Ownership Submission
FORM 3
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934, Section 17(a) of the Public Utility Holding Company Act of 1935 or Section 30(h) of the Investment Company Act of 1940
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(Print or Type Responses)
1. Name and Address of Reporting Person *
  Neff Douglas D
2. Date of Event Requiring Statement (Month/Day/Year)
01/25/2019
3. Issuer Name and Ticker or Trading Symbol
COMMERCE BANCSHARES INC /MO/ [CBSH]
(Last)
(First)
(Middle)
1000 WALNUT ST
4. Relationship of Reporting Person(s) to Issuer
(Check all applicable)
_____ Director _____ 10% Owner
__X__ Officer (give title below) _____ Other (specify below)
Senior Vice President
5. If Amendment, Date Original Filed(Month/Day/Year)
(Street)

KANSAS CITY, MO 64106
6. Individual or Joint/Group Filing(Check Applicable Line)
_X_ Form filed by One Reporting Person
___ Form filed by More than One Reporting Person
(City)
(State)
(Zip)
Table I - Non-Derivative Securities Beneficially Owned
1.Title of Security
(Instr. 4)
2. Amount of Securities Beneficially Owned
(Instr. 4)
3. Ownership Form: Direct (D) or Indirect (I)
(Instr. 5)
4. Nature of Indirect Beneficial Ownership
(Instr. 5)
Common Stock 4,495
D
 
Common Stock 449
I
401(k)

Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly. SEC 1473 (7-02)
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Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security
(Instr. 4)
2. Date Exercisable and Expiration Date
(Month/Day/Year)
3. Title and Amount of Securities Underlying Derivative Security
(Instr. 4)
4. Conversion or Exercise Price of Derivative Security 5. Ownership Form of Derivative Security: Direct (D) or Indirect (I)
(Instr. 5)
6. Nature of Indirect Beneficial Ownership
(Instr. 5)
Date Exercisable Expiration Date Title Amount or Number of Shares
Stock Appreciation Rights 04/17/2014(1) 04/17/2023 Common Stock 1,813 $ 29.1172 D  
Stock Appreciation Rights 03/05/2015(2) 03/05/2024 Common Stock 1,609 $ 34.8748 D  
Stock Appreciation Rights 03/03/2016(3) 03/03/2025 Common Stock 1,797 $ 34.4877 D  
Stock Appreciation Rights 03/01/2017(4) 03/01/2026 Common Stock 1,673 $ 37.931 D  
Stock Appreciation Rights 03/02/2018(5) 03/02/2027 Common Stock 992 $ 53.3424 D  
Stock Appreciation Rights 03/01/2019(6) 03/01/2028 Common Stock 995 $ 55.0762 D  

Reporting Owners

Reporting Owner Name / Address Relationships
Director 10% Owner Officer Other
Neff Douglas D
1000 WALNUT ST
KANSAS CITY, MO 64106
      Senior Vice President  

Signatures

/s/ By: Jeffery D. Aberdeen For: Douglas D. Neff 02/01/2019
**Signature of Reporting Person Date

Explanation of Responses:

* If the form is filed by more than one reporting person, see Instruction 5(b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
(1) The stock appreciation right vests in four equal annual installments beginning April 17, 2014.
(2) The stock appreciation right vests in four equal annual installments beginning March 5, 2015.
(3) The stock appreciation right vests in four equal annual installments beginning March 3, 2016.
(4) The stock appreciation right vests in four equal annual installments beginning March 1, 2017.
(5) The stock appreciation right vests in four equal annual installments beginning March 2, 2018.
(6) The stock appreciation right vests in four equal annual installments beginning March 1, 2019.

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