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SEC Comment Letter for CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Aug 4, 2017

CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: Aug. 4, 2017 · CIK: 0001045520 · Accession: 0000000000-17-027566

Regulatory Compliance Offering / Registration Process Financial Reporting

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File numbers found in text: 333-219550

Date
August 4, 2017
Author
/s/ Dietrich A. King
Form
UPLOAD
Company
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)

Letter

Mail Stop 4720 August 4, 2017 Michael G. Capatides Senior Executive Vice -President, 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 July 28, 2017 File No. 333-219550

Dear Mr. Capatides :

This is to advise you that we have not reviewed and will not review your registration statement .

Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absen ce of action by the staff.

Please contact Christopher Dunham, Staff Attorney, at (202) 551 -3783 with any questions .

Sincerely,
/s/ Dietrich A. King

Show Raw Text
Mail Stop 4720

August 4, 2017

Michael G. Capatides
Senior Executive Vice -President,
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  July 28, 2017
  File No.  333-219550

Dear Mr. Capatides :

This is to advise you that we have not  reviewed and will not review your registration
statement .

Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absen ce of action by the staff.

Please  contact Christopher Dunham, Staff Attorney, at (202) 551 -3783  with any
questions .

Sincerely,

 /s/ Dietrich A. King

Dietrich A. King
Assistant Director
Office of Financial Services

cc: David S. Bakst , Esq.