| Commerce Bancshares, Inc. 1000 Walnut, P.O. Box 13686 Kansas City, MO 64199-3686 October 9, 2001 Via e-mail to GLB501Rule@ftc.gov Secretary Attention: Gramm-Leach-Bliley Act Privacy Safeguards Rule, 16CFR Part 314 - Comment Dear Sir or Madam, Commerce Bancshares, Inc. is a registered bank holding company with total assets of $11.7 billion at June 30, 2001, and four bank subsidiaries. Three of these banks are retail banks, with approximately 340 locations in Missouri, Illinois, and Kansas. The other bank is a limited-purpose bank, with one office in Omaha, Nebraska. All of the banks are national banks, subject to the enforcement authority of the Office of the Comptroller of the Currency. The Company also has operating subsidiaries involved in mortgage banking, credit related insurance, venture capital, and real estate activities. The Federal Trade Commission has requested comments on the proposed rule outlining Standards for Safeguarding Customer Information. We have reviewed the proposed rule and find it to generally parallel the joint final rule - Interagency Guidelines Establishing Standards for Safeguarding Customer Information published by the Banking Agenc ies on February 1, 2001. We thank you for attempting to ensure that your final rule complements that of the Banking Agencies. In light of this we ask that you accept the rule as proposed. Thank you for considering our comments. Sincerely, Lynn Tankesley |