University Revenue Bonds (Installment Payment Certificates) Series 2002 (XLCA) (NR/NR)
200,000		4.750		04/01/12		200,570
Springfield MO Public Building Corp. Leasehold Revenue Bonds (Taxable Improvement-Branson National Airport) (NR/Aa2)
540,000		6.750		03/01/28		563,911
575,000		6.850		03/01/29		601,088
Springfield MO Public Utility Revenue Certificates of Participation (Lease Purchase for Various Projects) Series A (NATL-RE) (AA/A1)
1,000,000		5.000		12/01/18		1,058,110
Springfield MO Special Obligation Revenue Bonds (College Station Garage Project) Series A (NR/Aa3)
190,000		4.500		11/01/18		201,742
530,000		4.500		11/01/19		556,140
610,000		4.500		11/01/20		636,498
645,000		4.750		11/01/21		678,443
685,000		4.750		11/01/22		717,305
Springfield MO Special Obligation Revenue Bonds (Heers Garage Project) Series B (NR/Aa3)
385,000		4.750		11/01/21		404,962
405,000		4.750		11/01/22		424,100
St. Charles County MO Community College GO Bonds (Refunding) (NATL-RE) (NR/Aa1)
2,585,000		5.000		02/15/17		2,989,449
St. Charles County MO Public Water Supply District No. 2 Certificates of Participation (AA/NR)
2,115,000		4.000		12/01/20		2,144,991
100,000		5.200		12/01/31		102,903


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Missouri – (continued)
St. Charles County MO Public Water Supply District No. 2 Certificates of Participation Series B (Refunding) (NR/Baa1)
$ 530,000		5.000	%	12/01/12	$	555,032
St. Charles County MO Water Supply District No. 2 Certificates of Participation (AA/NR)
650,000		5.375		12/01/36		659,035
St. Charles MO Certificates of Participation Build America Bonds Series B (NR/Aa3)
1,250,000		5.650		02/01/30		1,196,962
St. Charles MO Certificates of Participation Series B (NR/A1)
1,000,000		5.500		05/01/18		1,031,920
St. Charles MO Community College Educational Facilities Authority Leasehold Revenue Bonds (NR/Aa2)
100,000		5.250		06/01/19		106,076
735,000		5.200		06/01/24		772,860
St. Louis County MO Industrial Development Authority Health Facilities Revenue Bonds (Refunding-Ranken Jordan Project) (NR/NR)
490,000		5.000		11/15/15		486,859
515,000		5.000		11/15/16		506,698
St. Louis County MO Parkway School District No. C-2 GO Bonds (Refunding & Improvement) (AAA/NR)
400,000		3.250		03/01/19		419,160
St. Louis MO Airport Revenue Bonds (Refunding-Lambert International Airport) (FGIC) (BBB/Baa1)
100,000		5.125		07/01/15		100,168
St. Louis MO Airport Revenue Bonds (Refunding-Lambert International Airport) Series B (AMT) (AGM) (AA+/Aa3)
2,000,000		5.000		07/01/24		1,980,860
St. Louis MO Airport Revenue Bonds (Refunding-Lambert/St. Louis International Airport) (NATL-RE) (FGIC) (BBB/Baa1)
185,000		5.125		07/01/12		185,389
St. Louis MO Junior College District Building Corp. Leasehold Revenue Bonds (AA/NR)
100,000		4.000		04/01/16		107,461
St. Louis MO Municipal Finance Corp. Leasehold Revenue Bonds (Refunding-City Justice Center) Series A (AMBAC) (A/NR)
700,000		5.250		02/15/15		713,391
St. Louis MO Municipal Finance Corp. Leasehold Revenue Bonds (Refunding-Civil Courts Building) (A/NR)
1,255,000		3.000		08/01/14		1,284,643
1,345,000		4.000		08/01/14		1,418,585
St. Louis MO Parking Revenue Bonds (Downtown Parking Facilities-Subordinated A) (NR/NR)^(b)
835,000		5.500		02/01/12		864,459
St. Louis MO Parking Revenue Bonds (Taxable) Series B (BBB/Baa1)
100,000		5.140		12/15/14		104,963
St. Louis MO Special Administrative Board Transitional School District GO Bonds (Direct Deposit Program) (AA+/NR)
4,250,000		5.000		04/01/21		4,602,835


34		The accompanying notes are an integral part of these financial statements.

COMMERCE MISSOURI TAX-FREE INTERMEDIATE BOND FUND


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Missouri – (continued)
Taney County MO Certificates of Participation (NATL-RE) (NR/A1)
$1,095,000		4.500	%	04/01/17	$	1,144,461
University of Missouri Revenue Bonds System Facilities (Refunding) Series B (AA+/Aa1)
375,000		5.375		11/01/14		383,006
Valley Park MO School District Educational Facilities Authority Leasehold Revenue Bonds (Refunding) (AA-/NR)
300,000		2.750		03/01/17		298,233
345,000		3.000		03/01/18		342,043
360,000		3.000		03/01/19		348,527
385,000		3.150		03/01/21		364,237
700,000		3.300		03/01/23		651,889
Warrensburg MO Certificates of Participation (Refunding & Improvement) (A/NR)
225,000		3.000		09/01/12		229,646
Washington MO School District Direct Deposit GO Bonds (Refunding) (AGM) (AA+/Aa3)
1,000,000		5.250		03/01/13		1,082,550
West Plains R-VII School District MO Lease Certificates of Participation Howell County (Refunding-GTD Performance) Series A (A-/NR)
405,000		2.700		04/15/16		398,621
470,000		3.250		04/15/18		454,654
Willard MO Certificates of Participation (Parks & Recreation Project) Series B (A/NR)
625,000		6.625		06/01/28		718,131

						204,973,173

Nevada – 1.0%
Las Vegas NV Convention & Visitors Authority Revenue Bonds (Refunding) Series E (AGM) (AA+/Aa3)
2,505,000		5.400		07/01/33		2,510,185

Pennsylvania – 0.7%
Delaware County Authority University Revenue Bonds for Neumann University (BBB/NR)
1,000,000		5.000		10/01/25		918,870
St. Mary’s PA Area Water Authority Revenue Bonds (BBB+/NR)
1,000,000		4.750		02/01/25		989,000

						1,907,870

Puerto Rico – 1.0%
Puerto Rico Electric Power Authority Revenue Bonds (Refunding) (NATL-RE) (BBB+/A3)
555,000		5.000		07/01/22		562,071
Puerto Rico Public Buildings Authority Revenue Bond (Unrefunded Balance-Government Facilities) Series l (BBB/A3)
2,320,000		5.250		07/01/33		2,110,689

						2,672,760


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
South Carolina – 0.4%
Kershaw County SC Public School Foundation Installment Power Revenue Bonds (School District Project) (CIFG) (BBB+/NR)
$1,035,000		5.000	%	12/01/28	$	994,014

Texas – 0.3%
Mansfield TX GO Certificates (AA/Aa2)
700,000		5.750		02/15/22		787,101

Washington – 0.9%
Washington State Health Care Facilities Authority Revenue Bonds (Overlake Hospital Medical Center) (A-/A3)
2,500,000		5.250		07/01/25		2,431,700

TOTAL MUNICIPAL BOND OBLIGATIONS
(Cost $247,042,859)					$	251,552,146


Short-term Investment^(c) – 2.1%
Repurchase Agreement – 2.1%
State Street Bank & Trust Co.
$5,478,000		0.010	%	05/02/11	$	5,478,000
Maturity Value: $5,478,005
(Cost $5,478,000)

TOTAL INVESTMENTS – 99.5%
(Cost $252,520,859)					$	257,030,146

OTHER ASSETS IN EXCESS OF LIABILITIES – 0.5%						1,216,148

NET ASSETS – 100.0%					$	258,246,294


The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets.
^(a)		Issued with a zero coupon. Income is recognized through the accretion of discount.
^(b)		Prerefunded security. Maturity date disclosed is prerefunding date.
^(c)		Repurchase agreement was entered into on April 29, 2011. This agreement was fully collateralized by $5,520,000 U.S. Treasury Note, 1.000% due 04/30/12 with a market value of $5,587,985.
Security ratings disclosed, if any, are issued by Standard & Poor’s Ratings Services/Moody’s Investors Service and are unaudited. A description of the ratings is available in the Fund’s Statement of Additional Information.


The accompanying notes are an integral part of these financial statements.		35

COMMERCE MISSOURI TAX-FREE INTERMEDIATE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)



Investment Abbreviations:
AGM		—Insured by Assured Guaranty Municipal Corp.
AMBAC		—Insured by American Municipal Bond Assurance Corp.
AMT		—Alternative Minimum Tax
CIFG		—Insured by CIFG Assurance North America, Inc.
FGIC		—Insured by Financial Guaranty Insurance Co.
FHA		—Insured by Federal Housing Administration
FHLMC		—Federal Home Loan Mortgage Corp.
FNMA		—Federal National Mortgage Association
GNMA		—Government National Mortgage Association
GO		—General Obligation
GTD		—Guaranteed
NATL-RE		—Insured by National Reinsurance Corp.
NR		—Not Rated
Radian		—Insured by Radian Asset Assurance
WR		—Withdrawn Rating
XLCA		—Insured by XL Capital Assurance, Inc.

PORTFOLIO COMPOSITION


Sector Allocation	AS OF 4/30/11			AS OF 10/31/10

Lease		24.8	%		23.5	%
General Obligations		23.6			25.0
Hospital		17.3			17.7
General		10.3			9.9
Water/Sewer		5.1			5.7
Education		4.9			4.6
Transportation		4.5			4.9
Single Family Housing		2.3			2.1
Prerefunded/Escrow to Maturity		2.0			1.9
Multi Family Housing		1.4			1.6
Power		0.8			1.3
Crossover		0.4			1.1
Short-term Investment		2.1			0.0

TOTAL INVESTMENTS		99.5	%		99.3	%

The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets.

The Fund is actively managed and, as such its composition may differ over time.


36		The accompanying notes are an integral part of these financial statements.

COMMERCE KANSAS TAX-FREE INTERMEDIATE BOND FUND

Schedule of Investments

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – 98.9%
Arizona – 0.5%
Arizona Healthcare & Education Facilities Authority Revenue Bonds (Kirksville College) (A-/NR)
$ 450,000		5.000	%	01/01/25	$	449,969

California – 1.4%
Burbank CA Unified School District GO Bonds Capital Appreciation Election of 1997 Series C (NATL-RE) (FGIC) (AA-/NR)^(a)
670,000		0.000		07/01/27		231,840
Sacramento County CA Airport System Revenue Bonds (A/A2)
500,000		5.000		07/01/27		504,355
San Francisco City & County Airports Commission Revenue Bonds (Refunding Second Series 32G) (NATL-RE) (FGIC) (A/A1)
445,000		5.000		05/01/24		453,255

						1,189,450

Florida – 4.6%
Duval County FL School Board Certificates of Participation (Master Lease Program) Series B (AA-/Aa3)
1,250,000		5.000		07/01/35		1,224,162
Miami-Dade County Aviation Revenue Bonds Series B (A-/A2)
2,000,000		5.000		10/01/41		1,766,880
Port St. Lucie FL Lease Revenue Bonds (Wyndcrest Project-Recovery Zone Facility Bonds) Series B (A/Aa3)
1,000,000		4.500		09/01/24		982,240

						3,973,282

Illinois – 1.0%
Illinois Finance Authority Revenue Bonds (Poetry Foundation Project) (A+/A1)
900,000		5.300		01/01/40		842,175

Indiana – 3.7%
Evansville IN Redevelopment Authority Revenue Bonds Lease Rent Tax Allocation (Build America Bonds-Taxable) Series B (A/Aa3)
1,000,000		6.860		02/01/29		1,032,290
Indiana State Finance Authority Revenue Bonds (Educational Facilities for Indiana Historical Society, Inc.) (NR/A3)
1,000,000		5.000		07/01/35		889,300
North West Hendricks Multi School Building Corp. Industry (First Mortgage) Series A (AA+/Aa3)
1,300,000		5.000		01/15/31		1,317,940

						3,239,530

Iowa – 0.4%
Iowa Finance Authority Single Family Mortgage Revenue Bonds Series E (GNMA/FNMA) (Go of Authority) (AAA/Aaa)
370,000		5.000		07/01/23		375,935

Kansas – 75.1%
Augusta KS Electric Systems Revenue Bonds (AMBAC) (NR/NR)^(b)
1,000,000		4.750		08/01/12		1,053,950


