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October 7, 2005

Donald Walker

Senior Assistant Chief Accountant

United States Securities and Exchange Commission

Washington, D.C. 20549

    Re:

    Canadian Imperial Bank of Commerce

    Form 40-F for the Fiscal Year Ended October 31, 2004

    File Number 001-14678

Dear Mr. Walker:

          Thank you for your letter dated September 23, 2005, addressed to Gerald T. McCaughey of
Canadian Imperial Bank of Commerce (“CIBC” or “the Company”), setting forth comments of the staff
of the Division of Corporation Finance (the “Staff”) on CIBC’s Form 40-F for the fiscal year ended
October 31, 2004.

          We appreciate the effort that went into the Staff’s comments. We have considered the Staff’s
comments carefully and our responses to the Staff’s comments are set forth below. To facilitate
the Staff’s review, we have keyed our responses to the headings and numbered comments used in the
Staff’s comment letter, which we have reproduced in bold face text. Our responses follow each
comment.

    1.

    We read your policy for determination of market value when quoted prices in an active market
or suitable market proxies are not available. Please tell us what methods (other than
observed market quotations or data) you use to recognize gains or losses in income. Include
in your response the periods used for each method of income recognition, and quantify any
deferred gains and/or losses, as applicable, as of October 31, 2004.

    As the above referenced discussion in the MD&A relates to the determination of market value
of securities and derivatives held for trading purposes, we have responded to the question
within this context.

    In accordance with Canadian GAAP, investment securities and the majority of derivatives used
for hedging purposes are not recorded on a mark-to-market basis. As a result, market
valuation changes for these investments during the holding period do not result in gains or
losses being recognized in income, and therefore these instruments are not covered in this
response. Additional information relating to the valuation of investment securities and
hedging derivatives can be provided if required.

    Securities purchased (long) and sold (short)

    As noted in the sources of fair value table (page 47 of CIBC’s Form 40-F filing), the
majority of the Company’s security positions, both long and short, are valued using quoted
market prices.

    In arriving at the fair value of securities, market risk aging valuation adjustments are
provided for slow moving positions that do not turnover on a frequent basis. Concentration
and liquidity market risk valuation adjustments are also recorded to reflect large positions
relative to market depth and the likely cost of closing the positions out in the
marketplace. These valuation adjustments are recorded to ensure that we record the best
estimate of fair value for securities purchased (long) and sold (short) and are discussed in
greater detail in responses to questions 2 and 3.

    The total valuation adjustments recorded for securities purchased (long) and sold (short),
are C$45mm as at October 31, 2004 (C$32mm — October 31, 2003).

    Derivatives

    As noted on page 47 of the Form 40-F filing, 3% of the Company’s derivatives are valued
using quoted market prices. These products generally consist of listed interest rate,
equity and commodity options. These listed derivatives are readily priced using quotes
obtained from the relevant market.

    The majority of the Company’s derivatives trade over-the-counter (“OTC”) and are priced
using internal pricing models.

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    Income Recognition — Revenue on derivative products embedded in Equity-Linked Notes

    Derivative product exposure can arise from equity linked-note products with embedded
derivatives that have been issued by our Company. These equity linked-note products are
issued by our Treasury group and are themselves non-trading liabilities on our balance
sheet. However, the derivative exposure arising from these note issuances is hedged via our
Company’s trading room.

    Canadian GAAP Accounting Guideline 17 governs the accounting treatment of Non-Trading
liabilities that contain embedded equity linked derivatives, which is similar to the
accounting for these types of liabilities under US GAAP SFAS133. We therefore follow US
GAAP accounting principles for these products. On all equity-linked note programs, we do
not recognize day 1 revenue in respect of the retail spread on these notes. Instead, the
inception revenue representing the retail spread is recognized over the life of the issued
note on a yield basis as required under the SEC’s SFAS133 Implementation Issue B6 (“B6”)
related pronouncement of December 11, 2003. Subsequent to inception date, the valuation of
the derivative is formulaically based on internal models and model inputs (after excluding
the inception revenue impact).

    As at October 31, 2004, a valuation adjustment of C$39mm was recorded in connection with
equity-linked-notes B6 requirements. Based on the maturity profile of our equity-linked
notes, these valuation adjustments will be released into income over a period of four to
eight years.

