Firm profile

Cibc Private Wealth Advisors, Inc..

CHICAGO, ILCRD 109644Registration Status: ApprovedEffective since October 27, 2000SEC # 801-57986Latest ADV June 22, 2026

Cibc Private Wealth Advisors, Inc. is an SEC registered investment adviser organized as a corporation with a primary office location in Chicago, IL. Its latest Form ADV filing, dated June 22, 2026, reports $67.8B in regulatory assets under management, 610 employees, 17 offices, and 29,019 accounts.

Assets Under Management
$67.8B
Employees
610
Offices
17 offices
Total Clients
9,236

Associated firm names

9 names listed
  • AT INVESTMENT ADVISERS, INC.
  • STEIN ROE INVESTMENT COUNSEL,LLC
  • STEIN ROE INVESTMENT COUNSEL, INC.
  • STEIN ROE INVESTMENT COUNSEL LLC

Leadership

4 roles identified
CEOJohn S. Markwalter
CCOBrian Delman
CFOPaul Carey

Advisory services offered

7 types reported
Financial Planning Services
Other advisory services
Portfolio management for businesses

Fee models offered

2 types reported
Asset based fees
Fixed fees

Offices & Contact

Primary office

CHICAGO, Illinois, United States

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Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Illinois

CHICAGOPrimary office

California

SAN FRANCISCO · NEWPORT BEACH

Colorado

DENVER

District of Columbia

WASHINGTON

Florida

WEST PALM BEACH · TAMPA

Georgia

ST. SIMONS ISLAND · ATLANTA

Massachusetts

BOSTON

Michigan

BIRMINGHAM

Missouri

ST. LOUIS

New York

NEW YORK

Texas

HOUSTON · DALLAS · AUSTIN

Wisconsin

MILWAUKEE

17 office records listed · 17 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$67.8Bas of June 22, 2026
Discretionary95.0%
$64.4B
95% of total RAUM95.0%
Non-discretionary5.0%
$3.4B
5% of total RAUM5.0%
Regulatory assets under management are split between discretionary and non-discretionary assets.

Client Coverage Demographics

Top client segmentIndividuals represent 65.6% of total clients.
Top client categories% of clientsClients
1
Individuals
65.6%
6,063
2
HNWI
21.9%
2,020
3
Corporations
4.6%
427
4
Charitable
4.4%
402
5
Pension Plans
3.3%
309
Additional categories (<0.1%)
INDIAN TRIBE<5 clients

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$67.8B
Total Accounts29,019
10Y AUM Change+$57.7B (+571.2%)

Private Funds

Private funds reported by Cibc Private Wealth Advisors, Inc..

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Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees610
Clients per Employee15:1
10Y Employee Change+350 (+134.6%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.


Ownership

Reported direct and indirect ownership ranges

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
CIBC PRIVATE WEALTH GROUP LLCDirect owner · Schedule AInterest in CIBC PRIVATE WEALTH ADVISORS, INC.
75%+
CANADIAN IMPERIAL BANK OF COMMERCEIndirect owner · Schedule BInterest in CIBC BANCORP USA, INC.
75%+
CIBC BANCORP USA, INC.Indirect owner · Schedule BInterest in CIBC PRIVATE WEALTH GROUP LLC
75%+

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Cibc Private Wealth Advisors, Inc...

