CBSI Institutional
Division

Commerce Bank expanded its Institutional Fixed Income business with the development of the Institutional Division of our Broker Dealer, Commerce Brokerage Services, Inc. (CBSI). This new Institutional Division will complement Commerce Bank’s existing Capital Markets Group (CMG). The business activities of this new Institutional Division of CBSI will primarily be operated by the incumbent supervisory principals and staff of CMG. The Institutional Division will allow us to offer clients access to DTCC’s Central Trade Management Platform (CTM) for trade allocation and matching through our clearing relationship with National Financial Services LLC (NFS). The NFS clearing relationship will also connect us with the Continuous Net Settlement (CNS) network for an enhanced settlement experience. Building on the outstanding reputation, values and culture of one of America’s premier financial institutions, CBSI takes a conservative, consultative approach to helping meet the fixed income investment needs of financial institutions, money managers, hedge funds, insurance companies and state and local governments.

Collaborating with the right service provider who can offer knowledgeable solutions and prudent investment strategies is critical to making your money work harder toward achieving your goals.

For general inquiries, please email us at: CBSIInstitutionalDivision@CommerceBank.com

Commerce Brokerage Services, Inc. (CBSI) Business Continuity Statement

Business continuity plan

Since the timing and impact of disasters and disruptions are unpredictable, our firm has an obligation to prepare for unforeseen events as they occur. Our Business Continuity Plan (BCP) is designed to permit our firm to resume operations in a reasonable amount of time at a secure remote location, given the scope and severity of a major event.

Varying disruptions

If a business disruption affects only our firm or a specific building within our firm, we will transfer our operations to a local worksite. In a disruption affecting our business district, city, or region, we will transfer our operations to an alternate worksite outside of the affected area. In either situation, we plan to continue conducting business and notify our clients how to contact us through a voice message reached via our main telephone number.

In order to accommodate our recovery time objective, telephone service will continue, and normal work processes will resume at the alternate worksite. Recovery times may vary depending on the nature and severity of the disruption; however, our recovery time objective for mission critical operations is 0-72 hours. If the significant business disruption is so severe that it prevents us from conducting business, we will update our voice message.

Contacting us

At a minimum, CBSI’s business continuity plan is reviewed and updated on an annual basis. Additionally, our primary internal and external application providers periodically conduct testing of their own back-up capabilities to ensure that, in the event of an emergency or significant business disruption, they will be able to provide us with the critical information and applications we need to continue or promptly resume our business. Our business continuity plan is designed to allow us to continue to provide the quality service you have come to expect from CBSI.

If after a significant business disruption, if you are having difficulty reaching CBSI, you should call our alternative emergency number at (816) 234-1837 or check back to this website.

Order Routing

On November 17, 2000, the United States Securities and Exchange Commission adopted Exchange Act Rules 11Ac1-5 and 11Ac1-6 to provide further visibility to the investing public regarding the execution quality of the securities markets and the order routing practices of registered brokerage firms.

Rule 11Ac1-5 generally requires market centers that trade national market securities to make available to the public monthly electronic reports that include uniform statistical measures of execution quality for market orders or limit orders received or executed during regular market trading hours.

Rule 11Ac1-6 generally requires broker/dealers that route customer orders in national system securities, NASDAQ SmallCap equities, and listed options to make publicly available quarterly reports that disclose venues to which they route non-directed orders. It also requires broker/dealers to disclose the nature of any relationship they have with those venues, including any payment for order flow arrangements.

A copy of this quarterly report is available to Commerce Customers by clicking on the link below. You may review the report online or obtain a copy by electing to print the report directly from the web site. You may also request a copy of our most recent quarterly report be provided, without charge, by writing us at 1000 Walnut Suite 300, Kansas City, Missouri 64106 or by phoning 816-234-1837.

The report will compile order routing statistics for all Commerce Brokerage Services clients for that particular quarter. The provisions of Rule 11Ac1-6 also require Commerce Brokerage to provide, upon request, information regarding the venues to which your particular account orders were routed. Requests regarding your particular account must be made by writing us at 1000 Walnut Suite 300 Kansas City, Missouri 64106.

Information regarding your account for the prior six months is available for the following types of requests:

• Order Routing history for all of your account orders
• Order Routing history for a specific date or date range (within the last 6 months)
• Order Routing for a specific security traded in your account based upon its symbol
• Order Routing for a specific security traded in your account based upon its symbol and date range

As customers of Commerce Brokerage Services, Inc we encourage you to review the order execution and order routing information contained in our most recent quarterly report.

Click links below for current reports.

Previous Order Routing reports.