COMMERCE BANCSHARES, INC. Keefe, Bruyette & Woods 2012 Boston Bank Conference

February 29 – March 1, 2012

Charles Kim Chief Financial Officer Jeffery Aberdeen Controller Nicole Rose Manager Mergers & Acquisitions CAUTIONARY STATEMENT

A number of statements we will be making in our presentation and in the accompanying slides are “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995, such as statements of the Corporation’s plans, goals, objectives, expectations, projections, estimates and intentions. These forward-looking statements involve significant risks and uncertainties and are subject to change based on various factors (some of which are beyond the Corporation’s control). Factors that could cause the Corporation’s actual results to differ materially from such forward-looking statements made herein or by management of the Corporation are set forth in the Corporation’s 2011 Report on 10K and the Corporation’s Current Reports on Form 8-K.

1 2011 BANK STOCK PERFORMANCE “The year in bank stocks got off to a rough start. It turned worse still in the second half amid high volatility and repeated rallies inspired by euro zone rescue attempts that failed to sustain investor confidence.” – American Banker

15% Final Durbin Amendment Debt-ceiling CBSH Highlights: 10% published deadline

5% S&P downgrades U.S. debt • Record earnings for 2011 despite 0% difficult operating environment of weak loan demand and record low -5% interest rates -10% Oil tops $100, -15% escalating Fed declares low rates • Higher revenues in corporate card Mideast through mid-2013 violence and money management -20% CBSH businesses -25% KBW Bank -30% Index • Decline in loan loss provision -35% • Constant focus on expense 10 11 11 11 11 11 11 11 11 11 11 11 11 11 ------management Jul Apr Oct Jan Jun Feb Mar Dec Aug Aug Sep Nov Dec May

• “In a turbulent market, CBSH was rewarded for its quiet stability.” • “They don’t chase the latest fads and they don’t run out to hot markets,” an analyst told American Banker in July.

Sources: American Banker, Bloomberg 2 COMMERCE BANK THE TOP PERFORMING BANK STOCK OF 2011 IN THE KBW LARGE-CAP BANK INDEX

KBW Large-Cap Bank Index 2011 Stock Performance

Ticker KBW Bank Index Total Return* Rank Ticker KBW Bank Index Total Return* Rank CBSH Commerce Bancshares 3.14 1 HBAN (18.58) 13 USB US Bancorp 2.29 2 JPM JPMorgan Chase (19.97) 14 COF Capital One Financial (0.21) 3 NTRS (26.56) 15 BBT BB&T Corp (1.88) 4 NYB New York Community Bancorp (29.83) 16 PNC PNC Financial Services (3.06) 5 ZION Zions (32.67) 17 PBCT People’s United Financial (3.78) 6 BK Bank of New York Mellon (32.86) 18 MTB M&T Bank Corp (9.15) 7 FNFG First Niagara Financial (34.80) 19 WFC Wells Fargo (9.54) 8 RF Regions (38.07) 20 CFR Cullen/Frost (10.41) 9 CMA Comerica (38.08) 21 FITB Fifth Third Bancorp (11.31) 10 STI SunTrust (39.65) 22 STT State Street (11.45) 11 C Citigroup (44.33) 23 KEY KeyCorp (11.90) 12 BAC Bank of America (58.13) 24

*12/31/2010 – 12/31/2011; Includes dividends Source: Bloomberg 3 EARNINGS PERFORMANCE SIGNIFICANTLY ABOVE PEERS AND LARGE BANKS

Financial Returns

Return on Assets Return on Equity

1.40% 1.32% 14.00% 1.22% 12.15% 1.20% 12.00% 11.15%

1.00% 0.96% 10.00% 9.76%

0.76% 8.10% 0.80% 0.75% 8.00% 7.13% 7.01% 0.70% 0.67% 6.83% 6.58% 0.60% 0.57% 6.00% 0.42% 4.11% 0.40% 4.00%