Reported ownership and control details

Form ADV · Filing date 2026-06-22 · Schedules A and B

13 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1JOHN SHEEHAN MARKWALTERCHAIRMAN OF THE BOARD, CHIEF EXECUTIVE OFFICERIndividualCIBC PRIVATE WEALTH ADVISORS, INC.Less than 5%Code NAYesCHAIRMAN OF THE BOARD, CHIEF EXECUTIVE OFFICER03/2004Schedule APDF page 61
2CIBC PRIVATE WEALTH GROUP LLCSOLE SHAREHOLDERDomestic entityCIBC PRIVATE WEALTH ADVISORS, INC.75% or moreCode EYesSOLE SHAREHOLDER03/2004Schedule APDF page 61
3GREGORY BRENT CAMPBELLGENERAL COUNSEL & ASST SECRETARY, DIRECTORIndividualCIBC PRIVATE WEALTH ADVISORS, INC.Less than 5%Code NAYesGENERAL COUNSEL & ASST SECRETARY, DIRECTOR08/2022Schedule APDF page 61
4Paul CareyCHIEF FINANCIAL OFFICERIndividualCIBC PRIVATE WEALTH ADVISORS, INC.Less than 5%Code NAYesCHIEF FINANCIAL OFFICER02/2019Schedule APDF page 61
5PHILIP WAYNE CECILSECRETARYIndividualCIBC PRIVATE WEALTH ADVISORS, INC.Less than 5%Code NAYesSECRETARY02/2021Schedule APDF page 61
6DIANA KIFARKIS VASQUEZDIRECTORIndividualCIBC PRIVATE WEALTH ADVISORS, INC.Less than 5%Code NAYesDIRECTOR11/2023Schedule APDF page 61
7Kishore SettyPRESIDENTIndividualCIBC PRIVATE WEALTH ADVISORS, INC.Less than 5%Code NAYesPRESIDENT11/2023Schedule APDF page 61
8Brian DELMANCHIEF COMPLIANCE OFFICERIndividualCIBC PRIVATE WEALTH ADVISORS, INC.Less than 5%Code NAYesCHIEF COMPLIANCE OFFICER11/2024Schedule APDF page 61
9Gary PzegeoCHIEF INVESTMENT OFFICERIndividualCIBC PRIVATE WEALTH ADVISORS, INC.Less than 5%Code NAYesCHIEF INVESTMENT OFFICER02/2025Schedule APDF page 61
10Trevor C ChambersDIRECTORIndividualCIBC PRIVATE WEALTH ADVISORS, INC.Less than 5%Code NAYesDIRECTOR05/2025Schedule APDF page 61
11DANIEL ERIC FELDMANDIRECTORIndividualCIBC PRIVATE WEALTH ADVISORS, INC.Less than 5%Code NAYesDIRECTOR05/2025Schedule APDF page 61
12CANADIAN IMPERIAL BANK OF COMMERCE100% SHAREHOLDERForeign entityCIBC BANCORP USA, INC.75% or moreCode EYes100% SHAREHOLDER08/2008Schedule BPDF page 62
13CIBC BANCORP USA, INC.100% SHAREHOLDERDomestic entityCIBC PRIVATE WEALTH GROUP LLC75% or moreCode EYes100% SHAREHOLDER12/2013Schedule BPDF page 62

Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.

Compliance & Disclosures

Filing dated 6/22/2026 5:13:46 PM

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that none of the events below involve the firm or its supervised persons.RIA responseNo
AFelonies2 No

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?No
  • A2Been charged with a felony?No
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions3 Yes2 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?No
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions5 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions1 Yes3 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings2 Yes2 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?Yes

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?Yes
Additional DRP filings 8 source blocks

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

regulatory · block 1CIBC WORLD MARKETS CORP.PDF pages 62–64
Advisory affiliate name — filed text
CIBC WORLD MARKETS CORP.
Regulator name — filed text
CHICAGO BOARD OF OPTIONS, INC.
Monetary/Fine Amount — filed text
$ 100,000.00
How was matter resolved — filed text
Consent

Action status / disposition — filed text

THE CBOE DETERMINED THAT ON OR ABOUT 6/1/16, CIBC WORLD MARKETS CORP. ("CIBC") (1) THROUGH AN ASSOCIATED PERSON ENGAGED IN AN ANTICIPATORY HEDGING TRANSACTION (2) FAILED TO KEEP CURRENT AND PRESERVE ACCURATE BOOKS AND RECORDS ASSOCIATED WITH THE RECEIPT, ROUTING, AND EXECUTION OF CUSTOMER ORDERS IN SPX AND XSP AS WELL AS FOR CIBC'S RELATED FIRM TRANSACTIONS (3) FAILED TO ESTABLISH, IMPLEMENT AND ENFORCE WSPS THAT WERE REASONABLY DESIGNED TO PREVENT VIOLATIONS OF EXCHANGE RULES 4.1 AND 6.9 AND (4) FAILED TO SUPERVISE THE ACTIVITY OF ITS ASSOCIATED PERSON TO ASSURE COMPLIANCE WITH EXCHANGE RULES 4.1, 4.2, 4.24, 6.9 AND 15.1; SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER.
Other filed details

