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[1ST CONSTITUTION BANCORP LETTERHEAD]

December 5, 2005Mr. John P. Nolan

Accounting Branch Chief

Securities and Exchange Commission

Division of Corporate Finance

450 Fifth Street, N.W.

Washington, D.C. 20549

Re:

1ST Constitution Bancorp

Form 10-K filed March 24, 2005

File No. 0-32891

Dear Mr. Nolan:
This letter is in response to your comment letter dated November 9, 2005 with regard to the above-referenced filing.  Each comment in your letter is addressed below and is included for your review.

Form 10-K for Year ended December 31, 2004

Item 9A. “Controls and Procedures”, page 29.

	We refer to your response to Comment 1. In future filings, please discuss in this section your non-accelerated filing status under SEC Release Nos. 33-8545 and 34-51293 and the expected timing for filing
	Management’s annual report on internal control over financial reporting
 	and the Attestation report of the registered public accounting firm
	required to comply with the reporting requirements of Items 308(a) and 308(b) of Regulation S-K.

Response to question number 1:

In future filings, the Company will discuss its non-accelerated filing status and the expected timing for filing these reports.

Note 1, Summary of Significant Accounting Policies, page F-8

Segment Information, page F-12

 We refer to your response to Comment 2. Considering gains on sale of mortgage loans held for sale accounted for 37% of your net income for 2004, in future filings, based on your response, please state in the footnote why
your mortgage banking operations do not qualify as a separate reportable segment under SFAS 131.

Response to question number 2:
SFAS No. 131, Segment Reporting, establishes standards for public business enterprises to report information about operating segments in their annual
financial statements and requires that those enterprises report selected information about operating segments in subsequent interim financial reports issued to shareholders. It also established standards for related disclosure about products and
services, geographic areas, and major customers.  Operating segments are components of an enterprise, which are evaluated regularly by the chief operating decision-maker in deciding how to allocate and assess resources and performance.  The
Company’s chief operating decision-maker is the President and Chief Executive Officer.  The Company has applied the aggregation criteria set forth in SFAS No. 131 for its operating segments to create one reportable segment, “Community
Banking.”

The Company’s community banking segment consists of construction, commercial, retail and mortgage banking. The community banking segment is managed as a single strategic unit, which generates revenue from a variety of
products and services provided by the Company.  For example, construction and commercial lending is dependent upon the ability of the Company to fund itself with retail deposits and other borrowings and to manage interest rate and credit risk.  This
situation is also similar for consumer and residential real estate lending

Critical Accounting Policies, Allowance for Loan Losses and Related Provision, page 22

 We refer to your response to Comment 4. Provide us the proposed disclosure to be included in future filings, regarding how the charge-offs by loan type disclosed in Exhibit A have affected your risk assessments and the
determination of the changes in the allowance for loan losses through your provision for each of the five years. For example, discuss how the inherent risk related to commercial and commercial real estate loans have affect your risk assessments
considering over 90% of the charge-offs during the five year period relate to these types of loans.

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Response to question number 3:
The Company’s primary lending emphasis is the origination of commercial and commercial real estate loans including construction loans. Based on the composition of the loan portfolio, the primary risks inherent in it
are deteriorating credit quality, increases in interest rates, a decline in the economy, and a decline in New Jersey real estate market values. Any one or a combination of these events may adversely affect the loan portfolio and may result in
increased delinquencies, loan losses and increased future provision levels.

All, or part, of the principal balance of commercial and commercial real estate loans, and construction loans are charged off to the allowance as soon as it is determined that the repayment of all, or part, of the principal
balance is highly unlikely. Consumer loans are generally charged off no later than 120 days past due on a contractual basis, earlier in the event of bankruptcy, or if there is an amount deemed uncollectible.
Because all identified losses are immediately charged off, no portion of the allowance for loan and lease losses is restricted to any individual loan or groups of loans, and the entire allowance is available to
absorb any and all loan and lease losses.

