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CONFIDENTIAL TREATMENT HAS BEEN REQUESTED FOR CERTAIN INFORMATION CONTAINED IN THIS LETTER
PURSUANT TO RULE 83. THIS LETTER OMITS CONFIDENTIAL INFORMATION INCLUDED IN AN UNREDACTED VERSION
OF THE LETTER FILED WITH THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION. ASTERISKS DENOTE THE
REDACTIONS

August 25, 2006

By EDGAR

Mr. John P. Nolan

Accounting Branch Chief

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, 2005

    File Number 001-14678

Dear Mr. Nolan:

     Thank you for your letter dated August 11, 2006, addressed to Gerald T. McCaughey, Chief
Executive Officer 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, 2005.

     We appreciate the effort that went into the Staff’s comments. We have considered the
comments carefully and our responses 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.

     The Company is seeking confidential treatment for the information that is redacted from this
letter. The contact at the Company for this request is Charles Gerber, Senior Vice President and
Deputy General Counsel; telephone (212) 667-8310; fax (212) 667-8362.

Form 40-F as of and for the fiscal year ended October 31, 2004

General

    1.

    On October 7, 2005 you submitted a written response letter to our comment letter dated
September 23, 2005. However, we note that your response letter, which was signed by
Francesca Shaw, Senior Vice President and Chief Accountant, was not filed on EDGAR as
required for all registrant correspondence with the staff. Please file your October 7,
2005 response letter on EDGAR as soon as practicable.

    We filed our October 7, 2005 response letter on EDGAR on August 16, 2006.

Form 40-F as of and for the fiscal year ended October 31, 2005

CIBC Annual Accountability Report 2005

Management’s Discussion and Analysis

Disclosure Controls and Procedures, page 93

    2.

    Please tell us and revise future filings to disclose the date as of which management
evaluated the effectiveness of disclosure controls and procedures and concluded that they
were effective.

    Management evaluated the effectiveness of the Company’s disclosure controls and procedures
and concluded that they were effective as at October 31, 2005, the last day of CIBC’s fiscal
year. Future Form 40-F filings will disclose the date as of which management evaluated the
effectiveness of the Company’s disclosure controls and procedures.

Consolidated
— Financial Statements

Consolidated Statements of Operations, page 99

    3.

    We note from a review of your financial statement presentation for the past several
years that you have historically followed an income statement format which includes a
presentation of net interest income but excludes a presentation of net interest income
after provision for loan losses. We further note the Management’s Discussion and Analysis
section of your Form 40-F seems to focus on total revenue (net interest income plus
non-interest income, excluding the provision for credit losses) instead of net interest
income, particularly in your discussion of results for each of your reporting segments.
Please tell us the following, related to your current income statement presentation:

    a.

    Please tell us how you believe you have complied with the requirements
of Rule 9-04 of Regulation S-X or why you believe the rule is not applicable to
you;

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    Our financial statements were prepared to conform with Canadian generally accepted
accounting principles (“GAAP”), which does not specify an income statement
presentation for credit losses. However, we believe that we have properly
identified and disclosed this US GAAP difference through the table at the bottom of
page 147 of our annual report in our US GAAP reconciliation note.

    b.

    Please tell us what your intent is in presenting total revenue and why
you believe such a measure provides meaningful information to your investors;

    We believe that presenting total revenue (excluding provision for credit losses) on
the income statement provides the most meaningful information to our investors as we
believe that an important focus of our investors is revenue growth. We believe that
revenue growth would be distorted by netting the provision for credit losses from
total revenue because these provisions are not necessarily related to current period
revenues. We agree that the provision for credit losses is also an important metric
to investors and, as required, we continue to report it as a separate line item on
the statement of operations. In addition, our income statement presentation is
consistent with the presentation followed by Royal Bank of Canada, our largest
competitor in Canada, and with the presentation followed by JPMorgan Chase & Co. and
Bank of America Corporation in the United States.

    c.

