SEC Company Response from CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Mar 22, 2017
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: March 22, 2017 · CIK: 0001045520 · Accession: 0001104659-17-018639
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File numbers found in text: 333-216286
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CORRESP 1 filename1.htm March 22, 2017 BY EDGAR United States Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Canadian Imperial Bank of Commerce Registration Statement on Form F-3 File No. 333-216286 Request for Acceleration Ladies and Gentlemen: In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Canadian Imperial Bank of Commerce, a Canadian chartered bank (the “Registrant”), hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-3, as amended (the “Registration Statement”), be accelerated so that it will be declared effective at 12:00 p.m., noon, Eastern time on March 23, 2017, or as soon thereafter as practicable. The Registrant hereby acknowledges that: (i) should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; (ii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and (iii) the Registrant may not assert staff comments and the declaration of the effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Very truly yours, Canadian Imperial Bank of Commerce By: /s/ E. Gage Olcott Name: E. Gage Olcott Title: Managing Director