This report does not constitute a rating action. ALAC--Additional loss-absorbing capacity. CRA--Comparable ratings analysis. GRE--Government-related entity. ICR--Issuer credit rating. SACP--Stand-alone credit profile. Overview Key strengths Key risks Strong capital ratios and consistent profitability Substantial geographic concentration in the Midwest, most notably in Kansas and Missouri Historically strong credit quality Fairly modest domestic market share, especially when compared with the market shares at similarly rated peers High noninterest income contribution, helping revenue stability and diversification Strong funding metrics and a low-cost deposit franchise, aided by its large proportion of noninterest-bearing deposits Our ratings on Commerce Bancshares Inc. reflects its strong customer relationships, stable business franchise, and diversified revenue profile, though offset by significant geographic concentrations. Commerce is geographically concentrated in the
