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SEC Comment Letter for CANADIAN IMPERIAL BANK OF COMMERCE (CM) — May 11, 2017

CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: May 11, 2017 · CIK: 0001045520 · Accession: 0000000000-17-016632

Regulatory Compliance Financial Reporting Internal Controls

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File numbers found in text: 001-14678

Date
October 31, 2016
Author
/s/ Stephanie L. Sullivan
Form
UPLOAD
Company
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)

Letter

May 11 , 2017 Mail Stop 4720 Via E -mail Kevin Glass 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 the Fiscal Year Ended October 31, 2016 Filed December 1, 2016 File No. 001-14678

Dear Mr. Glass ,

We have completed our review of your filing. We remind you that the company and its management are responsible for the accuracy and adequacy of the ir disclosure s, notwithstanding any review, comments, action or absence of action by the staff .

Sincerely,
/s/ Stephanie L. Sullivan

Show Raw Text
May 11 , 2017

Mail Stop 4720

Via E -mail
Kevin Glass
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 the Fiscal Year Ended October 31, 2016
 Filed December 1, 2016
File No. 001-14678

Dear Mr. Glass ,

We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of the ir disclosure s, notwithstanding
any review, comments, action or absence of action by the staff .

Sincerely,

 /s/ Stephanie L. Sullivan

 Stephanie L. Sullivan
Senior Technical & Policy Advisor
Office of Financial Services