The Company maintains an allowance for loan and lease losses at a level deemed sufficient to absorb losses which are inherent in the loan portfolio at each balance sheet date. Management reviews the adequacy of the
allowance on at least a quarterly basis to ensure that the provision for loan and lease losses has been charged against earnings in an amount necessary to maintain the allowance at a level that is adequate based on management’s assessment of
probable estimated losses.  The Company’s methodology for assessing the adequacy of the allowance for loan and lease losses consists of several key elements. These elements include a specific reserve for doubtful or high risk loans, an
allocated reserve, and an unallocated portion. The Company consistently applies the following comprehensive methodology.

The specific reserve for high risk loans is established for specific commercial loans, commercial real estate loans, and construction loans which have been identified by bank management as being high risk loan assets. These
high risk loans are assigned a doubtful risk rating grade because the loan has not performed according to payment terms and there is reason to believe that repayment of the loan principal in whole, or part, is unlikely.  The specific portion of the
allowance is the total amount of potential unconfirmed losses for these individual doubtful loans. To assist in determining the fair value of loan collateral, the Company often utilizes independent third party qualified appraisal firms which in turn
employ their own criteria and assumptions that may include occupancy rates, rental rates, and property expenses, among others.

The second category of reserves consists of the allocated portion of the allowance. The allocated portion of the allowance is determined by taking pools of loans outstanding and commitments that have similar characteristics
and applying historical loss experience for each pool. This estimate represents the potential unconfirmed losses within the portfolio. Individual loan pools are created for commercial and commercial real estate loans,

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construction loans, and for the various types of loans to individuals.  The historical estimation for each loan pool is then adjusted to account for current conditions, current loan portfolio performance, loan policy or
management changes, or any other factor which may cause future losses to deviate from historical levels.

The Company also maintains an unallocated allowance.  The unallocated allowance is used to cover any factors or conditions which may cause a potential loan loss but are not specifically identifiable. It is prudent to
maintain an unallocated portion of the allowance because no matter how detailed an analysis of potential loan losses is performed, these estimates by definition lack precision.  Management must make estimates using assumptions and information which
is often subjective and changing rapidly.  At December 31, 2004, management believed that the allowance for loan losses and nonperforming loans was adequate.

During the quarterly review of the allowance for loan and lease losses, the Company considers a variety of factors that include:

 General economic conditions.

 Trends in charge-offs.

 Trends and levels of delinquent loans.

 Trends and levels of non-performing loans, including loans over 90 days delinquent.

 Trends in volume and terms of loans.

 Levels of allowance for specific classified loans.

 Credit concentrations.

  We refer to your response to Comment 5.  Please provide us the proposed disclosure to be included in future filings that explains the
 specific
factors that occurred during each fiscal period which management considered in determining the additions to the allowance through the yearly provision for each of the five
years presented. Include in your discussion the following:

 Explain why in 2003 the Company charged off $116,000 in construction loans as compared to $7,000 in 2002 but made provisions of
$240,000 in both years.

 With respect to MD&A disclosure in the “Provisions for Loan Losses” section on page 12 of the June 30, 2005 10-Q, explain the
specific changes in the risk characteristics of your loan portfolio that required an increase in the provision to $135,000 during the three months ended June 30, 2005. Consider in your response the loan charge-offs of $10,000 during that
period and that the provisions for interim periods during the last three fiscal years had been $60,000.

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Response to question number 4:
Management maintains the allowance for loan losses at a level that is considered adequate to absorb losses on existing loans based upon an evaluation of known and inherent risks in the portfolio.  Additions to the allowance
are made by charges to the provision for loan losses. The evaluation considers a complete review of the following specific factors: historical losses by loan category, non-accrual loans, problem loans as identified through internal classifications,
collateral values, and the growth and size of the portfolio.  Additionally, current economic conditions and local real estate market conditions are considered.

For 2003, the losses incurred for commercial loans increased significantly in relation to the losses recorded in the prior year. The increase in 2003 losses was primarily due to the loss incurred from one commercial
borrower and was not commensurate with the historical losses incurred in the commercial loan portfolio. Considering that this was an anomaly for the year, the 2003 provision was unchanged from the prior year as the entire allowance is available to
absorb probable losses, and the entire allowance was considered adequate without increased provisions.  The other specific factors considered in the evaluation of the allowance did not change significantly enough to warrant the need for an
increase.

