SecProbe.io

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      August 30, 2005

     Mail Stop 4561
Richard J. Morgan
President and Chief Executive Officer
CommerceFirst Bancorp, Inc.
1804 West Street
Annapolis, MD 21401

      Re:	CommerceFirst Bancorp, Inc.
		Form 10-K for the period ended December 31, 2004
		File No. 0-51104

Dear Mr. Morgan:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  In some of our comments, we may ask
you
to provide us with information so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Exhibit 13 - 2004 Annual Report

Consolidated Financial Statements

Note 10 - Income Taxes, page 28

1. We note that you recorded a $944 thousand reduction of your
valuation allowance during the fiscal year 2004, reducing it to
zero.
Please refer to paragraphs 21 - 23 of SFAS 109 and provide us with
your comprehensive analysis of how you determined the amount of
your
deferred tax asset valuation allowance as of December 31, 2003 and
December 31, 2004.

Item 8A - Controls and Procedures, page 11

2. We note your disclosure that your principal executive officer
and
principal financial officer have concluded that the Company`s
disclosure controls and procedures were adequate.  It does not
appear
that your certifying officers have reached a conclusion that your
disclosure controls and procedures are effective.  Please tell us
your certifying officers` conclusions regarding the effectiveness
of
your disclosure controls and procedures as of December 31, 2004.
Please revise your disclosures in future filings to address your
officers` conclusions regarding the effectiveness of your
disclosure
controls and procedures.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a response letter that keys your responses to our
comments and provides any requested information.  Detailed letters
greatly facilitate our review.  Please file your response letter
on
EDGAR.  Please understand that we may have additional comments
after
reviewing your responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

You may contact Sharon Johnson, Staff Accountant, at (202) 551-
3474
or me at (202) 551-3449 if you have questions.

      Sincerely,

      Joyce Sweeney
								Branch Chief

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Richard J. Morgan
CommerceFirst Bancorp, Inc.
August 30, 2005
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