Ownership Submission
FORM 4
Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934, Section 17(a) of the Public Utility Holding Company Act of 1935 or Section 30(h) of the Investment Company Act of 1940
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(Print or Type Responses)
1. Name and Address of Reporting Person *
PAULS DOUGLAS J
   2. Issuer Name and Ticker or Trading Symbol
COMMERCE BANCORP INC /NJ/ [CBH] 		5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)
_____ Director _____ 10% Owner
__X__ Officer (give title below) _____ Other (specify below)
Senior Vice President
(Last)
(First)
(Middle)
COMMERCE BANCORP, INC., 1701 ROUTE 70 EAST		 3. Date of Earliest Transaction (Month/Day/Year)
11/22/2004
(Street)

CHERRY HILL, NJ 08034		 4. If Amendment, Date Original Filed(Month/Day/Year)
 6. Individual or Joint/Group Filing(Check Applicable Line)
_X_ Form filed by One Reporting Person
___ Form filed by More than One Reporting Person
(City)
(State)
(Zip)
Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1.Title of Security
(Instr. 3)		 2. Transaction Date (Month/Day/Year) 2A. Deemed Execution Date, if any (Month/Day/Year) 3. Transaction Code
(Instr. 8)		 4. Securities Acquired (A) or Disposed of (D)
(Instr. 3, 4 and 5)		 5. Amount of Securities Beneficially Owned Following Reported Transaction(s)
(Instr. 3 and 4)		 6. Ownership Form: Direct (D) or Indirect (I)
(Instr. 4)		 7. Nature of Indirect Beneficial Ownership
(Instr. 4)
Code V Amount (A) or (D) Price
Common Stock               6,274 D  
Common Stock 11/22/2004   J(4)   8 A $ 5,779 654 I By Wife
Common Stock               5,391 I ESOP Allocation

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Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned
(e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security
(Instr. 3)		 2. Conversion or Exercise Price of Derivative Security 3. Transaction Date (Month/Day/Year) 3A. Deemed Execution Date, if any (Month/Day/Year) 4. Transaction Code
(Instr. 8)		 5. Number of Derivative Securities Acquired (A) or Disposed of (D)
(Instr. 3, 4, and 5)		 6. Date Exercisable and Expiration Date
(Month/Day/Year)		 7. Title and Amount of Underlying Securities
(Instr. 3 and 4)		 8. Price of Derivative Security
(Instr. 5)		 9. Number of Derivative Securities Beneficially Owned Following Reported Transaction(s)
(Instr. 4)		 10. Ownership Form of Derivative Security: Direct (D) or Indirect (I)
(Instr. 4)		 11. Nature of Indirect Beneficial Ownership
(Instr. 4)
Code V (A) (D) Date Exercisable Expiration Date Title Amount or Number of Shares
Right to Buy (1) $ 9.57 12/18/1996   A     3,110 12/18/1997 12/18/2006 Common Stock 3,110 $ 0 3,110 D  
Right to Buy (1) $ 16.1 12/16/1997   A   11,976   12/16/1998 12/16/2007 Common Stock 11,976 $ 0 11,976 D  
Right to Buy (1) $ 21.85 12/15/1998   A   18,534   12/15/1999 12/15/2008 Common Stock 18,534 $ 0 18,534 D  
Right to Buy (1) $ 19.28 12/21/1999   A   21,000   12/21/2000 12/21/2009 Common Stock 21,000 $ 0 21,000 D  
Right to Buy (1) $ 30.6 01/31/2001   A   30,000   01/31/2002 01/31/2011 Common Stock 30,000 $ 0 30,000 D  
Right to Buy (1) $ 40.12 02/04/2002   A   20,000   02/04/2003 02/04/2012 Common Stock 20,000 $ 0 20,000 D  
Right to Buy (1) $ 42.8 02/18/2003   A   25,000   02/18/2007(3) 02/18/2013 Common Stock 25,000 $ 0 25,000 D  
Right to Buy (1) $ 58.9 02/18/2003   A   25,000   02/18/2007(3) 02/03/2014 Common Stock 25,000 $ 0 25,000 D  
5.95% Conv. Trust Pref. Sec. of Commerce Capital Trust II $ 0               (2) 03/11/2032(2) Common Stock 2,000   1,895 D  

Reporting Owners

Reporting Owner Name / Address Relationships
 Director  10% Owner  Officer  Other
PAULS DOUGLAS J
COMMERCE BANCORP, INC.
1701 ROUTE 70 EAST
CHERRY HILL, NJ 08034		       Senior Vice President  

Signatures

 Douglas Pauls   11/24/2004
**Signature of Reporting Person Date

Explanation of Responses:

* If the form is filed by more than one reporting person, see Instruction 4(b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
(1) Granted under the Company's 1997 Employee Stock Option Plans, which are 16b-3 plans.
(2) Each 5.95% Convertible Trust Preferred Security is convertible at any time on or after the occurrence of certain events described below and prior to 5:00 p.m., New York City time, on the business day immediately preceding the date of repayment of such preferred security, whether at stated maturity (i.e. March 11, 2032) or upon redemption, at the option of the holder thereof, into shares of Commerce Bancorp, Inc.'s common stock at an initial conversion ratio of 0.9478 shares of Commerce Bancorp, Inc. common stock for each preferred security, subject to adjustment under certain circumstances.
(3) The stock options are exercisable in 25% increments on the 1st, 2nd, 3rd, and 4th anniversaries of the grant date.
(4) Purchase under DRIP

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