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CIBC DODD-FRANK DISCLOSURES
1. Home
2. Disclosures
3. CIBC Dodd-Frank Disclosures
* CIBC World Markets Inc. is a Member of the Canadian Investor Protection Fund
* CIBC World Markets Corp. (US Broker Dealer) Disclosures
* CIBC World Markets Inc. Trade Matching Statement
* Libor Transition
* The US Foreign Account Tax Compliance Act (FATCA)
* Dodd-Frank Disclosures
* Dodd-Frank Complaints Mailbox
* CIBC Capital Markets Best Execution Policy (Canada)
* European Regulatory Disclosures
* CIBC Foreign Exchange Disclosure Statement
* CIBC Foreign Exchange Liquidity Provider Disclosure Cover Sheet
* CIBC Precious Metals Disclosure Statement
* Canadian Imperial Bank of Commerce’s New York Branch Disclosures
In accordance with Title VII of the Dodd-Frank Wall Street Reform and Consumer
Protection Act of 2010, prior to entering into a swap transaction or
security-based swap transaction as defined by the CFTC & SEC, respectively,
(collectively “swap”), CIBC Capital Markets, a Swap Dealer, must provide several
disclosures to a counterparty who is not a Swap Dealer (SD), Major Swap
Participant (MSP), Security Based Swap Dealer (SBSD) or Major Security Based
Swap Participant (SBMSP).
Disclosures maintained on this website are applicable to multiple swaps. The
specific swaps to which these disclosures may apply to are listed in the below
attachment.
This website will be updated regularly with various Risk Disclosures and static
Material Economic Terms (METs) and is accessible to all clients. Throughout
these Disclosures, “you”, “your” and “yours” shall refer to the CIBC Capital
Markets’ counterparty, and “we”, “our”, “ours” and “us” will refer to CIBC
Capital Markets.
GENERAL CIBC CAPITAL MARKETS DISCLOSURES
Swap Dealers are required to provide a notice to each counterparty that contains
the physical address, email or other widely available electronic address and
telephone number of the department of the Swap Dealer to which any complaints
may be directed. You may direct complaints via email to the Dodd-Frank
Complaints Mailbox.
Swap dealers, when acting as a reporting counterparty for transactions executed
off-facility, must transmit to the counterparty the identity of the Swap Data
Repository (SDR) to which primary economic terms (PET) data is reported. All
swap transactions subjected to transaction reporting with CIBC Capital Markets
clients are reported to the DTCC Data Repository (US) LLC.
COUNTERPARTY REPRESENTATIONS UNDER THE US COMMODITY AND FUTURES TRADING
COMMISSION’S (CFTC) CROSS-BORDER GUIDANCE.
Please note that for the purpose of any questions posed or information requested
by CIBC Capital Markets from its existing or potential counterparties to swap
transactions to appropriately determine their cross border status under CFTC
rules, the terms “US Person”, “US Person Guarantees”, or “Affiliate Conduit”
shall have the meaning or criteria set forth in the “Interpretive Guidance and
Policy Statement Regarding Compliance with Certain Swap
Regulations”: https://www.cftc.gov/LawRegulation/FederalRegister/FinalRules/2013-17958 issued
by the CFTC, as amended, supplemented or modified from time to time by the CFTC.
CIBC Capital Markets strongly encourages you to provide formal written
representations using the standard representation template developed by the
International Swaps and Derivatives Association (ISDA); the “Cross Border
Representation Letter” via Markit’s ISDA Amend utility (available
at https://ihsmarkit.com/products/counterparty-manager.html). This shall ensure
that your status is reflected accurately, taking into account all relevant
factors necessary to determine such status for application of relevant CFTC
Rules issued under Dodd-Frank.