Description of allegations — filed text

THE CHICAGO BOARD OF OPTIONS, INC. ("CBOE") DETERMINED THAT ON OR ABOUT JUNE 1, 2016, CIBC WORLD MARKETS CORP. ("CIBC") BY AND THROUGH ITS ASSOCIATED PERSON, ACCEPTED A CUSTOMER HELD ORDER TO SELL SPX AND XSP AUGUST PUT OPTIONS AND IN TURN (1) ENGAGED IN ANTICIPATORY HEDGING TRANSACTIONS IN RELATED INSTRUMENTS; (2) FAILED TO MAKE, KEEP CURRENT AND PRESERVE ACCURATE BOOKS AND RECORDS ASSOCIATED WITH THE RECEIPT, ROUTING AND EXECUTION OF CIBC CUSTOMER ORDERS, AS WELL AS CIBC'S RELATED FIRM TRANSACTIONS; (3) FAILED TO ESTABLISH, IMPLEMENT AND ENFORCE WSPS THAT WERE REASONABLY DEISGNED TO PREVENT AND DETECT VIOLATIONS OF EXCHANGE RULES 4.1 AND 6.9; AND (4) FAILED TO SUPERVISE THE ACTIVITY OF ITS ASSOCIATED PERSON TO ASSURE COMPLIANCE WITH EXCHANGE RULES 4.1 AND 6.9.

Sanction detail — filed text

FINE OF $100,000
Full extracted filing text

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:
630
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CIBC WORLD MARKETS CORP.
(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) 
CHICAGO BOARD OF OPTIONS, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY FINE $100,000
3.
Date Initiated (MM/DD/YYYY): 
05/06/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20160502034
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OF OPTIONS, INC. ("CBOE") DETERMINED THAT ON OR ABOUT JUNE 1, 2016, CIBC WORLD MARKETS CORP. ("CIBC") BY AND
THROUGH ITS ASSOCIATED PERSON, ACCEPTED A CUSTOMER HELD ORDER TO SELL SPX AND XSP AUGUST PUT OPTIONS AND IN TURN (1) ENGAGED IN
ANTICIPATORY HEDGING TRANSACTIONS IN RELATED INSTRUMENTS; (2) FAILED TO MAKE, KEEP CURRENT AND PRESERVE ACCURATE BOOKS AND
RECORDS ASSOCIATED WITH THE RECEIPT, ROUTING AND EXECUTION OF CIBC CUSTOMER ORDERS, AS WELL AS CIBC'S RELATED FIRM
TRANSACTIONS; (3) FAILED TO ESTABLISH, IMPLEMENT AND ENFORCE WSPS THAT WERE REASONABLY DEISGNED TO PREVENT AND DETECT
VIOLATIONS OF EXCHANGE RULES 4.1 AND 6.9; AND (4) FAILED TO SUPERVISE THE ACTIVITY OF ITS ASSOCIATED PERSON TO ASSURE COMPLIANCE
WITH EXCHANGE RULES 4.1 AND 6.9.
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):
06/07/2019
 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: $ 100,000.00
 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: 
FINE OF $100,000
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).
THE CBOE DETERMINED THAT ON OR ABOUT 6/1/16, CIBC WORLD MARKETS CORP. ("CIBC") (1) THROUGH AN ASSOCIATED PERSON ENGAGED IN AN
ANTICIPATORY HEDGING TRANSACTION (2) FAILED TO KEEP CURRENT AND PRESERVE ACCURATE BOOKS AND RECORDS ASSOCIATED WITH THE
RECEIPT, ROUTING, AND EXECUTION OF CUSTOMER ORDERS IN SPX AND XSP AS WELL AS FOR CIBC'S RELATED FIRM TRANSACTIONS (3) FAILED TO
ESTABLISH, IMPLEMENT AND ENFORCE WSPS THAT WERE REASONABLY DESIGNED TO PREVENT VIOLATIONS OF EXCHANGE RULES 4.1 AND 6.9 AND (4)
FAILED TO SUPERVISE THE ACTIVITY OF ITS ASSOCIATED PERSON TO ASSURE COMPLIANCE WITH EXCHANGE RULES 4.1, 4.2, 4.24, 6.9 AND 15.1;
SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER.
regulatory · block 2CIBC WORLD MARKETS CORP.PDF pages 64–66
Advisory affiliate name — filed text
CIBC WORLD MARKETS CORP.
Regulator name — filed text
NASDAQ PHLX, LLC
Monetary/Fine Amount — filed text
$ 33,333.33
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

