COMMERCE BANCSHARES, INC.

Keefe, Bruyette & Woods 2012 Boston Bank Conference

COMMERCE BANCSHARES, INC.

Keefe, Bruyette & Woods 2012 Boston Bank Conference

Charles KimChief Financial Officer

Jeffery AberdeenController

Nicole RoseManager Mergers & Acquisitions

February 29 – March 1, 2012

1

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

CAUTIONARY STATEMENT

2

-35%

-30%

-25%

-20%

-15%

-10%

-5%

0%

5%

10%

15%

Dec

-10

Jan-

11

Feb

-11

Mar

-11

Apr

-11

May

-11

Jun-

11

Jul-1

1

Aug

-11

Aug

-11

Sep

-11

Oct

-11

Nov

-11

Dec

-11

Debt-ceiling deadline

Final Durbin Amendment published CBSH Highlights:

• Record earnings for 2011 despite difficult operating environment of weak loan demand and record low interest rates

• Higher revenues in corporate card and money management businesses

• Decline in loan loss provision

• Constant focus on expense management

• “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.

2011 BANK STOCK PERFORMANCE

Sources: American Banker, Bloomberg

“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

Oil tops $100,

escalating Mideast violence

Fed declares low rates through mid-2013

S&P downgrades U.S. debt

CBSH

KBW Bank Index

3

Ticker KBW Bank Index Total Return* Rank

CBSH Commerce Bancshares 3.14 1

USB US Bancorp 2.29 2

COF Capital One Financial (0.21) 3

BBT BB&T Corp (1.88) 4

PNC PNC Financial Services (3.06) 5

PBCT People’s United Financial (3.78) 6

MTB M&T Bank Corp (9.15) 7

WFC Wells Fargo (9.54) 8

CFR Cullen/Frost (10.41) 9

FITB Fifth Third Bancorp (11.31) 10

STT State Street (11.45) 11

KEY KeyCorp (11.90) 12

*12/31/2010 – 12/31/2011; Includes dividendsSource: Bloomberg

Ticker KBW Bank Index Total Return* Rank

HBAN Huntington Bancshares (18.58) 13

JPM JPMorgan Chase (19.97) 14

NTRS Northern Trust (26.56) 15

NYB New York Community Bancorp (29.83) 16

ZION Zions (32.67) 17

BK Bank of New York Mellon (32.86) 18

FNFG First Niagara Financial (34.80) 19

RF Regions (38.07) 20

CMA Comerica (38.08) 21

STI SunTrust (39.65) 22

C Citigroup (44.33) 23

BAC Bank of America (58.13) 24

KBW Large-Cap Bank Index 2011 Stock Performance

COMMERCE BANK THE TOP PERFORMING BANK STOCK OF 2011 IN THE KBW LARGE-CAP BANK INDEX

4

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 StreetSource: SNL Financial

1.32%

1.22%

0.96%

0.57%

0.67%

0.76%

0.42%

0.00%

0.20%

0.40%

0.60%

0.80%

1.00%

1.20%

1.40%

2010

0.75%

Dec YTD 2011

0.70%

2009

Large BanksCommerce Bank Peer Banks

12.15%

11.15%

9.76%

6.83% 7.01%

8.10%

4.11%

0.00%

2.00%

4.00%

6.00%

8.00%

10.00%

12.00%

14.00%

Dec YTD 2011

2010

6.58%7.13%

2009

Return on Assets Return on Equity

Financial Returns

EARNINGS PERFORMANCE SIGNIFICANTLY ABOVE PEERS AND LARGE BANKS

5

COMMERCE BANK HAS BEEN A SOLID PERFORMER OVER TIME

Peer banks include: ASBC, BOKF, CYN, CFR, FMER, MBFI, PVTB, TCB, UMBF, WTFC and ZIONSLarge banks include: BAC, C, FITB, JPM, MI, PNC, RF, STT, USB and WFCSource: SNL Financial & CBSH Annual Report

