Canadian Imperial Bank of Commerce - MRRS Decision

Headnote

Mutual Reliance Review Systemfor Exemptive Relief Applications - Relief granted to a groupof mutual fund trusts from requirement to deliver re-auditedannual financial statements.

Applicable Ontario StatutoryProvisions

Securities Act, R.S.O. 1990,c. S.5, as am. s. 80(b)(iii).

IN THE MATTER OF

THE SECURITIES LEGISLATIONOF

BRITISH COLUMBIA, ALBERTA,SASKATCHEWAN, MANITOBA,

ONTARIO, QUEBEC, NOVA SCOTIA,NEW BRUNSWICK,

NEWFOUNDLAND AND LABRADOR,

NORTHWEST TERRITORIES, NUNAVUTTERRITORY

AND YUKON TERRITORY

AND

IN THE MATTER OF

THE MUTUAL RELIANCE REVIEWSYSTEM

FOR EXEMPTIVE RELIEF APPLICATIONS

AND

IN THE MATTER OF

IMPERIAL CANADIAN BOND POOL

IMPERIAL CANADIAN EQUITY POOL

IMPERIAL EMERGING ECONOMIESPOOL

IMPERIAL INTERNATIONAL BONDPOOL

IMPERIAL INTERNATIONAL EQUITYPOOL

IMPERIAL MONEY MARKET POOL

IMPERIAL REGISTERED INTERNATIONALEQUITY INDEX POOL

IMPERIAL REGISTERED U.S. EQUITYINDEX POOL

IMPERIAL SHORT-TERM BOND POOL

IMPERIAL U.S. EQUITY POOL

(collectively, the "Pools")

AND

IN THE MATTER OF

CIBC CANADIAN BOND INDEX FUND

CIBC CANADIAN EMERGING COMPANIESFUND

CIBC CANADIAN REAL ESTATEFUND

CIBC CANADIAN SMALL COMPANIESFUND

CIBC EUROPEAN INDEX FUND

CIBC EUROPEAN INDEX RRSP FUND

CIBC FINANCIAL COMPANIES FUND

CIBC GLOBAL BOND INDEX FUND

CIBC INTERNATIONAL INDEX FUND

CIBC INTERNATIONAL INDEX RRSPFUND

CIBC INTERNATIONAL SMALL COMPANIESFUND

CIBC JAPANESE INDEX RRSP FUND

CIBC LATIN AMERICAN FUND

CIBC MONTHLY INCOME FUND

CIBC NASDAQ INDEX RRSP FUND

CIBC NORTH AMERICAN DEMOGRAPHICSFUND

CANADIAN IMPERIAL EQUITY FUND

(collectively, the "CIBCFunds", together with the Pools, the "Funds")

MRRS DECISION DOCUMENT

WHEREAS the local securitiesregulatory authority or regulator (the "Decision Maker")in each of the provinces and territories of Canada, except PrinceEdward Island, (the "Jurisdictions") has receivedan application (the "Application") from Canadian ImperialBank of Commerce ("CIBC"), the manager of the Funds,on behalf of each of the Funds, for a decision (the "Decision")pursuant to the securities legislation of the Jurisdictions(the "Legislation") that each of the Funds be exemptedfrom delivering to security holders annual financial statementsfor the year ended December 31, 2001 to be re-audited by Deloitte& Touche LLP ("Deloitte") at the time such statementsare filed, as would otherwise be required pursuant to applicableLegislation;

AND WHEREAS pursuantto the Mutual Reliance Review System for Exemptive Relief Applications(the "System"), the Ontario Securities Commissionis the principal regulator for this Application;

AND WHEREAS CIBC hasrepresented to the Decision Makers that:

1. CIBC is the manager ofthe Funds. CIBC is a bank listed in Schedule I to the BankAct (Canada). CIBC Trust Corporation, a wholly-owned subsidiaryof CIBC, is the trustee of the Funds.

2. Each of the Funds is anopen-ended mutual fund trust established under the laws ofthe Province of Ontario.

3. Units of the Pools arecurrently qualified for distribution in each of the Jurisdictionspursuant to a simplified prospectus and annual informationform dated July 6, 2001. Units of each of the CIBC Funds arecurrently qualified for distribution in each of the Jurisdictionspursuant to a simplified prospectus and annual informationform dated August 9, 2001.

4. Each of the Funds is areporting issuer in the Jurisdictions and is not in defaultof any requirements of the Legislation or the rules or regulationsmade thereunder. The financial year-end for each of the Fundsis December 31.

5. Arthur Andersen LLP ("Andersen")audited the annual financial statements of the Funds for theyear ended December 31, 2001 (the "Initial Statements")and issued its auditors' report thereon. The Initial Statementswere filed, pursuant to the Legislation, via SEDAR on May17, 2002 and mailed to unitholders of the Funds.

6. On June 3, 2002, Deloitteannounced the completion of "the transaction that willenable over 1,000 Andersen partners and staff to join Deloitte& Touche" and the integration of Andersen peopleand clients into Deloitte (the "Transaction"). Accordingly,the responsibility to audit the Funds has been transitionedto Deloitte.

7. In connection with theTransaction, each of the Funds has requested Deloitte to re-auditthe annual financial statements for the year ended December31, 2001 and to provide its auditors' report thereon (the"Deloitte Statements").

8. The Funds are to file theDeloitte Statements as "Audited Annual Financial Statements- English/French" under the existing SEDAR projects usedby the Funds to file their continuous disclosure documents,including the Initial Statements. Concurrently with the filingof the Deloitte Statements, the Funds propose to file on SEDARa letter indicating that the Initial Statements are supersededby the Deloitte Statements.

AND WHEREAS pursuantto the System this MRRS Decision Document evidences the Decisionof each Decision Maker;

AND WHEREAS each of theDecision Makers is satisfied that the test contained in theLegislation that provides the Decision Maker with the jurisdictionto make the Decision has been met;

THE DECISION of the DecisionMakers pursuant to the Legislation is that each of the Fundsbe exempted from delivering to security holders annual financialstatements for the year ended December 31, 2001 to be re-auditedby Deloitte at the time such statements are filed, providedthat the Deloitte Statements are substantially the same as theInitial Statements in all material respects.

July 23, 2002.

"Mary Theresa McLeod"                    "HaroldP. Hands"