CIBC WAS SUBJECT TO CENSURE AND A MONETARY FINE OF $33,333.33
Other filed details

Description of allegations — filed text

FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE PHLX AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 AND PHLX RULE 760. CIBC ALSO VIOLATED PHLX RULE 748 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATION OF THE APPLICABLE FEDERAL SECURITIES LAWS AND PHLX RULES THAT: (I)REQUIRE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS; AND (II) PRHOIBIT FRONT-RUNNING AND ANTICIPATORY HEDGING.

Sanction detail — filed text

FINE OF $33,333.33
Full extracted filing text

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:
630
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CIBC WORLD MARKETS CORP.

(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) 
NASDAQ PHLX, LLC
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
10/28/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2017053128902
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND
ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE PHLX AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES
FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 AND PHLX RULE 760. CIBC ALSO VIOLATED PHLX
RULE 748 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE
REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATION OF THE APPLICABLE FEDERAL SECURITIES LAWS
AND PHLX RULES THAT: (I)REQUIRE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS; AND (II)
PRHOIBIT FRONT-RUNNING AND ANTICIPATORY HEDGING.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
10/28/2019
 Exact
 Explanation

p
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 33,333.33
 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: 
FINE OF $33,333.33
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 WAS SUBJECT TO CENSURE AND A MONETARY FINE OF $33,333.33
regulatory · block 3CIBC WORLD MARKETS CORP.PDF pages 66–68
Advisory affiliate name — filed text
CIBC WORLD MARKETS CORP.
Regulator name — filed text
NASDQ ISE, LLC (ISE)
Monetary/Fine Amount — filed text
$ 33,333.33
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

CIBC WORLD MARKETS CORP (CIBC) WAS SUBJECT TO CENSURE AND A FINE OF $33,333.33.
Other filed details

Description of allegations — filed text

FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE ISE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 AND ISE RULE 1400. CIBC ALSO VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATION OF APPLICABLE FEDERAL SECURITIES LAWS AND ISE RULES THAT: (I) REQUIRE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS; AND (II) PROHIBIT FRONT-RUNNING AND ANTICIPATORY HEDGING.

Sanction detail — filed text

$33,333.33
Full extracted filing text

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:
630
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CIBC WORLD MARKETS CORP.
(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) 
NASDQ ISE, LLC (ISE)
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
02/13/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2017053128903
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND
ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE ISE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR
EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 AND ISE RULE 1400. CIBC ALSO VIOLATED ISE RULE
401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE
REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATION OF APPLICABLE FEDERAL SECURITIES LAWS AND
ISE RULES THAT: (I) REQUIRE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS; AND (II)
PROHIBIT FRONT-RUNNING AND ANTICIPATORY HEDGING.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
10/28/2019
 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: $ 33,333.33
 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: 
$33,333.33
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 WORLD MARKETS CORP (CIBC) WAS SUBJECT TO CENSURE AND A FINE OF $33,333.33.
regulatory · block 4CIBC WORLD MARKETS CORP.PDF pages 68–70
Advisory affiliate name — filed text
CIBC WORLD MARKETS CORP.
Regulator name — filed text
NASDAQ ACRA, INC.
Monetary/Fine Amount — filed text
$ 33,333.33
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

WITHOUT ADMITTING OR DENYING THE FINDINGS, CIBC CONSENTED TO THE SANCTIONS AND THE ENTRY OF THE FINDINGS THAT THE FIRM FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE EXCHANGE FOR EXECUTION.
Other filed details

Description of allegations — filed text

FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE ISE AND VARIOUS OTHER NATIONS SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 1400. CIBC ALSO VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH AND TO DETECT AND PREVENT VIOLATIONS OF THE APPLICABLE FEDERAL SECURITIES LAWS AND NYSE RULE THAT REQUIRE: ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS AND PROHIBIT FRONT- RUNNING AND ANTICIPATORY HEDGING.