-1.0%

-0.5%

0.0%

0.5%

1.0%

1.5%

2.0%

2011201020092008200720062005200420032002

Return on Assets

Return on Equity

-10.0%

-5.0%

0.0%

5.0%

10.0%

15.0%

20.0%

2003 2004 2005 2011201020092008200720062002

ROE 10-yr average CBSH: 13.5%Peers: 10.6%

ROA 10-yr average CBSH: 1.4%Peers: 1.0%

Large BanksPeer BanksCommerce Bank

6

Lower Midwest Footprint with over 200 branches and 4,745 employees

Seven Key Markets

1. Kansas City2. St. Louis3. Peoria/Bloomington4. Springfield5. Wichita6. Tulsa7. Denver

• 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

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

ABOUT COMMERCE BANCSHARES

Branch Footprint

Extended Market Area

1 2

3

45

6

7

Performance – CAGR

20112011 10yr10yr

EPS*EPS* 18%18% 6%6%

Cash Div*Cash Div* 3%3% 9%9%

Stock PriceStock Price 1%1% 5%5%

Total ReturnTotal Return 3%3% 7%7%

St. Louis & Kansas CityDeposit Market Share2

2011

US Bancorp 12%

BoA 12%

Commerce 9%

UMB 6%

Others 61%

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

7

ABOUT OUR MARKETS

1.Community markets include Wichita, Springfield, Columbia, Peoria and Bloomington2. 2011 households in county with CBI branch3. U.S. Bureau of Labor Statistics as of November 2011Sources: FDIC, Nielsen and U.S. Bureau of Labor Statistics

Kansas City St. Louis Denver Tulsa

Community Markets1

2010 Population (000’s)

2,031 2,835 2,582 930 1,759

5-year projected Population Growth

4.0% 1.7% 7.2% 3.5% 3.9%

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

Median Household Income (000’s)

$57 $54 $62 $47 N/A

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

2011 FDIC CBI Deposits (000’s)

$5,447 $4,888 $115 $122 $2,831

Deposit Share in footprint

13.2% 7.5% 3.8% 0.7% 7.0%

8

SUPER-COMMUNITY BANK PLATFORM

Super-Regional Back End • Sophisticated payment processing systems

• Broad consumer product offerings

• Private banking; trust; capital markets

• Competitive on unit costs

A More Nimble Format … With Higher Service Focus

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

Community Bank Front End• Flat organization – quick decisions

• Employees embrace strong culture• Award winning customer service• Knowledge of customers and markets

reduces risk

9

ENGAGEMENT SCORES AT COMMERCE BANK HOLD STRONG

87%U.S. Financial Services Companies’ Norm

92%U.S. High Performance Companies’ Norm

Percent Favorable

94%2010 Commerce Bank

94%2011 Commerce Bank

Engagement Index (historical scale)

Engagement Index (normative scale)

87%2006 Commerce Bank

89%2007 Commerce Bank

80%2004 Commerce Bank

89%2008 Commerce Bank

92%2009 Commerce Bank

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

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

10

INDUSTRY RECOGNITION

America’s Best Banks by Forbes

Commerce ranked among the top ten on Forbes’ list of America's Best Banks three years in a row

Bank Directors’ Top Banks

Commerce ranked #7 on Bank Director magazine’s 2011 Top 150 Bank Performance Scorecard

11

• Balanced mix of interest and non-interest income

• Meaningful, growing contribution from wealth management and card businesses

DIVERSE REVENUE SOURCES

9%

8%

14%

8%

2%

59%

Commerce Bank

8%

9%

4%

7%

3%

69%

Peer Banks

Card income

Wealth management

Other

Deposit service charges

Fees & commission

Net interest income

Note: Excludes Gains and Losses on Securities; Wealth Management excludes BrokerageSource: Financial Information Systems; data as of 12/31/2011

Peer Banks include: ASBC, BOKF, Central Bancompany, CYN, CFR, FMER, MBFI, PVTB, TCB, UMBF, WTFC, ZION

