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Commerce Bancshares, Inc., a bank holding company as defined in the Bank Holding
Company Act of 1956, as amended, was incorporated under the laws of Missouri on
August 4, 1966. Through a second tier wholly-owned bank holding company, it owns
all of the outstanding capital stock of Commerce Bank (the �Bank�), which is
headquartered in Missouri. The Bank engages in general banking business,
providing a broad range of retail, corporate, investment, trust, and asset
management products and services to individuals and businesses. Commerce
Bancshares, Inc. also owns, directly or through the Bank, various non-banking
subsidiaries. Their activities include underwriting credit life and credit
accident and health insurance, selling property and casualty insurance (relating
to consumer loans made by the Bank), private equity investment, securities
brokerage, mortgage banking, and leasing activities. A list of Commerce
Bancshares, Inc.'s subsidiaries is included as Exhibit 21.
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