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CORRESP
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corresp

September 8, 2006

Page 1

September 8, 2006

Cecelia D. Blye

Chief

Office of Global Security Risk

Division of Corporation Finance

U.S. Securities and Exchange Commission

Washington, D.C. 20549-5546

Dear Ms. Blye:

On behalf of Canadian Imperial Bank of Commerce (“CIBC”), a foreign banking organization and
financial holding company organized in Canada, I am writing to respond to your letter of August 24,
2006 addressed to Gerald T. McCaughey, President and CEO of CIBC, in which you request additional
follow-up information relating to my letter to you dated August 14, 2006. In your letter, you
request the information set forth below.

    1.

    Please expand your qualitative materiality analysis to address specifically whether the
governments of Cuba and Iran, or entities controlled by these governments, participate
directly or indirectly in your trade finance or other transactions with Cuba and Iran. If
these governments or entities controlled by them participate in the transactions, please
discuss the nature and extent of their involvement. Address specifically the possibility that
your involvement in transactions that may result in the provision of funds to the governments
of countries identified as terrorist-sponsoring states may negatively impact your reputation
and share value.

As noted in our response of August 14th, CIBC complies with applicable U.S. and Canadian
law regarding the imposition of economic sanctions on particular countries and entities including
the Canadian Foreign Extraterritorial Measures Act, the Canadian Anti-Boycott Policy and applicable
parts of the regulations promulgated by the U.S. Office of Foreign Assets Control, the U.S. Bureau
of Industry and Security and Foreign Affairs and International Trade Canada.

CIBC’s dealings with Cuban and Iranian entities or transactions involving these countries are not
material to CIBC’s business generally, either individually or in the aggregate. As noted in our
prior letter, through its non-U.S. offices and affiliates, CIBC does very limited business
involving Iran and Cuba. CIBC’s principal business exposure to these countries is with respect to
trade finance of non-U.S., non-Iranian, and non-Cuban customers who do business with entities
located in those countries, and with respect to CIBC’s non-U.S. correspondent banking business unit
which maintains accounts for Cuban or Iranian financial institutions.

You have asked whether the governments of Cuba and Iran, or entities controlled by these
governments, participate directly or indirectly in CIBC’s trade finance or other transactions with
Cuba and Iran. Given the nature of the Iranian and Cuban economies, many companies in Cuba and
Iran are effectively state-controlled. However, CIBC does not generally deal directly with the
governments of these countries.

September 8, 2006

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The only direct contact with the governments of Cuba and Iran is very limited. [

]

CIBC’s
principal exposure to these governments is through non-U.S., non-Iranian, and non-Cuban
clients’ contacts with companies that may be considered controlled by these governments and through
its contacts with Iranian and Cuban banks financing these transactions that may be considered
controlled by these governments. [

]

Although these companies and banks could be considered controlled by the Iranian or Cuban
government, CIBC believes that these indirect dealings with the governments of Iran and Cuba are
not material. As discussed in our prior letter, the quantity of such business is very small. In
addition, CIBC reviews and monitors such transactions not only for sanctions compliance but also
for terrorist financing. [

]

CIBC does not believe the size and types of business conducted with entities, which may be
considered controlled by the Iranian and Cuban governments, pose a material risk of furthering the
sponsoring of terrorism through the governments of those countries.

For the foregoing reasons, CIBC does not believe from either a qualitative or quantitative
perspective that its direct or indirect dealings with the governments of Cuba or Iran or entities
controlled by those governments, are material. However, CIBC continually evaluates the legal and
reputational risk associated with doing business directly and indirectly with entities located in
Iran and Cuba and the materiality of that business. Should this business ever become material,
CIBC would provide additional disclosure regarding such business.

Very truly yours,

K. Thomas Ko

Executive Director & Senior Counsel