CIBC U.S. Region Business Continuity Plan Overview

Canadian Imperial Bank of Commerce (CIBC) is a leading North American financial institution which provides financial services to more than nine million customers, including retail and small business banking customers as well as corporate and global investment banking customers.

It is CIBC’s policy to provide for the continuity of business during unplanned disruptions, which may arise from natural, accidental, or engineered occurrences such as:

• Ice storms, snow storms, earthquakes, floods, hurricanes, disease;
• Fires, chemical spills, power/systems/utility/communication failures;
• Civil unrest, arson, malicious damage, sabotage, acts of terrorism, and labor unrest.

CIBC has a corporate-wide sound Business Continuity Management program in place for each of our strategic business lines. In the event of a disaster affecting CIBC’s operations, the program will support the following objectives:

• Continuation of critical business functions according to approved, pre-determined recovery objectives, and
• A timely, organized and highly efficient return to full operations of all business functions.

Alternative Locations & Redundant Systems:

All critical business units have identified an alternate site that addresses the minimum requirements to counter the effects of a business disruption and serve as their base of operations in the event of a disaster affecting accessibility to the normal workplace. We have established a fully operational dedicated recovery facility located outside of New York City capable of addressing single location events and citywide events. In addition, CIBC in Canada has access to all principal systems and third party contacts of critical business units in the U.S.

Regular Testing: To ensure we have the ability to fulfill our obligations to our customers and business partners from our dedicated recovery facility in an emergency, we conduct two large-scale user tests and two large-scale vendor tests per year. Also, we conduct tests on new individual applications and upgrades. As part of that testing, we ensure plans reflect new applications, changes to existing applications, and potential alternatives for process improvement.

Preparedness: In the event of a disaster, every reasonable attempt will be made to restore and maintain normal service levels. All mission critical systems are recoverable within 2 to 4 hours. We anticipate that in the event of a disruption affecting a single building or affecting all of our New York City locations, recovery will be accomplished through the use of our dedicated recovery facility and/or CIBC facilities in Canada.

In addition, CIBC is enrolled in the Corporate Emergency Access System (CEAS) Program, which is a public-private partnership between local government (New York City) and the not-for-profit Business Network of Emergency Resources (BNet). CEAS provides pre-credentialing to a limited number of employees deemed “critical” to a business’ viability, permitting access to restricted areas following an emergency to shutdown critical systems and to retrieve critical documents, data and equipment.

Access to Funds and Securities: In the event that CIBC’s U.S. Operations were unable to continue business, then CIBC would perform the necessary functions through its facilities in Canada to provide clients with prompt access to their funds and securities.

Limitations

We are confident in our business continuity plans which have been developed and tested to support the continuation of critical business functions under unforeseen conditions of disaster, which may arise from a natural, accidental, or engineered occurrence. However, due to the unpredictability of disasters and the potential impact on critical infrastructures (i.e., public utilities, exchanges, private and public transportation) and/or critical suppliers we cannot guarantee that our business will always be available or recoverable after a disaster or significant business disruption. No contingency plan can eliminate all risks. We continually assess and update our plans to mitigate all reasonable risk.

Amendments:

The above summary is subject to change without prior notice. Any material changes will be promptly posted on our website and will be available to clients upon request at: CIBC World Markets Corp. (US Broker-Dealer) Disclosures.