For the three months ended June 30, 2005, the provision for loan losses increased to $135,000 as compared to the $60,000 in each interim period in the three prior fiscal years. The larger provision for the quarter
ended June 30, 2005 was necessitated by the size of the loan portfolio, which is one of the factors considered in determining the adequacy of the allowance for loan losses.  At June 30, 2005, the allowance for loan losses represented only 0.93% of
total loans and the ratio would have been the lowest ratio comparable to the other equivalent periods in the prior years had the larger provision not been made. Also, at June 30, 2005, loans 90 days or more delinquent and nonaccrual loans were
higher as a percentage of loans then any of the other corresponding periods.

 Considering your response to Comments 5, 6, and 7 regarding how you determined the adequacy of your loan loss allowance, please provide us with the proposed disclosure to be included in future filings regarding the
methodology and factors you use to determine that the allowance for loan losses, as adjusted by the annual provision, was adequate to provide for estimated losses inherent in the loan portfolio.

Response to question number 5:
Management maintains the allowance for loan losses at a level that is considered adequate to absorb losses on existing loans that may become uncollectible based upon an evaluation of known and inherent risks in the
portfolio. Additions to the allowance are made by charges to the provision for loan losses. The evaluation considers a complete review of the following specific factors: historical losses by loan category, non-accrual

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loans, problem loans as identified through internal classifications, collateral values, and the growth and size of the portfolio. Additionally, current economic conditions and local real estate market conditions are
considered.

The methodology includes the segregation of the loan portfolio into loan types with a further segregation into risk rating categories, such as special mention, substandard, doubtful, and loss. This allows for an allocation
of the allowance for loan losses by loan type; however, the allowance is available to absorb any loan loss without restriction. Larger balance, non-homogeneous loans representing significant individual credit exposures are evaluated individually
through the internal loan review process. It is this process that produces the watch list. The borrower’s overall financial condition, repayment sources, guarantors and value of collateral, if appropriate, are evaluated. Based on these reviews,
an estimate of probable losses for the individual larger-balance loans are determined, whenever possible, and used to establish loan loss reserves.  In general, for non-homogeneous loans not individually assessed, and for homogeneous groups, such as
residential mortgages and consumer credits, the loans are collectively evaluated based delinquency status, loan type, and industry historical losses. These loan groups are then internally risk rated.

The watch list includes loans that are assigned a rating of special mention, substandard, doubtful and loss. Loss factors range from 2.0% to 4.0% for special mention loans, 5% to 25% for substandard loans, and 30% to 70%
for doubtful loans depending on the type of credit.  Loans criticized special mention have potential weaknesses that deserve management’s close attention.  If uncorrected, the potential weaknesses may result in deterioration of the repayment
prospects.  Loans classified substandard have a well-defined weakness or weaknesses that jeopardize the liquidation of the debt. They include loans that are inadequately protected by the current sound worth and paying capacity of the obligor or of
the collateral pledged, if any.  Loans classified doubtful have all the weaknesses inherent in loans classified substandard with the added characteristic that collection or liquidation in full, on the basis of current conditions and facts, is highly
improbable. Loans rated as doubtful in whole, or in part, are placed in nonaccrual status. Loans classified as a loss are considered uncollectible and are charged to the allowance for loan losses.

The Company also maintains an unallocated allowance.  The unallocated allowance is used to cover any factors or conditions which may cause a potential loan loss but are not specifically identifiable. It is prudent to
maintain an unallocated portion of the allowance because no matter how detailed an analysis of potential loan losses is performed, these estimates by definition lack precision.  Management must make estimates using assumptions and information that
is often subjective and changing rapidly.

Loans are placed in a nonaccrual status when the ultimate collectibility of principal or interest in whole, or part, is in doubt. Past-due loans contractually past-due 90 days or more for either principal or interest are
also placed in nonaccrual status unless they are both well secured and in the process of collection. Impaired loans, in accordance with SFAS 114, are evaluated i