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Commerce Bancshares 401(k) retirement plan: the investment options
Does your 401(k) vote the way you would? $1.01bn of the $1.18bn in the Commerce Bancshares plan votes in secret. Fidelity 500 Index Fund, the most common fund in the plans we track, publishes every vote: answer 3 of its ballots, then see your result.
The question on the ballot
As filed
Commerce Bancshares 401(k) match and balances, from the filing
- Company money in
- about $4,150 per active participant
- $20m in plan year 2024
- Employees saved
- about $7,820 each
- $38m in plan year 2024
- Average balance
- $221,900
- 4,952 people with a balance
- In the plan
- $1.10bn
- at the end of plan year 2024
Company money is the match plus any other employer contributions, averaged over all 4,874 active participants, including anyone who did not contribute. The filing reports dollars, not the match formula; the plan’s summary plan description states the formula.
SourceThe plan’s annual report to the Department of Labor — Form 5500, Schedule H, plan year 2024 · filed by COMMERCE BANCSHARES, INC. as “COMMERCE BANCSHARES, INC. PARTICIPATING INVESTMENT PLAN” · EIN 430889454, plan number 002 · search the filings
The Commerce Bancshares 401(k) holds $1.18bn. Of the $1.01bn we could identify from the plan’s own filing, every dollar sits in a fund that publishes no record of how it voted your shares — collective trusts, which unlike a mutual fund file no Form N-PX and leave no public trace of a single vote.
SourceCommerce Bancshares’s own annual retirement-plan filing with the SEC (Form 11-K, Schedule of Assets) · open the filing
| What the plan holds | Vehicle | Voting record | Value |
|---|---|---|---|
| Spartan 500 Index Pool Class Clisted as “**” | Collective trust or separate account | NONE | $145m |
| T. Rowe Price Blue Chip Growth Fundlisted as “**” | Collective trust or separate account | NONE | $138m |
| Commerce Bancshares, Inc. Common Stocklisted as “**” | Employer stock | Voted by the plan trustee | $130m |
| Spartan Total Market Index Pool Class Clisted as “**” | Collective trust or separate account | NONE | $117m |
| Vanguard Equity-Income Fund Admiral Shareslisted as “**” | Collective trust or separate account | NONE | $52m |
| T. Rowe Price Retirement 2030 Trust Class Flisted as “**” | Collective trust or separate account | NONE | $49m |
| T. Rowe Price Retirement 2040 Trust Class Flisted as “**” | Collective trust or separate account | NONE | $41m |
| Commerce Bond Fundlisted as “**” | Collective trust or separate account | NONE | $38m |
| Vanguard Federal Money Market Fund Investor Shareslisted as “**” | Collective trust or separate account | NONE | $38m |
| Dodge & Cox International Stock Fundlisted as “**” | Employer stock | Voted by the plan trustee | $37m |
| T. Rowe Price Retirement 2050 Trust Class Flisted as “**” | Collective trust or separate account | NONE | $36m |
| T. Rowe Price Retirement 2035 Trust Class Flisted as “**” | Collective trust or separate account | NONE | $35m |
The 12 largest holdings in the plan. “Vehicle” is the description the filing itself gives each investment.
Why there is nothing to show
A mutual fund has to file Form N-PX every year listing every vote it cast on your behalf. A collective investment trust does not. It is a bank-run vehicle sold only inside retirement plans, it is cheaper, and it is now where most 401(k) default money sits — including most target-date funds, which is where savers who never chose anything are put.
So the shares bought with Commerce Bancshares employees’ retirement savings are voted every proxy season — on executive pay, on board seats, on climate and workforce proposals — and there is no public document anywhere recording how. This is not an oversight by Commerce Bancshares; it is what the disclosure rules currently require, which is to say: nothing.
What you can do
Check whether your plan offers any registered fund as an alternative — those publish their records, and you can read them here. If it does not, the menu itself is the thing that has to change, and that is a decision made by the plan’s fiduciary committee, not by you alone.
See how funds that do publish voted →
CoverageWe classified 100% of this plan’s assets from the filing. The figure above is the share of the money we could classify; anything we could not identify is excluded from it rather than assumed either way.
Other employer plans
The largest employer plans on the site, and a few more. Each page shows what the plan’s funds did with the shares its savers paid for.