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March 26, 2010

VIA EDGAR

Amit Pande

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, 2009

File Number 001-14678

Dear Mr. Pande:

Thank you for your letter dated February 25, 2010, addressed to Michael G. Capatides 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, 2009.

We appreciate the effort that went into the Staff’s comments. We have provided our responses in
the order the comments appeared in the Staff’s comment letter, which we have reproduced in bold
face text. Our responses follow each comment.

Form 40-F, filed December 7, 2009

General

    1.

    Please revise your future filings to include page numbers in your Form 40-F filed in EDGAR.

    Further to our discussions with Mr. John A. Spitz of the U.S. Securities and Exchange
Commission (SEC), in future filings, we will include page numbers on our consolidated financial
statements and management’s discussion and analysis (MD&A) filed as part of our Form 40-F that
match the equivalent page numbers in our Annual Accountability Report (AAR).

Exhibit B.3(B)
– Consolidated Financial Statements

Note 4 Securities

    2.

    We note that you recorded an impairment write-down of $100 million on securities
reclassified. Please tell us and revise your future filings to clearly disclose the specific
securities for which you recorded this impairment write-down and how you determined the amount
to record. Additionally, please tell us what transpired from July 2009, the date of adoption
of CICA handbook section 3855 for which you disclose that none of the securities reclassified
were impaired at the time of the transfer, to October 31, 2009 that led to recording this
impairment write-down.

    The specific securities for which we recorded the
$100 million impairment write-down were the
11.5% senior notes due November 15, 2015 of Barzel Industries, Inc. (Notes) (formerly known as
Novamerican Steel, Inc.). In future Form 40-F filings, we will disclose the types of securities
to which we apply significant other-than-temporary-impairment charges. Our disclosure will be
consistent with industry practice. To preserve the confidentiality of competitive information,
we would not disclose the name of the specific entity.

    As requested, we explain what transpired regarding the Notes below:

    (a)

    The impairment write-down of $100 million on securities reclassified was in
respect of (i) securities reclassified on August 1, 2008 pursuant to a first set of
amendments made to CICA handbook section 3855, effective that day permitting certain
trading financial assets to be reclassified to held-to-maturity (HTM) or
available-for-sale (AFS) in rare circumstances, rather than (ii) a second set of
amendments made to CICA handbook section 3855 in July 2009 that required securities with
fixed or determinable payments that were not quoted in an active market at November 1,
2008 to be reclassified to the loans and receivables category. Pursuant to the August
2008 amendments, we reclassified our investment with an initial carrying value of US$102
million in the Notes on August 1, 2008 (the first day in our Q4 2008 period) from
Trading to AFS at its fair value as at that date. As a result, no income or loss
resulted from the transfer and there were no unrealized losses that had to be assessed
for other-than-temporary impairment.

    (b)

    We subsequently conducted an other-than-temporary impairment analysis on the
Notes at the end of Q4 2008 and Q1 2009 and determined that the unrealized losses of
$12 million and $24 million, respectively, resulting from the changes in fair value
from August 1, 2008 did not represent an impairment. Our determination was based on our
assessment that Barzel’s liquidity profile and enterprise value was sufficient to allow
it to continue to service its debt obligations and continue to make its future principal and interest payments to us as required under
the terms of the Notes.

2

    (c)

    During Q2 2009, Barzel released poor financial results. Based on those results
and the global recession we determined that our investment was other-than-temporarily
impaired. As a result, we recognized a $55 million impairment charge in Q2 2009 based on
the difference between the estimated April 30, 2009 fair value of the securities and the
cost basis established by the August 1, 2008 transfer.

    (d)

    During Q3 2009, we recorded an additional impairment charge of $23 million based
on the continued reduction in the estimated fair value of the Notes. We assessed this
reduction to be other-than-temporary because we believed Barzel’s financial position was
worsening.

    (e)

    During Q4 2009, we recorded an additional loss of $22 million based on a final
expected payout of 12 cents on the dollar (US$14 million) on the Notes from Barzel’s
bankruptcy proceedings. As a result, the total impairment write-down for fiscal 2009
was $100 million.

    3.

