SEC Comment Letter for CANADIAN IMPERIAL BANK OF COMMERCE (CM) — May 10, 2012
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: May 10, 2012 · CIK: 0001045520 · Accession: 0000000000-12-024432
AI Filing Summary & Sentiment
Reasoning
Referenced dates: April 5, 2012
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE May 2, 2012 Via E-Mail Michael G. Capatides Chief Administrative Offi cer and General Counsel Canadian Imperial Bank of Commerce 425 Lexington Avenue, 3 rd Floor New York, New York, 10017
Re: Canadian Imperial Bank of Commerce Form 40-F for the Fiscal Year Ended October 31, 2011 Filed December 2, 2011 File No. 1-14678
Dear Mr. Capatides: We refer you to our comment letter dated April 5, 2012 regarding business contacts with Syria, Iran and Cuba. We have completed our review of this subject matter. We remind you that our comments or changes to disclosure in res ponse to our comments do not foreclose the Commission from taking an y action with respect to the company or the filing and the company may not assert sta ff comments as a defe nse in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all persons who are respons ible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.
S i n c e r e l y ,
/s/ Cecilia Blye C e c i l i a B l y e , C h i e f Office of Global Security Risk cc: Suzanne Hayes Assistant Director Division of Cor poration Finance
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
May 2, 2012
Via E-Mail
Michael G. Capatides Chief Administrative Offi cer and General Counsel
Canadian Imperial Bank of Commerce
425 Lexington Avenue, 3
rd Floor
New York, New York, 10017
Re: Canadian Imperial Bank of Commerce
Form 40-F for the Fiscal Year Ended October 31, 2011 Filed December 2, 2011 File No. 1-14678
Dear Mr. Capatides:
We refer you to our comment letter dated April 5, 2012 regarding business
contacts with Syria, Iran and Cuba. We have completed our review of this subject matter.
We remind you that our comments or changes to disclosure in res ponse to our comments
do not foreclose the Commission from taking an y action with respect to the company or
the filing and the company may not assert sta ff comments as a defe nse in any proceeding
initiated by the Commission or any person under the federal securities laws of the United
States. We urge all persons who are respons ible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable rules require.
S i n c e r e l y ,
/s/ Cecilia Blye C e c i l i a B l y e , C h i e f Office of Global Security Risk cc: Suzanne Hayes Assistant Director Division of Cor poration Finance