Sanction detail — filed text

FINED $33,333.33
Full extracted filing text

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:
630
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CIBC WORLD MARKETS CORP.
(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) 
NASDAQ ACRA, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY FINE OF $33,333.33
3.
Date Initiated (MM/DD/YYYY): 
10/28/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2017053128901
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND
ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE ISE AND VARIOUS OTHER NATIONS SECURITIES EXCHANGES FOR
EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 1400. CIBC ALSO VIOLATED ISE RULE 401
BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY
DESIGNED TO ASSURE COMPLIANCE WITH AND TO DETECT AND PREVENT VIOLATIONS OF THE APPLICABLE FEDERAL SECURITIES LAWS AND NYSE
RULE THAT REQUIRE: ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS AND PROHIBIT FRONT-
RUNNING AND ANTICIPATORY HEDGING.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
10/28/2019
 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: $ 33,333.33
 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: 
FINED $33,333.33

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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, CIBC CONSENTED TO THE SANCTIONS AND THE ENTRY OF THE FINDINGS THAT THE FIRM FAILED TO
ACCURATELY RECORD THE ORDER RECEIPT AND TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE EXCHANGE FOR
EXECUTION.
regulatory · block 5CIBC WORLD MARKETS CORP.PDF pages 70–71
Advisory affiliate name — filed text
CIBC WORLD MARKETS CORP.
Regulator name — filed text
CBOE EXCHANGE INC
Monetary/Fine Amount — filed text
$ 80,000.00
How was matter resolved — filed text
Consent

Action status / disposition — filed text

THE FIRM WAS CENSURED AND FINED $80,000
Other filed details

Description of allegations — filed text

CIBC WORLD MARKETS CORP VIOLATED CBOE RULES 4.2, 5.12, 8.1, 8.2 AND OCC BY LAWS ARTICLE VI SECTION I IN THAT THEY IMPROPERLY USED THE OCC ADJUSTMENT PROCESS. THE FIRM ALSO VIOLATED CBOE RULE 8.16 IN THAT THEY DID NOT ESTABLISH SUFFICIENT SUPERVISORY PROCEDURES REGARDING ITS USE OF THE OCC ADJUSTMENT PROCESS. THE FIRM HAD IN PLACE PROCEDURES REGARDING ITS ACCOMMODATION ACCOUNT, WHICH IT USED AS PART OF THE ADJUSTMENT PROCESS. HOWEVER, THOSE PROCEDURES WERE NOT CONSISTENT WITH INTERPRETATIONS AND POLICIES .01(A) TO OCC BYLAWS ARTICLE VI, SECTION I, SINCE THEY PERMITTED ADJUSTMENTS, AFTER SUPERVISORY REVIEW AND SIGN-OFF, FOR PURPOSES OTHER THAN TO CORRECT BONA FIDE ERRORS IN TRADES THAT WERE PREVIOUSLY SUMMITTED TO THE OCC.