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Kansas – (continued)
Burlington KS Pollution Control Revenue Bonds (Refunding Gas & Electric) (NATL-RE) (BBB+/Baa1)
$ 190,000		4.850	%	06/01/31	$	176,181
Chisholm Creek Utility Authority KS Water and Wastewater Facilities Revenue Bonds (Refunding) (AMBAC) (NR/NR)
1,000,000		5.250		09/01/24		1,045,860
Cowley County KS Unified School District No. 470 Arkansas City GO Bonds (Refunding) (A/NR)
940,000		4.000		09/01/17		1,015,134
235,000		4.000		09/01/18		249,415
Derby KS GO Bonds (Refunding) Series B (AMBAC) (NR/Aa3)
440,000		5.000		12/01/13		448,879
Dodge City KS Unified School District No. 443 Ford County Certificates of Participation (Lease Purchase Agreement) (NR/A2)
400,000		2.000		12/01/11		401,528
1,015,000		2.000		12/01/13		1,006,169
Dodge City KS Unified School District No. 443 GO Bonds (Refunding) (FGIC) (NR/A1)
1,450,000		5.000		03/01/12		1,481,407
Douglas County KS GO Bonds (Refunding Sales Tax) Series A (AMBAC) (NR/Aa2)
1,000,000		5.000		08/01/12		1,055,240
Harvey County KS School District No. 373 GO Bonds (Refunding & Improvement) (AGM) (AA+/Aa3)
495,000		5.000		09/01/15		550,787
Johnson County KS Community College Certificate of Participation (Improvement) (NR/Aaa)
765,000		4.000		04/01/13		783,727
Johnson County KS GO Bonds (Internal Improvement) Series A (AAA/Aaa)
1,000,000		5.000		09/01/21		1,049,650
Johnson County KS Public Building Commission Lease Purchase Revenue Bonds (Refunding) Series C (AAA/Aaa)
500,000		4.000		09/01/20		536,600
Johnson County KS Unified School District No 229 GO Bonds Series A (AA/Aaa)
945,000		4.000		10/01/23		996,758
Johnson County KS Unified School District No. 231 GO Bonds (Refunding & Improvement) Series A (FGIC) (AA-/NR)
500,000		6.000		10/01/16		596,935
1,770,000		5.000		10/01/18		1,900,467
Johnson County KS Unified School District No. 231 GO Bonds (Refunding & Improvement) Series B (AMBAC) (AA-/NR)
925,000		5.000		10/01/22		987,632
975,000		5.000		10/01/23		1,035,596
Johnson County KS Unified School District No. 232 GO Bonds (Refunding & Improvement) (NR/Aa3)
200,000		5.000		03/01/15		221,516
Johnson County KS Water District No. 001 Revenue Bonds (Refunding) (ADFA) (GTD) (AAA/Aaa)
275,000		5.000		12/01/19		285,376


The accompanying notes are an integral part of these financial statements.		37

COMMERCE KANSAS TAX-FREE INTERMEDIATE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Kansas – (continued)
Kansas State Development Finance Authority Health Facilities Revenue Bonds (Hays Medical Center, Inc.) Series Q (NR/A2)
$ 750,000		5.000	%	05/15/35	$	658,928
Kansas State Development Finance Authority Hospital Revenue Bonds (Adventist Health) (AA-/Aa3)
1,000,000		5.500		11/15/23		1,083,440
Kansas State Development Finance Authority Hospital Revenue Bonds (Adventist Health) Series D (AA-/Aa3)
800,000		5.000		11/15/24		819,224
Kansas State Development Finance Authority Lease Revenue Bonds (Juvenile Justice Authority) Series D (NATL-RE) (AA/Baa1)
1,270,000		5.250		05/01/13		1,273,886
Kansas State Development Finance Authority Revenue Bonds (Athletic Facilities) Series A-1 (A-/A1)
500,000		4.875		07/01/27		503,480
1,425,000		5.250		07/01/31		1,441,573
Kansas State Development Finance Authority Revenue Bonds (Athletic Facilities) Series C (A/Aa3)
1,375,000		4.750		06/01/25		1,403,531
Kansas State Development Finance Authority Revenue Bonds (Board of Regents University Housing) Series A (NATL-RE) (A/Aa3)
1,150,000		5.000		04/01/24		1,193,711
Kansas State Development Finance Authority Revenue Bonds (El Dorado Department of Corrections Refunding Project A1) (NATL-RE) (AA/Baa1)
400,000		5.000		02/01/12		400,928
Kansas State Development Finance Authority Revenue Bonds (Juvenile Justice Authority) Series D (NATL-RE) (AA/Baa1)
400,000		5.000		05/01/12		401,328
Kansas State Development Finance Authority Revenue Bonds (Kansas Project) Series M-1 (AA/Aa2)
2,000,000		5.000		11/01/27		2,095,820
Kansas State Development Finance Authority Revenue Bonds (Kansas State Projects) Series J (Unrefunded Balance) (AMBAC) (AA/NR)
1,600,000		5.000		08/01/17		1,688,768
Kansas State Development Finance Authority Revenue Bonds (Kansas State Projects) Series K (NATL-RE) (AA/Aa2)
1,000,000		5.250		11/01/22		1,108,790
Kansas State Development Finance Authority Revenue Bonds (Kansas State Projects) Series W (ETM) (NATL-RE) (AA/NR)
20,000		4.000		10/01/11		20,302
Kansas State Development Finance Authority Revenue Bonds (Public Water Supply Revolving Loan-2) (AMBAC) (AAA/Aaa)^(b)
705,000		5.500		04/01/12		738,755
Kansas State Development Finance Authority Revenue Bonds (Public Water Supply Revolving Loan-DW) (AAA/Aaa)^(b)
1,500,000		6.000		04/01/13		1,657,695


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Kansas – (continued)
Kansas State Development Finance Authority Revenue Bonds (Refunding-Wichita State University Housing System-P) (AMBAC) (A+/NR)
$ 600,000		5.000	%	06/01/13	$	622,632
630,000		5.000		06/01/14		651,496
300,000		5.000		06/01/16		308,094
Kansas State Development Finance Authority Revenue Bonds (Sisters of Charity of Leavenworth) Series A (AA/Aa3)
1,750,000		5.250		01/01/25		1,832,915
Kansas State Development Finance Authority Revenue Bonds (Transportation Revolving Fund Trust) (AA+/Aa1)
1,105,000		5.000		10/01/21		1,192,273
Kansas State Development Finance Authority Revenue Bonds (University of Kansas Athletic Facilities Refunding) Series K (A/Aa3)
1,015,000		5.000		06/01/17		1,094,637
Kansas State Development Finance Authority Revenue Bonds (Water Pollution Control Revolving Fund II) (AAA/Aaa)
280,000		5.500		05/01/17		334,379
Lawrence KS Hospital Revenue Bonds (Refunding Lawrence Memorial Hospital) (NR/A2)
1,000,000		5.375		07/01/14		1,049,450
455,000		5.375		07/01/15		476,139
Leavenworth County KS Unified School District No. 453 GO Bonds (Refunding & Improvement) Series A (AGM) (NR/Aa3)
1,455,000		5.250		03/01/23		1,625,191
Leavenworth County KS Unified School District No. 458 GO Bonds (Refunding & Improvement) Series A (NR/Aa3)
1,100,000		5.250		09/01/27		1,181,169
315,000		5.250		09/01/29		331,456
Leavenworth County KS Unified School District No. 464 Tonganoxie GO Bonds (Improvement) Series A (NATL-RE) (BBB/Baa1)
150,000		5.000		09/01/20		160,881
Lyons KS Public Building Commission Revenue Bonds (A/NR)
315,000		5.000		10/01/23		339,831
Miami County Unified School District No. 416 Louisburg, KS GO Bonds (Refunding and Improvement) (NATL-RE) (BBB/Baa1)
1,650,000		5.000		09/01/17		1,828,365
Olathe KS Health Facilities Revenue Bonds (Medical Center Project) Series 2008 (A+/NR)
1,195,000		5.125		09/01/21		1,239,633
Pittsburg KS GO Bonds (Refunding) (AGM) (NR/Aa3)
210,000		5.500		09/01/11		213,173
Reno County KS Unified School District No. 308 Hutchinson GO Bonds Series A (NATL-RE) (NR/Aa3)
500,000		4.500		09/01/22		520,345
Reno County KS Unified School District No. 308 Hutchinson GO Bonds Series A (NR/Aa3)
400,000		5.500		09/01/15		453,808


38		The accompanying notes are an integral part of these financial statements.

COMMERCE KANSAS TAX-FREE INTERMEDIATE BOND FUND


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Kansas – (continued)
Saline County KS Unified School District No. 305 Salina GO Bonds (AGM) (NR/Aa2)
$ 100,000		5.500	%	09/01/16	$	101,491
Saline County KS Unified School District No. 305 Salina GO Bonds (Unrefunded Balance) (AGM) (NR/Aa2)
70,000		5.500		09/01/16		70,734
Scott County KS Unified School District No. 466 GO Bonds (Refunding) (FGIC) (BBB/NR)
680,000		5.250		09/01/14		711,294
Sedgwick County KS Public Building Commission Revenue Bonds (Technical Education Complex Project) Series 2008-1 (NR/Aaa)
1,000,000		5.250		08/01/26		1,109,010
Sedgwick County Unified School District No. 261 (Refunding & School Improvement) (AGM) (AA+/NR)
1,500,000		5.000		11/01/32		1,506,585
Sedwick & Shawnee County KS Single Family Mortgage Revenue Bonds (Morgage Backed Securities Program) Series B-3 (FHLMC/FNMA/GNMA) (NR/Aaa)
850,000		5.250		12/01/38		869,941
Shawnee County KS GO Bonds (Refunding & Improvement) (NR/Aa2)
500,000		3.000		09/01/11		504,200
360,000		3.000		09/01/12		371,628
Shawnee County KS Unified School District No. 501 GO Bonds (NR/Aa2)^(b)
500,000		5.000		02/01/12		517,510
Topeka KS GO Bonds (Refunding) Series B (NR/Aa2)
1,360,000		2.500		08/15/19		1,323,117
Topeka KS Public Building Commission Revenue Bonds (Refunding 10th & Jackson Project) Series A (NATL-RE) (AA/Baa1)
535,000		5.000		06/01/16		614,030
1,000,000		5.000		06/01/23		1,111,580
Topeka KS Public Building Commission Revenue Bonds (Refunding Department of Social and Rehabilitation Project) Series B (NATL-RE) (AA/Baa1)
300,000		5.000		06/01/23		333,474
475,000		5.000		06/01/24		523,892
Wichita KS Water & Sewer Utility Revenue Bonds Series 2003 (FGIC) (BBB/Aa2)
1,000,000		5.000		10/01/19		1,053,020
Wyandotte County Kansas City KS Unified Government Utility System Revenue Bonds Series A (BHAC) (AA+/Aa1)
1,000,000		5.000		09/01/24		1,088,280
Wyandotte County KS School District No. 204 GO Bonds Bonner Springs (Refunding & Improvement) Series A (FGIC) (NR/A1)
1,595,000		5.000		09/01/21		1,682,310
Wyandotte County KS School District No. 204 GO Bonds Bonner Springs (Unrefunded Balance) Series 2000 A (AGM) (NR/Aa3)
85,000		6.375		09/01/11		86,567


Principal Amount	Interest Rate			Maturity Date	Value
Municipal Bond Obligations – (continued)
Kansas – (continued)
Wyandotte County KS School District No. 500 GO Bonds (Refunding) (AA-/Aa2)
$1,405,000		4.000	%	09/01/20	$	1,555,869
Wyandotte County KS Unified School District No. 202 GO Bonds (Refunding) Series A (AMBAC) (A+/NR)
1,000,000		5.250		09/01/17		1,155,490
Wyandotte County KS Unified School District No. 500 GO Bonds (Refunding) (AGM) (AA+/Aa2)
160,000		5.000		09/01/12		169,870

						65,284,725

Louisiana – 2.2%
Louisiana Local Government Environmental Facilities & Community Development Authority Revenue Bonds (Woman’s Hospital Foundation) Series A (BBB+/A3)
2,000,000		5.500		10/01/25		1,957,100

Massachusetts – 0.5%
Massachusetts Educational Financing Authority Education Loan Revenue Bonds (Issue I) Series A (AA/NR)
480,000		5.300		01/01/30		474,365

Ohio – 1.6%
Ohio State Higher Educational Facility Revenue Bonds (Kenyon College Project) (A+/A1)
1,500,000		5.000		07/01/41		1,360,770

Pennsylvania – 0.6%
Delaware County Authority University Revenue Bonds for Neumann University (BBB/NR)
605,000		5.000		10/01/25		555,916

Puerto Rico – 5.9%
Puerto Rico Commonwealth GO Bonds (Refunding & Public Improvement) Series A (NATL-RE) (BBB/A3)
475,000		5.500		07/01/16		511,323
Puerto Rico Commonwealth Highway & Transportation Authority Highway Revenue Bonds (Refunding) Series X (AGM) (AA+/Aa3)
425,000		5.500		07/01/15		465,707
Puerto Rico Commonwealth Highway & Transportation Authority Highway Revenue Bonds Series Y (BBB+/A2)
500,000		6.250		07/01/13		537,935
Puerto Rico Commonwealth Highway & Transportation Authority Revenue Bonds (Unrefunded Balance) Series G (FGIC) (BBB/A3)
345,000		5.250		07/01/21		346,232
Puerto Rico Electric Power Authority Revenue Bonds (Refunding) Series ZZ (BBB+/A3)
1,275,000		5.000		07/01/21		1,303,126
Puerto Rico Electric Power Authority Revenue Bonds Series AAA (BBB+/A3)
1,000,000		5.250		07/01/21		1,036,720


The accompanying notes are an integral part of these financial statements.		39

COMMERCE KANSAS TAX-FREE INTERMEDIATE BOND FUND

Schedule of Investments (continued)

April 30, 2011 (Unaudited)


Principal Amount	Interest Rate			Maturity Date		Value
Municipal Bond Obligations – (continued)
Puerto Rico – (continued)
Puerto Rico Public Buildings Authority Revenue Bonds (Unrefunded Balance - Government Facilities) Series l (BBB/A3)
$1,000,000		5.250	%		07/01/33	$	909,780

							5,110,823

South Carolina – 0.6%
Kershaw County SC Public School Foundation Installment Power Revenue Bonds (School District Project) (CIFG) (BBB+/NR)
500,000		5.000			12/01/28		480,200

Washington – 0.8%
Washington State Health Care Facilities Authority Revenue Bonds (Overlake Hospital Medical Center) (A-/A3)
750,000		5.250			07/01/25		729,510

TOTAL INVESTMENTS – 98.9%
(Cost $84,682,607)						$	86,023,750

OTHER ASSETS IN EXCESS OF LIABILITIES – 1.1%							912,889

NET ASSETS – 100.0%						$	86,936,639


The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets.
^(a)		Issued with a zero coupon. Income is recognized through the accretion of discount.
^(b)		Prerefunded security. Maturity date disclosed is prerefunding date.
Security ratings disclosed, if any, are issued by Standard & Poor’s Ratings Services/Moody’s Investors Service and are unaudited. A description of the ratings is available in the Fund’s Statement of Additional Information.