0.20% 2.00%

0.00% 0.00% 2009 2010 Dec YTD 2009 2010 Dec YTD 2011 2011

L a rg e B a n k sCommerce Bank Peer Banks Large BanksCommerce

Peer Banks include: ASBC, BOKF, Central Bancompany, CYN, CFR, FMER, MBFI, PVTB, TCB, UMBF, WTFC, ZION Large banks include: JP Morgan, Citigroup, BoA, Wells Fargo, US Bancorp, Regions, Fifth Third, PNC, State Street Source: SNL Financial 4 COMMERCE BANK HAS BEEN A SOLID PERFORMER OVER TIME

Return on Assets ROA 10-yr average 2.0% CBSH: 1.4% 1.5% Peers: 1.0% 1.0% 0.5% 0.0% -0.5% -1.0% 2011201020092008200720062005200420032002

Return on Equity ROE 10-yr average 20.0% CBSH: 13.5% 15.0% Peers: 10.6% 10.0% 5.0% 0.0% -5.0% -10.0% 2003 2004 2005 2011201020092008200720062002

Large BanksPeer BanksCommerce Bank BanksCommerce Large BanksPeer

Peer banks include: ASBC, BOKF, CYN, CFR, FMER, MBFI, PVTB, TCB, UMBF, WTFC and ZIONS Large banks include: BAC, C, FITB, JPM, MI, PNC, RF, STT, USB and WFC 5 Source: SNL Financial & CBSH Annual Report ABOUT COMMERCE BANCSHARES

Super-Community Bank – over 145 years in the industry – $20.6 billion in assets

Lower Midwest Footprint with over 200 branches and 4,745 employees • 30th largest U.S. bank based on asset size1 • 90% of 2011 pre-tax profit from seven key markets • Commercial calling efforts with strong credit customers in our extended markets • Commercial Payment Services offered in 48 states

Seven Key Markets 1. City 2. St. Louis 3. Peoria/Bloomington 4. Springfield 3 7 5. Wichita 1 2 5 6. Tulsa 4 7. Denver St. Louis & Kansas City 6 Deposit Market Share2 Performance – CAGR 2011 20112011 10yr10yr US Bancorp 12% EPS*EPS* 18%18% 6%6% BoA 12% Cash Div*Cash Div* 3%3% 9%9% Commerce 9% Branch Footprint UMB 6% Extended Market Area Stock PriceStock Price 1%1% 5%5% Others 61% Total ReturnTotal Return 3%3% 7%7%

*Per share figures have been restated for 5% stock dividend distributed on 12/19/2011 Sources: 1SNL Financial as of 12/31/2011, 2FDIC June, 2011 deposit data 6 ABOUT OUR MARKETS

Kansas Community City St. Louis Denver Tulsa Markets1

2010 Population 2,031 2,835 2,582 930 1,759 (000’s)

5-year projected 4.0% 1.7% 7.2% 3.5% 3.9% Population Growth

CBI Market 23.7% 18.8% 0.4% 0.5% 15.1% Penetration2

Median Household $57 $54 $62 $47 N/A Income (000’s)

Unemployment rate3 7.4% 8.1% 7.9% 6.4% 6.7%

2011 FDIC CBI $5,447 $4,888 $115 $122 $2,831 Deposits (000’s)

Deposit Share in 13.2% 7.5% 3.8% 0.7% 7.0% footprint

1.Community markets include Wichita, Springfield, Columbia, Peoria and Bloomington 2. 2011 households in county with CBI branch 3. U.S. Bureau of Labor Statistics as of November 2011 7 Sources: FDIC, Nielsen and U.S. Bureau of Labor Statistics SUPER-COMMUNITY BANK PLATFORM

A More Nimble Format … With Higher Service Focus

Community Bank Front End Super-Regional Back End • Flat organization – quick decisions • Sophisticated payment processing systems • Employees embrace strong culture • Broad consumer product offerings • Award winning customer service • Private banking; trust; capital markets • Knowledge of customers and markets • Competitive on unit costs reduces risk

A Strategy that Builds Results for Tomorrow • Sales across business lines • Focus on people/talent development • Investment in technology • Top quartile credit quality metrics • Disciplined approach to acquisitions

