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SEC Comment Letter for CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Sep 6, 2017

CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: Sept. 6, 2017 · CIK: 0001045520 · Accession: 0000000000-17-031454

Regulatory Compliance Financial Reporting Offering / Registration Process

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File numbers found in text: 333-220284

Date
September 6, 2017
Author
/s/ Era Anagnosti
Form
UPLOAD
Company
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)

Letter

Mail Stop 4720 September 6, 2017 Michael G. Capatides Senior Executive Vice -President 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 August 31 , 2017 File No. 333-220284

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, act ion or absence of action by the staff.

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

Sincerely,
/s/ Era Anagnosti

Show Raw Text
Mail Stop 4720

September 6, 2017

Michael G. Capatides
Senior Executive Vice -President
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  August 31 , 2017
  File No.  333-220284

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, act ion or absence of action by the staff.

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

Sincerely,

 /s/ Era Anagnosti

Era Anagnosti
Legal Branch Chief
Office of Financial Services

cc: David S. Bakst , Esq.