SEC Comment Letter for CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Nov 23, 2010

CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: Nov. 23, 2010 · CIK: 0001045520 · Accession: 0000000000-10-070214

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Referenced dates: September 30, 2010

Date

November 23, 2010

Author

Cecilia Blye

Form

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CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010

DIVISION OF CORPORATION FINANCE

November 23, 2010 Via Mail and Facsimile (416-784-7565)

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 the Fiscal Year Ended October 31, 2009 Filed December 7, 2009 File No. 1-14678 Response Letter Filed November 8, 2010 Dear Mr. McCaughey:

We refer you to our comment letter dated September 30, 2010 regarding business contacts with Iran and Cuba. We have comp leted our review of this subject matter and have no further comments at this time. S i n c e r e l y ,

C e c i l i a B l y e , C h i e f Office of Global Security Risk

cc: Todd Schiffman Assistant Director Division of Cor poration Finance

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

November 23, 2010
Via Mail and Facsimile (416-784-7565)

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 the Fiscal Year Ended October 31, 2009
  Filed December 7, 2009   File No. 1-14678   Response Letter Filed November 8, 2010
Dear Mr. McCaughey:

We refer you to our comment letter dated September 30, 2010 regarding business
contacts with Iran and Cuba.  We have comp leted our review of this subject matter and
have no further comments at this time.            S i n c e r e l y ,

          C e c i l i a  B l y e ,  C h i e f          Office of Global Security Risk

  cc:  Todd Schiffman   Assistant Director  Division of Cor poration Finance

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