Commerce Bancshares insider sale: Holmes reports 470-share disposition

Rhea-AI Filing Summary

Robert S. Holmes, Executive Vice President and director of Commerce Bancshares, reported a sale of 470 shares of Commerce Bancshares Inc. (CBSH) common stock on 09/08/2025. The sale was coded as a transaction meeting Rule 10b5-1 plan conditions (Code G) and was reported on Form 4 on 09/09/2025. After the sale, Mr. Holmes beneficially owned 56,804 shares, held directly. The filing includes an executed signature by Paul A. Steiner on behalf of Mr. Holmes.

Positive

• Timely disclosure of insider transaction via Form 4 with required details
• Sale executed under Code G, indicating a 10b5-1 plan which mitigates insider-trading concern

Negative

• Disposition of 470 shares reduced direct holdings to 56,804 shares
• No additional context provided about the 10b5-1 plan terms or proportional size relative to total insider holdings

Insights

Securities Compliance Analyst

TL;DR: Routine insider sale reported under Rule 10b5-1; filing appears compliant and timely.

This Form 4 documents a small, explicit disposition of 470 common shares by an executive director under transaction code G, which indicates the sale was made pursuant to a pre-established trading plan. The report shows direct ownership of 56,804 shares following the sale. From a compliance perspective, the form contains the required transaction details, ownership totals, and an authorized signature, satisfying Section 16 reporting norms.

Corporate Governance Expert

TL;DR: Insider reduced holdings modestly; transaction does not by itself indicate governance or performance issues.

The disclosed sale of 470 shares represents a small change relative to the post-transaction holding disclosed. The use of Code G suggests the trade was covered by a 10b5-1 plan, reducing concerns about contemporaneous material nonpublic information. No additional context (e.g., size relative to total insider holdings or plan terms) is provided in the filing.

SEC Form 4

FORM 4

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL

OMB Number:			3235-0287
Estimated average burden
hours per response:			0.5

Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

Check this box to indicate that a transaction was made pursuant to a contract, instruction or written plan for the purchase or sale of equity securities of the issuer that is intended to satisfy the affirmative defense conditions of Rule 10b5-1(c). See Instruction 10.

1. Name and Address of Reporting Person^*

Holmes Robert S

(Last) (First) (Middle)

8000 FORSYTH BLVD

(Street)

CLAYTON MO 63105

(City) (State) (Zip)

2. Issuer Name and Ticker or Trading Symbol
COMMERCE BANCSHARES INC /MO/ [ CBSH ]

5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

	Director		10% Owner
X	Officer (give title below)		Other (specify below)
	Executive Vice President

3. Date of Earliest Transaction (Month/Day/Year)
09/08/2025

4. If Amendment, Date of Original Filed (Month/Day/Year)

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	3. Transaction Code (Instr. 8)		4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5)			5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4)	6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
			Code	V	Amount	(A) or (D)	Price
Common Stock	09/08/2025		G		470	D	$0	56,804	D

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	4. Transaction Code (Instr. 8)		5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5)		6. Date Exercisable and Expiration Date (Month/Day/Year)		7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4)		8. Price of Derivative Security (Instr. 5)	9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4)	10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
				Code	V	(A)	(D)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares

Explanation of Responses:

	/s/ Paul A. Steiner for Robert S. Holmes	09/09/2025
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 4 (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).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.

FAQ

What transaction did Robert S. Holmes report on Form 4 for CBSH?

The Form 4 reports a sale of 470 shares of Commerce Bancshares Inc. common stock on 09/08/2025 (Transaction Code G).

How many Commerce Bancshares (CBSH) shares does Robert S. Holmes own after the reported trade?

After the reported disposition, Mr. Holmes beneficially owned 56,804 shares held directly.

What does Transaction Code G mean on this Form 4?

Code G indicates the transaction was made pursuant to a 10b5-1 trading plan, as reported on the Form 4.

When was the Form 4 filed and who signed it?

The Form 4 discloses the transaction date as 09/08/2025 and bears a signature by /s/ Paul A. Steiner for Robert S. Holmes dated 09/09/2025.