12

EARNINGS

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

($ millions) 2009 2010 201111 vs. 10

% 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%

13

REVENUE TRENDS

($ millions) 2009 2010 201111 vs.10

% 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

14

*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**Source: SNL Financial, excludes BAC

EXPENSES

($ millions) 2009 2010 201111 vs.10

% 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**

15

NET INTEREST INCOME: 2007 – 2011, TAX EQUATED

4245

6652133

653146

6081942

5471037

700

$750

650

600

550

50012/31/11

$668

12/31/1012/31/0912/31/0812/31/0712/31/06

$520

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

Net Interest Income$ in thousands (tax equivalent)

• 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

16

INVESTMENT PORTFOLIO: HIGH QUALITY, DIVERSE, SHORT DURATION

31.8%

13.7%

Source: InTrader

Weighted rate

Weighted Life(years)

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

12/31/2011 Portfolio

Total investments $9.4 billionUnrealized gain $160 million12 mo maturities $1.6 billion

DurationDec 2011 2.10 yrsDec 2010 2.08 yrsDec 2009 2.09 yrs

Treasury & agency Municipal

Agency MBS Other asset-backed

Corporate Other

17

LOANS – DIVERSE PORTFOLIO; CONSUMER GREATER THAN PEERS

Commerce BankCommercial: 59% Consumer: 41%

Peer BanksCommercial: 72%Consumer: 28%

Growth initiatives in 2011$ in millions

Owner occupied & multi-family $98

Auto lending 56

Tax-free 69

Other Commercial 42

Total $265

Factors reducing growth in 2011$ in millions

Run-off in construction $74

Strategic decline Marine/RV 115

Unplanned Comml payoffs 108

Lower Ag lending 202

Total $499

9%

24%

16%

16% 4%

31%

Consumer Card

Consumer & HELOC

Personal RE

Business RE

Construction

Business

33%

6%

0%11%

17%33%

Peer Banks include: ASBC, BOKF, Central Bancompany, CYN, CFR, FMER, MBFI, PVTB, TCB, UMBF, WTFC, ZION Data as of 12/31/2011

18

• CD’s comprised 15% of portfolio in 2011 vs. 32% in 2007

• Cost of deposits in 2011 was .42% compared to peer average of .52%

STRONG DEPOSIT GROWTH IN BOTH CONSUMER AND CORPORATE DEPOSITS

$16.8

$15.1

$14.2

$12.6$12.9

$17

16

15

14

13

12

+8%

20112010200920082007

Total deposits$ in billions

$ in billions 2007 2011Deposit growth

Consumer & Private Banking

$9.4 $10.5 12%

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

19

RISK MANAGEMENT REMAINS AN IMPORTANT PART OF OUR CULTURE

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

1.2%

1.0

0.8

0.6

0.4

0.2

0.0

$120

100

80

60

40

20

02011201020092008200720062005200420032002

OREO Non-accrualNon-performing to loans

Non-p

erf

orm

ing a

ssets

$ in

mill

ions

Non-p

erf

orm

ing

ass

ets

to loans

(%)

