SEC Company Response from CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Oct 26, 2016
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: Oct. 26, 2016 · CIK: 0001045520 · Accession: 0001104659-16-152156
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-213147
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, DC 20549 Re: Canadian Imperial Bank of Commerce Amendment No. 2 to the Registration Statement on Form F-4 Filed October 25, 2016 (File No. 333-213147)
Dear Mr. Windsor:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Canadian Imperial Bank of Commerce (the “Company”) hereby requests that the effective date of the above referenced Registration Statement be accelerated so that such Registration Statement will be declared effective at 9:00 a.m., Eastern Time, on October 28, 2016, or as soon as practical thereafter.
In connection with this acceleration request, the Company hereby acknowledges that:
· should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; and
· the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing.
If you have any questions or comments, please do not hesitate to contact me at (416) 304-2788 or Reb D. Wheeler at Mayer Brown LLP at (212) 506-2414. In addition, please notify Mr. Wheeler when this request for acceleration has been granted.
Thank you for your attention to this matter.
* * * * * * *
Very truly yours,
Canadian Imperial Bank of Commerce
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CORRESP 1 filename1.htm CANADIAN IMPERIAL BANK OF COMMERCE Commerce Court West 199 Bay Street, 11th Floor Toronto, ON M5L 1A2 ROBERT J. RICHARDSON, CD Senior Vice President & General Counsel (Canada) Tel: (416) 304-2788 Email: robert.richardson@cibc.com October 26, 2016 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, DC 20549 Attn: Christian Windsor, Special Counsel Re: Canadian Imperial Bank of Commerce Amendment No. 2 to the Registration Statement on Form F-4 Filed October 25, 2016 (File No. 333-213147) Dear Mr. Windsor: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Canadian Imperial Bank of Commerce (the “Company”) hereby requests that the effective date of the above referenced Registration Statement be accelerated so that such Registration Statement will be declared effective at 9:00 a.m., Eastern Time, on October 28, 2016, or as soon as practical thereafter. In connection with this acceleration request, the Company hereby acknowledges that: · should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; and · the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing. If you have any questions or comments, please do not hesitate to contact me at (416) 304-2788 or Reb D. Wheeler at Mayer Brown LLP at (212) 506-2414. In addition, please notify Mr. Wheeler when this request for acceleration has been granted. Thank you for your attention to this matter. * * * * * * * Very truly yours, Canadian Imperial Bank of Commerce By: /s/ Robert J. Richardson Name: Robert J. Richardson Title: Senior Vice President & General Counsel (Canada) cc: Reb D. Wheeler 2