    We note that you have corporate public equity securities in an unrealized loss position for
greater than 12 months as of October 31, 2009 and 2008. We also note your Critical Accounting
Policies and Estimates within your Management’s Discussion and Analysis which states that for
equity securities the significance of the unrealized loss or the length of time the
unrealized loss has persisted is considered. Please tell us and revise your future filings to
specifically elaborate on your accounting policies in this regard in light of the apparent
duration and unrealized loss position of these securities as of October 31, 2009.

    Of the gross unrealized losses of $40 million as at October 31, 2009 and $18 million as at
October 31, 2008 for public equity securities that have been in an unrealized loss position for
more than 12 months (as disclosed in Note 4 to our consolidated financial statements), $36
million and $16 million, respectively, relate to investment grade perpetual preferred shares
that we assess for impairment using a debt model rather than an equity model.

    We believe the application of a debt model is supported by the SEC’s October 14, 2008 letter to
the FASB in which SEC staff concluded it would not object to an issuer treating a perpetual
preferred share similar to a debt security in an other-than-temporary-impairment evaluation
provided there has been no evidence of deterioration in credit of the issuer. The perpetual
preferred shares in question were issued by BCE Inc., a large Canadian telecommunications
company.

3

    We assessed BCE Inc. to be investment grade quality and have no current plans to dispose of the
investment. We will revise the Critical Accounting Policies and
Estimates section of our MD&A and the Significant Accounting Policies note of our year-end
consolidated financial statements in future Form 40-F filings to indicate that we follow a debt
model for the purposes of assessing other-than-temporary-impairment of investment grade
perpetual preferred shares classified as AFS.

Note 5 Loans

    4.

    We note disclosures of your loan portfolio throughout your filing detailed by categories of
residential mortgages, personal, credit card, and business and government loans. For purposes
of greater transparency and understanding of your loan portfolio and the related movements in
your asset quality, please revise your future filings to provide further disaggregated
information about the loans included in these categories. We note, for instance, that in
discussion of the Risk Rating Method for your Business and Government portfolio you state
that the portfolio comprises exposures to corporate, sovereign, and bank obligor
sub-categories, but it is not clear what the level of exposure is. Also, we also note similar
discussion in your Risk Rating Method for your Retail portfolio, which is comprised of real
estate secured personal lending, qualifying revolving retail, and other retail categories.
For these and all of your other loan categories mentioned above, please consider making these
disclosure enhancements throughout your filing, including financial statement footnotes and
Management’s Discussion and Analysis.

    As noted in your letter, disclosure of our loan portfolio is detailed by categories of
residential mortgages, personal, credit card, and business and government loans. Further
disaggregated information about the loans included in these categories was provided in tables
under the heading “Supplementary annual financial information” included on pages 171 to 174 of
our 2009 AAR. These pages were not part of our Form 40-F filing. The tables relating to
“Analysis of Net Loans and Acceptances” and “Impaired Loans before General Allowances” will be
moved to our MD&A and, therefore, form part of our future Form 40-F filings.

    The discussion of our Risk Rating Method is based on our exposure categorization under Basel II
guidelines while the classification of loans in Note 5 to the financial statements is based on
accounting categories. In Note 29 — Financial Instruments —
Disclosures on page 158 of our 2009
AAR, we provide Basel II drawn credit exposure broken down by accounting categories. In
addition, on page 79 of our 2009 AAR, we provide industry group breakdown of our business and
government exposures under the Risk Rating Method.

4

Exhibit B.3(C)
– Management’s Discussion and Analysis

Provision for Credit Losses

    5.

    We note your disclosures relating to the reasons for the increases in your provision for
loan losses during the current year. For the purpose of greater transparency, please tell us
and revise your future filings to comprehensively bridge the gap between the increases in
your impaired loans and the resulting increases to your provision for credit losses and
allowance for loan losses. In your disclosure, please provide an expanded analysis of the
specific and general components of your allowance for loan losses detailing how you
determined that changes in each component were directionally consistent with changes in the
underlying credit quality of the applicable loan portfolio. Please be as specific and
detailed as needed to provide an investor with a clear understanding of the changes in credit
quality in each applicable loan portfolio and its effect on each component of the allowance
for loan loss. Please also provide us with your proposed disclosures using your financial
information as of October 31, 2009.