20

ASSET QUALITY - SELECT LARGE-CAP AND PEER BANKS4TH QUARTER 2011

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

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%

CHARGE-OFFS CONSISTENTLY BETTER THAN INDUSTRY

Source: Federal Reserve Statistical Release, not seasonally adjusted

Largest 100CBINet Charge-Off Rates for CBI vs. Large Banks

0.00%

0.20%

0.40%

0.60%

0.80%

1.00%

1.20%

1.40%

Dec-11Sep-11Jun-11Mar-11Dec-100.00%

0.50%

1.00%

1.50%

2.00%

2.50%

3.00%

Dec-11Sep-11Jun-11Mar-11Dec-10

0.60%

0.80%

1.00%

1.20%

1.40%

1.60%

1.80%

2.00%

Sep-11Jun-11Mar-11Dec-10 Dec-11

8.00%

7.00%

6.00%

5.00%

4.00%

Dec-11Sep-11Jun-11

3.00%

Mar-11Dec-10

Business C&I Net C/Os

Credit Card Net C/Os

Commercial R/E Net C/Os

Consumer Net C/Os Credit Card Net C/Os

0.30%

1.33%

0.55%

2.68%

1.72%

2.00%

4.97%

7.72%

1.08%

0.28%

1.63%

0.48%

1.28%

1.83%6.99%

4.73%

0.74%

0.20%0.23%

1.52%

0.78%

1.37%

4.57%

5.60%

0.14%

0.68%

0.42%

1.29%

1.07%

1.34%

3.87%

5.67%

21

0.14%

0.66%

0.53%

1.15%

0.93%

1.40%

3.78%

4.54%

22

STRONG CAPITAL POSITION – ALL COMMON

40

20

0

$250

200

150

100

50

020112010200920082007200620052004

140%

120

100

80

60

Treasury stockCash dividendPayout %

$ in

mill

ions

% to N

et

Inco

me -

com

bin

ed

Year-end capital ratios

Tangible common equity to assets 9.91%

Tier 1 risk-based capital 14.74%

Total risk-based capital 16.01%

23

Grow our specialty bank business…

Run the Core Bank more efficiently…

Invest in our people and future leaders…

KEY PRIORITIES FOR 2012 REFLECT THE CURRENT BANKING ENVIRONMENT

• Grow Commercial profit while improving return on capital

• Rebuild the Retail Banking model

• Retain and develop our top performers and future leaders

• Recruit and hire the best talent

• Accelerate growth in the wealth management business

• Invest in innovation, and explore new business line opportunities

• Continuously improve operational efficiency

• Deepen and broaden payments relationships and capabilities

• Address underperformance

24

CORE COMMERCIAL: 2012 KEY INITIATIVES

Identify New Loan Opportunities

• Improve segmentation by industry and product

• Market private placement of tax-advantaged loans

• Capitalize on increase in commercial real estate financing

Coordinate and Expand Healthcare Banking

• Increase market share through systematic sales effort by industry specialists

• Introduce Healthcare suite: mPay Gateway, RemitConnect and HSF

• Educate and train officers through quarterly Healthcare Forum

Expand Regional Presence

• Target middle market companies focusing on Commerce suite of services

• Continue to make opportunistic hires in expansion markets

• Potential Texas loan production office

• Open Denver Tech Center location

Focus on Comprehensive Payment System

• Customer focused needs based messaging

• Increase data mining for targeted prospect identification

• Improve campaign management tactics and strategies

Enhance Marketing and Officer Productivity

• Coordinate calling strategies for Corporate Card and Merchant Services

• Focus on increasing referrals, contribution and penetration rates

• Provide training on fraud prevention and security procedures

• Introduce integrated payables

25

CORE COMMERCIAL – SEGMENTING TO MORE EFFECTIVELY TARGET PROSPECTS

-9%

158%

93%

29% 24% 14%

-50%

0%

50%

100%

150%

200%

Total Loans Tax Free Expansion Mkts Healthcare Beverage Agribusiness

Loan Growth by Category 2007-2011

Industry Healthcare

Energy

Ag & Food Processing

Not-For-Profit

Beverage Distributors

Manufacturing

ESOP’s

Student Housing

Municipalities/Education

Other

Product Opportunity Interest Rate Swaps

Leasing

Tax-advantaged financing

SBA

Missouri Linked Deposit

Floor Plan Lending

Hospital Services Financing

RemitConnect

mPay Gateway

International Services

Commercial L/C’s

Other

Competitors Troubled Institutions

Relationship Management Issues

Drop In Service Levels

Other Issues

26

CORE RETAIL: 2012 KEY INITIATIVES

Focus on Value-Based Revenue Streams

• Develop new and reposition existing products that provide value to customers

• Relationship Advance, accessory sales (ID theft, checks, GPR)

