Commerce Bancorp's ambitious expansion strategy, designed to double its network in five years, could run into roadblocks in the City of Brotherly Love.

The Cherry Hill, N.J.-based holding company raised $27.6 million from a stock offering this month to help it build 50 new branches, but a Philadelphia coalition of community groups has vowed to block each site until the bank improves its lending record.

The Neighborhood Economic Survival Coalition, a group of Philadelphia community organizations, accuses the $2.3 billion-asset bank holding company of discriminating against low-income communities through its lending policies.

It also criticizes the company for locating its branches only in suburban areas inhabited by whites, and not in the major cities of its market.

Commerce is opening the first of the 50 new branches in Trooper, Pa., on March 11. The company has already planned four more openings in Pennsylvania communities and five in southern New Jersey between March and August. Officials expect to have 94 by the year 2000.

"These 10 are not in Camden or in Philadelphia," said Chris A. Schweitzer, director of the Kensington Joint Action Council, a member of the coalition. "It exactly follows the pattern of bias."

The coalition claims that Commerce didn't make any housing loans to minorities in Pennsylvania in 1992 or 1993. And only 1.2% of its housing loans went to minorities in the Garden State.

Commerce's main New Jersey subsidiary and its Pennsylvania banks both received "needs to improve" ratings from the Office of the Comptroller of the Currency on their last Community Reinvestment Act examinations.

Commerce officials were not available for comment, but they have previously noted that the bank has donated more $500,000 to local organizations in both states and agreed to invest $400,000 in community development credit unions.

Mr. Schweitzer said. "They have yet to do anything that's equitable or reasonable as far as having a fair representation of services to people in urban areas."

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