Investment Abbreviations:
ADFA		—Arkansas Development Finance Authority
AGM		—Insured by Assured Guaranty Municipal Corp.
AMBAC		—Insured by American Municipal Bond Assurance Corp.
BHAC		—Berkshire Hathaway Assurance Corp.
CIFG		—Insured by CIFG Assurance North America, Inc.
ETM		—Escrow to Maturity
FGIC		—Insured by Financial Guaranty Insurance Co.
FHLMC		—Federal Home Loan Mortgage Corp.
FNMA		—Federal National Mortgage Association
GNMA		—Government National Mortgage Association
GO		—General Obligation
GTD		—Guaranteed
NATL-RE		—Insured by National Reinsurance Corp.
NR		—Not Rated


40		The accompanying notes are an integral part of these financial statements.

COMMERCE KANSAS TAX-FREE INTERMEDIATE BOND FUND

PORTFOLIO COMPOSITION


Sector Allocation	AS OF 4/30/11			AS OF 10/31/10

General Obligations		34.8	%		39.1	%
Education		14.1			8.2
Lease		13.4			13.7
Hospital		11.3			16.1
General		7.6			3.3
Prerefunded/Escrow to Maturity		5.1			4.9
Transportation		3.6			3.3
Water/Sewer		3.1			4.0
Power		2.7			4.3
Single Family Housing		1.4			1.9
Crossover		1.2			0.0
Student		0.6			0.0
Short-term Investment		0.0			0.9

TOTAL INVESTMENTS		98.9	%		99.7	%

The percentage shown for each investment category reflects the value of investments in that category as a percentage of net assets.

The Fund is actively managed and, as such its composition may differ over time.


The accompanying notes are an integral part of these financial statements.		41

COMMERCE FUNDS

Statements of Assets and Liabilities

April 30, 2011 (Unaudited)


	Growth Fund			Value Fund			MidCap Growth Fund
Assets:
Investments in securities, at value (identified cost $116,412,910, $52,528,975, $51,195,051, $597,135,695, $117,037,716, $172,163,744, $252,520,859 and $84,682,607, respectively)	$	137,576,267		$	57,291,307		$	70,186,520
Cash		616			—			919
Receivables:
Interest and dividends		55,982			102,031			19,698
Fund shares sold		75,856			73,463			1,046
Reimbursement from adviser		1,227			—			—
Other assets		12,182			5,098			6,192
Total Assets		137,722,130			57,471,899			70,214,375


Liabilities:
Due to custodian		—			—			—
Payables:
Investment securities purchased		—			—			—
Income distributions		—			—			—
Fund shares redeemed		2,200			33,919			41,987
Advisory fees		83,096			13,910			42,577
Deferred trustee fees		46,862			29,837			20,209
Administration fees		16,619			6,867			8,515
Accrued expenses		66,976			39,910			55,775
Total Liabilities		215,753			124,443			169,063


Net Assets:
Paid-in capital		120,336,821			63,125,574			50,367,106
Accumulated undistributed (distributions in excess of) net investment income (loss)		588,868			72,677			(66,083	)
Accumulated net realized gain (loss) from investment transactions		(4,582,669	)		(10,613,127	)		752,820
Net unrealized gain on investments		21,163,357			4,762,332			18,991,469
Net Assets	$	137,506,377		$	57,347,456		$	70,045,312


Shares Outstanding/Net Asset Value:
Total shares outstanding, no par value (unlimited number of shares authorized):		4,913,619			2,569,389			1,879,054
Net asset value (net assets/shares outstanding)	$	27.98		$	22.32		$	37.28


42		The accompanying notes are an integral part of these financial statements.

COMMERCE FUNDS


Bond Fund			Short-Term Government Fund			National Tax-Free Intermediate Bond Fund		Missouri Tax-Free Intermediate Bond Fund			Kansas Tax-Free Intermediate Bond Fund


$	640,764,265		$	121,307,972		$	173,594,793	$	257,030,146		$	86,023,750
	109,694			—			230		532			—

	5,831,749			730,913			2,358,867		3,363,230			1,056,717
	1,651,227			311,604			237,398		998,383			265,008
	—			22,291			18,253		33,655			14,052
	59,050			11,636			16,310		23,681			7,928
	648,415,985			122,384,416			176,225,851		261,449,627			87,367,455



	—			—			—		—			89,144

	4,008,472			320,081			—		2,239,032			—
	1,953,262			212,308			552,953		671,688			223,908
	221,252			181,168			1,620,618		32,600			2,089
	260,972			50,075			70,980		104,636			35,215
	154,076			42,184			44,242		48,414			19,390
	78,291			15,023			21,294		31,391			10,565
	168,109			62,677			71,789		75,572			50,505
	6,844,434			883,516			2,381,876		3,203,333			430,816



	605,168,130			131,627,566			171,937,866		253,177,418			85,489,544
	(2,091,717	)		(1,004,626	)		128,287		(80,581	)		(65,102	)
	(5,133,432	)		(13,392,296	)		346,773		640,170			171,054
	43,628,570			4,270,256			1,431,049		4,509,287			1,341,143
$	641,571,551		$	121,500,900		$	173,843,975	$	258,246,294		$	86,936,639



	31,918,583			6,664,942			9,299,275		13,442,145			4,638,760
$	20.10		$	18.23		$	18.69	$	19.21		$	18.74


The accompanying notes are an integral part of these financial statements.		43

COMMERCE FUNDS

Statements of Operations

For the Six Months Ended April 30, 2011 (Unaudited)


	Growth Fund			Value Fund			MidCap Growth Fund
Investment Income:
Interest	$	—		$	—		$	—
Dividends		1,003,519			691,785			338,731
Total Investment Income		1,003,519			691,785			338,731


Expenses:
Advisory fees		480,028			153,909			238,633
Administration fees		96,006			38,933			47,727
Shareowner servicing fees		68,329			14,221			26,720
Transfer Agent fees		39,910			21,832			27,175
Professional fees		20,467			13,191			14,048
Custody and accounting fees		11,306			15,589			12,628
Registration fees		10,838			10,523			10,261
Trustee fees		6,783			2,531			3,345
Printing and mailing fees		4,659			2,801			2,978
Other		8,991			5,076			5,040
Total Expenses		747,317			278,606			388,555
Less — expense reimbursements		(24,075	)		(12,429	)		—
Net Expenses		723,242			266,177			388,555
Net Investment Income (Loss)		280,277			425,608			(49,824	)


Realized and unrealized gain (loss) from investment transactions:
Net realized gain from investment transactions		6,027,253			8,297,572			2,464,810
Net change in unrealized gain (loss) on investments		10,141,837			387,375			8,558,288
Net realized and unrealized gain (loss) from investment transactions		16,169,090			8,684,947			11,023,098
NET INCREASE (DECREASE) IN NET ASSETS RESULTING FROM OPERATIONS	$	16,449,367		$	9,110,555		$	10,973,274


44		The accompanying notes are an integral part of these financial statements.

COMMERCE FUNDS


Bond Fund			Short-Term Government Fund			National Tax-Free Intermediate Bond Fund			Missouri Tax-Free Intermediate Bond Fund			Kansas Tax-Free Intermediate Bond Fund

$	17,521,752		$	1,719,008		$	3,993,091		$	5,475,635		$	1,773,638
	134,340			—			—			—			—
	17,656,092			1,719,008			3,993,091			5,475,635			1,773,638



	1,572,585			309,597			438,000			629,649			207,120
	471,775			92,880			131,400			188,895			62,136
	236,733			46,200			55,367			91,757			28,407
	45,313			23,915			17,402			27,809			16,963
	67,986			19,317			23,791			30,087			15,645
	56,830			22,086			29,015			36,786			17,165
	12,364			10,846			9,805			5,991			9,270
	32,914			6,762			9,490			13,593			4,484
	26,665			6,255			7,971			10,546			3,515
	39,702			9,565			13,447			17,729			6,908
	2,562,867			547,423			735,688			1,052,842			371,613
	—			(126,412	)		(122,491	)		(171,345	)		(81,649	)
	2,562,867			421,011			613,197			881,497			289,964
	15,093,225			1,297,997			3,379,894			4,594,138			1,483,674



	1,375,411			48,001			347,013			640,716			171,144
	(9,403,646	)		(1,277,216	)		(5,954,052	)		(6,749,910	)		(2,001,373	)
	(8,028,235	)		(1,229,215	)		(5,607,039	)		(6,109,194	)		(1,830,229	)
$	7,064,990		$	68,782		$	(2,227,145	)	$	(1,515,056	)	$	(346,555	)


The accompanying notes are an integral part of these financial statements.		45

COMMERCE FUNDS

Statements of Changes in Net Assets


	Growth Fund						Value Fund
	For the Six Months Ended April 30, 2011 (Unaudited)			For the Fiscal Year Ended October 31, 2010			For the Six Months Ended April 30, 2011 (Unaudited)			For the Fiscal Year Ended October 31, 2010
From Operations:
Net investment income (loss)	$	280,277		$	927,619		$	425,608		$	773,238
Net realized gain (loss) from investment transactions		6,027,253			5,759,676			8,297,572			(1,025,763	)
Net change in unrealized gain (loss) on investments		10,141,837			11,679,609			387,375			8,277,144
Net increase in net assets resulting from operations		16,449,367			18,366,904			9,110,555			8,024,619


Distributions to Shareholders:
From net investment income		(599,910	)		(550,888	)		(374,856	)		(790,500	)


From Share Transactions:
Proceeds from sales of shares		14,311,496			14,117,639			6,194,111			10,092,891
Reinvestment of distributions		243,853			231,828			77,581			159,149
Cost of shares redeemed		(12,465,467	)		(23,120,014	)		(7,591,554	)		(31,176,821	)
Net increase (decrease) in net assets resulting from share transactions		2,089,882			(8,770,547	)		(1,319,862	)		(20,924,781	)
TOTAL INCREASE (DECREASE)		17,939,339			9,045,469			7,415,837			(13,690,662	)


Net Assets:
Beginning of period		119,567,038			110,521,569			49,931,619			63,622,281
End of period	$	137,506,377		$	119,567,038		$	57,347,456		$	49,931,619
Accumulated undistributed (distributions in excess of) net investment income	$	588,868		$	908,501		$	72,677		$	21,925


46		The accompanying notes are an integral part of these financial statements.

COMMERCE FUNDS


MidCap Growth Fund						Bond Fund
For the Six Months Ended April 30, 2011 (Unaudited)			For the Fiscal Year Ended October 31, 2010			For the Six Months Ended April 30, 2011 (Unaudited)			For the Fiscal Year Ended October 31, 2010

$	(49,824	)	$	(122,286	)	$	15,093,225		$	28,995,274
	2,464,810			3,655,511			1,375,411			4,360,130
	8,558,288			9,862,640			(9,403,646	)		33,158,157
	10,973,274			13,395,865			7,064,990			66,513,561



	—			(73,820	)		(14,993,557	)		(29,868,886	)



	10,477,610			3,943,245			74,531,765			139,473,917
	—			17,725			2,943,887			5,321,497
	(4,785,755	)		(12,674,320	)		(76,670,312	)		(103,304,905	)
	5,691,855			(8,713,350	)		805,340			41,490,509
	16,665,129			4,608,695			(7,123,227	)		78,135,184



	53,380,183			48,771,488			648,694,778			570,559,594
$	70,045,312		$	53,380,183		$	641,571,551		$	648,694,778
$	(66,083	)	$	(16,259	)	$	(2,091,717	)	$	(2,191,385	)


The accompanying notes are an integral part of these financial statements.		47

COMMERCE FUNDS

Statements of Changes in Net Assets (continued)


	Short-Term Government Fund						National Tax-Free Intermediate Bond Fund
	For the Six Months Ended April 30, 2011 (Unaudited)			For the Fiscal Year Ended October 31, 2010			For the Six Months Ended April 30, 2011 (Unaudited)			For the Fiscal Year Ended October 31, 2010
From Operations:
Net investment income	$	1,297,997		$	3,167,816		$	3,379,894		$	6,281,136
Net realized gain from investment transactions		48,001			61,822			347,013			2,425,189
Net change in unrealized gain (loss) on investments		(1,277,216	)		2,783,401			(5,954,052	)		4,152,801
Net increase (decrease) in net assets from operations		68,782			6,013,039			(2,227,145	)		12,859,126


