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Law Offices
Drinker Biddle & Reath LLP
Philadelphia National Bank Building
1345 Chestnut Street
Philadelphia, PA 19107-3496
Telephone: (215) 988-2700
Fax: (215) 988-2757
March 6, 1998
VIA EDGAR TRANSMISSION
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Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, NW
Washington, DC 20549
Re: The Commerce Funds
File Nos. 33-80966/811-8598
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Ladies and Gentlemen:
On behalf of The Commerce Funds (the "Trust") and pursuant to Rule
497(j) under the Securities Act of 1933, as amended (the "1933 Act"), I hereby
certify that the Prospectuses and Statement of Additional Information, each
dated March 2, 1998 for Institutional and Service Shares (as applicable) of the
National Tax-Free Intermediate Bond, Missouri Tax-Free Intermediate Bond, Short-
Term Government, Bond, Balanced, Growth and Income, Growth, MidCap and
International Equity Funds that would have been filed under paragraph (c) of
Rule 497 under the 1933 Act would not have differed from the Prospectuses and
Statement of Additional Information contained in the Trust's most recent Post-
Effective Amendment to its Registration Statement on Form N-1A under the 1933
Act and the Investment Company Act of 1940, as amended, ("PEA #7"), which was
filed on March 2, 1998; and (ii) the text of PEA #7 has been filed
electronically.
Questions and comments concerning this letter may be directed to the
undersigned at (215) 988-1146.
Sincerely,
/s/ Diana E. McCarthy
Diana E. McCarthy