8 ENGAGEMENT SCORES AT COMMERCE BANK HOLD STRONG

Engagement Index (normative scale) Percent Favorable 2011 Commerce Bank 94%

2010 Commerce Bank 94%

U.S. Financial Services Companies’ Norm 87%

U.S. High Performance Companies’ Norm 92%

Engagement Index (historical scale) 2009 Commerce Bank 92%

2008 Commerce Bank 89%

2007 Commerce Bank 89%

2006 Commerce Bank 87%

2004 Commerce Bank 80%

Items receiving the most positive responses included employees’ understanding of how their department contributes to Commerce’s success; fully applying their skills and abilities in their work; and being personally motivated to help Commerce be successful

Source: Towers Watson 9 © 2011 Towers Watson. All rights reserved. Proprietary and Confidential. For Towers Watson and Towers Watson client use only. INDUSTRY RECOGNITION

America’s Best Banks by Forbes Bank Directors’ Top Banks

Commerce ranked among the top Commerce ranked #7 on Bank ten on Forbes’ list of America's Director magazine’s 2011 Top 150 Best Banks three years in a row Bank Performance Scorecard

10 DIVERSE REVENUE SOURCES

• Balanced mix of interest and non-interest income • Meaningful, growing contribution from wealth management and card businesses

Commerce Bank Peer Banks

14% 4% 8%

9% 59% 7% 69%

8% 9% 8% 3% 2%

Net interest income Deposit service charges Wealth management Fees & commission Other Card income

Peer Banks include: ASBC, BOKF, Central Bancompany, CYN, CFR, FMER, MBFI, PVTB, TCB, UMBF, WTFC, ZION Note: Excludes Gains and Losses on Securities; Wealth Management excludes Brokerage Source: Financial Information Systems; data as of 12/31/2011 11 EARNINGS

11 vs. 10 ($ millions) 2009 2010 2011 % change Net Interest Income $636 $646 $646 - Non-Interest Income 396 405 393 (3%) Total Revenue $1,032 $1,051 $1,039 (1%) Securities Gains/(Losses) (7) (2) 11 NM Non-Interest Expense (621) (631) (621) (2%) Provision for Loan Losses (161) (100) (51) (49%) Pre-Tax Income 243 318 378 19% Income Taxes (74) (96) (122) 27% Net Income $169 $222 $256 15%

Diluted EPS* $1.87 $2.40 $2.82 18% ROA .96% 1.22% 1.32% ROE 9.8% 11.2% 12.2% Efficiency Ratio 59.9% 59.7% 59.1%

*Per shares figures have been restated for 5% stock dividend distributed on December 19, 2011 12 REVENUE TRENDS

11 vs.10 ($ millions) 2009 2010 2011 % change Interest Income $790 $729 $698 (4%) Interest Expense 154 83 52 (37%) Net Interest Income $636 $646 $646 - Contribution from … Deposit fees 106 93 83 (11%) Cards 122 149 157 (5%) Trust 77 81 88 9% Bond Trading & Brokerage 33 30 30 - Other 58 52 35 (33%) Non-Interest Income $396 $405 $393 (3%) Total Revenue $1,032 $1,051 $1,039 (1%)

Revenues declined $32 million in 2011 due to lost fees on debit interchange (Durbin), overdraft (Reg. E), and exit of student loan business

13 EXPENSES

11 vs.10 ($ millions) 2009 2010 2011 % change Salaries & Benefits $345 $347 $345 (1%) Occupancy 46 47 46 (2%) Equipment 25 23 22 (4%) Supplies & Communications 32 27 22 (19%) Data Processing 62 68 68 - Deposit Insurance 27 19 13 (32%) Other 86 93 90 (3%) Subtotal $623 $624 $606 (3%) Non-recurring* (2) 7 15 N/M Total Non-Interest Expense $621 $631 $621 (2%)