Sanction detail — filed text

CENSURE AND MONETARY FINE OF $80,000
Full extracted filing text

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:
630
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CIBC WORLD MARKETS CORP.
(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) 
CBOE EXCHANGE INC
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY FINE $80,000
3.
Date Initiated (MM/DD/YYYY): 
05/04/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
STAR NO 20200660058/FILE NO URE-31-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CIBC WORLD MARKETS CORP VIOLATED CBOE RULES 4.2, 5.12, 8.1, 8.2 AND OCC BY LAWS ARTICLE VI SECTION I IN THAT THEY IMPROPERLY USED
THE OCC ADJUSTMENT PROCESS. THE FIRM ALSO VIOLATED CBOE RULE 8.16 IN THAT THEY DID NOT ESTABLISH SUFFICIENT SUPERVISORY
PROCEDURES REGARDING ITS USE OF THE OCC ADJUSTMENT PROCESS. THE FIRM HAD IN PLACE PROCEDURES REGARDING ITS ACCOMMODATION
ACCOUNT, WHICH IT USED AS PART OF THE ADJUSTMENT PROCESS. HOWEVER, THOSE PROCEDURES WERE NOT CONSISTENT WITH INTERPRETATIONS
AND POLICIES .01(A) TO OCC BYLAWS ARTICLE VI, SECTION I, SINCE THEY PERMITTED ADJUSTMENTS, AFTER SUPERVISORY REVIEW AND SIGN-OFF,
FOR PURPOSES OTHER THAN TO CORRECT BONA FIDE ERRORS IN TRADES THAT WERE PREVIOUSLY SUMMITTED TO THE OCC.
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):
05/08/2023
 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: $ 80,000.00
 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: 
CENSURE AND MONETARY FINE OF $80,000
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).
THE FIRM WAS CENSURED AND FINED $80,000
regulatory · block 6PDF pages 72–73
Regulator name — filed text
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Monetary/Fine Amount — filed text
$ 12,000,000.00
How was matter resolved — filed text
Decision & Order of Offer of Settlement

Action status / disposition — filed text

ON SEPTEMBER 24, 2024, THE SECURITIES AND EXCHANGE COMMISSION (SEC) ANNOUNCED A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS. IN DETERMINING TO ACCEPT CIBC'S SETTLEMENT OFFER, THE SEC CONSIDERED CIBC'S' COOPERATION AS WELL AS REMEDIAL STEPS THAT CIBC UNDERTOOK BOTH BEFORE AND AFTER BEING APPROACHED BY THE SEC STAFF. PRIOR TO THIS SETTLEMENT, CIBC ENHANCED ITS POLICIES AND PROCEDURES, INCREASED TRAINING AND COMPLIANCE REMINDERS CONCERNING THE USE OF APPROVED COMMUNICATIONS METHODS, ENHANCED ITS SURVEILLANCE PROCESSES, AND IMPLEMENTED SIGNIFICANT CHANGES TO THE TECHNOLOGY AVAILABLE TO PERSONNEL. AS PART OF THE SETTLEMENT, CIBC HAS UNDERTAKEN TO RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW AND ASSESSMENT OF CIBC'S REMEDIATION ACTIVITIES TO COMPLY WITH SEC RECORDKEEPING REQUIREMENTS TO PRESERVE ELECTRONIC COMMUNICATIONS.
Other filed details

Description of allegations — filed text

ON SEPTEMBER 24, 2024, THE SECURITIES AND EXCHANGE COMMISSION (SEC) ANNOUNCED A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS. IN DETERMINING TO ACCEPT CIBC'S SETTLEMENT OFFER, THE SEC CONSIDERED CIBC'S' COOPERATION AS WELL AS REMEDIAL STEPS THAT CIBC UNDERTOOK BOTH BEFORE AND AFTER BEING APPROACHED BY THE SEC STAFF. PRIOR TO THIS SETTLEMENT, CIBC ENHANCED ITS POLICIES AND PROCEDURES, INCREASED TRAINING AND COMPLIANCE REMINDERS CONCERNING THE USE OF APPROVED COMMUNICATIONS METHODS, ENHANCED ITS SURVEILLANCE PROCESSES, AND IMPLEMENTED SIGNIFICANT CHANGES TO THE TECHNOLOGY AVAILABLE TO PERSONNEL. AS PART OF THE SETTLEMENT, CIBC HAS UNDERTAKEN TO RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW AND ASSESSMENT OF CIBC'S REMEDIATION ACTIVITIES TO COMPLY WITH SEC RECORDKEEPING REQUIREMENTS TO PRESERVE ELECTRONIC COMMUNICATIONS.

