SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549- 5546

       DIVISION OF
CORPORATION FINANCE

Mail Stop 5546         August 24, 2006

Via Facsimile 416 360- 5271 and US Mail

Gerald T. McCaughey
President and CEO
Canadian  Imperial Bank of Commerce
Commerce Court
Toronto, Ontario
Canada, M5L 1A2
 Re: Canadian Imperial Bank of Commerce
  Form 40- F for the Fis cal Year Ended October 31, 2005
Filed December 12, 2005
Response Letter Dated August 14, 2006
   File No. 1- 14678

Dear Mr. McCaughey:

We have reviewed your response dated August 14, 2006 and have the following comment.
Please be as detailed as necessary in your response.  After reviewing this information, we may raise additional comments.

1. Please expand your qualitative materiality analysis to address specifically whether the governments of Cuba and Iran, or entities controlled by those governments, participate directly or indirectly in your trade finance and other transactions with Cuba and Iran.  If these governments or entities controlled by them participate in the transactions, please discuss the nature and extent of their involvement.  Address specifically the possibility that your involvement in transactions that may result in the provision of funds to the governments of countries identified as terrorist -sponsoring states may negatively impact
your reputation and share value.  General
 Please respond to this comment  within 10 business days or tell us when you will provide us
with a response .  Please file your response letter on EDGAR.

Gerald T. McCaughey
Canadian Imperial Bank of Commerce
Page 2

Please contact James Lopez at (202) 551 -3536 if you have any questions about the comment
or our review.  You may also contact me at (202) 551- 3470.
          Sincerely,
           Cecilia D. Blye, Chief
        Office of Global  Security Risk
  cc:  Todd Schiffman
  Assistant Director
  Division of Corporation Finance
    Donald Walker
  Senior Assistant Chief Accountant
  Division of Corporation Finance