Distributions to Shareholders:
From net investment income		(1,819,822	)		(3,849,938	)		(3,391,450	)		(6,266,632	)
From net realized gains		—			—			(2,394,933	)		(422,586	)
Total distributions to shareholders		(1,819,822	)		(3,849,938	)		(5,786,383	)		(6,689,218	)


From Share Transactions:
Proceeds from sales of shares		18,899,084			64,398,029			16,374,672			46,150,365
Reinvestment of distributions		571,713			1,160,258			536,769			222,529
Cost of shares redeemed		(29,241,142	)		(40,679,699	)		(26,951,287	)		(24,523,400	)
Net increase (decrease) in net assets resulting from share transactions		(9,770,345	)		24,878,588			(10,039,846	)		21,849,494
TOTAL INCREASE (DECREASE)		(11,521,385	)		27,041,689			(18,053,374	)		28,019,402


Net Assets:
Beginning of period		133,022,285			105,980,596			191,897,349			163,877,947
End of period	$	121,500,900		$	133,022,285		$	173,843,975		$	191,897,349
Accumulated undistributed (distributions in excess of) net investment income	$	(1,004,626	)	$	(482,801	)	$	128,287		$	139,843


48		The accompanying notes are an integral part of these financial statements.

COMMERCE FUNDS


Missouri Tax-Free Intermediate Bond Fund						Kansas Tax-Free Intermediate Bond Fund
For the Six Months Ended April 30, 2011 (Unaudited)			For the Fiscal Year Ended October 31, 2010			For the Six Months Ended April 30, 2011 (Unaudited)			For the Fiscal Year Ended October 31, 2010

$	4,594,138		$	8,420,634		$	1,483,674		$	2,646,896
	640,716			507,154			171,144			654,148
	(6,749,910	)		4,912,633			(2,001,373	)		727,425
	(1,515,056	)		13,840,421			(346,555	)		4,028,469



	(4,584,144	)		(8,414,142	)		(1,484,513	)		(2,647,292	)
	(521,922	)		(336,038	)		(653,556	)		(242,550	)
	(5,106,066	)		(8,750,180	)		(2,138,069	)		(2,889,842	)



	34,554,702			80,752,601			13,050,603			21,235,888
	657,246			913,400			335,278			303,525
	(36,142,532	)		(50,644,920	)		(8,031,547	)		(14,488,676	)
	(930,584	)		31,021,081			5,354,334			7,050,737
	(7,551,706	)		36,111,322			2,869,710			8,189,364



	265,798,000			229,686,678			84,066,929			75,877,565
$	258,246,294		$	265,798,000		$	86,936,639		$	84,066,929
$	(80,581	)	$	(90,575	)	$	(65,102	)	$	(64,263	)


The accompanying notes are an integral part of these financial statements.		49

COMMERCE FUNDS

Financial Highlights

Selected Data for a Share Outstanding Throughout Each Period


			Income (loss) from investment operations									Distributions to shareholders
Year	Net asset value, beginning of period		Net investment income^(a)			Net realized and unrealized gain (loss)			Total from investment operations			From net investment income			From net realized gains			Total distributions
GROWTH FUND
For the Six Months Ended April 30, (Unaudited)
2011	$	24.73	$	0.06	^(c)	$	3.31		$	3.37		$	(0.12	)	$	—		$	(0.12	)
For the Fiscal Years Ended October 31,
2010		21.24		0.19	^(c)		3.41			3.60			(0.11	)		—			(0.11	)
2009^(e)		18.44		0.10			2.75			2.85			(0.05	)		—			(0.05	)
2008		29.11		0.05			(10.39	)		(10.34	)		(0.04	)		(0.29	)		(0.33	)
2007		25.56		0.04			3.55			3.59			(0.04	)		—			(0.04	)
2006^(f)		22.56		0.04			3.08			3.12			(0.12	)		—			(0.12	)

VALUE FUND
For the Six Months Ended April 30, (Unaudited)
2011	$	18.91	$	0.17		$	3.39		$	3.56		$	(0.15	)	$	—		$	(0.15	)
For the Fiscal Years Ended October 31,
2010		16.81		0.22			2.10			2.32			(0.22	)		—			(0.22	)
2009^(e)		16.31		0.30			0.50			0.80			(0.30	)		—			(0.30	)
2008		29.02		0.39			(9.84	)		(9.45	)		(0.39	)		(2.87	)		(3.26	)
2007		29.53		0.36			1.90			2.26			(0.36	)		(2.41	)		(2.77	)
2006^(f)		24.96		0.35			4.66			5.01			(0.34	)		(0.10	)		(0.44	)

(a)

Calculated based on the average shares outstanding methodology.

(b)

Assumes investment at the net asset value at the beginning of the period, reinvestment of all dividends and distributions, a complete redemption of the investment at the net asset value at the end of the period and no sales or redemption charges. Total return would be reduced if a sales or redemption charge was taken into account. Returns do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares.

(c)

Reflects income recognized from a special dividend which amounted to $0.02 and $0.13 per share and 0.16% and 0.56% of average net assets for the six months ended April 30, 2011 and the fiscal year ended October 31, 2010.

(d)

Annualized.

(e)

On February 10, 2009, all outstanding Institutional Shares were redesignated as Shares.

(f)

On February 3, 2006, all outstanding Service Shares were converted into Institutional Shares.


50		The accompanying notes are an integral part of these financial statements.

COMMERCE FUNDS



Net asset value, end of period	Total return⁽^b)			Net assets at end of period (in 000s)		Ratio of net expenses to average net assets			Ratio of total expenses to average net assets			Ratio of net investment income to average net assets			Portfolio turnover rate


$27.98		13.68	%	$	137,506		1.13	%^(d)		1.17	%^(d)		0.44	%^(c)(d)		26	%

24.73		16.98			119,567		1.13			1.24			0.82	^(c)		46
21.24		15.55			110,522		1.13			1.20			0.52			39
18.44		(35.82	)		111,319		1.11			1.11			0.18			43
29.11		14.04			223,441		1.13			1.14			0.15			70
25.56		13.86			173,813		1.13			1.18			0.16			47



$22.32		18.88	%	$	57,347		1.03	%^(d)		1.07	%^(d)		1.64	%^(d)		66	%

18.91		13.88			49,932		1.20			1.26			1.24			47
16.81		5.19			63,622		1.20			1.22			1.98			61
16.31		(36.04	)		64,726		1.14			1.14			1.74			45
29.02		8.11			141,455		1.13			1.13			1.25			55
29.53		20.29			120,685		1.18			1.18			1.28			49


The accompanying notes are an integral part of these financial statements.		51

COMMERCE FUNDS

Financial Highlights

Selected Data for a Share Outstanding Throughout Each Period


			Income (loss) from investment operations									Distributions to shareholders
Year	Net asset value, beginning of period		Net investment income (loss)^(a)			Net realized and unrealized gain (loss)			Total from investment operations			From net investment income			From net realized gains			Total distributions
MIDCAP GROWTH FUND
For the Six Months Ended April 30, (Unaudited)
2011	$	31.24	$	(0.03	)^(c)	$	6.07		$	6.04		$	—		$	—		$	—
For the Fiscal Years Ended October 31,
2010		24.06		(0.07	)		7.29			7.22			(0.04	)		—			(0.04	)
2009^(e)		21.13		0.02			3.81			3.83			(0.01	)		(0.89	)		(0.90	)
2008		37.60		0.01			(13.72	)		(13.71	)		—			(2.76	)		(2.76	)
2007		33.61		(0.11	)		4.14			4.03			—			(0.04	)		(0.04	)
2006^(f)		28.45		(0.11	)		5.27			5.16			—			—			—

BOND FUND
For the Six Months Ended April 30, (Unaudited)
2011	$	20.35	$	0.48		$	(0.26	)	$	0.22		$	(0.47	)	$	—		$	(0.47	)
For the Fiscal Years Ended October 31,
2010		19.17		0.93			1.21			2.14			(0.96	)		—			(0.96	)
2009^(e)		17.29		0.96			1.91			2.87			(0.99	)		—			(0.99	)
2008		18.39		0.85			(1.07	)		(0.22	)		(0.88	)		—			(0.88	)
2007		18.12		0.82			0.31	^(g)		1.13			(0.86	)		—			(0.86	)
2006^(f)		18.12		0.78			0.06			0.84			(0.84	)		—			(0.84	)

(a)

Calculated based on the average shares outstanding methodology.

(b)

(c)

Reflects income recognized from non-recurring special dividends which amounted to $0.04 per share and 0.21% of average net assets.

(d)

Annualized.

(e)

On February 10, 2009, all outstanding Institutional Shares were redesignated as Shares.

(f)

On February 3, 2006, all outstanding Service Shares were converted into Institutional Shares.

(g)

Reflects an increase of $0.19 per share and 1.06% of average net assets due in payments received for class action settlements received.

(h)

Total return reflects the impact of payments received for class action settlements received. Excluding such payments, the total return would have been 5.31%.


52		The accompanying notes are an integral part of these financial statements.

COMMERCE FUNDS



Net asset value, end of period	Total return^(b)			Net assets at end of period (in 000s)		Ratio of net expenses to average net assets			Ratio of total expenses to average net assets			Ratio of net investment income (loss) to average net assets			Portfolio turnover rate


$37.28		19.33	%	$	70,045		1.22	%^(d)		1.22	%^(d)		(0.16	)%^(c)(d)		17	%

31.24		30.08			53,380		1.33			1.33			(0.24	)		45
24.06		19.76			48,771		1.33			1.33			0.12			58
21.13		(39.07	)		40,444		1.21			1.21			0.02			57
37.60		12.01			100,357		1.18			1.18			(0.32	)		65
33.61		18.14			91,874		1.22			1.22			(0.35	)		64



$20.10		1.13	%	$	641,572		0.81	%^(d)		0.81	%^(d)		4.80	%^(d)		15	%

20.35		11.46			648,695		0.83			0.83			4.75			26
19.17		17.00			570,560		0.81			0.81			5.23			22
17.29		(1.37	)		495,168		0.79			0.79			4.62			9
18.39		6.37	^(h)		537,430		0.82			0.82			4.50			23
18.12		4.76			548,713		0.85			0.85			4.35			38


The accompanying notes are an integral part of these financial statements.		53

COMMERCE FUNDS

Financial Highlights

Selected Data for a Share Outstanding Throughout Each Period


				Income (loss) from investment operations								Distributions to shareholders
Year	Net asset value, beginning of period			Net investment income^(a)		Net realized and unrealized gain (loss)			Total from investment operations			From net investment income			From net realized gains			Total distributions
SHORT TERM GOVERNMENT FUND
For the Six Months Ended April 30, (Unaudited)
2011	$	18.48		$	0.19	$	(0.17	)	$	0.02		$	(0.27	)	$	—		$	(0.27	)
For the Fiscal Years Ended October 31,
2010		18.16			0.48		0.42			0.90			(0.58	)		—			(0.58	)
2009^(d)		17.53			0.56		0.79			1.35			(0.72	)		—			(0.72	)
2008		17.65			0.66		(0.03	)		0.63			(0.75	)		—			(0.75	)
2007		17.56			0.69		0.16			0.85			(0.76	)		—			(0.76	)
2006^(e)		17.57			0.61		0.11			0.72			(0.73	)		—			(0.73	)
			��
NATIONAL TAX-FREE INTERMEDIATE BOND FUND
For the Six Months Ended April 30, (Unaudited)
2011	$	19.50		$	0.36	$	(0.57	)	$	(0.21	)	$	(0.36	)	$	(0.24	)	$	(0.60	)
For the Fiscal Years Ended October 31,
2010		18.84			0.67		0.71			1.38			(0.67	)		(0.05	)		(0.72	)
2009^(d)		17.82			0.70		1.20			1.90			(0.70	)		(0.18	)		(0.88	)
2008		18.83			0.70		(0.96	)		(0.26	)		(0.70	)		(0.05	)		(0.75	)
2007		19.07			0.71		(0.19	)		0.52			(0.71	)		(0.05	)		(0.76	)
2006^(e)		19.05			0.72		0.13			0.85			(0.73	)		(0.10	)		(0.83	)

(a)

Calculated based on the average shares outstanding methodology.

(b)

(c)

Annualized.

(d)

On February 10, 2009, all outstanding Institutional Shares were redesignated as Shares.

(e)

On February 3, 2006, all outstanding Service Shares were converted into Institutional Shares.


