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SEC Company Response from CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Sep 6, 2011

CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: Sept. 6, 2011 · CIK: 0001045520 · Accession: 0000902561-11-000065

Regulatory Compliance Financial Reporting Internal Controls

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
September 6, 2011
Author
Michelle Caturay
Form
CORRESP
Company
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)

Letter

Assistant Director United States Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549

Dear Ms. Hayes:

Re:

Canadian Imperial Bank of Commerce

Form 40-F for the Fiscal Year Ended October 31, 2010

Filed December 6, 2010

Forms 6-K

Filed May 26, 2011 and July 29, 2011

File No. 1-14678

We received your letter of August 30, 2011 and are pleased to provide the requested response. As we agreed on the phone, in light of the number of comments, our response will be provided by September 30, 2011.

Thank you.

Yours truly,

/s/ Michelle Caturay

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[

Michelle Caturay

Vice-President, Corporate Secretary

& Associate General Counsel

Corporate Secretary’s Division

199 Bay Street

Commerce Court West, 44th Floor

Toronto, Ontario

Canada M5L 1A2

September 6, 2011

Tel:  416-980-3045

Fax:  416-980-7012

michelle.caturay@cibc.com

Ms. Suzanne Hayes

Assistant Director

United States Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549

Dear Ms. Hayes:

Re:

Canadian Imperial Bank of Commerce

Form 40-F for the Fiscal Year Ended October 31, 2010

Filed December 6, 2010

Forms 6-K

Filed May 26, 2011 and July 29, 2011

File No. 1-14678

We received your letter of August 30, 2011 and are pleased to provide the requested response. As we agreed on the phone, in light of the number of comments, our response will be provided by September 30, 2011.

Thank you.

Yours truly,

/s/ Michelle Caturay