Cibc Global Asset Management

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CANADIAN IMPERIAL BANK OF
COMMERCE (CIBC)
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CFTC
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
MONETARY FINE: $1.25 MILLION
3.
Date Initiated (MM/DD/YYYY): 
09/24/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
24-29
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
SWAPS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON SEPTEMBER 24, 2024, THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ANNOUNCED A SETTLEMENT WITH CANADIAN IMPERIAL BANK OF
COMMERCE ("CIBC") FOR FAILING TO TIMELY REPORT SWAP TRANSACTIONS TO A REGISTERED SWAP DATA REPOSITORY AS REQUIRED BY THE
COMMODITY EXCHANGE ACT (CEA) AND CFTC REGULATIONS SECTIONS 2(A)(13)(F) AND (G) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. §§
2(A)(13)(F), (G), AND CURRENT COMMISSION REGULATIONS ("REGULATIONS") 43.3(A), 45.3(B)(1), AND 45.4(C), 17 C.F.R. §§ 43.3(A), 45.3(B)
(1),45.4(C) (2023), AS WELL AS FORMER COMMISSION REGULATIONS 43.3(A), 43.4(A), 45.3(B) AND 45.4, 17 C.F.R. §§ 43.3(A), 43.4(A), 45.3(B), 45.4
(2020).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
09/24/2024
 Exact
 Explanation
If not exact, provide explanation:

12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,250,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CIBC AND ITS SUCCESSORS AND ASSIGNS SHALL CEASE AND DESIST FROM VIOLATING THE APPLICABLE SECTIONS CFTC REGULATIONS AND
CIBC SHALL PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF USD$1,250,000 WITHIN FOURTEEN DAYS OF THE DATE OF THE ENTRY OF THIS
ORDER.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
CIBC HAS SUBMITTED AN OFFER OF SETTLEMENT ("OFFER"), WHICH THE COMMISSION HAS DETERMINED TO ACCEPT, AND ADMITS THE FACTS SET
FORTH IN SECTION II BELOW, ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE ACT AND REGULATIONS AND CONSENTS TO THE ENTRY OF THIS
ORDER INSTITUTING PROCEEDINGS PURSUANT TO SECTION 6(C) AND (D) OF THE COMMODITY EXCHANGE ACT, MAKING FINDINGS, AND IMPOSING
REMEDIAL SANCTIONS ("ORDER"), AND ACKNOWLEDGES SERVICE OF THE ORDER.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CANADIAN IMPERIAL BANK OF
COMMERCE (CIBC)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the

adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CFTC
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
AS PART OF THE SETTLEMENT, CIBC HAS UNDERTAKEN TO CONDUCT A COMPREHENSIVE REVIEW AND ASSESSMENT OF CIBC'S REMEDIATION
ACTIVITIES TO COMPLY WITH CFTC RECORDKEEPING REQUIREMENTS TO PRESERVE ELECTRONIC COMMUNICATIONS.
3.
Date Initiated (MM/DD/YYYY): 
09/24/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
24-28
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
SWAPS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION") HAS REASON TO BELIEVE THAT FROM AT LEAST SEPTEMBER 2018 TO THE PRESENT
("RELEVANT PERIOD"), CANADIAN IMPERIAL BANK OF COMMERCE ("CIBC") VIOLATED, AS SET FORTH BELOW, SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3),
AND 4S(H)(1)(B) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. §§ 6S(F)(1)(C), 6S(G)(1), (3), 6S(H)(1)(B), AND COMMISSION REGULATIONS
("REGULATIONS") 1.31, 23.201(A),23.202(A)(1) AND (B)(1), AND 23.602(A), 17 C.F.R. §§ 1.31, 23.201(A), 23.202(A)(1), (B) (1), AND 23.602(A) (2023).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
09/24/2024
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 30,000,000.00

 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
MONETARY FINE OF 30 MILLION
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
DURING THE RELEVANT PERIOD, AS A RESULT OF THE WIDESPREAD EMPLOYEE USE OF UNAPPROVED COMMUNICATION METHODS, CIBC FAILED TO
MAINTAIN COMMISSION-REQUIRED TRANSACTION RECORDS AND PRE-EXECUTION COMMUNICATIONS. BY THIS CONDUCT, CIBC VIOLATED SECTIONS
4S(F)(1)(C) AND 4S(G)(1) AND (3) OF THE ACT AND REGULATIONS 23.201(A) AND 23.202(A)(1) AND (B)(1). BY FAILING TO KEEP ALL COMMISSION-
REQUIRED RECORDS IN SUCH A MANNER AS TO MAKE THEM "READILY ACCESSIBLE," CIBC VIOLATED REGULATION 1.31. CIBC FAILED TO SUPERVISE
ITS SWAP DEALER BUSINESS ACTIVITIES DILIGENTLY DURING THE RELEVANT PERIOD. CIBC FAILED TO MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM
TO ENSURE THAT EMPLOYEES DID NOT UTILIZE UNAPPROVED METHODS TO ENGAGE IN COMMUNICATIONS RELATING TO FIRM BUSINESS, INCLUDING
THE SWAP DEALER BUSINESS. CIBC'S FAILURE TO SUPERVISE IS DEMONSTRATED BY ITS FAILURE TO DETECT, PREVENT, AND REMEDIATE REPEATED
VIOLATIONS OF THE COMMISSION'S RECORDKEEPING REQUIREMENTS AND FIRM POLICIES AND PROCEDURES. SUPERVISORY PERSONNEL FAILED TO
ENSURE THAT EMPLOYEES COMPLIED WITH CIBC'S COMMISSION RECORDKEEPING OBLIGATIONS AND FIRM COMMUNICATIONS POLICIES AND IN SOME
INSTANCES, THEMSELVES VIOLATED THE POLICIES. THESE SUPERVISION FAILURES ALSO RESULTED IN THE FAILURE TO KEEP AND MAINTAIN
COMMISSION-REQUIRED RECORDS AND THE FAILURE TO MAINTAIN THE RECORDS IN SUCH A MANNER AS TO MAKE THEM READILY AVAILABLE. BY THIS
CONDUCT, CIBC FAILED TO SUPERVISE DILIGENTLY ITS OFFICERS, EMPLOYEES, AND AGENTS, IN VIOLATION OF SECTION 4S(H)(1)(B) OF THE ACT AND
REGULATION 23.602(A).