54		The accompanying notes are an integral part of these financial statements.

COMMERCE FUNDS



Net asset value, end of period	Total return^(b)			Net assets at end of period (in 000s)		Ratio of net expenses to average net assets			Ratio of total expenses to average net assets			Ratio of net investment income to average net assets			Portfolio turnover rate


$18.23		0.10	%	$	121,501		0.68	%^(c)		0.88	%^(c)		2.10	%^(c)		9	%

18.48		5.04			133,022		0.68			0.89			2.60			28
18.16		7.85			105,981		0.68			0.93			3.14			25
17.53		3.60			78,455		0.68			0.90			3.68			30
17.65		4.97			87,511		0.68			0.90			3.91			15
17.56		4.21			129,940		0.68			0.89			3.49			28



$18.69		(1.03	)%	$	173,844		0.70	%^(c)		0.84	%^(c)		3.86	%^(c)		22	%

19.50		7.43			191,897		0.70			0.86			3.49			46
18.84		10.89			163,878		0.70			0.85			3.77			27
17.82		(1.47	)		136,575		0.70			0.82			3.76			45
18.83		2.81			145,265		0.70			0.83			3.78			42
19.07		4.57			154,304		0.70			0.88			3.80			42


The accompanying notes are an integral part of these financial statements.		55

COMMERCE FUNDS

Financial Highlights

Selected Data for a Share Outstanding Throughout Each Period


			Income (loss) from investment operations								Distributions to shareholders
Year	Net asset value, beginning of period		Net investment income^(a)		Net realized and unrealized gain (loss)			Total from investment operations			From net investment income			From net realized gains			Total distributions
MISSOURI TAX-FREE INTERMEDIATE BOND FUND
For the Six Months Ended April 30, (Unaudited)
2011	$	19.70	$	0.35	$	(0.46	)	$	(0.11	)	$	(0.34	)	$	(0.04	)	$	(0.38	)
For the Fiscal Years Ended October 31,
2010		19.30		0.66		0.43			1.09			(0.66	)		(0.03	)		(0.69	)
2009^(d)		18.27		0.67		1.05			1.72			(0.67	)		(0.02	)		(0.69	)
2008		19.01		0.69		(0.66	)		0.03			(0.69	)		(0.08	)		(0.77	)
2007		19.22		0.71		(0.19	)		0.52			(0.71	)		(0.02	)		(0.73	)
2006^(e)		19.19		0.74		0.10			0.84			(0.75	)		(0.06	)		(0.81	)

KANSAS TAX-FREE INTERMEDIATE BOND FUND
For the Six Months Ended April 30, (Unaudited)
2011	$	19.32	$	0.33	$	(0.43	)	$	(0.10	)	$	(0.33	)	$	(0.15	)	$	(0.48	)
For the Fiscal Years Ended October 31,
2010		19.05		0.63		0.33			0.96			(0.63	)		(0.06	)		(0.69	)
2009^(d)		17.90		0.63		1.20			1.83			(0.64	)		(0.04	)		(0.68	)
2008		18.58		0.64		(0.63	)		0.01			(0.64	)		(0.05	)		(0.69	)
2007		18.78		0.66		(0.14	)		0.52			(0.66	)		(0.06	)		(0.72	)
2006^(e)		18.75		0.70		0.08			0.78			(0.70	)		(0.05	)		(0.75	)

(a)

Calculated based on the average shares outstanding methodology.

(b)

(c)

Annualized.

(d)

On February 10, 2009, all outstanding Institutional Shares were redesignated as Shares.

(e)

On February 3, 2006, all outstanding Service Shares were converted into Institutional Shares.


56		The accompanying notes are an integral part of these financial statements.

COMMERCE FUNDS



Net asset value, end of period	Total return^(b)			Net assets at end of period (in 000s)		Ratio of net expenses to average net assets			Ratio of total expenses to average net assets			Ratio of net investment income to average net assets			Portfolio turnover rate


$19.21		(0.51	)%	$	258,246		0.70	%^(c)		0.84	%^(c)		3.65	%^(c)		8	%

19.70		5.72			265,798		0.70			0.84			3.37			19
19.30		9.54			229,687		0.70			0.83			3.50			10
18.27		0.10			169,838		0.70			0.81			3.63			7
19.01		2.77			148,824		0.68			0.82			3.74			21
19.22		4.48			159,628		0.65			0.88			3.87			15



$18.74		(0.49	)%	$	86,937		0.70	%^(c)		0.90	%^(c)		3.58	%^(c)		12	%

19.32		5.15			84,067		0.70			0.94			3.31			23
19.05		10.33			75,878		0.70			0.93			3.38			16
17.90		0.01			68,986		0.70			0.90			3.46			13
18.58		2.82			69,270		0.68			0.92			3.55			18
18.78		4.28			69,075		0.65			0.98			3.75			33


The accompanying notes are an integral part of these financial statements.		57

COMMERCE FUNDS

Notes to Financial Statements

April 30, 2011 (Unaudited)


1. ORGANIZATION

The Commerce Funds (the “Trust”) are a Delaware statutory trust registered under the Investment Company Act of 1940, as amended (the “1940 Act”), as an open-end, management investment company. The Trust consists of eight portfolios (individually, a “Fund” and collectively, the “Funds”): the Growth Fund, Value Fund, MidCap Growth Fund, Bond Fund, Short-Term Government Fund, National Tax-Free Intermediate Bond Fund, Missouri Tax-Free Intermediate Bond Fund and Kansas Tax-Free Intermediate Bond Fund. Each of the Funds offers one class of shares (the “Shares”). Each Fund is registered as a diversified open-end management investment company, other than the Missouri Tax-Free Intermediate Bond Fund and the Kansas Tax-Free Intermediate Bond Fund, which are registered as non-diversified under the 1940 Act.

The Funds have entered into an Advisory Agreement with Commerce Investment Advisors, Inc. (the “Adviser” or “Commerce”), a subsidiary of Commerce Bank (“Commerce Bank”).


2. SIGNIFICANT ACCOUNTING POLICIES

The following is a summary of the significant accounting policies consistently followed by the Funds. The preparation of financial statements in conformity with accounting principles generally accepted in the United States of America (“GAAP”) requires management to make estimates and assumptions that may affect the amounts and disclosures in the financial statements. Actual results could differ from those estimates and assumptions.

A. Investment Valuation — The investment valuation policy of the Funds is to value investments at market value. Investments in equity securities and investment companies traded on a United States (“U.S.”) securities exchange or the NASDAQ system are valued daily at their last sale price or official closing price on the principal exchange or system on which they are traded. If no sale occurs, such securities and investment companies are valued at the last bid price. Debt securities for which market quotations are readily available are valued on the basis of quotations furnished by an independent pricing service or provided by securities dealers. The pricing services may use valuation models or matrix pricing, which considers yield or price with respect to comparable bonds, quotations from bond dealers or by reference to other securities that are considered comparable in such characteristics as rating, interest rate and maturity date, to determine current value. Unlisted equity securities for which market quotations are available are valued at the last sale price on valuation date, or if no sale occurs, at the last bid price. In the absence of market quotations, broker quotes will be utilized or the security will be fair valued. Investments in investment companies (other than those that are exchange traded) are valued at the net asset value per share (“NAV”) of the investment company on the valuation date. Short-term debt obligations that mature in sixty days or less and that do not exhibit signs of credit deterioration are valued at amortized cost, which approximates market value.

Securities for which market quotations are not readily available or are deemed not to reflect market value by the Adviser are valued at fair value using methods approved by the Board of Trustees.

B. Security and Fund Share Transactions, and Investment Income — Security and Fund share transactions are reflected for financial reporting purposes as of the trade date, which may cause the NAV as stated in the accompanying financial statements to be different than the NAV applied to Fund share transactions. Realized gains and losses on sales of portfolio securities are calculated using the identified cost basis. Dividend income is recognized on the ex-dividend date. Interest income is recorded on the basis of interest accrued, premium amortized and discount accreted. Certain mortgage security paydown gains and losses are included in interest income in the accompanying Statements of Operations. Market discounts, original issue discount and market premiums on debt securities are accreted/amortized to interest income over the life of the security with a corresponding adjustment in the cost basis of that security.

In addition, distributions received from the Funds’ investments in U.S. real estate investment trusts (“REITs”) often include a “return of capital”, which is recorded by the Funds as a reduction of the cost basis of the securities held. The Internal Revenue Code of 1986, as amended (the “Code”) requires a REIT to distribute at least 95% of its taxable income to investors.

COMMERCE FUNDS


2. SIGNIFICANT ACCOUNTING POLICIES (continued)

In many cases, however, because of “non-cash” expenses such as property depreciation, a REIT’s cash flow will exceed its taxable income. The REIT may distribute this excess cash to offer a more competitive yield. This portion of the Funds’ distributions is deemed a return of capital and is generally not taxable to shareholders.

C. Expenses — Expenses incurred by the Trust that do not specifically relate to an individual Fund of the Trust are allocated to the Funds based on each Fund’s relative average net assets and are accrued daily.

D. Federal Taxes and Distributions to Shareholders — It is each Fund’s policy to comply with the requirements of the Code, applicable to regulated investment companies (mutual funds) and to distribute each year substantially all of its investment company taxable income and capital gains to its shareholders. Accordingly, the Funds are not required to make any provisions for the payment of federal income tax. Distributions to shareholders are recorded on the ex-dividend date. Income and capital gains distributions, if any, are declared and paid according to the following schedule:


	Income Distribution		Capital Gains Distribution
Fund	Declared	Paid	Declared	Paid
Value	Quarterly	Quarterly	Annually	Annually
Growth and MidCap Growth	Annually	Annually	Annually	Annually
Bond, Short-Term Government, National Tax-Free Intermediate Bond, Missouri Tax-Free Intermediate Bond and Kansas Tax-Free Intermediate Bond	Daily	Monthly	Annually	Annually

Net capital losses are carried forward to future fiscal years and may be used to the extent allowed by the Code to offset any future capital gains. Utilization of capital loss carryforwards will reduce the requirement of future capital gains distributions.

The characterization of distributions to shareholders for financial reporting purposes is determined in accordance with federal income tax rules, which may differ from GAAP. The source of each Fund’s distributions may be shown in the accompanying financial statements as from net investment income, net realized gain or capital. Certain components of the Funds’ net assets on the Statements of Assets and Liabilities reflect permanent GAAP/tax differences based on the appropriate tax character.

E. Repurchase Agreements — The Funds may enter into repurchase agreements. Repurchase agreements involve the purchase of securities subject to the seller’s agreement to repurchase the securities at a mutually agreed upon date and price. During the term of a repurchase agreement, the value of the underlying securities held as collateral on behalf of the Funds, including accrued interest, is required to exceed the value of the repurchase agreement, including accrued interest. If the seller defaults or becomes insolvent, realization of the collateral by the Funds may be delayed or limited and there may be a decline in the value of the collateral during the period while the Funds seek to assert their rights. The underlying securities for all repurchase agreements are held in safekeeping at the Funds’ custodian.

3. FAIR VALUE OF INVESTMENTS

The fair value of a financial instrument is the amount that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date (i.e., the exit price). GAAP establishes a fair value hierarchy that prioritizes the inputs to valuation techniques used to measure fair value. The hierarchy gives the highest priority

COMMERCE FUNDS

Notes to Financial Statements (continued)

April 30, 2011 (Unaudited)


3. FAIR VALUE OF INVESTMENTS (continued)

to unadjusted quoted prices in active markets for identical assets or liabilities (Level 1 measurements) and the lowest priority to unobservable inputs (Level 3 measurements). The three levels of the fair value hierarchy are described below:

Level 1 — Unadjusted quoted prices in active markets that are accessible at the measurement date for identical, unrestricted assets or liabilities;

Level 2 — Quoted prices in markets that are not active or financial instruments for which significant inputs are observable (including, but not limited to, quoted prices for similar securities, interest rates, prepayment speeds and credit risk), either directly or indirectly;

Level 3 — Prices or valuations that require significant unobservable inputs (including the Adviser’s assumptions in determining fair value measurement).