• “Focus on efficiency” resulted in 3% reduction in core expense in 2011 • Virtually no category left untouched • Efficiency ratio in 2011 was 59.1% compared to 64.6% for top 50 U.S. bank holding companies**

*Non-recurring includes partial reversal of VISA indemnification expenses in 2009, 2010 & 2011, pre-payment penalty in 2010 on FHLB debt & debit OD litigation costs in 2011 14 **Source: SNL Financial, excludes BAC NET INTEREST INCOME: 2007 – 2011, TAX EQUATED

Net Interest Income $ in thousands (tax equivalent)

$750 4245 700 2133 665 $668 146 653 650 60819 600 42 1037 547 550 $520 500 12/31/1012/31/0912/31/0812/31/0712/31/06 12/31/11

Total net interest income Change due to volume Change due to rates

• Over the last 5 years, growth in net interest income mainly due to larger balance sheet – net earning assets up $2.9 billion or 85% • Rates have pressured margins during previous 5 years; modest decline in deposit rates in 2011

15 INVESTMENT PORTFOLIO: HIGH QUALITY, DIVERSE, SHORT DURATION

12/31/2011 Portfolio 31.8% Total investments $9.4 billion Unrealized gain $160 million 12 mo maturities $1.6 billion Treasury & agency Municipal Agency MBS Other asset-backed Duration Corporate Other Dec 2011 2.10 yrs Dec 2010 2.08 yrs Dec 2009 2.09 yrs Weighted Weighted Life rate (years)13.7% Treasury and agency 1.8% 5.9 Municipal - TE 4.5% 7.5 Agency MBS 3.3% 4.1 Other asset-backed 1.1% 1.7 Corporate 4.5% 1.1

Source: InTrader 16 LOANS – DIVERSE PORTFOLIO; CONSUMER GREATER THAN PEERS Commerce Bank Peer Banks Commercial: 59% Commercial: 72% Consumer: 41% 9% Consumer: 28% 11% 0% 16% 31% 33% 17%

16% 4% 6%

24% 33%

Business Business RE Consumer & HELOC Construction Personal RE Consumer Card

Growth initiatives in 2011 Factors reducing growth in 2011 $ in millions $ in millions Owner occupied & multi-family $98 Run-off in construction $74 Auto lending 56 Strategic decline Marine/RV 115 Tax-free 69 Unplanned Comml payoffs 108 Other Commercial 42 Lower Ag lending 202 Total $265 Total $499

Peer Banks include: ASBC, BOKF, Central Bancompany, CYN, CFR, FMER, MBFI, PVTB, TCB, UMBF, WTFC, ZION Data as of 12/31/2011 17 STRONG DEPOSIT GROWTH IN BOTH CONSUMER AND CORPORATE DEPOSITS

Total deposits $ in billions $17 $16.8

16 +8% $15.1 • CD’s comprised 15 15% of portfolio $14.2 in 2011 vs. 32% 14 in 2007 $12.9 13 $12.6 • Cost of deposits in 2011 was 12 .42% compared 20112010200920082007 to peer average of .52% Deposit $ in billions 2007 2011 growth Consumer & $9.4 $10.5 12% Private Banking Commercial $3.2 $6.3 97% Total $12.6 $16.8 33%

Peer banks include: ASBC, BOKF, Central Bancompany, CYN, CFR, FMER, MBFI, PVTB, TCB, UMBF, WTFC, ZION 18 RISK MANAGEMENT REMAINS AN IMPORTANT PART OF OUR CULTURE

$120 1.2%

100 1.0

80 0.8 ing assets 60 0.6

40 0.4 n millions on-perform Non-performing Non-performing to loans assets (%) N i $ 20 0.2

0 0.0 2011201020092008200720062005200420032002

ORE O Non-accrualNon-performing to loans OREO Non-accrualNon-performing

Non-accrual loans to average loans totaled .82% compared to 1.92% for top 50 U.S. banks at year end 2011

Source: SNL Financial 19 ASSET QUALITY - SELECT LARGE-CAP AND PEER BANKS 4TH QUARTER 2011

