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Drinker Biddle & Reath LLP
One Logan Square, 18th and Cherry Streets
Philadelphia, PA 19103-6996
(215) 988-2700
February 28, 2000
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 dated
March 1, 2000 for the Institutional and Service Shares of the Trust 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 #10"), which was filed on February 25,
2000; and (ii) the text of PEA #10 has been filed electronically.
Questions and comments concerning this letter may be directed to
the undersigned at (215) 988-1146.
Very truly yours,
/s/ Diana McCarthy
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Diana McCarthy
DEM:tsw