The following is a summary of the Funds’ investments categorized in the fair value hierarchy as of April 30, 2011:


GROWTH
Investment Type	Level 1		Level 2		Level 3
Assets
Common Stock and/or Other Equity Investments	$	135,067,267	$	—	$	—
Short-term Investment		—		2,509,000		—
Total	$	135,067,267	$	2,509,000	$	—

VALUE Investment Type	Level 1		Level 2		Level 3
Assets
Common Stock and/or Other Equity Investments	$	55,634,307	$	—	$	—
Short-term Investment		—		1,657,000		—
Total	$	55,634,307	$	1,657,000	$	—

MIDCAP GROWTH Investment Type	Level 1		Level 2		Level 3
Assets
Common Stock and/or Other Equity Investments	$	69,848,520	$	—	$	—
Short-term Investment		—		338,000		—
Total	$	69,848,520	$	338,000	$	—

BOND Investment Type	Level 1		Level 2		Level 3
Assets
Fixed Income
Asset-Backed Securities	$	—	$	57,298,249	$	—
Taxable Municipal Bond Obligations		—		78,971,745		—
Mortgage-Backed Obligations		—		200,730,166		—
Corporate Obligations		—		175,437,938		—
U.S. Treasury Obligations and/or Other U.S. Government Agencies		15,322,877		91,569,828		—
Government Guarantee Obligations		—		3,062,910		—
Investment Company		4,776,552		—		—
Short-term Investment		—		13,594,000		—
Total	$	20,099,429	$	620,664,836	$	—

COMMERCE FUNDS


3. FAIR VALUE OF INVESTMENTS (continued)



SHORT-TERM GOVERNMENT Investment Type	Level 1		Level 2		Level 3
Assets
Fixed Income
Asset-Backed Securities	$	—	$	1,934,729	$	—
Mortgage-Backed Obligations		—		32,848,886		—
Government Guarantee Obligations		—		7,544,032		—
U.S. Treasury Obligations and/or Other U.S. Government Agencies		15,945,374		62,209,951		—
Short-term Investment		—		825,000		—
Total	$	15,945,374	$	105,362,598	$	—

NATIONAL TAX-FREE INTERMEDIATE BOND Investment Type	Level 1		Level 2		Level 3
Assets
Fixed Income
Municipal Bond Obligations	$	—	$	171,655,793	$	—
Short-term Investment		—		1,939,000		—
Total	$	—	$	173,594,793	$	—

MISSOURI TAX-FREE INTERMEDIATE BOND Investment Type	Level 1		Level 2		Level 3
Assets
Fixed Income
Municipal Bond Obligations	$	—	$	251,552,146	$	—
Short-term Investment		—		5,478,000		—
Total	$	—	$	257,030,146	$	—

KANSAS TAX-FREE INTERMEDIATE BOND Investment Type	Level 1		Level 2		Level 3
Assets
Fixed Income
Municipal Bond Obligations	$	—	$	86,023,750	$	—


4. AGREEMENTS AND OTHER AFFILIATED TRANSACTIONS

A. Advisory Agreement — Pursuant to the terms of the Advisory Agreement, the Adviser is responsible for managing the investments and making investment decisions for each of the Funds. For these services and for assuming related expenses, the Adviser is entitled to a fee, accrued daily and payable monthly, at the contractual annual rate of the corresponding Fund’s average daily net assets. The contractual annual rate is 0.75% for the Growth and MidCap Growth Funds and 0.50% for the Bond, Short-Term Government, National Tax-Free Intermediate Bond, Missouri Tax-Free Intermediate Bond and Kansas Tax-Free Intermediate Bond Funds, respectively. Effective March 1, 2011, the Adviser entered into a Fee Reduction Agreement to reduce the Value Fund’s contractual advisory fee annual rate from 0.75% to 0.30%. The effective advisory fee for the Value Fund for the six months ended April 30, 2011 was 0.59%.

B. Administration Agreements — Goldman Sachs Asset Management, L.P. (“GSAM”), an affiliate of Goldman, Sachs & Co. (“Goldman Sachs”), and Commerce, serve as Co-Administrators of the Trust pursuant to a Co-Administration Agreement. Under the Co-Administration Agreement, GSAM and Commerce administer the Trust’s business affairs. As compensation for the services rendered under the Co-Administration Agreement, GSAM and Commerce are entitled to a fee, accrued daily and

COMMERCE FUNDS

Notes to Financial Statements (continued)

April 30, 2011 (Unaudited)


4. AGREEMENTS AND OTHER AFFILIATED TRANSACTIONS (continued)

payable monthly, at the contractual annual rate of the corresponding Fund’s average daily net assets. Pursuant to the Co-Administration Agreement, the Funds will pay an aggregate administrative fee at the annual rate of 0.15%, allocated as follows: (1) for each Fund, GSAM is entitled to receive 0.03% of each Fund’s average daily net assets; and (2) for each Fund, Commerce is entitled to receive 0.12% of each Fund’s average daily net assets.

C. Other Agreements — The Adviser has contractually agreed to waive fees and/or reimburse expenses (excluding interest, taxes and extraordinary expenses exclusive of any custody expense reductions for all Funds (other than the Mid Cap Growth Fund)) to the extent that such expenses exceeded, on an annualized basis, 1.13%, 0.70% (effective March 1, 2011), 0.88%, 0.68%, 0.70%, 0.70% and 0.70% of the average net assets of the Growth, Value, Bond, Short-Term Government, National Tax-Free Intermediate Bond, Missouri Tax-Free Intermediate Bond and Kansas Tax-Free Intermediate Bond Funds, respectively. Prior to March 1, 2011, the Adviser had contractually agreed to waive fees and/or reimburse expenses to 1.20% for the value Fund. In addition, the Funds are not obligated to reimburse the Adviser for prior fiscal year expense reimbursements, if any. Such expense reimbursements, if any, are accrued daily and paid monthly and are disclosed in the Statements of Operations for the six months ended April 30, 2011.

Pursuant to a Shareholder Administrative Services Plan adopted by its Board of Trustees, the Funds may enter into agreements with service organizations, such as banks and financial institutions, which include affiliates of the Adviser (“Service Organizations”), under which they will render shareholder administration support services. For these services, the Service Organizations are entitled to receive fees from each Fund at an annual rate of up to 0.25% of the average daily net asset value of Fund shares beneficially owned by clients of such Service Organizations. For the six months ended April 30, 2011, Commerce Bank has received $359,487 in shareowner servicing fees.

D. Deferred Compensation Plan — Certain Trustees participate in a Deferred Compensation Plan, as amended and restated (the “Plan”), which allows eligible non-affiliated Trustees as described in the Plan to defer the receipt of all or a portion of the Trustees’ fees payable. Under the Plan, such Trustees have deferred fees treated as if they had been invested by The Commerce Funds in the shares of one or more Funds of the Trust. All amounts payable to the Trustees under the Plan are determined based on the performance of such Funds and are accrued quarterly.


5. PORTFOLIO SECURITIES TRANSACTIONS

The cost of purchases and proceeds from sales and maturities of long-term securities for the six months ended April 30, 2011, were as follows:


Fund	Purchases of U.S. Government and Agency Obligations		Purchases (Excluding U.S. Government and Agency Obligations)		Sales and Maturities of U.S. Government and Agency Obligations		Sales and Maturities (Excluding U.S. Government and Agency Obligations)
Growth	$	—	$	33,376,515	$	—	$	33,490,304
Value		—		34,056,872		—		36,717,164
MidCap Growth		—		16,198,805		—		10,573,444
Bond		23,792,820		69,945,924		40,038,298		57,291,213
Short-Term Government		6,516,311		5,009,347		12,503,495		4,232,801
National Tax-Free Intermediate Bond		—		38,070,392		—		51,076,199
Missouri Tax-Free Intermediate Bond		—		19,950,965		—		25,763,617
Kansas Tax-Free Intermediate Bond		—		14,481,252		—		9,488,398

COMMERCE FUNDS


6. TAX INFORMATION

As of the Funds’ most recent fiscal year ended, October 31, 2010, the Funds’ capital loss carryforwards and certain timing differences on a tax basis were as follows:


	Growth			Value			MidCap Growth			Bond
Capital loss carryforward:⁽¹⁾
Expiring 2012	$	—		$	—		$	—		$	(2,391,657	)
Expiring 2013		—			—			—			(540,238	)
Expiring 2014		—			—			—			(3,576,948	)
Expiring 2016		—			(4,798,672	)		—			—
Expiring 2017		(10,176,163	)		(11,694,039	)		(1,701,305	)		—
Expiring 2018		—			(1,344,255	)		—			—
Total capital loss carryforward:	$	(10,176,163	)	$	(17,836,966	)	$	(1,701,305	)	$	(6,508,843	)
Timing differences (income distributions, deferred compensation)	$	(26,881	)	$	(21,976	)	$	(16,259	)	$	(2,215,335	)

	Short-Term Government			National Tax-Free Intermediate Bond			Missouri Tax-Free Intermediate Bond			Kansas Tax-Free Intermediate Bond
Capital loss carryforward:⁽¹⁾
Expiring 2011	$	(2,174,462	)	$	—		$	—		$	—
Expiring 2012		(3,771,248	)		—			—			—
Expiring 2013		(2,538,488	)		—			—			—
Expiring 2014		(2,653,199	)		—			—			—
Expiring 2015		(1,094,544	)		—			—			—
Expiring 2016		(347,228	)		—			—			—
Expiring 2017		(400,692	)		—			—			—
Expiring 2018		(460,436	)		—			—			—
Total capital loss carryforward:	$	(13,440,297	)	$	—		$	—		$	—
Timing differences (income distributions, deferred compensation)	$	(237,078	)	$	(562,085	)	$	(707,836	)	$	(224,933	)

⁽¹⁾

Expiration occurs on October 31 of the year indicated.

As of April 30, 2011, the Funds’ aggregate security unrealized gains and losses based on cost for U.S. federal income tax purposes were as follows:


	Growth			Value			MidCap Growth			Bond
Tax Cost	$	116,407,865		$	53,602,707		$	51,205,736		$	598,927,732
Gross unrealized gain		25,655,978			5,296,819			19,422,593			50,121,797
Gross unrealized loss		(4,487,576	)		(1,608,219	)		(441,809	)		(8,285,264	)
Net unrealized security gain	$	21,168,402		$	3,688,600		$	18,980,784		$	41,836,533

COMMERCE FUNDS

Notes to Financial Statements (continued)

April 30, 2011 (Unaudited)


6. TAX INFORMATION (continued)


	Short-Term Government			National Tax-Free Intermediate Bond			Missouri Tax-Free Intermediate Bond			Kansas Tax-Free Intermediate Bond
Tax Cost	$	117,795,618		$	172,137,254		$	252,511,414		$	84,680,094
Gross unrealized gain		4,496,948			3,478,253			6,739,602			2,156,863
Gross unrealized loss		(984,594	)		(2,020,714	)		(2,220,870	)		(813,207	)
Net unrealized security gain	$	3,512,354		$	1,457,539		$	4,518,732		$	1,343,656

The difference between GAAP-basis and tax-basis unrealized gains (losses) is primarily attributable to wash sales, differences in the tax treatment of market discount accretion and premium amortization.

GSAM and Commerce have reviewed the Funds’ tax positions for all open tax years (the current and prior three fiscal years) and have concluded that no provision for income tax is required in the Funds’ financial statements. Such open tax years remain subject to examination and adjustment by tax authorities.

Under the recently enacted Regulated Investment Company Modernization Act of 2010, the Funds will be permitted to carry forward capital losses incurred in taxable years beginning after December 22, 2010 for an unlimited period. However, any losses incurred during those future taxable years will be required to be utilized prior to the losses incurred in pre-enactment taxable years. As a result of this ordering rule, pre-enactment capital loss carryforwards may be more likely to expire unused. Additionally, post-enactment capital losses that are carried forward will retain their character as either short-term or long term capital losses rather than being considered all short-term as under previous law.

7. OTHER RISKS

Market and Credit Risks — In the normal course of business, the Funds trade financial instruments and enter into financial transactions where risk of potential loss exists due to changes in the market (market risk). Additionally, the Funds may also be exposed to credit risk in the event that an issuer fails to perform or that an institution or entity with which the Funds have unsettled or open transaction defaults.

Portfolio Concentrations — As a result of the Missouri Tax-Free Intermediate Bond and Kansas Tax-Free Intermediate Bond Funds’ ability to invest a large percentage of their assets in obligations of issuers within certain states, they are subject to possible concentration risks associated with economic, political or legal developments or industrial or regional matters specifically affecting such states.

Under normal market conditions, the Missouri Tax-Free Intermediate Bond Fund and the Kansas Tax-Free Intermediate Bond Fund invest at least 80% of their assets plus any borrowings for investment purposes (measured at the time of purchase) in Missouri and Kansas municipal securities, respectively, the income from which, in the opinion of bond counsel, is exempt from regular federal income tax, federal alternative minimum taxes and Missouri and Kansas state taxes, respectively. For each of the Missouri and Kansas Tax-Free Funds, the actual payment of principal and interest on Missouri and Kansas municipal securities is dependent on the Missouri General Assembly and the Kansas legislature, respectively, allotting money each fiscal year for these payments.

The investments of the Growth Fund may be concentrated in securities of technology companies. The Mid-Cap Growth Fund concentrates in mid-cap stocks. Investing in mid-sized companies may be riskier than investing in larger, more established companies. At times, securities of technology companies may experience significant price fluctuations.

The Bond and Short-Term Government Funds may invest 80% and 100%, respectively, of their total assets in mortgage and asset-related securities and the Bond Fund may invest 80% of its total assets in asset-backed securities. Mortgage-backed securities, especially collateralized mortgage-backed securities, may be subject to risks that include price volatility, liquidity, and enhanced sensitivity to interest rates. As a result, mortgage-backed securities may be more difficult to value and liquidate, if

COMMERCE FUNDS


7. OTHER RISKS (continued)

necessary. Mortgage-backed securities are also subject to prepayment risk, which may result in a decreased rate of return and a decline in the value of the securities. Asset-backed securities are dependent upon payment of the underlying consumer loans or receivables by individuals, and the certificate holder frequently has no recourse against the entity that originated the loans or receivables. Asset-backed securities have a greater risk of default during periods of economic downturn than other securities. Also, asset-backed securities may be less liquid than other securities and therefore more difficult to value and liquidate, if necessary.

8. INDEMNIFICATIONS

Under the Trust’s organizational documents, its trustees, officers, employees and agents are indemnified, to the extent permitted by the Act, against certain liabilities that may arise out of performance of their duties to the Funds. Additionally, in the course of business, the Funds enter into contracts that contain a variety of indemnification clauses. The Funds’ maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Funds that have not yet occurred. However, Commerce and GSAM believe the risk of loss under these arrangements to be remote.

9. OTHER MATTERS

Approval of Advisory Agreement — The Trustees oversee the management of the Trust, and review the investment performance and expenses of the Funds at regularly scheduled meetings held during the Funds’ fiscal year. In addition, the Trustees determine annually whether to reapprove and continue the Trust’s investment advisory agreement (“Advisory Agreement”) with the Adviser (also referred to as “Commerce”) for the Funds.