Please refer to the following link for a copy of the ISDA Cross Border Swaps
Representation Letter which also includes the definitions or factors relevant to
determining counterparty’s cross border status as a “US Person”, “Guaranteed
Affiliate”, or “Conduit Affiliate” under CFTC’s Cross Border Guidance: The most
efficient way of providing the ISDA Cross Border Representation is via the Cross
Border Representation functionality of ISDA Markit Amend:
https://ihsmarkit.com/products/counterparty-manager.html
ISDA RISK DISCLOSURES
ISDA created standard industry documentation, such as general and product
specific risk disclosures, to assist regulated swap entities in satisfying their
on-going regulatory requirements and to allow other entities to continue trading
with regulated swap entities. The following disclosures are meant to capture
general risks of swap transactions related to the following asset classes:
interest rates, foreign exchange rates and currencies, credit instruments,
asset-backed instruments, equities and commodities. The latest published
documents are attached below:
* General Disclosure Statement for Transactions
* Disclosure Annex for Commodity Derivative Transactions
* Disclosure Annex for Equity Derivative Transactions
* Disclosure Annex for Interest Rate Transactions
* Disclosure Annex for Foreign Exchange Transactions
* Disclosure Annex for Credit Derivative Transactions
* Disclosure Annex for ABS Derivative Transactions
* IBOR Alternative Reference Rates Disclosure
MATERIAL ECONOMIC TERMS (METS) DISCLOSURES
Disclosure Statement regarding transaction terms
This Disclosure Statement describes the manner in which the terms of a
Transaction, as defined in the General Disclosure Statement for Transactions,
between CIBC Capital Markets and you may be defined.
Before entering into any Transaction, you should conduct a thorough and
independent evaluation of the terms of the Transaction in light of your
particular circumstances and the nature and extent of your exposure to, and
willingness to incur, risk. You should also consider whether the Transaction is
appropriate for you in light of your experience, objectives, financial and
operational resources and other relevant circumstances. Unless expressly agreed
in writing, we are not providing you with legal, financial, tax, accounting or
other advice in connection with any Transaction.
The terms of any Transaction that CIBC Capital Markets and you enter into will
be set forth in the confirmation or other agreement evidencing the Transaction,
including any terms incorporated by reference therein. Any Transaction that CIBC
Capital Markets and you enter into will be subject to the terms that CIBC
Capital Markets and you and expressly agree to and the exceptions below:
(1) Specified prior transaction, form confirmation or terms spreadsheet. If we
notify you that the Transaction will have the terms set forth in a specified
prior transaction, form confirmation or terms spreadsheet, the Transaction will
have such terms, subject to any express agreement between CIBC Capital Markets
and you in connection with the Transaction.
(2) Master confirmation agreement. If (1) does not apply and CIBC Capital
Markets and you are party to a master confirmation agreement that governs the
Transaction, the Transaction will have the terms set forth in the master
confirmation agreement, subject to any express agreement between CIBC Capital
Markets and you in connection with the Transaction.
(3) Unspecified prior transaction. If neither (1) nor (2) applies and CIBC
Capital Markets and you have previously entered into a transaction of the same
type, the Transaction will have the terms set forth in the most recent
transaction of the same type that CIBC Capital Markets and you entered into,
subject to any express agreement between CIBC Capital Markets and you in
connection with the Transaction.
The description above of the manner in which the terms of any Transaction that
CIBC Capital Markets and you enter into will be determined is subject to the
following important exceptions.
(A) If CIBC Capital Markets and you enter into a Transaction that is cleared
through a clearinghouse or executed through a trading platform that prescribes
the terms of the Transaction, the Transaction will have the terms specified by
the applicable clearinghouse or trading platform and, subject to the rules of
the clearinghouse or trading platform, any additional terms that CIBC Capital
Markets and you expressly agree upon in connection with the Transaction.
(B) If CIBC Capital Markets and you enter into a Transaction for “give-up” to a
third party, the terms of the Transaction will be subject to the terms of any
agreement with that third party.
SCENARIO ANALYSIS
Pursuant to CFTC regulation 23.431(b), prior to any Swap Transaction Event with
respect to any Swap that is not “available for trading” (as such term is defined
in the CFTC Regulations) on a DCM or SEF, you can request, and consult on the
design of, a scenario analysis to allow you to assess its potential exposure in
connection with such Swap.
Please contact your CIBC Capital Markets Salesperson to request a scenario
analysis.
PRE-TRADE MID-MARKET MARKS AND DAILY MARKS
Under applicable CFTC regulations, CIBC Capital Markets is required to deliver
pre-trade mid-market marks and daily marks to all non-Swap Dealer or non-Major
Swap Participant counterparties. You must elect whether you want to receive
pre-trade mid-market marks orally or in writing. In the event you do not make
this election, CIBC Capital Markets will disclose the pre-trade mid-market mark
in writing. Pre-trade mid-market marks provided orally will also be provided in
writing to clients post-trade.
