Imperial Pools -- NI 81-101 Mutual Fund Prospectus Disclosure, General Instruction 8

Headnote

National Policy 11-203 Process for Exemptive Relief Applications in Multiple Jurisdictions -- Exemption from general instruction 8 of the Form to include fund codes in the Fund Facts document.

Applicable Legislative Provisions

National Instrument 81-101 Mutual Fund Prospectus Disclosure, Part 6.

General Instruction 8 to Form 81-101F3 Contents of Fund Facts Document.

November 28, 2011

Attention: Valerie Lockerbie

Dear Sirs/Mesdames:

By letter dated October 26, 2011 (the Application), Canadian Imperial Bank of Commerce, on behalf of the Funds, applied to the Director of the Ontario Securities Commission (the Director) under Part 6 of NI 81-101 for relief from General Instruction 8 to Form 81-101F3 Contents of Fund Facts (the Form), which prohibits an issuer from including any information not specifically prescribed by the Form, to include fund codes in the Fund Facts document.

This letter confirms that, based on the information and representations made in the Application, and for the purposes described in the Application, the Director intends to grant the requested exemption to be evidenced by the issuance of a receipt for the Funds' prospectus.

Yours very truly,