Exhibit 23.1






            Consent of Independent Registered Public Accounting Firm


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,  No.  333-120715 and No.  333-106941)  pertaining to the Stock Option
Plans and Employee Stock Purchase Plan of Commerce Bancorp,  Inc. of our reports
dated March 15, 2005 with respect to the  consolidated  financial  statements of
Commerce Bancorp,  Inc., Commerce Bancorp, Inc.  management's  assessment of the
effectiveness   of  internal   control  over   financial   reporting,   and  the
effectiveness of internal control over financial  reporting of Commerce Bancorp,
Inc., included in this Annual Report (Form 10-K) for the year ended December 31,
2004.


                                                         /s/ Ernst & Young LLP

Philadelphia, Pennsylvania
March 16, 2005