NET CHARGE-OFFS (%) LOAN LOSS RESERVE (%) NPA COVERAGE (%)

4Q10 4Q11 4Q10 4Q11 4Q10 4Q11 SELECT LARGE BANKS: BoA 2.87% 1.74% 4.47% 3.68% 116% 101% JPMorgan 3.31% 1.81% 4.71% 3.84% 190% 223% Wells Fargo 2.02% 1.36% 3.10% 2.56% 71% 92% US Bank 1.19% 1.90% 3.03% 2.52% 110% 133%

SELECT PEER BANKS: Associated 3.41% 0.64% 3.78% 2.70% 83% 106% Cullen/Frost 0.55% 0.26% 1.57% 1.38% 76% 91% Zions 2.77% 1.03% 4.01% 2.87% 96% 119% BOKF 0.53% 0.34% 3.78% 2.25% 127% 126% TCF 1.75% 1.63% 1.80% 1.81% 77% 86%

Select Bank Average 2.04% 1.19% 3.36% 2.62% 105% 120% Commerce 0.92% 0.68% 2.10% 2.01% 193% 196%

Net charge-offs have outperformed industry results, while reserves provide strong coverage to non-performers

20 CHARGE-OFFS CONSISTENTLY BETTER THAN INDUSTRY

Net Charge-Off Rates for CBI vs. Large Banks Largest 100CBI Business C&I Net C/Os Commercial R/E Net C/Os

1.40% 1.33% 3.00% 2.68% 1.20% 1.08% 2.50% 1.00% 0.74% 2.00% 1.63% 0.80% 0.68% 0.66% 1.52% 1.50% 1.29% 0.60% 1.15% 1.00% 0.40% 0.30% 0.28% 0.55% 0.53% 0.20% 0.14% 0.14% 0.48% 0.42% 0.20% 0.50% 0.23%

0.00% 0.00% Dec-11Sep-11Jun-11Mar-11Dec-10 Dec-11Sep-11Jun-11Mar-11Dec-10

Consumer Net C/Os CreditCredit Card Card Net Net C/Os C/Os 2.00% 2.00% 8.00% 7.72% 1.83% 1.80% 1.72% 6.99% 7.00% 1.60% 1.37% 1.34% 1.40% 5.67% 1.40% 1.28% 6.00% 5.60% 1.20% 4.97% 1.07% 5.00% 4.73% 4.57% 4.54% 1.00% 0.93% 0.78% 4.00% 3.87% 3.78% 0.80% 0.60% 3.00% Sep-11Jun-11Mar-11Dec-10 Dec-11 Mar-11Dec-10 Dec-11Sep-11Jun-11

Source: Federal Reserve Statistical Release, not seasonally adjusted 21 STRONG CAPITAL POSITION – ALL COMMON

$250 140% 120 200 100

150 80 millions 60 $ in $ 100 40 50

20 to Net % -Income combined

0 0 20112010200920082007200620052004 Treasury stockCash dividendPayout % dividendPayout Treasury stockCash

Year-end capital ratios Tangible common equity to assets 9.91% Tier 1 risk-based capital 14.74% Total risk-based capital 16.01%

22 KEY PRIORITIES FOR 2012 REFLECT THE CURRENT BANKING ENVIRONMENT

• Rebuild the Retail Banking model Run the Core • Grow Commercial profit while improving Bank more return on capital efficiently… • Continuously improve operational efficiency

• Deepen and broaden payments relationships and capabilities Grow our • Accelerate growth in the wealth management specialty bank business business… • Invest in innovation, and explore new business line opportunities

• Recruit and hire the best talent Invest in our people and • Retain and develop our top performers and future future leaders leaders… • Address underperformance

23 CORE COMMERCIAL: 2012 KEY INITIATIVES

Identify New • Improve segmentation by industry and product Loan • Market private placement of tax-advantaged loans Opportunities • Capitalize on increase in commercial real estate financing

