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SEC Comment Letter for CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Jul 9, 2015

CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: July 9, 2015 · CIK: 0001045520 · Accession: 0000000000-15-036057

Regulatory Compliance Financial Reporting Internal Controls

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
October 31, 2014
Author
/s/ Stephanie J. Ciboroski
Form
UPLOAD
Company
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)

Letter

July 9 , 2015 Via E -mail Kevin Glass Senior Executive Vice President & Chief Financial Officer Canadian Imperial Bank of Commerce Commerce Court Toronto, Ontario, Canada M5L 1A2

Re: Canadian Imperial Bank of Commerce Form 40-F for Fiscal Year Ended October 31, 2014 Filed December 4, 2014 File No. 001 -14678

Dear Mr. Glass :

We have completed 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 applicable r ules require.

Sincerely,
/s/ Stephanie J. Ciboroski

Show Raw Text
July 9 , 2015

Via E -mail
Kevin Glass
Senior Executive Vice President & Chief Financial Officer
Canadian Imperial Bank  of Commerce
Commerce Court
Toronto, Ontario, Canada M5L 1A2

Re: Canadian Imperial Bank of Commerce
 Form 40-F for Fiscal Year Ended October 31, 2014
Filed December 4, 2014
File No. 001 -14678

Dear Mr. Glass :

We have completed 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 applicable r ules require.

Sincerely,

 /s/ Stephanie J. Ciboroski

Stephanie J. Ciboroski
Senior Assistant Chief Accountant