    Income Recognition on derivative products other than those embedded in Equity-Linked
Notes

    Recognition of inception revenue on a derivative is subject to the fair value hierarchy
summarized in footnote 3 of EITF 02-3, which the Company also applies for its Canadian GAAP
reporting. Where a pricing input is not observable, then the requirements under EITF 02-3
are applied and inception revenue is deferred.

    In instances where inception revenue has been deferred, as a result of applying EITF 02-3,
we recognize the deferred revenue into income ratably over the period of unobservable market
data up to a maximum of the tenor of the derivative. The exception to recognition of day 1
revenue over the tenor of the derivative occurs only in instances where model inputs become
observable thereby meeting the EITF 02-3 requirements. In these instances, the previously
deferred revenue would be recorded into income in the period where the EITF 02-3
requirements were met.

    Once a derivative is valued and recorded, subsequent changes in market value are
recorded into income. Subsequent valuation amounts are determined by formulaically
adjusting model inputs to new and current levels.

    Derivative valuations are also subject to valuation adjustments that are described in
greater detail in the response to question 2.

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    2.

    Please tell us your methodology for calculating each of your valuation adjustments for
market, model and credit risks and for administrative costs.

    As noted in our response to question 1, management uses valuation adjustments in its
estimation of fair value of financial instruments to arrive at what it believes to be the
most accurate level of market valuation.

    Any valuation adjustment applied reflects what management believes a knowledgeable, willing
counterparty, under no compulsion to act, would use to assess the fair value of a financial
instrument in an arms length transaction carried out in the normal course of business. In
so determining, management considers factors such as those referenced in the Group of Thirty
Report, Derivatives Practices and Principles referred in certain US GAAP accounting
literature (i.e. AICPA Audit and Accounting Guide: Brokers and Dealers in Securities).

    Methodologies for determination of these valuation adjustments are as follows:

    Valuation adjustments provided for securities purchased (long) and sold (short)

    There are market risk related valuation adjustments applied securities covering three major
areas: aging, reflecting the length of time the instruments are held in the trading
inventory; concentration, for large positions held relative to issue size; and, liquidity,
from the standpoint of securities with low trading volumes. Each adjustment type is
described below:

    Market risk aging valuation adjustment

    This valuation adjustment is assessed for products that do not frequently turnover. The lack
of turnover, and a resulting increase in the length of time a security is held, is
indicative of a need to adjust the fair value of the position. The methodology for
determining the size of this adjustment is constructed primarily around two factors — the
issuer quality, and the period of time the security is held. These two factors are used to
formulaically derive a discount factor to be applied in arriving at the fair market value of
the position.

    This valuation adjustment is made at the security level, not on a portfolio basis. Releases
of this valuation adjustment and monthly changes will formulaically result from either
dispositions of securities, changes in issuer credit quality, or the passage of time.

    Market risk concentration valuation adjustment

    Large holdings in one position relative to issue size can be a valuation risk given the
potential for loss in attempting to sell the position within a given time period. This
valuation adjustment is formulaically applied against large holdings relative to the issued
float, and centers on a discount factor applied to the present value price sensitivity of
the

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    position. The factor applied is based on issuer quality and position size held. The
factors increase significantly as issuer quality degrades and position sizes increase.

    This adjustment is formulaically calculated at the security level, not on a portfolio basis.
Releases of this valuation adjustment and monthly movements of valuation adjustment balances
will result from either dispositions of securities, changes to the size of positions held,
or changes to issuer credit quality.

    Market risk liquidity valuation adjustment

    This valuation adjustment is provided in cases where a trading desk holds a position in a
thinly traded security. In such cases, the thinly traded position, if valued at its quoted
price excluding any valuation adjustment, would not reflect the true value that would be
derived if the position were sold. To consider the true costs of unwinding positions in a
thin market, valuation adjustments are made based on the position size held relative to
average trading volume.

    Under U.S. GAAP, valuation adjustments to exchange-traded securities are not permissible.
These valuation adjustments are therefore recorded under Canadian GAAP and are adjusted as
reconciling items in the Company’s US GAAP reconciliation.

