SEC Comment Letter for CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Jun 12, 2013

CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: June 12, 2013 · CIK: 0001045520 · Accession: 0000000000-13-031962

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File numbers found in text: 001-14678

Date

October 31, 2012

Author

/s/ Michael Seaman for

Form

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Company

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

Letter

June 12 , 2013 Via E -mail Gerald 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, 2012 Filed December 6, 2012 File No. 001-14678

Dear Mr. McCaughey :

We have comp leted our review of your filing . We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense 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 responsible 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 applicabl e rules require.

Sincerely,
/s/ Michael Seaman for

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June 12 , 2013

Via E -mail
Gerald 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, 2012
Filed December 6, 2012
File No. 001-14678

Dear Mr. McCaughey :

We have comp leted our review of your filing .  We remind you that our comments or
changes to disclosure  in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense 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 responsible 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 applicabl e rules require.

Sincerely,

 /s/ Michael Seaman for

 Suzanne Hayes
Assistant Director

SecProbe.io