Consent of Independent Registered Public Accounting Firm



We consent to the  incorporation  by  reference in the  Commerce  Bancorp,  Inc.
Registration  Statement  (Form S-8 No.  333-26965)  pertaining  to the  Commerce
Bancorp,  Inc.  401(k)  Retirement  Plan of our report dated June 11, 2004, with
respect to the financial  statements and schedule of the Commerce Bancorp,  Inc.
401(k)  Retirement  Plan included in this Annual Report (Form 11-K) for the year
ended December 31, 2003.

                                                        /s/  Ernst & Young LLP

Philadelphia, Pennsylvania
June 25, 2004