Sanction detail — filed text

A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS.
Full extracted filing text

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
No Information Filed
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) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/24/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO 3-22160

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON SEPTEMBER 24, 2024, THE SECURITIES AND EXCHANGE COMMISSION (SEC) ANNOUNCED A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH
ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A
CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF
RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS. IN DETERMINING TO ACCEPT CIBC'S SETTLEMENT OFFER, THE SEC CONSIDERED
CIBC'S' COOPERATION AS WELL AS REMEDIAL STEPS THAT CIBC UNDERTOOK BOTH BEFORE AND AFTER BEING APPROACHED BY THE SEC STAFF. PRIOR
TO THIS SETTLEMENT, CIBC ENHANCED ITS POLICIES AND PROCEDURES, INCREASED TRAINING AND COMPLIANCE REMINDERS CONCERNING THE USE
OF APPROVED COMMUNICATIONS METHODS, ENHANCED ITS SURVEILLANCE PROCESSES, AND IMPLEMENTED SIGNIFICANT CHANGES TO THE
TECHNOLOGY AVAILABLE TO PERSONNEL. AS PART OF THE SETTLEMENT, CIBC HAS UNDERTAKEN TO RETAIN AN INDEPENDENT COMPLIANCE
CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW AND ASSESSMENT OF CIBC'S REMEDIATION ACTIVITIES TO COMPLY WITH SEC
RECORDKEEPING REQUIREMENTS TO PRESERVE ELECTRONIC COMMUNICATIONS.
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:
Decision & Order of Offer of Settlement
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: $ 12,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE SETTLEMENT IMPOSES A CEASE-AND-DESIST ORDER WHICH REQUIRES CIBC PRIVATE WEALTH ADVISORS, INC., IN ADDITION TO THE
PAYMENT OF A MONETARY PENALTY TO COMPLY WITH UNDERTAKINGS INCLUDING RETENTION OF AN INDEPENDENT COMPLIANCE CONSULTANT
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: 
A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS
PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND
PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS.
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).
ON SEPTEMBER 24, 2024, THE SECURITIES AND EXCHANGE COMMISSION (SEC) ANNOUNCED A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH
ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A
CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF
RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS. IN DETERMINING TO ACCEPT CIBC'S SETTLEMENT OFFER, THE SEC CONSIDERED
CIBC'S' COOPERATION AS WELL AS REMEDIAL STEPS THAT CIBC UNDERTOOK BOTH BEFORE AND AFTER BEING APPROACHED BY THE SEC STAFF. PRIOR
TO THIS SETTLEMENT, CIBC ENHANCED ITS POLICIES AND PROCEDURES, INCREASED TRAINING AND COMPLIANCE REMINDERS CONCERNING THE USE
OF APPROVED COMMUNICATIONS METHODS, ENHANCED ITS SURVEILLANCE PROCESSES, AND IMPLEMENTED SIGNIFICANT CHANGES TO THE
TECHNOLOGY AVAILABLE TO PERSONNEL. AS PART OF THE SETTLEMENT, CIBC HAS UNDERTAKEN TO RETAIN AN INDEPENDENT COMPLIANCE
CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW AND ASSESSMENT OF CIBC'S REMEDIATION ACTIVITIES TO COMPLY WITH SEC
RECORDKEEPING REQUIREMENTS TO PRESERVE ELECTRONIC COMMUNICATIONS.
Show 2 more source blocks
regulatory · block 7CANADIAN IMPERIAL BANK OF COMMERCE (CIBC)PDF pages 73–75
Advisory affiliate name — filed text
CANADIAN IMPERIAL BANK OF COMMERCE (CIBC)
Regulator name — filed text
CFTC
Monetary/Fine Amount — filed text
$ 30,000,000.00
How was matter resolved — filed text
Consent

Action status / disposition — filed text

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).
Other filed details

Description of allegations — filed text

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).

