| 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 |
April 11, 2017
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
Registration Statement on Form F-4 (File No. 333-217170)
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 10:00 a.m., Eastern Time, on April 12, 2017, 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 David S. Bakst at Mayer Brown LLP at (212) 506-2551. In addition, please notify Mr. Bakst when this request for acceleration has been granted.
Thank you for your attention to this matter.
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