CMHC-Registered Covered Bonds

Response of the Office of Structured Finance
Division of Corporation Finance

May 12, 2026

Via Email
Jerry R. Marlatt
Mayer Brown LLP
jmarlatt@mayerbrown.com

Anna T. Pinedo
Mayer Brown LLP
apinedo@mayerbrown.com

Re: Canadian Covered Bonds
      Incoming Letter dated May 7, 2026

Dear Mr. Marlatt and Ms. Pinedo:

We are responding to your letter dated May 7, 2026, addressed to Kayla Roberts. To avoid having to recite or summarize the facts set forth in your letter, we attach a copy of your letter. Unless otherwise noted, capitalized terms in this response letter have the same meaning as in your letter.

Based on the facts and representations presented in your letter, the Division of Corporation Finance will not recommend enforcement action to the Commission if Covered Bonds and the related Guarantees are offered and sold by CMHC registered Banks pursuant to a Registration Statement on Form F-3 in the manner outlined in your letter.

This position is based on the representations made to the Division in your letter. Any different facts or conditions might require the Division to reach a different conclusion. Further, this response expresses the Division’s position on enforcement action only and does not express any legal conclusion on the issues presented.

Sincerely,
/s/ Kayla Roberts

Kayla Roberts
Chief, Office of Structured Finance
Division of Corporation Finance

Division of Corporation Finance Team:
Hodan Siad, Special Counsel, Office of Structured Finance
Tom Kluck, Special Counsel, Office of International Corporate Finance
Stephanie Sullivan, Accountant, Office of the Chief Accountant
Chris Windsor, Legal Branch Chief, Finance Office