Coordinate and • Increase market share through systematic sales effort by industry specialists Expand • Introduce Healthcare suite: mPay Gateway, RemitConnect and HSF Healthcare • Educate and train officers through quarterly Healthcare Forum Banking • Target middle market companies focusing on Commerce suite of services Expand • Continue to make opportunistic hires in expansion markets Regional • Potential Texas loan production office Presence • Open Denver Tech Center location

Focus on • Coordinate calling strategies for Corporate Card and Merchant Services Comprehensive • Focus on increasing referrals, contribution and penetration rates Payment • Provide training on fraud prevention and security procedures System • Introduce integrated payables Enhance Marketing and • Customer focused needs based messaging Officer • Increase data mining for targeted prospect identification Productivity • Improve campaign management tactics and strategies

24 CORE COMMERCIAL – SEGMENTING TO MORE EFFECTIVELY TARGET PROSPECTS Industry Product Opportunity Competitors  Healthcare  Interest Rate Swaps  Troubled Institutions  Energy  Leasing  Relationship  Ag & Food Processing  Tax-advantaged financing Management Issues  Not-For-Profit  SBA  Drop In Service Levels  Beverage Distributors  Linked Deposit  Other Issues  Manufacturing  Floor Plan Lending  ESOP’s  Hospital Services Financing  Student Housing  RemitConnect  Municipalities/Education  mPay Gateway  Other  International Services  Commercial L/C’s  Other

Loan Growth by Category 2007-2011 200% 158% 150% 93% 100%

50% 29% 24% 14% 0% -9% -50% Total Loans Tax Free Expansion Mkts Healthcare Beverage Agribusiness

25 CORE RETAIL: 2012 KEY INITIATIVES

Focus on Value- • Develop new and reposition existing products that provide value to Based Revenue customers Streams • Relationship Advance, accessory sales (ID theft, checks, GPR) Focus on Profitable • Focus on multi-channel increase in volumes (branch, direct mail, Loan Growth web, inside sales) and more efficient delivery (systems, underwriting, risk) Expand Key Customer • Expand customer relationships through effective targeting, Relationships messaging and special offers Transition Sales Force into new • Guide the sales force through the changes driven by the shift away Sales Environment from a “free” checking model

Define Future • Identify the future branch footprint, layout, staffing and purpose Branch Strategy within the overall redefined strategy for managing customer traffic

Execute Future • Develop strategy to increase sales of deposit and loan products as Online Strategy well as accessory services on commercebank.com

Talent Management • Address the competencies required from our sales force

26 CORE RETAIL – FOCUS ON OPERATIONAL EXCELLENCE FOR EXPENSE SAVINGS CRITICAL TO SHORT-TERM SUCCESS Core Retail Total Expense $ in millions $15.5 $240 $1.2 Online banking $2.1 Customer checks 235 7% reduction $2.4 Other 230

225 $2.6 Check processing

220 $3.2 Teller costs

215 2010 2011 $4.0 FDIC Insurance • Focused on productivity to offset loss of retail revenues 2011 • Closed/merged 10 branches in last 2 years • Imaging technologies have reduced paper related costs while better servicing customers – longer hours in some locations

27 REBUILDING CORE RETAIL REVENUE Core Retail Fee Income $ in millions $120 $109 Core Retail efforts will expand menu 100 Other of accessory products and services to help mitigate lower debit fees Mtge banking 80 • “myAdvance” – short-term consumer Check sales lending 60 ATM • Expanded branch focus and sales of Dep fees 40 consumer loans OD • Increase in ATM revenues – domestic 20 Debit and international • Theft ID Restoration 0 2011 • Interchange network adjustments • Growth in check sales revenues • Debit and OD fees make up • Expanded service fees from sales of 79% of total core retail fees non-free checking

• “Durbin” effect on debit fees will have whole year effect in 2012

28 COMMERCE TRUST COMPANY – SOLID GROWTH IN FEES AND ASSETS

As one of the largest trust companies in the US, The Commerce Trust Company excels at providing objective financial advice, exceptional personal service and comprehensive wealth management solutions. • $27.3 billion in assets under administration • Ranked #29 based on assets under management* • Team of over 470 and average officer has 15 years of experience • 100+ years in the business

