CIBC Asset Management Inc. et al.

Headnote

National Policy 11-203 Process for Exemptive Relief Applications in Multiple Jurisdictions -Approval to suspend the rights of redemption of certain unitholders during a one-day data transfer and records conversion period - Integration of two unitholder record-keeping platforms into one platform - One-day suspension of redemptions needed to facilitate administration of the conversion and ensure there will be no pending transactions following the conversion - National Instrument 81-102 Mutual Funds.

Applicable Legislative Provisions

National Instrument 81-102 Mutual Funds, paragraph 5.5(1)(d) and subsection 5.5(2).

July 10, 2008

IN THE MATTER OF

THE SECURITIES LEGISLATION OF

ONTARIO (the "Jurisdiction")

AND

IN THE MATTER OF

THE PROCESS FOR EXEMPTIVE RELIEF

APPLICATIONS IN MULTIPLE JURISDICTIONS

AND

IN THE MATTER OF

CIBC ASSET MANAGEMENT INC.

(the "Filer")

AND

IN THE MATTER OF

THE RENAISSANCE INVESTMENTS FAMILY OF FUNDS

AND AXIOMS PORTFOLIOS LISTED IN APPENDIX "A"

(individually a "Fund" and collectively, the "Funds")

DECISION

Background

The principal regulator in the Jurisdiction has received an application from the Filer for a decision under the securities legislation of the Jurisdiction of the principal regulator (the "Legislation") for an approval pursuant to paragraph 5.5(1)(d) of National Instrument 81-102 Mutual Funds ("NI 81-102"), to suspend the rights of redemption of certain unitholders of the Funds during a one-day data transfer and records conversion period (the "Suspension of Redemption Approval").

Under the Process for Exemptive Relief Applications in Multiple Jurisdictions (for a passport application):

(a) the Ontario Securities Commission is the principal regulator for this application, and

(b) the Filer, on behalf of the Funds, has provided notice that section 4.7(1) of Multilateral Instrument 11-102 Passport System ("MI 11-102") is intended to be relied upon in each of the other Provinces and Territories of Canada (together with Ontario, the "Jurisdictions").

Interpretation

Terms defined in National Instrument 14-101 Definitions and MI 11-102 have the same meaning if used in this decision, unless otherwise defined.

Representations

This decision is based on the following facts represented by the Filer:

1. The Filer is a corporation established under the laws of Ontario and is the manager and trustee of each of the Funds.

2. The Funds are open-ended mutual fund trusts established under the laws of the Province of Ontario pursuant to an amended and restated master declaration of trust dated as of June 27, 2006, as further amended.

3. Each of the Funds is a reporting issuer in each of the Jurisdictions and, to the knowledge of the Filer, is not in default in any of the Jurisdictions of any requirements of applicable securities legislation.

4. Units of the Renaissance Investments family of funds (the "Renaissance Funds") are offered for sale on a continuous basis in each of the Jurisdictions pursuant to a simplified prospectus and annual information form dated August 20, 2007, as amended by amendment no. 1 dated January 4, 2008, amendment no. 2 dated April 21, 2008 and amendment no. 3 dated May 1, 2008, which have been filed and receipted in each of the Jurisdictions (collectively, the "Renaissance Funds Prospectus").

5. Units of the Axiom Portfolios are offered for sale on a continuous basis in each of the Jurisdictions pursuant to a simplified prospectus and annual information form dated March 6, 2008, which have been filed and receipted in each of the Jurisdictions (collectively, the "Axiom Portfolios Prospectus").

6. The Renaissance Funds, which currently consist of 42 different mutual funds (two of which will be terminated on or about August 5, 2008), and the Axiom Portfolios, which currently consist of 8 different mutual funds, are offered for sale through registered dealers.

7. The net asset value for each class of units of the Funds is calculated on a daily basis on each day the Toronto Stock Exchange is open for trading.

8. The Filer is the registrar and transfer agent of the Funds and maintains records of all unitholders of the Funds. Records of unitholders of the Funds are maintained under two different record-keeping systems (collectively, the "Platforms" and individually, a "Platform"), one located in Montréal and known as the TAS platform ("TAS Platform") and one located in Toronto and known as the Unitrax Platform ("Unitrax Platform").

9. Each of the Platforms uses a specific fund code for each class of units of the Funds and each eligible purchase option. On the TAS Platform, fund codes begin with "TAL" ("TAL Codes") and on the Unitrax Platform, fund codes begin with "ATL" ("ATL Codes"). Units of the Renaissance Funds and Axiom Portfolios can be purchased under either of the two Platforms and records are maintained accordingly.

