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SEC Comment Letter for CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Mar 11, 2015

CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: March 11, 2015 · CIK: 0001045520 · Accession: 0000000000-15-014489

Regulatory Compliance Financial Reporting Internal Controls

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File numbers found in text: 333-202584

Date
March 11, 2015
Author
/s/ Suzanne Hayes
Form
UPLOAD
Company
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)

Letter

March 11, 2015 Via Email Michael G. Capatides Chief Administrative Officer and General Counsel Canadian Imperial Bank of Commerce 425 Lexington Avenue – 3rd Floor New York, NY 10017

Re: Canadian Imperial Bank of Commerce Registration Statement on Form F-3 Filed March 6, 2015 File No. 333-202584

Dear Mr. Capatides :

This letter is to inform you that we are conducting a limited review of the above - captioned filing for resolution of outstanding comments relating to your most recent ly filed Form 40-F. Please understand that the purpose of this review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects.

Please note that before you request that the effective date of the above -captioned registration statement be accelerated, you should resolve all outstanding comments to your most recent Form 40-F.

Please contact Will Dorton at (202) 551 -3107 or me at (202) 551 -3675 with any other questions.

Sincerely,
/s/ Suzanne Hayes

Show Raw Text
March  11, 2015

Via Email
Michael G. Capatides
Chief Administrative Officer and General Counsel
Canadian  Imperial Bank of Commerce
425 Lexington Avenue – 3rd Floor
New York, NY 10017

Re: Canadian Imperial Bank of Commerce
  Registration Statement on Form F-3
Filed  March  6, 2015
  File No.  333-202584

Dear Mr. Capatides :

This letter is to inform you that we are conducting a limited review of the above -
captioned filing for resolution of outstanding comments relating to your most recent ly filed
Form  40-F.  Please understand that the purpose of this review process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in
your filing.  We look forward to working with you in these respects.

Please note that before you request that the effective date of the above -captioned
registration statement be accelerated, you should resolve all outstanding comments to your most
recent Form  40-F.

Please contact Will Dorton  at (202) 551 -3107  or me at (202) 551 -3675  with any other
questions.

Sincerely,

/s/ Suzanne Hayes

Suzanne Hayes
Assistant Director