    Please tell us how you believe your current income statement
presentation affects the comparability of your financial statements to other bank
holding companies and why, at a minimum, you have not included a net interest
income after provision for credit losses measure on the face of the financial
statements; and

    We believe that our current income statement approach is comparable to other
financial institutions in North America because all of the interest income
components and the credit losses are plainly disclosed on the face of the income
statement. Moreover, as noted in our response to Comment 3(b), many of our
competitors provide a similar income statement presentation. To assist investors in
making a comparison to other financial institutions that have adopted a different
income statement presentation, we have included a table showing the net interest
income after provision for credit losses in the notes to the financial statements on
page 147 of our annual report.

    d.

    Please tell us why the Management’s Discussion and Analysis section of
your Form 40-F focuses on the total revenue measure for each of your segments and
why you believe discussion of this measure, as opposed to a discussion focused on
net interest income, and other revenues separately, provides the most meaningful
information to investors.

    Our Management’s Discussion and Analysis section focuses on total revenue for our
segments because that is how we assess the performance of our businesses

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    and is the focus that we believe is most meaningful to investors. Within our
segments, our organizational structure and performance assessment systems are built
around the individual businesses that comprise the segments and the revenues
reported by those businesses, as opposed to being built around total segment net
interest income and other revenues. In addition, we believe that the allocation of
revenue between net interest income and other revenue is not reflective of the key
drivers of the performance of our businesses because of corporate liquidity and
funding management initiatives such as securitization which have the effect of
reallocating these revenues. As a result, we believe that our Management’s
Discussion and Analysis provides the most meaningful information to investors by
aligning with a business focused format through its discussion of the total revenues
within the various businesses that comprise our segments. We believe that this is
consistent with both Canadian GAAP [Canadian Institute of Chartered Accountants
Handbook (“CICA HB”) Section 1701] and US GAAP (FAS 131), which require us to report
externally the way we manage our segments for making operating decisions and
performance measurement.

Note 24 — Commitments, Guarantees, Pledged Assets and Contingent Liabilities, page 139

    4.

    We note your disclosure on page 141 that your provisions taken to date to cover
Enron-related settlements and reserve against remaining Enron matters take into account
expected insurance recoveries. Please tell us whether the Enron-related provisions recorded
under Canadian GAAP are of the same amount as those recorded under US GAAP. If the amounts
are different, please quantify and fully explain the reasons for the differences. Also,
please explain where any differences appear in your reconciliation to US GAAP in Note 27,
including the individual adjustments and related line-items in those particular financial
statements.

    The Enron related provisions we have recorded for settlements and reserves in our Canadian
GAAP financial statements are identical to those we have recorded under US GAAP. The
accounting guidance we followed for Enron under CICA HB 3290 of Canadian GAAP is similar to
that contained in SFAS 5. As a result, no differences appear in our reconciliation to US
GAAP in Note 27 to our consolidated financial statements.

    5.

    Please quantify for us the amount of expected insurance recoveries that you have netted
against your Enron-related provisions to date. Please compare and contrast your accounting
treatment in Canadian GAAP as opposed to US GAA.P. As a related matter, please also tell us
the specific facts and circumstances that you have relied upon in determining that
Enron-related insurance recoveries are probable (as defined in paragraph 5 of SFAS 5 as
likely to happen), if true.

    The expected insurance recoveries we took into account in determining our Enron related
provisions for fiscal 2005 and prior periods amounted to Cdn$* * * *. The total provision
that we recorded in our statement of operations was net of these expected

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    insurance recoveries. The insurance recovery estimates we made took into account the nature
of our insurance coverage (including the language of our policies), the status of ongoing
negotiations with our carriers and discussions with the internal counsel and external
insurance coverage counsel who were assisting us in both evaluating coverage and negotiating
with our carriers. Based on this, we assessed that a recovery in the amount of Cdn$* * * *
was probable (likely) under both CICA HB 3290 and SFAS5. This assessment proved accurate as
the actual amounts we recovered subsequently totaled Cdn$* * * *. These amounts were all
recovered in the period from November 2005 to May 2006 and there are no further outstanding
insurance recoveries. We did not record any accounting differences at any time between
Canadian and US GAAP.

    6.