Focus on Profitable Loan Growth

• Focus on multi-channel increase in volumes (branch, direct mail, web, inside sales) and more efficient delivery (systems, underwriting, risk)

Expand Key Customer Relationships

• Expand customer relationships through effective targeting, messaging and special offers

Transition Sales Force into new Sales Environment

• Guide the sales force through the changes driven by the shift away from a “free” checking model

Define Future Branch Strategy

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

Execute Future Online Strategy

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

Talent Management • Address the competencies required from our sales force

27

CORE RETAIL – FOCUS ON OPERATIONAL EXCELLENCE FOR EXPENSE SAVINGS CRITICAL TO SHORT-TERM SUCCESS

Core Retail Total Expense$ in millions

Check processing

Other

Customer checks

Online banking

2011

$15.5

$4.0

$3.2

$2.6

$2.4

$2.1

$1.2

Teller costs

FDIC Insurance

$240

220

230

2010 2011

235

215

225

7% reduction

• Focused on productivity to offset loss of retail revenues

• Closed/merged 10 branches in last 2 years

• Imaging technologies have reduced paper related costs while better servicing customers – longer hours in some locations

28

REBUILDING CORE RETAIL REVENUE

• Debit and OD fees make up 79% of total core retail fees

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

Core Retail efforts will expand menu of accessory products and services to help mitigate lower debit fees

• “myAdvance” – short-term consumer lending

• Expanded branch focus and sales of consumer loans

• Increase in ATM revenues – domestic and international

• Theft ID Restoration

• Interchange network adjustments

• Growth in check sales revenues

• Expanded service fees from sales of non-free checking

20

40

60

80

100

$120

0

$109

2011

OD

Debit

Dep fees

ATM

Check sales

Mtge banking

Other

Core Retail Fee Income$ in millions

29

COMMERCE TRUST COMPANY – SOLID GROWTH IN FEES AND ASSETS

• Record asset management sales three years in a row

• Account attrition has remained low for last 5 years

• $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

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.

$23

$90

85

80

75

70

$30

25

20

15

10

5

02011

$27

2010

$25

2009

$22

2008

$19

2007

Trust AssetsTrust Fees

Tru

st A

ssets

$ in b

illio

ns

Tru

st F

ees

$ in m

illio

ns

*Source: SNL Financial – Total managed fiduciary related assets as of December 31, 2011

30

COMMERCE TRUST COMPANY – 2012 KEY INITIATIVES

Core Private Client Growth

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

Commerce Family Office

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

Expand Institutional Product Offering

• Invest in flagship fixed income products and expand product set and sales resources for 401(k) and investment consulting

Complete Restructuring of Commerce Brokerage

Consider Strategic Acquisitions

• Explore strategic acquisitions to supplement organic growth initiatives

• Upgrade and expand sales force, while streamlining the back office for more profitable margins

31

CARD PRODUCTS – A LEADER IN THE PAYMENTS INDUSTRY

Consistently ranked among the top issuers in the Nilson Report

Debit / Prepaid Card

Consumer Card

Merchant Services

Commercial Card

#10 Purchasing Card Issuer

#12 Bank Acquirer*

#23 Consumer Card Issuer

#35 Debit Card Issuer

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

VISA Service Quality Performance Award Winner

*Excludes non-bank acquirersSource: 2011 Nilson Reports (Debit: April, 2011; Consumer Card: June, 2011; Merchant: March, 2011; Commercial Card June, 2011)

#14 Commercial Card Issuer

32

CONSUMER CARD - PROFITABILITY REMAINED STRONG THROUGHOUT THE CYCLE

• 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

Consumer Credit Card Trends$ in millions

Loan b

ala

nce

s

5

0

$800

750

700

650

600

550

500

+5%

201120102009200820072006

$40

35

30

25

20

15

10

Loan balancesPre-tax profit

Pre

-tax

pro

fit

33

CONSUMER CARD – 2012 KEY INITIATIVES

Merchant Funded Rewards

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

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

Grow Quality Loans

• Leverage direct mail and convenience checks to grow active accounts and outstandings

• Utilize predictive analytics and customer insight to optimize response through various channels.