The Advisory Agreement for the Funds was most recently approved by the Trustees, including all of the Trustees who are not parties to the Advisory Agreement or “interested persons” (as such term is defined in the 1940 Act) of any party thereto (the “non-interested Trustees”), on November 18, 2010 (the “Annual Contract Meeting”).

Prior to the Annual Contract Meeting, the Board of Trustees received written materials provided by the Adviser relating to the Trustees’ consideration of the Advisory Agreement. At the Annual Contract Meeting, the Trustees also received and considered the Adviser’s oral presentations and discussed the information that had been provided. In connection with their deliberations, the Trustees were advised by their independent legal counsel regarding their responsibilities under applicable law and met separately in executive session with independent counsel without members of management present.

In evaluating the Advisory Agreement, the Trustees relied upon their knowledge, resulting from their meetings and other interactions throughout the year, of the Adviser and its services and personnel. Both in meetings specifically dedicated to the review of the Advisory Agreement and meetings held during the year, the Trustees reviewed materials relating to the Adviser’s investment management services. Specifically, the Trustees reviewed, among other things, information relating to: (i) the terms of the Advisory Agreement; (ii) the Funds’ investment performance over different time periods in comparison to the investment performance of mutual fund peer categories selected by Lipper Inc. (“Lipper”), a third-party provider of mutual fund data; (iii) the contractual investment advisory fees, the actual investment advisory fees (after expense reimbursements) and the total expenses borne by the Funds in comparison to those borne by mutual fund peer groups selected by Lipper; (iv) the Adviser’s staffing for the Funds and the experience of the portfolio managers; (v) the scope and depth of the Adviser’s resources and their ability to attract and retain portfolio management investment talent; (vi) the fees paid by the Funds to the Adviser and its affiliates for services, and the expenses incurred by them in connection with the provision of those services, the profitability of the Advisory Agreement to the Adviser, and a comparison of the Adviser’s profitability with that of other publicly reported profitability information of other advisers; (vii) the fall out benefits received by the Adviser and its affiliates from their relationships with the Funds; (viii) information about fees charged to institutional accounts for which an affiliate of the Adviser, Commerce Trust Company (“CTC”) was performing services similar to those performed for the Funds; and (ix) potential economies of scale.

COMMERCE FUNDS

Notes to Financial Statements (continued)

April 30, 2011 (Unaudited)


9. OTHER MATTERS (continued)

In connection with their approval of the Advisory Agreement for each of the Funds, the Trustees gave weight to various factors, but did not identify any single factor as controlling their decision. As part of their review, the Trustees considered the following factors:

Nature, quality and extent of services – The Trustees reviewed the nature, quality and extent of services of the Adviser to the Funds, taking into account the investment objectives and strategies of each Fund and knowledge gained from meetings with management, which were held on at least a quarterly basis. The Trustees also considered the available resources and key investment personnel of the Adviser and their experience and length of service to the Funds. The Trustees also discussed the Adviser’s reports to the Board, compliance record and effectiveness of oversight over the Funds’ other service providers, communications and support services to shareholders, service as the Funds’ co-administrator, adherence to investment policies, execution of portfolio transactions and selection of broker dealers and other similar factors.

The Trustees determined that the Adviser had invested in the Funds and provided a seasoned and experienced portfolio management and compliance staff. Moreover, they considered that the Adviser had a highly disciplined money management and research and analytic process and was able to attract and retain high quality personnel. The Trustees also considered that the Adviser had provided clear, concise reports to the Board and updated the Trustees frequently on issues of current interest. They concluded that the Adviser had an excellent compliance record and had provided strong oversight over the other service providers to the Funds. Finally, the Trustees considered that the Adviser and its affiliates had other client relationships with most of the shareholders and provided them with other services through these relationships. The Trustees concluded that the Funds would therefore benefit from the Adviser’s continued service to them.

Performance of the Funds – The Trustees considered both the short-term and long-term performance of the Funds. They reviewed and discussed the Lipper information presented, which compared each Fund’s performance with performance of comparable funds and peer groups identified by Lipper. They asked a number of questions with respect to how the Lipper peer groups were constructed, all of which were addressed by the co-administrators and Adviser. The Trustees also considered performance versus each Fund’s benchmark. The Trustees determined that the Fixed Income Funds were generally competitive with their Lipper peers for the one- and three-year periods, with all Fixed Income Funds being in or near to the first quartile of their Lipper peers for the three-year period. The Trustees considered that this outperformance was particularly significant given that the Fixed Income Funds generally take on less risk than other similar competing funds. The Trustees also considered performance versus the Funds’ benchmarks, noting that the Bond Fund outperformed is benchmark for the one- and three-year time periods, the Short-Term Government and National Intermediate Bond Fund had more mixed performance versus their benchmarks and the other Tax-Free Funds had under performed their benchmarks. The Trustees considered, however, that the Missouri and Kansas Tax-Free Intermediate Bond Funds tracked benchmarks that were not necessarily reflective of their concentrated state holdings.

The Trustees also considered the Equity Funds’ performance. They concluded that the Growth and Mid-Cap Growth Funds had generally competitive performance with their Lipper peers for the one- and three-year time periods. They concluded that the Value Fund had under performed during these same periods but that the Adviser was considering and discussing with the Trustees changes in order to improve performance of the Fund. The Trustees also considered performance versus the Funds’ benchmarks, noting that the Growth and Value Funds had under performed their benchmarks for the one- and three-year periods, while the Mid-Cap Growth Fund had outperformed its benchmark for the same periods.

The Trustees also reviewed and evaluated information prepared by Lipper that compared each Fund’s performance with its expenses. The Trustees noted that each Fund’s performance versus expense levels was satisfactory given the level of assets in the Funds; however the Value Fund’s comparison of performance versus assets was not as favorable. The Trustees noted that the Adviser was working on a plan to address both performance and expense issues.

COMMERCE FUNDS


9. OTHER MATTERS (continued)

The Trustees concluded that while past performance is not necessarily indicative of future performance, the majority of the Funds had satisfactory performance and that the Adviser was taking steps to address the Value Fund’s performance. They also concluded that Fund shareholders were generally receiving value for the services provided by the Adviser.

Costs of Services and Profits Realized by the Adviser – The Board considered the fees and expenses of the Funds and the Lipper information provided comparing the Funds’ fees to Lipper peers. It was noted that the Funds’ advisory fees, except the Kansas Tax-Free Intermediate Bond Fund, were higher than the average advisory fees for comparable funds and that total net operating expenses were between four to nine basis points higher than the average, except for the Growth Fund, which was below the average for net operating expenses. The Trustees considered this information in light of the Adviser’s cost of providing advisory services as well as its profitability. It was noted that the Adviser’s costs had increased in the past year and that profitability had also increased by a small margin; it was also noted that the Adviser’s cost allocation methodology had not changed and had previously been reviewed by the Funds’ auditors for reasonableness. The Trustees also discussed that the Adviser appeared to have a rigorous and consistent program in place to control Fund expenses and had instituted requests for proposals and negotiated fees aggressively with other service providers when appropriate. The Trustees considered the Adviser’s profitability in light of the profitability of other investment advisers’ publicly-reported profitability margins. The Trustees considered the differences in the scale, lines of business, operations, products offered and other differences with regard to the investment advisers included in the profitability comparison.

The Trustees also considered the information provided on the Adviser’s advisory fees compared to advisory fees charged to similar institutional accounts managed by Commerce personnel. There were no comparable institutional accounts with the three Tax-Free Funds. These accounts were not managed by the Adviser but by its affiliate, but some of the same Fund investment personnel provided these advisory services. In some cases, the fees charged were lower than the fees charged to the Funds and in other cases the fees were about the same. The Trustees noted that the Adviser provides significant additional services for the Funds that its affiliate does not provide to non-mutual fund clients, including administrative services, oversight of the Funds’ other service providers, Trustee support, regulatory compliance and numerous other services, and that in servicing the Funds, the Adviser assumes many legal risks that its affiliate does not assume in servicing many of its similar clients.

Economies of Scale – The Trustees determined after review of the financial reports that the Funds had not achieved sufficient size and scale to institute breakpoints. In addition, the Trustees considered that the Adviser was managing its operations in a manner that was as efficient as possible under the circumstance of more or less static assets, with a view to keeping shareholder expense ratios as low as possible.

Fall-Out Benefits – The principal benefits to the Adviser of its relationship with the Funds are its receipt of soft dollars and its contract as a Co-Administrator of the Funds. The Trustees considered that they receive regular, extensive quarterly reports on the Adviser’s soft dollar program and that its program is in compliance with Section 28(e) of the Securities Exchange Act of 1934. They also considered that the Adviser had a system in place to test for best execution, which was also reviewed with the Board on at least an annual basis. In summary, the Trustees concluded that the Adviser and Funds were benefitting from the soft dollar products and services. With respect to the Co-Administration Agreement, the Trustees noted that they review that agreement annually using substantially the same review framework as the Advisory Agreement. The Trustees believed that Commerce was providing satisfactory services to shareholders under that agreement for reasonable rates.

After deliberation, the Trustees concluded at the Annual Contract Meeting with respect to all of the Funds, that the fees paid by Funds were reasonable in light of the services provided by the Adviser, its costs and the Funds’ current and reasonably foreseeable asset levels, and that the Advisory Agreement should be approved and continued.

COMMERCE FUNDS

Notes to Financial Statements (continued)

April 30, 2011 (Unaudited)


10. SUBSEQUENT EVENTS

Subsequent events after the balance sheet date have been evaluated through the date the financial statements were issued and Commerce and GSAM have concluded that there is no impact requiring adjustment or disclosure in the financial statements.


11. SUMMARY OF SHARE TRANSACTIONS

Share activity is as follows:


	Growth Fund
	For the Six Months Ended April 30, 2011 (Unaudited)						For the Fiscal Year Ended October 31, 2010
	Shares			Dollars			Shares			Dollars
Shares sold		540,591		$	14,311,496			616,040		$	14,117,639
Reinvestment of distributions		9,336			243,853			9,915			231,828
Shares redeemed		(471,408	)		(12,465,467	)		(995,250	)		(23,120,014	)
Net Increase (Decrease)		78,519		$	2,089,882			(369,295	)	$	(8,770,547	)


	Value Fund
	For the Six Months Ended April 30, 2011 (Unaudited)						For the Fiscal Year Ended October 31, 2010
	Shares			Dollars			Shares			Dollars
Shares sold		297,940		$	6,194,111			564,117		$	10,092,891
Reinvestment of distributions		3,749			77,581			8,717			159,149
Shares redeemed		(372,537	)		(7,591,554	)		(1,717,652	)		(31,176,821	)
Net Decrease		(70,848	)	$	(1,319,862	)		(1,144,818	)	$	(20,924,781	)


	MidCap Growth Fund
	For the Six Months Ended April 30, 2011 (Unaudited)						For the Fiscal Year Ended October 31, 2010
	Shares			Dollars			Shares			Dollars
Shares sold		306,223		$	10,477,610			141,993		$	3,943,245
Reinvestment of distributions		—			—			660			17,725
Shares redeemed		(135,849	)		(4,785,755	)		(461,310	)		(12,674,320	)
Net Increase (Decrease)		170,374		$	5,691,855			(318,657	)	$	(8,713,350	)


	Bond Fund
	For the Six Months Ended April 30, 2011 (Unaudited)						For the Fiscal Year Ended October 31, 2010
	Shares			Dollars			Shares			Dollars
Shares sold		3,733,671		$	74,531,765			7,088,103		$	139,473,917
Reinvestment of distributions		147,095			2,943,887			269,514			5,321,497
Shares redeemed		(3,843,093	)		(76,670,312	)		(5,232,442	)		(103,304,905	)
Net Increase		37,673		$	805,340			2,125,175		$	41,490,509

COMMERCE FUNDS


11. SUMMARY OF SHARE TRANSACTIONS (continued)


	Short-Term Government Fund
	For the Six Months Ended April 30, 2011 (Unaudited)						For the Fiscal Year Ended October 31, 2010
	Shares			Dollars			Shares			Dollars
Shares sold		1,036,445		$	18,899,084			3,529,360		$	64,398,029
Reinvestment of distributions		31,341			571,713			63,425			1,160,258
Shares redeemed		(1,601,379	)		(29,241,142	)		(2,229,565	)		(40,679,699	)
Net Increase (Decrease)		(533,593	)	$	(9,770,345	)		1,363,220		$	24,878,588


	National Tax-Free Intermediate Bond Fund
	For the Six Months Ended April 30, 2011 (Unaudited)						For the Fiscal Year Ended October 31, 2010
	Shares			Dollars			Shares			Dollars
Shares sold		884,307		$	16,374,672			2,410,272		$	46,150,365
Reinvestment of distributions		28,570			536,769			11,631			222,529
Shares redeemed		(1,455,758	)		(26,951,287	)		(1,279,385	)		(24,523,400	)
Net Increase (Decrease)		(542,881	)	$	(10,039,846	)		1,142,518		$	21,849,494


	Missouri Tax-Free Intermediate Bond Fund
	For the Six Months Ended April 30, 2011 (Unaudited)						For the Fiscal Year Ended October 31, 2010
	Shares			Dollars			Shares			Dollars
Shares sold		1,811,286		$	34,554,702			4,142,096		$	80,752,601
Reinvestment of distributions		34,363			657,246			46,781			913,400
Shares redeemed		(1,895,408	)		(36,142,532	)		(2,595,547	)		(50,644,920	)
Net Increase (Decrease)		(49,759	)	$	(930,584	)		1,593,330		$	31,021,081


	Kansas Tax-Free Intermediate Bond Fund
	For the Six Months Ended April 30, 2011 (Unaudited)						For the Fiscal Year Ended October 31, 2010
	Shares			Dollars			Shares			Dollars
Shares sold		702,003		$	13,050,603			1,107,510		$	21,235,888
Reinvestment of distributions		17,910			335,278			15,826			303,525
Shares redeemed		(432,479	)		(8,031,547	)		(756,113	)		(14,488,676	)
Net Increase		287,434		$	5,354,334			367,223		$	7,050,737

COMMERCE FUNDS

Fund Expenses – Six Month Period Ended April 30, 2011 (Unaudited)

As a shareholder of the Funds you incur two types of costs: (1) transaction costs and (2) ongoing costs, including management fees; shareholder servicing fees and other Fund expenses. This Example is intended to help you understand your ongoing costs (in dollars) of investing in the Fund and to compare these costs with the ongoing costs of investing in other mutual funds.

