# Commerce Investment Advisors, Inc.

> Commerce Investment Advisors, Inc. is an SEC-registered investment advisory firm in Kansas City, MO, registered since 2001, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated March 13, 2026.

- CRD: 104705
- Filed as: COMMERCE INVESTMENT ADVISORS, INC.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Kansas City, MO
- Filing period: October 2026
- Form ADV filing dated: March 13, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/104705
- AdvisorCensus page: https://advisorcensus.com/firm/commerce-investment-advisors-inc-kansas-city-mo-104705

## Quick answers

**How is Commerce Investment Advisors, Inc. compensated?**
On its Form ADV (Item 5.E, October 2026), Commerce Investment Advisors, Inc. reports these compensation arrangements: a percentage of assets under its management. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Commerce Investment Advisors, Inc. located?**
Commerce Investment Advisors, Inc.'s principal office is in Kansas City, MO, according to its Form ADV; the April 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Commerce Investment Advisors, Inc. registered with the SEC or a state?**
Commerce Investment Advisors, Inc. is an SEC-registered investment advisory firm, registered since 2001. Status as filed: Approved. CRD 104705.

**How much does Commerce Investment Advisors, Inc. manage?**
Commerce Investment Advisors, Inc. reports $2,535,873,300 in regulatory assets under management in its Form ADV filing dated March 13, 2026 (100% discretionary).

**How have Commerce Investment Advisors, Inc.'s assets and staff changed since 2021?**
In the Form ADV data for Commerce Investment Advisors, Inc.: Regulatory assets under management: $3,104,190,379 in the October 2021 data and $2,535,873,300 in the October 2026 data, down 18%. Total employees: 36 in October 2021 and 34 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Commerce Investment Advisors, Inc. serve?**
By number of clients on Form ADV Item 5.D: investment companies (9).

**Does Commerce Investment Advisors, Inc. report any disciplinary disclosures?**
Reports 3 disclosure items on Form ADV Item 11: yes answers to 11.C(2) (SEC or CFTC finding of a violation), 11.C(4) (SEC or CFTC order), and 11.C(5) (SEC or CFTC civil money penalty or cease-and-desist order). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/104705

**What changed in Commerce Investment Advisors, Inc.'s recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 35 to 34. Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management

### Regulatory assets under management (Item 5.F)
- Total: $2,535,873,300
- Discretionary: $2,535,873,300
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Investment companies | 9 | $2,535,873,300 |

### Advisory services (Item 5.G)
- Portfolio management for investment companies (and business development companies)

### Firm details
- Registered since: 2001 (25 years)
- Employees: 34 total, 34 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: MO
- Disclosures (Item 11): Reports 3 disclosure items on Form ADV Item 11.

### Item 11 questions answered yes
- 11.C(2): Has the SEC or the CFTC ever found that the firm or an advisory affiliate was involved in a violation of SEC or CFTC regulations or statutes?
- 11.C(4): Has the SEC or the CFTC ever entered an order against the firm or an advisory affiliate in connection with investment-related activity?
- 11.C(5): Has the SEC or the CFTC ever imposed a civil money penalty on the firm or an advisory affiliate, or ordered the firm or an advisory affiliate to cease and desist from an activity?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/104705

### Other offices (Schedule D, Section 1.F), as of the April 2026 filing
- St. Louis, MO

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $3,104,190,379 | 36 | September 2, 2021 |
| October 2022 | $2,944,239,455 | 37 | April 18, 2022 |
| October 2023 | $2,554,571,399 | 34 | August 18, 2023 |
| October 2024 | $2,700,724,346 | 36 | March 26, 2024 |
| October 2025 | $2,641,358,832 | 35 | March 28, 2025 |
| October 2026 | $2,535,873,300 | 34 | March 13, 2026 |

Regulatory assets under management: $3,104,190,379 in the October 2021 data and $2,535,873,300 in the October 2026 data, down 18%.
Total employees: 36 in October 2021 and 34 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 35 to 34.
- Updated its list of owners and control persons (Schedule A).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Commerce Investment Advisors, Inc. (CRD 104705): Form ADV filing data as of October 2026.