September 23, 2005


Mail Stop 4561

By U.S. Mail and facsimile to (416)304-5047

Mr. Gerald T. McCaughey
President and Chief Executive Officer
Canadian Imperial Bank of Commerce
Commerce Court
Toronto, Ontario
Canada, M5L 1A2

Re:	Canadian Imperial Bank of Commerce
	Form 40-F for the Fiscal Year Ended October 31, 2004
	File Number: 001-14678

Dear Mr. McCaughey:

      We have reviewed your filing and have limited our review to
the
following comments.  Where indicated, we think you should revise
your
document in response to these comments.  If you disagree, we will
consider your explanation as to why our comments are inapplicable
or
a revision is unnecessary.  Please be as detailed as necessary in
your explanation.  In our comments, we may ask you to provide us
with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.











Form 40-F, filed on December 13, 2004

Annual Report for the year ended October 31, 2004 (Exhibit B.3(b)-
(c))

Sources of Fair Value, page 47, and Note 23 - Fair Value of
Financial
Instruments, page 140

1. We read your policy for determination of market value when
quoted
prices in an active market or suitable market proxies are not
available.  Please tell us what methods (other than observed
market
quotations or data) you use to recognize gains or losses in
income.
Include in your response the periods used for each method of
income
recognition, and quantify any deferred gains and/or losses, as
applicable, as of October 31, 2004.
2. Please tell us your methodology for calculating each of your
valuation adjustments for market, model and credit risks and for
administrative costs.
3. Please separately quantify each of these valuation reserves as
of
the balance sheet dates and analyze any significant increases or
decreases.



* * * * *


      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.


	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.


      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.


      You may contact Amanda Roberts at (202) 551-3417 or me at
(202)
551-3490 if you have questions.


Sincerely,


      Donald Walker
Senior Assistant Chief Accountant


Mr. Gerald T. McCaughey
Canadian Imperial Bank of Commerce
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