Sanction detail — filed text

FINE OF $30 MILLION
Full extracted filing text

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: 
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: 
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).
civil judicial · block 1PDF pages 76–78
Full extracted filing text

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 Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
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:
4592303
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
EKMEKJIAN, VICKEN
(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.H.
(1)(a), 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.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
RACHEL RENDEL AS GENERAL PARTNER OF THE RENDEL FAMILY LTD. PARTNERSHIP I
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought: 
3.
Filing Date of Court Action (MM/DD/YYYY):

09/22/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO CASE #:CGC-21-595440
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
CIBC PRIVATE WEALTH ADVISORS, INC.
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE COMPLAINT ALLEGES THAT CIBC PRIVATE WEALTH ADVISORS, INC. AND ITS ADVISORY AFFILIATE (THE "DEFENDANT") BREACHED THEIR FIDUCIARY
DUTY AND FAILED TO EXERCISE REASONABLE CARE AND TO ACT WITH REASONABLE DILIGENCE IN THE COURSE OF PROVIDING DISCRETIONARY
INVESTMENT ADVISORY SERVICES TO THE PLAINTIFF. THE COMPLAINT CLAIMS THAT DEFENDANT FAILED TO DISCLOSE MATERIAL INFORMATION ABOUT
THE COURSE OF ACTION RECOMMENDED BY THE DEFENDANT, FAILED TO EXPLAIN THE NATURE, RISKS, AND IMPLICATIONS OF THE INVESTMENT
DECISIONS RECOMMENDED BY THE DEFENDANT, AND MADE INVESTMENT DECISIONS IN MARCH 2020 THAT WERE CONTRARY TO THE BEST INTEREST,
OBJECTIVES, AND RECOMMENDED ASSET ALLOCATION FOR THE PLAINTIFF'S ACCOUNT.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
PLAINTIFF HAS DISMISSED THE ACTION
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Dismissed
12. Resolution Date (MM/DD/YYYY): 
07/20/2023
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 250,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
ON MAY 31, 2023, THE PLAINTIFF VOLUNTARILY DISMISSED VICKEN EKMEKJIAN FROM THIS MATTER.
C.
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:
TO AVOID THE TIME, COSTS, AND UNCERTAINTIES OF A LITIGATION, WITHOUT ADMITTING ANY WRONGDOING ON JULY 6, 2023, THE PLAINTIFF
AND CIBC PRIVATE WEALTH ADVISORS SETTLED THIS MATTER FOR $250,000. VICKEN EKMEKJIAN WAS NOT ASKED TO PARTICIPATE IN OR
CONTRIBUTE TOWARDS THE SETTLEMENT. ON JULY 20, 2023, THE PLAINTIFF DISMISSED THE MATTER.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
THE COMPLAINT ALLEGES THAT CIBC PRIVATE WEALTH ADVISORS, INC. AND ITS ADVISORY AFFILIATE (THE "DEFENDANT") BREACHED THEIR FIDUCIARY
DUTY AND FAILED TO EXERCISE REASONABLE CARE AND TO ACT WITH REASONABLE DILIGENCE IN THE COURSE OF PROVIDING DISCRETIONARY
INVESTMENT ADVISORY SERVICES TO THE PLAINTIFF. THE COMPLAINT CLAIMS THAT DEFENDANT FAILED TO DISCLOSE MATERIAL INFORMATION ABOUT
THE COURSE OF ACTION RECOMMENDED BY THE DEFENDANT, FAILED TO EXPLAIN THE NATURE, RISKS, AND IMPLICATIONS OF THE INVESTMENT
DECISIONS RECOMMENDED BY THE DEFENDANT, AND MADE INVESTMENT DECISIONS IN MARCH 2020 THAT WERE CONTRARY TO THE BEST INTEREST,
OBJECTIVES, AND RECOMMENDED ASSET ALLOCATION FOR THE PLAINTIFF'S ACCOUNT. ON MAY 31, 2023, THE PLAINTIFF VOLUNTARILY DISMISSED

VICKEN EKMEKJIAN FROM THIS MATTER. TO AVOID THE TIME, COSTS, AND UNCERTAINTIES OF A LITIGATION, WITHOUT ADMITTING ANY WRONGDOING
ON JULY 6, 2023, THE PLAINTIFF AND CIBC PRIVATE WEALTH ADVISORS SETTLED THIS MATTER FOR $250,000. VICKEN EKMEKJIAN WAS NOT ASKED TO
PARTICIPATE IN OR CONTRIBUTE TOWARDS THE SETTLEMENT. ON JULY 20, 2023, THE PLAINTIFF DISMISSED THE MATTER.

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