$30 $27 $90 $25 25 $23 $22 85

$19 s 20

illions 15 80 st Assets st 10 Tru b in$ 75 Fees Trust millionin$ 5 0 70 2007 2008 2009 2010 2011 Trust AssetsTrust Fees Trust AssetsTrust • Record asset management sales three years in a row • Account attrition has remained low for last 5 years

*Source: SNL Financial – Total managed fiduciary related assets as of December 31, 2011 29 COMMERCE TRUST COMPANY – 2012 KEY INITIATIVES

Core Private • Expand sales staff, increase Commerce Trust Company Client Growth marketing, and accelerate key product development initiatives

Commerce • Launch Commerce Family Office sales and marketing initiative Family Office to accelerate revenue growth

Expand Institutional • Invest in flagship fixed income products and expand product Product set and sales resources for 401(k) and investment consulting Offering Complete Restructuring • Upgrade and expand sales force, while streamlining the back of Commerce office for more profitable margins Brokerage

Consider Explore strategic acquisitions to supplement organic growth Strategic • Acquisitions initiatives

30 CARD PRODUCTS – A LEADER IN THE PAYMENTS INDUSTRY Consistently ranked among the top issuers in the Nilson Report

#35 Debit Card Issuer Debit / Prepaid Card

#23 Consumer Card Issuer Consumer Card

#12 Bank Acquirer* Merchant Services

#10 Purchasing Card Issuer Commercial Card #14 Commercial Card Issuer

VISA Service Quality Performance Award Winner

Commerce Bank acknowledged by VISA for consistent, superior performance and continued service quality improvement, receiving over 50 awards since 1992.

*Excludes non-bank acquirers Source: 2011 Nilson Reports (Debit: April, 2011; Consumer Card: 31 June, 2011; Merchant: March, 2011; Commercial Card June, 2011) CONSUMER CARD - PROFITABILITY REMAINED STRONG THROUGHOUT THE CYCLE Consumer Credit Card Trends $ in millions

+5% $800 $40 750 35 30 nces 700 25 650 20

Loan bala Loan 15

600 profit Pre-tax 10 550 5 500 0 201120102009200820072006 Loan balancesPre-tax profit Loan balancesPre-tax

• Lower loan losses and funding costs contributed to growth in contribution over last 5 years • 5 year CAGR of card balances 5%; greater competition and consumer deleveraging has made growing loans more difficult in 2011

32 CONSUMER CARD – 2012 KEY INITIATIVES

Merchant Funded • Utilize merchant partners to drive transaction volume and fee Rewards income while reducing redemption expenses in existing rewards platform

Product Innovation • myRewards general purpose reloadable card rolled out in 2012

• Leverage direct mail and convenience checks to grow active Grow Quality accounts and outstandings Loans • Utilize predictive analytics and customer insight to optimize response through various channels.

• Increase proportion of “transactor” customers to better Transactor Focus balance revenue streams (decrease reliance on revolving customer balances)

33 COMMERCIAL CARD AND MERCHANT SERVICES 2012 KEY INITIATIVES

ControlPay EIPP • Maintain EIPP momentum, explore receivables and trade finance product enhancements

• Implement Hospital Services Financing, enhance ActiveFunds, New Product Verient and Visa Payables platforms, and incorporate debit cial Development functionality into Business Rewards offering ard

C • Enhance underwriting process, maintain acceptable levels of Credit Strategy risk & address extended payment terms offered by competitors Commer

• Implement Merchant Services referral program from Card B2B Payment Strategy employees and data mine enrolled vendors for large Merchant opportunities • Expand sales in a cost effective and controlled manner by Alternative establishing “preferred vendor” relationships Sales Channels • Franchises, Associations, Agent Banks, BIN Sponsorships, 3rd Party Vendors ant Acquisition Strategy • Fully define and approve an acquisition strategy rvices Development Se Merch New Product • Recognize and develop new products Development • Certified Internet Gateway, mPay Gateway, International processing