The Example is based on an investment of $1,000 invested at the beginning of the period and held for the entire period from November 1, 2010 through April 30, 2011.

Actual Expenses – The first line in the table below provides information about actual account values and actual expenses. You may use the information in this line, together with the amount you invested, to estimate the expenses that you paid over the period. Simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000=8.6), then multiply the result by the number in the first line under the heading entitled “Expenses Paid” to estimate the expenses you paid on your account during this period.

Hypothetical Example for Comparison Purposes – The second line in the table below provides information about hypothetical account values and hypothetical expenses based on the Funds’ actual net expense ratios and an assumed rate of return of 5% per year before expenses, which is not the Funds’ actual return. The hypothetical account values and expenses may not be used to estimate the actual ending account balance or expenses you paid for the period. You may use this information to compare the ongoing costs of investing in the Funds and other funds. To do so, compare this 5% hypothetical example with the 5% hypothetical examples that appear in the shareholder reports of the other funds.

Please note that the expenses shown in the table are meant to highlight your ongoing costs only and do not reflect any transactional costs, such as exchange fees, but shareholders of other funds may incur such costs. Therefore, the second line of the table is useful in comparing ongoing costs only, and will not help you determine the relative total costs of owning different funds. In addition, if these transactional costs were included, your costs would have been higher.


	Beginning Account Value 11/1/10		Ending Account Value 4/30/11			Expenses Paid for the 6 months ended 4/30/11*		Beginning Account Value 11/1/10		Ending Account Value 4/30/11			Expenses Paid for the 6 months ended 4/30/11*		Beginning Account Value 11/1/10		Ending Account Value 4/30/11			Expenses Paid for the 6 months ended 4/30/11*		Beginning Account Value 11/1/10		Ending Account Value 4/30/11			Expenses Paid for the 6 months ended 4/30/11*
Fund	Growth Fund							Value Fund							MidCap Growth Fund							Bond Fund
Shares
Actual	$	1,000.00	$	1,136.80		$	5.99	$	1,000.00	$	1,188.80		$	5.59	$	1,000.00	$	1,193.30		$	6.63	$	1,000.00	$	1,011.30		$	4.04
Hypothetical 5% return		1,000.00		1,019.19	+		5.66		1,000.00		1,019.69	+		5.16		1,000.00		1,018.74	+		6.11		1,000.00		1,020.78	+		4.06
	Short-Term Government Fund							National Tax-Free Intermediate Bond Fund							Missouri Tax-Free Intermediate Bond Fund							Kansas Tax-Free Intermediate Bond Fund
Shares
Actual	$	1,000.00	$	1,001.00		$	3.37	$	1,000.00	$	989.70		$	3.45	$	1,000.00	$	994.90		$	3.46	$	1,000.00	$	995.10		$	3.46
Hypothetical 5% return		1,000.00		1,021.42	+		3.41		1,000.00		1,021.32	+		3.51		1,000.00		1,021.32	+		3.51		1,000.00		1,021.32	+		3.51

Expenses are calculated using each Fund’s annualized net expense ratio, which represents the ongoing expenses as a percentage of net assets for the six months ended April 30, 2011. Expenses are calculated by multiplying the annualized net expense ratio by the average account value for the period; then multiplying the result by the number of days in the most recent fiscal half year; and then dividing that result by the number of days in the year. The annualized net expense ratios for the period were as follows:


Fund			Fund
Growth	1.13	%	Short-Term Government	0.68	%
Value	1.03		National Tax-Free Intermediate Bond	0.70
MidCap Growth	1.22		Missouri Tax-Free Intermediate Bond	0.70
Bond	0.81		Kansas Tax-Free Intermediate Bond	0.70

Hypothetical expenses are based on the Funds’ actual annualized net expense ratios and an assumed rate of return of 5% per year before expenses.

COMMERCE FUNDS

The Commerce Funds

Growth Fund:

The Fund is subject to market risk so that the value of the securities in which it invests may go up or down in response to the prospects of individual companies, particular industry sectors and/or general economic conditions. Investments in technology companies, which may produce or use products or services that prove commercially unsuccessful or become obsolete, may be subject to greater price volatility than securities of companies in other sectors.

Value Fund:

MidCap Growth Fund:

The Fund invests in small- and mid-capitalization securities. Generally, smaller and mid-sized companies are more vulnerable to adverse developments because of more limited product lines, markets or financial resources. As a result, the securities of smaller and mid-sized companies involve greater risks than those associated with larger, more established companies and may be subject to more abrupt or erratic trading and price movements. Investments in technology companies, which may produce or use products or services that prove commercially unsuccessful or become obsolete, may be subject to greater price volatility than securities of companies in other sectors.

Bond Fund:

Investments in fixed income securities are subject to the risks associated with debt securities including credit and interest rate risk. The guarantee on U.S. government securities applies only to the underlying securities of the Fund if held to maturity and not to the value of the Fund’s shares. Mortgage-backed securities, especially collateralized mortgage-backed securities, may be subject to risks that include price volatility, liquidity and enhanced sensitivity to interest rates. Asset-backed securities may be less liquid than other securities and therefore more difficult to value and liquidate, if necessary.

Short-Term Government Fund:

National Tax-Free Intermediate Bond Fund

Investments in fixed income securities are subject to the risks associated with debt securities including credit and interest rate risk. Investments in municipal securities can be significantly affected by political changes as well as uncertainties in the municipal market related to taxation or legislative changes. The Fund’s investments may subject shareholders to the federal alternative minimum tax and state income taxes.

Missouri Tax-Free Intermediate Bond Fund:

COMMERCE FUNDS

The Commerce Funds (continued)

diversified fund that holds more investments. Investments in municipal securities can be significantly affected by political changes as well as uncertainties in the municipal market related to taxation or legislative changes. In addition, the Fund’s investments may subject shareholders to federal alternative minimum tax. The investment income from this Fund may be subject to state income taxes.

Kansas Tax-Free Intermediate Bond Fund:

Investments in fixed income securities are subject to the risks associated with debt securities including credit and interest rate risk. The Fund invests its assets predominately in Kansas bonds. The actual payment of principal and interest on these bonds is dependent on the Kansas legislature allotting money each fiscal year for these payments. The Fund is non-diversified. Due to the smaller number of bonds generally held in the portfolio, the Fund may be subject to greater risks than a more diversified fund. A change in the value of any single holding may affect the overall value more than it would affect a diversified fund that holds more investments. Investments in municipal securities can be significantly affected by political changes as well as uncertainties in the municipal market related to taxation or legislative changes. In addition, the Fund’s investments may subject shareholders to federal alternative minimum tax. The investment income from this Fund may be subject to state income taxes.

LOGO

INVESTMENT ADVISER

AND CO-ADMINISTRATOR

Commerce Investment Advisors, Inc.

922 Walnut Street

4th Floor

Kansas City, Missouri 64106

CUSTODIAN/ACCOUNTING AGENT

State Street Bank & Trust Company

1 Lincoln Street

Boston, Massachusetts 02111

TRANSFER AGENT

Boston Financial Data Services, Inc.

330 W. 9th

4th Floor

Kansas City, Missouri 64105

DISTRIBUTOR

Goldman, Sachs & Co.

200 West Street

New York, New York 10282

CO-ADMINISTRATOR

Goldman Sachs Asset Management, L.P.

200 West Street

New York, New York 10282

INDEPENDENT REGISTERED

PUBLIC ACCOUNTING FIRM

KPMG LLP

Two Financial Center

60 South St.

Boston, M 02111

LEGAL COUNSEL

Drinker Biddle & Reath LLP

One Logan Square

Ste. 2000

Philadelphia, Pennsylvania 19103-6996

This Semi-Annual Report contains facts concerning The Commerce Funds’ objectives and policies, management, expenses, and other information. For more complete information about The Commerce Funds, a prospectus may be obtained by calling 1-800-995-6365. An investor should read the prospectus carefully before investing or sending money.

The Commerce Funds are advised by Commerce Investment Advisors, Inc., a subsidiary of Commerce Bank, which receives a fee for its services. The Commerce Funds are distributed by Goldman, Sachs & Co.

The Commerce Funds file their complete schedule of portfolio holdings with the Securities and Exchange Commission (the “SEC”) for the first and third quarters of each fiscal year on Form N-Q. The Funds’ Form N-Q is available on the SEC’s website at http://www.sec.gov. You may also review and obtain copies at the SEC’s Public Reference Room in Washington, D.C. Information about the Public Reference Room may be obtained by calling 1-800-SEC-0330.

A description of the policies and procedures that The Commerce Funds use to determine how to vote proxies relating to portfolio securities and information regarding how the Funds voted proxies relating to portfolio securities during the most recent 12-month period ended June 30 is available (i) without change, upon request by calling 1-800-995-6365 and (ii) on the SEC’s website at http://www.sec.gov.

This report is not authorized for distribution to prospective investors unless preceded or accompanied by a current prospectus, which contains, more complete information about the Commerce Funds’ investment policies, fees and expenses. Investors should read the prospectus carefully before investing.

NOT FDIC INSURED

MAY LOSE VALUE

NO BANK GUARANTEE

LOGO

TRUSTEES

Martin E. Galt III, Chairman

David L. Bodde, Lead Independent Trustee

Charles W. Peffer

James M. Snowden, Jr.

OFFICERS

William Schuetter, President

Angela Dew, Vice President, Chief Compliance Officer, and Secretary

Jeffrey Bolin, Assistant Vice President

Peter W. Fortner, Chief Accounting Officer

Scott McHugh, Treasurer

Philip V. Giuca Jr., Assistant Treasurer

Patricia Meyer, Assistant Secretary

922 Walnut

Fourth Floor

Kansas City, Missouri 64106

www.commercefunds.com

1-800-995-6365

07-938/CB 5026

6/11

ITEM 2.

CODE OF ETHICS.

Not applicable for the reporting period.

ITEM 3.

AUDIT COMMITTEE FINANCIAL EXPERT.

Not applicable for the reporting period.

ITEM 4.

PRINCIPAL ACCOUNTANT FEES AND SERVICES.

Not applicable for the reporting period.

ITEM 5.

AUDIT COMMITTEE OF LISTED REGISTRANTS.

Not applicable.

ITEM 6.

INVESTMENTS

(a) The Schedule of Investments is included as part of the Report to Shareholders filed under Item 1.

(b) Not applicable.

ITEM 7.

DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END MANAGEMENT

INVESTMENT

COMPANIES.

Not applicable.

ITEM 8.

PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

Not applicable.

ITEM 9.

PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND

AFFILIATED

PURCHASERS.

Not applicable.

ITEM 10.

SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS.

There has been no material change to the procedures by which shareholders may recommend nominees to the registrant’s Board of Trustees.

ITEM 11.

CONTROLS AND PROCEDURES.

(a)

The registrant’s principal executive and principal financial officers or persons performing similar functions have concluded that the registrant’s disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940, as amended (the “1940 Act”)) are effective as of a date within 90 days of the filing of this report, based on the evaluation of these controls and procedures required by Rule 30a-3(b) under the 1940 Act and 15d-15(b) under the Securities Exchange Act of 1934, as amended.

(b)

There were no changes in the registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act) that occurred during the second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.

ITEM 12.

EXHIBITS


(a)(1)	Not applicable for the reporting period.

(a)(2)	Exhibit 99.CERT	Certifications pursuant to Section 302 of the Sarbanes-Oxley Act of 2002 are filed herewith.

(a)(3)	Not applicable.

(b)(1)	Exhibit 99.906CERT	Certifications pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 are filed herewith.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

THE COMMERCE FUNDS

/s/ William R. Schuetter

William R. Schuetter

President

June 24, 2011

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

/s/ William R. Schuetter

William R. Schuetter

President

The Commerce Funds

June 24, 2011

/s/ Peter W. Fortner

Peter W. Fortner

Chief Accounting Officer

The Commerce Funds

June 24, 2011

Commerce Funds N-CSRSCertified semi-annual shareholder report (management investment company)