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SEC Comment Letter for CANADIAN IMPERIAL BANK OF COMMERCE (CM) — May 11, 2010

CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: May 11, 2010 · CIK: 0001045520 · Accession: 0000000000-10-025987

Regulatory Compliance Financial Reporting Business Model Clarity

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File numbers found in text: 001-14678

Date
May 11, 2010
Author
Amit Pande
Form
UPLOAD
Company
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549

DIVISION OF CORPORATION FINANCE

May 11, 2010

By U.S. Mail and facsimile: (212) 667-8366

Mr. Michael G. Capatides Chief Administrative Offi cer and General Counsel Canadian Imperial Bank of Commerce 425 Lexington Avenue-3rd Floor New York, New York 10017 Re: Canadian Imperial Bank of Commerce Form 40-F for the fiscal year ended October 31, 2009 File Number 001-14678 Dear Mr. Capatides:

We have completed our review of your Form 40-F and have no further comments at this time. Sincerely,

Amit Pande Accounting Branch Chief

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

DIVISION OF
  CORPORATION FINANCE

May 11, 2010

By U.S. Mail and facsimile: (212) 667-8366

Mr. Michael G. Capatides Chief Administrative Offi cer and General Counsel
Canadian Imperial Bank of Commerce
425 Lexington Avenue-3rd Floor New York, New York 10017
 Re: Canadian Imperial Bank of Commerce
Form 40-F for the fiscal year ended October 31, 2009
File Number 001-14678
 Dear Mr. Capatides:

We have completed our review of your Form 40-F and have no further comments
at this time.
Sincerely,

Amit Pande Accounting Branch Chief