34 COMMERCIAL CARD: GROWTH OPPORTUNITIES IN THE PAYMENTS SYSTEM Commercial Card Revenue $ in millions $60 $57.8 50 +30% $48.3 40 $32.2 30 $25.9 $20.2 20 10 0 2007 2008 2009 2010 2011 Comm ercial Card Expansion IIAgent BankCommercial Card Expansion IExisting BankCommercial Commercial Card Expansion IIAgent

• High ROE business flagged for investment and growth • Strong growth driven by continuing product innovation and expansion into new geographies / customer segments • Growth in out years will come from new products – ActiveFunds – Health Services Financing – ControlPay EIPP – Agent Bank program

35 M&A OUTLOOK

M&A Outlook for 2012 • Industry consolidation continues, but at a slow pace • Buyers reluctant to pay high prices and sellers still have high expectations – Failed BankUnited sale process – ING Direct sold at tangible book value • Regulatory burden and cost will lead to community bank consolidation, but not clear when consolidation will begin – predicting late 2012

Commerce Focus • Commerce remains a strategic buyer • Augment expansion markets if right fit becomes available • Management “lift-outs” are attractive, especially in asset management

COMMERCE IS A STRATEGIC BUYER – ORGANIC GROWTH IS PRIORITY ONE

Source: SNL Bank M&A Scorecard: 2011 in Review 36 THEMES IN BANKING – 2012

• Low rates will continue to weigh on bank profitability

• Loan growth dependent on the level of overall economic growth

• Profitability remains under pressure as NIM’s, fee income and efficiency remain challenged

• Top line pressure forces reliance on cost reduction and lowered expenses, although efficiency gains and reserve releases may be topping out

• Money center banks have reduced European counterparty risk

• Community bank business model at risk due to regulatory changes and demands

• Year has opened strong and investors expect that 2012 will see a recovery in bank stocks

Sources: Barclays Capital, SNL Financial, and Goldman Sachs Global Investment Research 37 RECORD EPS AND CONTINUED DIVIDEND GROWTH

$13.00 Revenue Per Share Earnings Per Share $3.00

$12.00 $2.60 $11.00 Share $10.00 $2.20

$9.00 $1.80 $8.00 Revenue Per Per Revenue Earnings Per Per Share Earnings $1.40 $7.00

$6.00 $1.00 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 Dividends $0.40 $0.50 $0.62 $0.68 $0.73 $0.78 $0.82 $0.83 $0.85 $0.88 per share*

Commerce Bank dividend increased for the 44th consecutive year and paid its 18th consecutive 5% stock dividend More than three-fourths of large banks cut or eliminated their dividend since 2007**

*Restated for 5% stock dividend distributed in December 2011 **Reflects Top 50 banks total dividends paid in 2007 compared to 2010 Source: SNL Financial 38 STEADY SHAREHOLDER RETURNS IN A HIGHLY VOLATILE MARKET

Total shareholder returns* Indexed, 12/31/2001 = 100 200 COMMERCE BANK Total Shareholder Returns* Percent 1 yr1 yr 3 yr3 yr 5 yr5 yr 10 yr10 yr 150 CBSHCBSH 3.1%3.1% 2.7%2.7% 2.6%2.6% 7.0%7.0% S&P 500 INDEX S&P 500S&P 500 2.1%2.1% 14.1%14.1% (0.3%)(0.3%) 2.9%2.9%

NASDAQ NASDAQ 100 (10.5%)(10.5%) (4.0%)(4.0%) (12.5%)(12.5%) (1.7%)(1.7%) BANKS BanksBanks KBW KBW BANK Bank (23.2%)(23.2%) (2.4%)(2.4%) (17.5%)(17.5%) (4.8%)(4.8%) INDEX IndexIndex 50 201120092007200520032001

Commerce Bank the top performing bank stock of 2011 in the KBW Large-Cap Bank Index

*Assumes reinvested dividends, multi-year returns are annualized Sources: Bloomberg, American Banker 39