This mid-market mark is indicative, as at the date noted, and does not reflect
terms under which we are committing ourselves to transact. This mark is not an
offer to enter into, transfer or assign any transaction. This is a mid-market
mark, which does not include amounts for profit, credit reserve, hedging,
funding, liquidity, or any other costs or adjustments.
The daily mark for each of the listed transactions displayed on this statement
represents the change in the net present value (“NPV”) of the future cash flows,
measured from the trade date to the date of this statement. The future cash
flows are those known under the terms of the transaction or estimated using
future rates and prices implied by current mid-market rates and prices
determined using the process as outlined below. The resulting cash flows are
then discounted using the appropriate discount factor from the swap yield curve
in the relevant currency. If such currency is not the currency in which the
mid-market mark is reported, it has been converted to the reporting currency at
the spot rate of exchange disclosed in this statement.
The mid-market mark of an OTC derivative is based on quoted mid-market prices or
third-party consensus pricing for those factors that have a direct impact on the
transaction. Where quoted market prices or third-party consensus pricing
information are not available, valuation techniques are employed to estimate the
mid-market mark on the basis of pricing models. Such vetted pricing models
incorporate current mid-market measures for interest rates, currency exchange
rates, equity and commodity prices and indices, credit spreads, corresponding
market volatility levels, and other market-based pricing factors. CIBC may
provide you a two-way market (i.e. bid and offer) prior to transacting in a
liquid product. In the case where you receive a two-way market from CIBC, you
may calculate the pre-trade mid-market mark by taking the arithmetic average of
the bid and offer prices provided, unless otherwise noted.
In determining the mid-market mark of complex and customized derivatives, such
as equity, credit, and commodity derivatives written in reference to indices or
baskets of reference securities, we consider all reasonably available
information including any relevant observable market inputs, third-party
consensus pricing inputs, indicative dealer and broker quotations, and our own
internal model-based estimates, which are vetted and pre-approved in accordance
with our model risk policy and regularly and periodically calibrated. The model
calculates amounts based on inputs specific to the type of contract, which may
include stock prices, correlation for multiple assets, interest rates, foreign
exchange rates, yield curves, and volatility surfaces. Where observable prices
or inputs are not available, management judgment is required to determine fair
values by assessing other relevant sources of information such as historical
data, proxy information from similar transactions, and through extrapolation and
interpolation techniques.
Valuations or marks provided by other parties or determined for the purposes of
your financial or regulatory disclosure may not necessarily yield the same
result and may vary significantly. Marks provided by other dealers, and the
price at which the identified transaction could actually be unwound, may be less
favorable than our mark due to various factors, including our own hedging
positions. The marks provided above may not necessarily be the value of the
transaction that is marked on CIBC Capital Markets’ books. Calls for margin may
be based on considerations other than the marks provided above.
If the OTC transaction identified above was undertaken as part of an asset swap
transaction or as a hedge for a structured debt obligation you issued, generally
the change in value of the related debt obligation should roughly offset a
change in the value of the OTC transaction, subject to potential differences
attributable to the credit spread of the issuer, which is not taken into account
in our mark of the OTC transaction.
If a structured bond you bought from us is identified above, please note that
its valuation is derived by adjusting the issue price of the bond by our
estimate of the value of unwinding the OTC transaction that hedges the issuer’s
obligations under the bond, using the issuer’s funding levels implied at the
date of issue. The information provided is not a valuation of the price at which
the bond could be redeemed or sold. That price is likely to be significantly
less favorable to you because our valuation does not take into account the
bid/asked spread on the funding component of the bond’s price or any applicable
early redemption fee or trading charge. Our valuations normally include accrued
interest.
With respect to each cleared Swap originally executed between you and CIBC
Capital Markets, you will obtain daily marks for such cleared Swap from the
Futures Commission Merchant (FCM) through which you clear such cleared Swap or
the relevant Derivatives Clearing Organization (DCO).
We believe the above information to be accurate, but we assume no liability for
errors. We will not be liable for any use, or any reliance by you on the
information above or the information contained in any valuation. We make no
representation or warranty in relation to any such information, whether as to
the correctness, completeness, sufficiency or reliability for any purpose of
such information, any entitlement of you to receive, use or rely on such
information or otherwise. By agreeing to trade with CIBC Capital Markets, you
also agree that CIBC Capital Markets incurs no liability as to any losses you
may incur in connection with any representations, errors or omission on our
part, our related or associated companies or by any of their respective
officers, employees or agents.