10. To increase operational efficiency, reduce operating costs for the Funds through consolidation of unitholder record-keeping and improve ease of access to the dealers and ultimately their clients, the Filer has decided to integrate the two Platforms into one Platform commencing on Friday September 12, 2008 (the "Conversion"). The Conversion shall be completed over the weekend and the Filer's system shall be operational by Monday September 15, 2008. In order to implement the Conversion, the Filer will convert, through a number of conversion programs, all records maintained under the TAS Platform to the Unitrax Platform and will discontinue the use of the TAS Platform. As part of the Conversion, all records maintained under the TAS Platform will be transferred onto the Unitrax Platform and all existing TAL Codes related to those records will be changed for the corresponding ATL Codes on the Unitrax Platform. Changes to the TAL Codes are required, as the Unitrax Platform cannot accommodate different fund codes for the same funds and, in some instances, similar fund codes are used on both Platforms. In addition, each unitholder's account number on the TAS Platform will also be changed to preserve integrity of client information and ensure client privacy as account numbers are not unique to the Unitrax and TAS Platform, which could result in different unitholders having the same account number as a result of the Conversion.

11. In order to facilitate the administration of the Conversion and ensure that there will be no pending transactions following the Conversion, the Filer proposes to suspend the right of redemption of unitholders holding the Funds under the TAS Platform for one day, on Friday September 12, 2008 (the "Suspension Date"). The Filer proposes to take the following measures prior to and on the Suspension Date with respect to units of the Funds offered and held under the TAL Codes: redemption and purchase orders through FundSERV for non-money market funds will be disallowed on the close of business on Tuesday September 9, 2008, as purchase and redemption orders via FundSERV settle on a T+3 basis; dealers will be able to submit direct (fax and paper) redemption, purchase and switch orders on all Funds up to the close of business on Thursday September 11, 2008, as these transactions settle on a T+1 basis. If the Suspension of Redemption Approval is granted, the Filer will not accept orders for redemptions, switches and purchases on the Suspension Date. Unitholders of the Funds with records on the TAS Platform will be able to request redemption of their units of the Funds on the following business day, Monday September 15, 2008 once the Conversion has been completed and all unitholders' records are on the new platform.

12. The Filer does not propose to suspend the rights of redemptions of unitholders of the Funds holding such Funds under the Unitrax Platform since the Conversion will not impact the records and accounts for unitholders holding their records on that Platform and the Conversion should be seamless and transparent for these unitholders.

13. On the Suspension Date, most of the Filer's resources will be assigned to the implementation of the Conversion. Accordingly, there will be fewer resources available to manually execute direct orders for redemptions, purchases and switches received for the Funds. The Suspension of Redemption Approval is therefore necessary in order to appropriately implement the Conversion and to eliminate the potential of orders that could not be executed due to the availability of resources.

14. The Suspension of Redemption Approval will assist in the Filer avoiding any pending transaction during or after the Conversion due to unsettled direct trades, pending requests or errors in manual entries (collectively, the "Pending Transactions"). Any Pending Transaction would require records readjustment and/or reconciliation between the Filer's records and those of the dealers' back offices making the reconciliation very complex due to the change in fund codes and account numbers and potentially involving risks of manual errors in the reconciliation process and accordingly, in the unitholders' records. The Suspension of Redemption Approval will facilitate the administration of the Conversion and ensure that all records and data are converted during the Conversion.

15. On or about August 29, 2008, the Filer will send a written notice to each registered unitholder of the Funds with records on the TAS Platform. Such notice will provide unitholders with information relating to the Conversion, including their new account numbers with the Filer and a notification of fund code changes, and if the Suspension of Redemption Relief is granted, the notice will also inform unitholders about the suspension of their redemption rights on September 12, 2008.

16. On or about July 18, 2008, the Filer will communicate to all dealers through a FundSERV bulletin. The FundSERV bulletin will provide dealers with information relating to the Conversion, including information about the fund code changes, the Filer account number changes, the reconciliation files for the dealers, the trading schedule described above, and if the Suspension of Redemption Approval is granted, the suspension of redemption rights of certain unitholders of the Funds on September 12, 2008.

Decision

The principal regulator is satisfied that the decision meets the test set out in the Legislation for the principal regulator to make the decision.

The decision of the principal regulator under the Legislation is that the Suspension of Redemption Approval is granted to permit the Funds to suspend, on the Suspension Date, the right of redemption of unitholders holding units of the Funds under the TAS Platform.

SEDAR# 1285071 & 1285104

APPENDIX "A"

Axiom Portfolios