Consent of Independent Auditors

We consent to the incorporation by reference in the Registration  Statements and
related Prospectuses (Forms S-3 No. 333-87512,  No. 333-73421, No. 33-40465, No.
333-36704,  No.  333-107780,  No.  333-105861  and  Form S-4 No.  333-10771)  of
Commerce  Bancorp,  Inc.  and in the  Registration  Statements  (Forms  S-8  No.
33-82742,  No. 33-82740,  No.  333-26965,  No.  333-57497,  No.  333-37764,  No.
333-40386, and No. 333-106941) pertaining to the Stock Option Plans and Employee
Stock Purchase Plan of Commerce  Bancorp,  Inc. of our report dated February 16,
2004 with respect to the consolidated  financial statements of Commerce Bancorp,
Inc. and  Subsidiaries  included in this Annual  Report (Form 10-K) for the year
ended December 31, 2003.

                                                        /s/ Ernst & Young LLP

Philadelphia, Pennsylvania
March 12, 2004