POTENTIAL CONFLICTS OF INTERESTS
If CIBC Capital Markets determines that it may have a conflict of interest in
connection with a particular swap or that it may have received compensation or
other material incentives from a source other than the counterparty to the swap
in connection with such swap, CIBC Capital Markets will notify such counterparty
of such apparent conflicts of interest or material incentives. CIBC Capital
Markets is required to manage any conflicts of interest in connection with any
transaction as part of the CIBC Code of Conduct.
If you have any questions, please contact your CIBC Capital Markets Salesperson.
CLEARING DISCLOSURES
Upon acceptance of a swap by a DCO:
* The original swap is extinguished
* The original swap is replaced by equal and opposite swaps with the DCO; and
* All terms of the swap shall confirm to the product specifications of the
cleared swap established under the DCO’s rule
Swaps Required to be Cleared
If you are not a Regulated Swap Entity, with respect to any Swap entered into
between you and CIBC Capital Markets under any applicable agreement that is
subject to the mandatory clearing requirements under Section 2(h) of the
Commodity Exchange Act or section 240.15Fh-3(d) of the Securities Exchange Act ,
you have the sole right to select the DCO at which the Swap will be cleared. We
are not obligated, however, to execute a swap for clearing on a DCO where CIBC
Capital Markets does not have clearing rights through direct membership or
through a clearing intermediary.
Swaps Not Required to be Cleared
If you are not a Regulated Swap Entity, with respect to any Swap entered into
you and CIBC Capital Markets under any applicable agreement that is not subject
to the mandatory clearing requirements under Section 2(h) of the Commodity
Exchange Act or section 240.15Fh-3(d) of the Securities Exchange Act, you may
elect to clear such Swap and have the sole right to select the DCO at which the
Swap will be cleared. We are not obligated, however, to execute a swap for
clearing on a DCO where CIBC Capital Markets does not have clearing rights
through direct membership or through a clearing intermediary.
SEGREGATION OF ASSETS HELD AS COLLATERAL IN UNCLEARED SWAP TRANSACTIONS
DISCLOSURES
You have the right to require that any Initial Margin for the applicable
Transaction be segregated in accordance with Regulation 23.702 and 23.703 except
in those circumstances where segregation is mandatory. Upon request, CIBC
Capital Markets and you will identify one or more custodians, one of which must
be a creditworthy and of which must be a legal entity independent of both CIBC
Capital Markets and you, as an acceptable depository for segregated Initial
Margin.
For counterparties who elect not to segregate Initial Margin, CIBC Capital
Markets is required to, on a quarterly basis, report to each counterparty
whether or not the back office procedures of the CIBC Capital Markets relating
to margin and collateral requirements were, at any point during the previous
calendar quarter, not in compliance with the agreement of the counterparties.
DISCLAIMER & TERMS OF USE
TERMS OF USE
CIBC Capital Markets owns and maintains this website (the “Site”). By accessing
or using the Site, you signify your agreement with and understanding of the
following terms and conditions of use (“Terms of Use”). If you do not agree with
any of the Terms of Use, do not access or use the Site. We reserve the right, in
our sole discretion, to modify, alter or otherwise update these Terms of Use at
any time and you agree to be bound by such revisions, modifications, alterations
or updates. You agree to review these Terms of Use on a regular basis and your
continued use of the Site means that you agree with any revisions,
modifications, alterations or other updates made to the Terms of Use.
ACCESS TO RESEARCH SITES
You may be provided with a login and password to access to certain restricted
research related content on certain parts of the Site (the “Research Sites”).
Your use of the Research Sites is subject to these Terms of Use in addition to
any supplementary terms or conditions of use that apply specifically to the use
of the Research Sites as may be found on the Research Sites.
GENERAL
CIBC Capital Markets is a trademark brand name under which Canadian Imperial
Bank of Commerce (“CIBC”), its subsidiaries and affiliates (including, without
limitation, CIBC World Markets Inc., CIBC World Markets Corp. and CIBC World
Markets Limited plc) provide products and services to our customers around the
world. Services offered by the Canadian Imperial Bank of Commerce include
corporate lending services, foreign exchange, money market instruments,
structured notes, interest rate products and OTC derivatives. Canadian Imperial
Bank of Commerce is a provisionally-registered Swap Dealer with the Commodity
Futures Trading Commission (CFTC) and the National Futures Association (NFA).