    In future Form 40-F filings we will:

    (a)

    update our discussion on impaired loans in the MD&A (page 80 of the 2009 AAR)
to explain the relationship between changes in impaired loans and the resulting change
in provision for credit losses and allowance for loan losses. Please see our enhanced
discussion under “Impaired Loans” on page 8 of the updated MD&A attached to this
letter as Appendix 1;

    (b)

    enhance our analysis of the specific and general allowance for credit losses
in our MD&A (page 80 of the 2009 AAR) by detailing how we determined that changes in
each component were directionally consistent with changes in the underlying credit
quality of the applicable loan portfolio. Please see our enhanced discussion under
“Allowance for credit losses” on pages 8 and 9 of the updated MD&A attached to this
letter as Appendix 1;

    (c)

    include the “Impaired Loans before General
Allowances” table from the “Supplementary Annual Financial Information” section in our
MD&A as noted in our response to question 4 above; and

    (d)

    include two new tables for “Specific Allowances for Credit Losses as a
Percentage of Gross Impaired Loans” and “General Allowance as a Percentage of Total
Net Loans” which will break down this information by major loan categories and by
domestic versus foreign impairments. Please see the tables on page 10 of the updated
MD&A attached to this letter as Appendix 1.

5

    6.

    As a related matter, we note references to “Supplementary annual financial information” for
geographic distribution disclosures related to your impaired loans and allowance for credit
losses. We were able to obtain this information in your Annual Accountability Report 2009
located on your website, but not within your filed Form 40-F. Since you have considerable
operations outside of Canada, please expand on your asset quality disclosures in future filings
to include the “Supplementary annual financial information” in your Management’s Discussion and
Analysis. Please also provide an enhanced qualitative discussion explaining the information
provided and reasons for the periodic changes to these disclosures as you deem appropriate for
a reader’s understanding. Please provide us with your proposed disclosures using your financial
information as of October 31, 2009.

    In future Form 40-F filings we will:

    (a)

    include the following tables presently disclosed in the “Supplementary
Annual Financial Information” section on pages 171 to 174 of the
2009 AAR:

    •

    Analysis of Net Loans and Acceptances

    •

    Summary of Allowance for Credit Losses

    •

    Net Loans and Acceptances by Geographic Location

    •

    Impaired Loans before General Allowances; and

    (b)

    include enhanced qualitative discussion
regarding our asset quality and two new tables for “Specific
Allowances for Credit Losses as a Percentage of Gross Impaired
Loans” and “General Allowance as a Percentage of Total Net
Loans” as noted in our response to question 5 above.
Please see our enhanced discussion under “Allowance for credit
losses” on pages 8 and 9 of the updated MD&A attached to this letter
as Appendix 1.

*    *    *    *    *

In connection with these responses, the Company acknowledges that:

    •

    the Company is responsible for the adequacy and accuracy of the
disclosure in the above filing;

6

    •

    the Staff comments or changes to disclosure in response to Staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

    •

    the Company may not assert the Staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal securities
laws of the United States.

We would
be pleased to discuss any of our responses with you if it would
assist you or your team. Please do
not hesitate to contact the undersigned at (416) 956-3364 or Shuaib Shariff, our Chief Accountant,
at (416) 980-5465.

Very truly yours,

David Williamson

Senior Executive Vice President and Chief Financial Officer

    cc:

    John Spitz,

U.S. Securities and Exchange Commission

Michael G. Capatides,

Chief Administrative Officer and General Counsel, CIBC

Edward S. Best,
Mayer Brown LLP

Robert Swegle,
Colleen Berry-Hiller,

Ernst & Young LLP

    Encl:

    Appendix 1

7

Appendix 1

Impaired
loans and allowance and provision for credit losses

    Business

    Business

    and

    and

    government

    Consumer

    2009

    government

    Consumer

    2008

    $ millions, as at or for the year ended October 31

    loans

    loans

    Total

    loans

    loans

    Total

    Gross impaired loans

    Balance at beginning of year

    $
    399

    $
    584

    $
    983

    $
    370

    $
    493

    $
    863

    New additions

    1,142

    1,646

    2,788

    297

    1,041

    1,338

    Returned to performing status, repaid or sold

    (201
    )

    (436
    )

    (637
    )

    (120
    )

    (248
    )

    (368
    )

    Gross impaired loans prior to write-offs

    1,340

    1,794

    3,134

    547

    1,286

    1,833

    Write-offs

    (156
    )

    (1,067
    )

    (1,223
    )

    (148
    )

    (702
    )