Transactor Focus• Increase proportion of “transactor” customers to better

balance revenue streams (decrease reliance on revolving customer balances)

34

COMMERCIAL CARD AND MERCHANT SERVICES 2012 KEY INITIATIVES

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

New Product Development

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

Alternative Sales Channels

• Expand sales in a cost effective and controlled manner by establishing “preferred vendor” relationships

• Franchises, Associations, Agent Banks, BIN Sponsorships, 3rd Party Vendors

Acquisition Strategy Development

• Fully define and approve an acquisition strategy

New Product Development

• Recognize and develop new products

• Certified Internet Gateway, mPay Gateway, International processing

Credit Strategy

B2B Payment Strategy

Co

mm

erc

ial

Ca

rdM

erc

ha

nt

Se

rvic

es

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

• Implement Merchant Services referral program from Card employees and data mine enrolled vendors for large Merchant opportunities

35

COMMERCIAL CARD: GROWTH OPPORTUNITIES IN THE PAYMENTS SYSTEM

• 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

Commercial Card Revenue$ in millions

$60

50

40

30

20

10

0

+30%

2011

$57.8

2010

$48.3

2009

$32.2

2008

$25.9

2007

$20.2

Commercial Card Expansion IIAgent BankCommercial Card Expansion IExisting

36

M&A OUTLOOK

Source: SNL Bank M&A Scorecard: 2011 in Review

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 remains a strategic buyer

• Augment expansion markets if right fit becomes available

• Management “lift-outs” are attractive, especially in asset management

Commerce Focus

COMMERCE IS A STRATEGIC BUYER – ORGANIC GROWTH IS PRIORITY ONE

37

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

$1.00

$1.40

$1.80

$2.20

$2.60

$3.00

$6.00

$7.00

$8.00

$9.00

$10.00

$11.00

$12.00

$13.00

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Earn

ing

s P

er

Sh

are

Reven

ue

Per

Sh

are

Revenue Per Share Earnings Per Share

*Restated for 5% stock dividend distributed in December 2011**Reflects Top 50 banks total dividends paid in 2007 compared to 2010Source: SNL Financial

Dividends per share*

$0.40 $0.50 $0.62 $0.68 $0.73 $0.78 $0.82 $0.83 $0.85 $0.88

RECORD EPS AND CONTINUED DIVIDEND GROWTH

Commerce Bank dividend increased for the 44th consecutive yearand paid its 18th consecutive 5% stock dividend

More than three-fourths of large banks cut or eliminated their dividend since 2007**

38

39

STEADY SHAREHOLDER RETURNS IN A HIGHLY VOLATILE MARKET

*Assumes reinvested dividends, multi-year returns are annualizedSources: Bloomberg, American Banker

Total shareholder returns*Indexed, 12/31/2001 = 100

50

100

150

200

KBW BANK INDEX

S&P 500INDEX

NASDAQBANKS

COMMERCEBANK Total Shareholder Returns*

Percent

1 yr1 yr 3 yr3 yr 5 yr5 yr 10 yr10 yr

CBSHCBSH 3.1%3.1% 2.7%2.7% 2.6%2.6% 7.0%7.0%

S&P 500S&P 500 2.1%2.1% 14.1%14.1% (0.3%)(0.3%) 2.9%2.9%

NASDAQ NASDAQ BanksBanks

(10.5%)(10.5%) (4.0%)(4.0%) (12.5%)(12.5%) (1.7%)(1.7%)

KBW KBW Bank Bank IndexIndex

(23.2%)(23.2%) (2.4%)(2.4%) (17.5%)(17.5%) (4.8%)(4.8%)

201120092007200520032001

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