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SEC Comment Letter for CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Jul 24, 2008

CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: July 24, 2008 · CIK: 0001045520 · Accession: 0000000000-08-036957

Financial Reporting Regulatory Compliance Internal Controls

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Confidence
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File numbers found in text: 001-14678

Date
July 24, 2008
Author
Mark Webb
Form
UPLOAD
Company
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)

Letter

July 24, 2008

Mail Stop 4561 Mr. Gerald T. McCaughey President and Chief Executive Officer Canadian Imperial Bank of Commerce Commerce Court Toronto, Ontario, Canada, M5L 1A2 Re: Canadian Imperial Bank of Commerce Form 40-F for Fiscal Year Ended October 31, 2007 Filed December 10, 2007 File Number: 001-14678 Dear Mr. McCaughey: We have completed our review of your Form 40-F and related filings and have no further comments at this time. S i n c e r e l y ,

Mark Webb Legal Branch Chief

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July 24, 2008

Mail Stop 4561  Mr. Gerald T. McCaughey President and Chief Executive Officer Canadian Imperial Bank of Commerce Commerce Court Toronto, Ontario, Canada, M5L 1A2
Re: Canadian Imperial Bank of Commerce
 Form 40-F for Fiscal Year Ended October 31, 2007
 Filed December 10, 2007  File Number: 001-14678
  Dear Mr. McCaughey:   We have completed our review of your Form 40-F and related filings and have no
further comments at this time.
        S i n c e r e l y ,

Mark Webb Legal Branch Chief