    As a related matter, please tell us whether any of the insurance companies from which
you are seeking recoveries for Enron-related matters are asserting that they are not liable
to indemnify your losses. If so, please tell us how this is accounted for under Canadian
GAAP. Compare and contrast this treatment to that under US GAAP which requires that
recoveries of these losses are considered probable. Refer to SAB Topic 5Y.

    All insurance amounts were settled as noted in 5 above. In the period prior to settlement,
our legal counsel evaluation had concluded that recoveries were probable as discussed more
fully in the answer to the prior question.

    7.

    We note your disclosure on page 141 that you have recorded a tax benefit of $297
million relating to your 2005 Enron-related provision but that there is a significant
uncertainty associated with the ultimate tax benefits to be realized for these settlements.
Please tell us whether you have also recorded this tax benefit for US GAAP purposes and if
so, the accounting literature that you relied upon to determine that realization of this
tax benefit was more likely than not.

    The amounts we have recorded under both Canadian and US GAAP totaled Cdn$297 million
for the 2005 provision. In determining the amount of recovery to record, we complied with
the criteria for tax benefits in CICA 3465 and FASB 109. The Cdn$297 million recovery we
recognized represents about * * * * of the total potential tax benefit that we may
ultimately realize and was the amount we regarded as probable of recovery. Our note
disclosures referring to significant uncertainty primarily pertain to the tax benefits we
did not recognize.

Note 27 — Reconciliation of Canadian and United States Generally Accepted Accounting
Principles, page 146

General

    8.

    For all income statement periods presented, please revise your filing to provide either
a statement of cash flows prepared in accordance with US GAAP or IAS 7 or revise to include
a note to your financial statements quantifying the material differences between cash flows
under Canadian GAAP as compared to US GAAP.

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    Refer to Item 17(c)(2)(iii) of Form 20-F. Alternatively, please tell us why you believe this
disclosure requirement is not applicable to you.

    We have complied with this disclosure requirement because we believe that consolidated
statements of cash flows prepared under US GAAP for the Company would not be materially
different from the consolidated statements of cash flows presented in accordance with
Canadian GAAP in the consolidated financial statements on page 101 of the annual report.

    We believe that the only difference between the consolidated statement of cash flows
prepared in accordance with Canadian GAAP and a consolidated statement of cash flows
prepared in accordance with US GAAP is that the amount of net income would differ. This
difference affects only the components of the reconciliation from “net (loss) income” to
total “cash flows provided by (used in) operating activities” in the operating activities
section of the statement of cash flows. We believe that this presentation difference is not
material because the differences arise from items that do not reflect cash flows.
Accordingly, there would be no material differences in the total “cash flows provided by
(used in) operating activities”, “cash flows provided by (used in) financing activities” or
“cash flows provided by (used in) investing activities” amounts or the line items within the
financing activities or investing activities sections of the statement of cash flows.

    In our forthcoming Form 40-F filing for the fiscal year ended October 31, 2006, we will make
a statement in our US GAAP reconciliation note indicating that we have not included
consolidated statements of cash flow prepared under US GAAP because the differences from the
consolidated statements of cash flows prepared under Canadian GAAP are not material.

I. — Liabilities and Equity, page 149

    9.

    We note your disclosure beginning on page 149 regarding your Canadian GAAP accounting
change regarding the classification of convertible preferred shares. Please tell as how you
considered the guidance of SFAS 150 in determining that these preferred shares should be
classified as equity for US GAAP purposes.

    The convertible preferred shares referred to in note 27(i) of the Company’s consolidated
financial statements on page 149 of the annual report are the “preferred share liabilities”
described in note 13 of the consolidated financial statements. These convertible preferred
shares provide the holder and the Company with the right, but not the obligation, to convert
the preferred shares at set dates into a variable number of common shares based on the
trading price of the common shares.

    Pursuant to paragraph 13 of CICA HB 3861 Financial
Instruments — Disclosure and Presentation
these convertible preferred shares have been classified as liabilities under Canadian GAAP
because they can be converted into a variable number of the Company’s common shares at the
option of the holder.

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    Under US GAAP, Paragraph 12 of SFAS 150 provides an exception