CIBC’s Disclosures pursuant to the External Business Conduct rules are located
at the following link: cibccm.com/doddfrank. CIBC’s Foreign Exchange Disclosure
Statement relating to guidelines contained in the FX Global Code can be found at
cibccm.com/fxdisclosure. Other products and services, such as exchange-traded
equity and equity options, fixed income securities and futures execution of
Canadian securities, are offered through directly or indirectly held
subsidiaries of CIBC as indicated below. In the U.S.US, CIBC Capital Markets
also provides investment banking services under the trademark brand name CIBC
Cleary Gull.
Securities and other products offered or sold by CIBC Capital Markets are
subject to investment risks, including possible loss of the principal invested.
Each subsidiary or affiliate of CIBC is solely responsible for its own
contractual obligations and commitments. Unless stated otherwise in writing CIBC
Capital Markets products and services are not insured by the Canada Deposit
Insurance Corporation, the Federal Deposit Insurance Corporation, or other
similar deposit insurance and are not endorsed or guaranteed by any bank.
CIBC World Markets Inc. is a member of the Canadian Investor Protection Fund and
the Investment Industry Regulatory Organization of Canada. In the United States,
CIBC World Markets Corp. is a member of the Financial Industry Regulatory
Authority and the Securities Investor Protection Corporation. CIBC Bank USA is
regulated by the Illinois Department of Financial and Professional Regulation
and a member of the Federal Deposit Insurance Corporation. CIBC World Markets
plc is authorized by the Prudential Regulation Authority and regulated by the
Financial Conduct Authority and Prudential Regulation Authority. Canadian
Imperial Bank of Commerce, London Branch, is authorised by the Prudential
Regulation Authority and subject to regulation by the Financial Conduct
Authority and limited regulation by the Prudential Regulation Authority. CIBC
Capital Markets (Europe) S.A. (RCS Luxembourg: B236326) is authorised by the
European Central Bank (the “ECB”) and supervised by the Luxembourg Financial
Supervisory Authority (Commission de Surveillance du Secteur Financier) under
the oversight of the ECB. Canadian Imperial Bank of Commerce, Sydney Branch
(ABN: 33 608 235 847), is an authorized foreign bank branch regulated by the
Australian Prudential Regulation Authority (APRA). CIBC Australia Ltd (AFSL No:
240603) is regulated by the Australian Securities and Investment Commission
(“ASIC”). CIBC World Markets (Japan) Inc. is a member of the Japanese Securities
Dealer Association. Canadian Imperial Bank of Commerce, Hong Kong Branch, is a
registered institution under the Securities and Futures Ordinance, Cap 571.
Canadian Imperial Bank of Commerce, Singapore Branch, is an offshore bank
licensed and regulated by the Monetary Authority of Singapore.
For important disclosures regarding CIBC Capital Markets click here.
NO WARRANTY
The materials found on the Site are provided “as is” without warranty of any
kind, either express or implied, to the fullest extent permissible pursuant to
applicable law, including but not limited to the implied warranties of
merchantability, operation, usefulness, completeness, accuracy, currentness,
reliability, fitness for a particular purpose or non-infringement. CIBC Capital
Markets assumes no responsibility for, and makes no warranties that (i) the
information on the Site is complete, accurate and suitable for your purposes;
(ii) functions contained on the Site will be uninterrupted or error-free; (iii)
the Site may be accessed at all times and in an uninterrupted manner; (iv) that
defects and errors on the Site will be corrected; and (v) that the Site or the
server that makes it available will be free of viruses or other harmful
components. The information and content contained on the Site may be changed
without notice and CIBC Capital Markets has no duty to update or correct any
information on the Site, nor to update you regarding any changes or updates that
have been made. CIBC Capital Markets will not be liable for any damages to,
viruses that may infect, or services, repairs or corrections that must be
performed on your computer or other property on account of your accessing or use
of this site. Please note that some jurisdictions do not allow the exclusion of
implied warranties, so some or all of the above exclusion may not apply to you.
LIABILITY WAIVER
Your use of the Site is not intended to and shall be deemed not to create a
legal relationship of any kind between yourself and CIBC Capital Markets, nor to
amend or vary any existing legal relationship. Under no circumstances,
including, but not limited to, negligence, will CIBC Capital Markets be liable
for any special or consequential damages that result from the access, reliance,
use of, or the inability to access or use the Site or the materials on the Site,
even if CIBC Capital Markets or an authorized representative of CIBC Capital
Markets has been advised of the possibility of such damages. In no event shall
CIBC Capital Markets’ total liability for any and all damages and causes of
action exceed the amount paid by you, if any, for the access to and use of the
Site.