    Releases of this valuation adjustment and monthly movements of balances will result from
either disposition of securities, or market movements of the securities.

    Valuation adjustments provided for derivative products

    The following outlines the valuation adjustments provided on OTC derivatives:

    Credit risk valuation adjustment

    OTC derivatives priced with internal models are valued using pricing curves that do not
incorporate consideration for any specific counterparty credit risk. Consequently, our
Company’s policy is to measure a credit valuation adjustment to account for counterparty
credit risk based on expected future credit losses.

    The credit risk valuation adjustment for OTC derivatives captures the counterparty risk of
default and is quantified as:

     M

Valuation Adjustment =

    ∑ LE(ti) ´ ΔPD(ti) ´ LGD

  0

    where, t is the point on the profile, LE is Loan Equivalent
Exposure, Delta PD is the probability of default, LGD is Loss Given Default,
and M is maturity.

    Counterparty credit risk valuation adjustments for non-defaulted OTC derivative
contingent credit risks, are calculated based on loan equivalent (“LE”) exposures, and

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    counterparty internal obligor and loss given default (“LGD”) ratings. LE is the profile of
the expected positive credit exposure at default over time to maturity. The posting of
financial collateral, netting and portfolio effects are factored into the calculation of
exposure.

    Market risk valuation adjustment

    This market risk valuation adjustment is applied to books that are marked to mid price to
represent an equivalent bid-offer valuation adjustment and is applicable for derivative
trading books. The Company’s value-at-risk (VaR) is the underlying risk measure to
formulaically calculate this valuation adjustment.

    The Company’s global market risk VaR calculations are based on a parametric model, which
relies on historical market data to derive variance and co-variance relationships between
each of the risk factors that are measured.

    Administrative valuation adjustment

    This valuation adjustment represents the present value of the future costs to administer
CIBC’s derivative portfolio to maturity and is booked to reflect the future costs that will
be incurred to maintain the derivative portfolio to maturity. This valuation adjustment is
also viewed as the cost a potential buyer of the derivative portfolio would incur in
administering the portfolio over the remaining term to maturity.

    The methodology considers the direct costs of our Middle Office and Back Office operations
groups, Finance, Information Technology and Risk Management and excludes general corporate
governance and other non-deal specific costs. The direct support costs to service and
administer the derivative portfolio to maturity are estimated to determine an average cost
per deal per year factor. This factor is applied to the actual trade count in the derivative
pool and the average remaining maturity of the pool, at a specific point in time.

    Month-over-month changes to the valuation adjustment reflect fluctuations to the actual deal
count and average remaining maturity. Changes in direct support costs are also incorporated
into the valuation adjustment estimate periodically.

    Specific counterparty credit risk

    The credit risk valuation adjustment previously described addresses the need to consider the
potential for future counterparty credit default aspects in valuing a derivative when using
models that are based on non-credit specific pricing inputs. However, as the counterparty’s
credit rating actually declines, and eventually a derivative falls into credit default
status, there is a need to assess additional valuation adjustments for the fact that the
counterparty may not settle the obligation. Consequently, this specific counterparty credit
risk valuation adjustment provides for specific instances where counterparties have

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    either defaulted or are close to default on their derivative obligations. These valuation
adjustments are therefore counterparty name and trade specific.

    The Company’s credit analysis and approval process requires that each counterparty name be
assigned a risk rating based upon the Company’s risk rating scale. For each name, ratings
are adjusted to reflect the most-current financial situation.

    As the counterparty name declines on the rating scale, the Company will conduct additional
detailed credit analysis and will closely observe the valuation of the derivative and its
volatility. When the risk rating reaches a set target level, a determination is made as to
the provision of a specific credit valuation adjustment, despite the counterparty
potentially not being in default of any of its agreements. The determination of such
valuation adjustment is based upon the derivative valuation, its volatility and the severity
of any loss, which might be incurred if a default actually occurred.

    The valuation adjustment is determined each month based upon changes to the derivative
valuation. If a default actually occurs then the derivative would be closed out and we
would determine the amount owing by the counterparty to the Company.

    Releases of valuation adjustments will normally result from full or partial settlements made
by the counterparty, assignments or sales of the derivative to t