SEC Company Response from CANADIAN IMPERIAL BANK OF COMMERCE (CM) — Apr 29, 2015
CANADIAN IMPERIAL BANK OF COMMERCE /CAN/ (CM, CNDIF) (CIK 0001045520)
Date: April 29, 2015 · CIK: 0001045520 · Accession: 0001193125-15-156015
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-202584
Letter
Re: Canadian Imperial Bank of Commerce
April 28, 2015
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Registration Statement on Form F-3
File Number 333-202584
Ladies and Gentlemen:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Canadian Imperial Bank of Commerce (the “Company”) hereby requests that the effectiveness of the above-referenced registration statement be accelerated so that it will become effective at 2:00 p.m., eastern time on Thursday, April 30, 2015, or as soon thereafter as practicable.
In connection with this acceleration request, the Company 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;
•
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; and
•
the Company may not assert staff comments and the declaration of 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
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CORRESP 1 filename1.htm corresp April 28, 2015 VIA EDGAR 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 Number 333-202584 Ladies and Gentlemen: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Canadian Imperial Bank of Commerce (the “Company”) hereby requests that the effectiveness of the above-referenced registration statement be accelerated so that it will become effective at 2:00 p.m., eastern time on Thursday, April 30, 2015, or as soon thereafter as practicable. In connection with this acceleration request, the Company 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; • 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; and • the Company may not assert staff comments and the declaration of 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/ David Dickinson Name: David Dickinson Title: VP, Treasury Financing