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SEC Company Response from CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Dec 12, 2019

CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: Dec. 12, 2019 · CIK: 0001045520 · Accession: 0001104659-19-072060

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File numbers found in text: 333-233663

Date
December 12, 2019
Author
Canadian Imperial Bank of Commerce
Form
CORRESP
Company
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)

Letter

Re: Canadian Imperial Bank of Commerce Registration Statement on Form F-3

December 12, 2019

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

File No. 333-233663

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933 (the “Act”), Canadian Imperial Bank of Commerce (the “Registrant”) hereby requests that the above-referenced Registration Statement on Form F-3, as amended by Pre-Effective Amendment No. 1 (the “Registration Statement”), be declared effective at 4:00 p.m., Eastern Time on December 16, 2019, or as soon as practicable thereafter.

Once the Registration Statement has been declared effective, it would be appreciated if you would so inform Edward S. Best via telephone at (312) 701-7100 or via e-mail at EBest@mayerbrown.com or Shouhua Yu via telephone at (212) 506-2556 or via e-mail at SYu@mayerbrown.com.

[Remainder of page left intentionally blank; signature page follows]

Thank you for your assistance in this matter.

Very truly yours,
Canadian Imperial Bank of Commerce

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CORRESP
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December 12, 2019

Via EDGAR

United States Securities and  Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re:                          Canadian Imperial Bank of Commerce Registration Statement on Form F-3

File No. 333-233663

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933 (the “Act”), Canadian Imperial Bank of Commerce (the “Registrant”) hereby requests that the above-referenced Registration Statement on Form F-3, as amended by Pre-Effective Amendment No. 1 (the “Registration Statement”), be declared effective at 4:00 p.m., Eastern Time on December 16, 2019, or as soon as practicable thereafter.

Once the Registration Statement has been declared effective, it would be appreciated if you would so inform Edward S. Best via telephone at (312) 701-7100 or via e-mail at EBest@mayerbrown.com or Shouhua Yu via telephone at (212) 506-2556 or via e-mail at SYu@mayerbrown.com.

[Remainder of page left intentionally blank; signature page follows]

Thank you for your assistance in this matter.

Very   truly yours,

Canadian   Imperial Bank of Commerce

By:

/s/ ACHILLES   M. PERRY

Name:

Achilles   M. Perry

Title:

Vice   President & General Counsel – CIBC Capital Markets (US, Europe,   Asia)