GLOBAL DEALING RESTRICTIONS
The Site contains material regarding our offerings and such material, depending
on the jurisdiction, may not be applicable or available in all jurisdictions.
Every jurisdiction has specific laws regarding the types of products that may be
offered to its residents, therefore not all products and services shown on the
Site may be available in all jurisdictions. Accordingly, CIBC Capital Markets
makes no representations that materials found on the Site are appropriate for
use in all locations, or that transactions, securities, products, instruments,
services or other offerings discussed on the Site are available or appropriate
for sale or use in all jurisdictions, or by all investors or counterparties.
Please be aware of the laws of your country or that otherwise apply to you in
respect of any of the matters described on the Site. Those who access the Site
do so of their own initiative, and are responsible for compliance with the laws
that are applicable in their jurisdiction. Users of the Site may not necessarily
be able to deal directly with all entities whose material is available on the
Site. No software or information on the Site may be downloaded or otherwise
exported in contravention of any applicable laws or regulations, including all
applicable export control laws and regulations.
NO OFFER OF SECURITIES – DISCLOSURE OF INTERESTS
Under no circumstances should any material on the Site be used or considered as
an offer to sell or a solicitation of any offer to buy the securities, products
or any other instruments of CIBC World Markets Inc. or any other issuer or
subsidiary of Canadian Imperial Bank of Commerce. The material found on the Site
is not intended to constitute financial, legal, tax, investment, professional or
expert advice and is only intended for general circulation purposes to users of
the Site.
CONFLICT OF INTERESTS
CIBC Capital Markets may make a market or deal as principal in the securities,
commodities or instruments mentioned in our materials or in options or other
derivative instruments based thereon. In addition, CIBC Capital Markets, or its
shareholders, directors, officers, employees and/or other affiliates, may from
time to time have long or short positions in such securities or in options,
futures or other derivative instruments based thereon. One or more of CIBC
Capital Markets’ directors, officers and/or employees may be a director of the
issuer of the securities mentioned. CIBC Capital Markets or its affiliates may
have managed or co-managed a public offering of, or acted as initial purchaser
or placement agent for a private placement of, any of the securities of any
issuer mentioned, or may from time to time perform investment banking or other
services for, or solicit investment banking or other business from, mentioned
companies. CIBC Capital Markets and/or any of its affiliates may have received
remuneration in connection with any of the activities described immediately
above.
PRICE INFORMATION / VALUATIONS
Actionable prices may only be obtained on a real-time, expressly agreed upon
basis. Any indicative valuations or estimates in materials on the Site are
provided for informational purposes only. Any information regarding any
valuations with respect to any materials does not constitute an offer to enter
into, transfer and assign or terminate any transaction, or a commitment by CIBC
Capital Markets to make such an offer. Indicative valuations on the Site may
vary significantly from indicative valuations available from other sources.
While CIBC Capital Markets has obtained the information on which these
valuations are based from sources believed to be reliable, CIBC Capital Markets
makes no representations or warranties with respect to the correctness, accuracy
or completeness of any indicative valuations.
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CIBC CAPITAL MARKETS DISCLOSURES
* CIBC World Markets Inc. is a Member of the Canadian Investor Protection Fund
* CIBC World Markets Corp. (US Broker Dealer) Disclosures
* CIBC World Markets Inc. Trade Matching Statement
* Libor Transition
* The US Foreign Account Tax Compliance Act (FATCA)
* Dodd-Frank Disclosures
* Dodd-Frank Complaints Mailbox
* CIBC Capital Markets Best Execution Policy (Canada)
* European Regulatory Disclosures
* CIBC Foreign Exchange Disclosure Statement
* CIBC Foreign Exchange Liquidity Provider Disclosure Cover Sheet
* CIBC Precious Metals Disclosure Statement
* Canadian Imperial Bank of Commerce’s New York Branch Disclosures
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* CIBC Foreign Cash Online™
* CIBC Precious Metals Online
* CIBC Air Canada® AC conversion™ Visa* Prepaid Card
Personal Banking
Business Banking
About CIBC
* Corporate Profile
* Corporate Responsibility
* Investor Relations
* Media Centre
* Careers
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