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SEC Comment Letter for CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Nov 30, 2011

CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: Nov. 30, 2011 · CIK: 0001045520 · Accession: 0000000000-11-068924

Regulatory Compliance Financial Reporting Internal Controls

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
November 30, 2011
Author
Assistant Director
Form
UPLOAD
Company
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)

Letter

November 30, 2011 Via E-mail Canadian Imperial Bank of Commerce Kevin Glass Senior Executive Vice President and Chief Financial Officer Commerce Court Toronto, Ontario, Canada M5L 1A2 Re: Canadian Imperial Bank of Commerce Form 40-F for the Fiscal Year Ended October 31, 2010 Filed December 6, 2010 Forms 6-K Filed May 26, 2011 and July 29, 2011 File No. 1-14678

Dear Mr. Glass: We have completed our review of your f ilings. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or the filings and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi lings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Suzanne Hayes Suzanne Hayes
Assistant Director

Show Raw Text
November 30, 2011
 Via E-mail

Canadian Imperial Bank of Commerce
Kevin Glass Senior Executive Vice President and Chief Financial Officer Commerce Court Toronto, Ontario, Canada M5L 1A2
Re: Canadian Imperial Bank of Commerce
Form 40-F for the Fiscal Year Ended October 31, 2010 Filed December 6, 2010 Forms 6-K  Filed May 26, 2011 and July 29, 2011
  File No. 1-14678

Dear Mr. Glass:
We have completed our review of your f ilings.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or the filings and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi lings to be certain that the filings include the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
   /s/ Suzanne Hayes  Suzanne Hayes
Assistant Director