Report of Independent
Registered Public Accounting Firm

To the Shareholders of the Funds and Board of Trustees of
The Commerce Funds:

In planning and performing our audits of the financial statements
of The Growth Fund, The Value Fund, The MidCap Growth Fund,
The Bond Fund, The Short-Term Government Fund, The National
Tax-Free Intermediate Bond Fund, The Missouri Tax-Free
Intermediate Bond Fund, and The Kansas Tax-Free Intermediate
Bond Fund, portfolios of The Commerce Funds, (collectively the
"Funds"), as of and for the year ended October 31, 2020, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), we considered the
Funds' internal control over financial reporting, including controls
over safeguarding securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on the
financial statements and to comply with the requirements of Form
N-CEN, but not for the purpose of expressing an opinion on the
effectiveness of the Funds' internal control over financial reporting.
Accordingly, we express no such opinion. Management of the Funds
is responsible for establishing and maintaining effective internal
control over financial reporting. In fulfilling this responsibility,
estimates and judgments by management are required to assess the
expected benefits and related costs of controls. A fund's internal
control over financial reporting is a process designed to provide
reasonable assurance regarding the reliability of financial reporting
and the preparation of financial statements for external purposes in
accordance with generally accepted accounting principles (GAAP).
A fund's internal control over financial reporting includes those
policies and procedures that (1) pertain to the maintenance of
records that, in reasonable detail, accurately and fairly reflect the
transactions and dispositions of the assets of the fund; (2) provide
reasonable assurance that transactions are recorded as necessary to
permit preparation of financial statements in accordance with
GAAP, and that receipts and expenditures of the fund are being
made only in accordance with authorizations of management and
trustees of the fund; and (3) provide reasonable assurance
regarding prevention or timely detection of unauthorized
acquisition, use, or disposition of the fund's assets that could have
a material effect on the financial statements.

Because of its inherent limitations, internal control over financial
reporting may not prevent or detect misstatements. Also,
projections of any evaluation of effectiveness to future periods are
subject to the risk that controls may become inadequate because of
changes in conditions, or that the degree of compliance with the
policies or procedures may deteriorate.

A deficiency in internal control over financial reporting exists when the
design or operation of a control does not allow management or
employees, in the normal course of performing their assigned
functions, to prevent or detect misstatements on a timely basis. A
material weakness is a deficiency, or a combination of
deficiencies, in internal control over financial reporting, such that
there is a reasonable possibility that a material misstatement of the
Funds' annual or interim financial statements will not be prevented or
detected on a timely basis.
Our consideration of the Funds' internal control over financial
reporting was for the limited purpose described in the first
paragraph and would not necessarily disclose all deficiencies in
internal control that might be material weaknesses under standards
established by the PCAOB. However, we noted no deficiencies in
the Funds' internal control over financial reporting and their
operations, including controls over safeguarding securities that we
consider to be a material weakness as defined above as of October
31, 2020.

This report is intended solely for the information and use of
management and the Board of Trustees of The Commerce Funds and the
Securities and Exchange Commission and is not intended to be and
should not be used by anyone other than these specified parties.



/s/KPMG LLP

Boston, Massachusetts
December 21, 2020