Securities Law & Instruments


Exemption from the reporting requirements ofclause 117(1)(c) of the Securities Act (Ontario) provided thatcertain disclosure is made in the statement of portfolio transactionsfor each mutual fund.

Statutes Cited

Securities Act (Ontario), R.S.O. 1990 c. S.5,as am., 117(1)(c) and 117(2).
















WHEREAS the local securities regulatoryauthority or regulator (the "Decision Maker")in each of the provinces of British Columbia, Alberta, Saskatchewan,Ontario, Nova Scotia and Newfoundland and Labrador (the "Jurisdictions")has received an application (the "Application")from Canadian Imperial Bank of Commerce ("CIBC")and CIBC Asset Management Inc. ("CIBC AMI")(collectively, the "Filer", and collectively,with their affiliates, the "CIBC Group of Companies")for a decision (the "Decision") pursuant tothe securities legislation of the Jurisdictions (the "Legislation")that the provisions of the Legislation requiring a managementcompany, or in British Columbia a mutual fund manager, to filea report, within thirty days after each month end and in respectof each mutual fund to which it provides services, relatingto every purchase or sale effected by such mutual fund throughany related person or company with respect to which the relatedperson or company received a fee either from the mutual fundor from the other party to the transaction or both (the "ReportingRequirement") shall not apply to purchases and saleseffected by the Funds (as defined below) through CIBC WorldMarkets Inc. ("CWMI"), CIBC World Markets Corp.("CWMC"), CIBC or any other Related Company(as defined below);

AND WHEREAS pursuant to the Mutual RelianceReview System for Exemptive Relief Applications (the "System"),the Ontario Securities Commission is the principal regulatorfor this Application;

AND WHEREAS, unless otherwise defined,the terms herein have the meaning set out in National Instrument14-101 -- Definitions;

AND WHEREAS it has been represented bythe Filer to the Decision Makers that:

1. CIBC is a bank listed in Schedule I tothe Bank Act (Canada), S.C. 1991, c. 46, as amended,with its head office currently in Toronto, Ontario. CIBC AMIis a corporation established under the laws of Canada withits head office currently in Montreal, Quebec. CIBC AMI isregistered under the Act as a mutual fund dealer and an adviserin the categories of investment counsel and portfolio manager,and under the Commodity Futures Act (Ontario), R.S.O.1990, c. C.20, as amended, in the category of commodity tradingmanager;

2. CIBC and CIBC AMI act as managers of thegroups of mutual funds that currently consist of the fundsset out in Schedule "A" hereto (such funds, togetherwith such other funds managed by a member of the CIBC Groupof Companies from time to time, being herein referred to asthe "Funds");

3. CWMI is a registered dealer in each ofthe provinces of Canada. CWMC is registered as an internationaldealer with the Ontario Securities Commission;

4. The Funds are open-ended investment trustsor mutual fund trusts established under the laws of the Provinceof Ontario. Each Fund is a reporting issuer in each of theprovinces and territories of Canada where units (the "Units")of the Fund are sold pursuant to a prospectus accepted bythe decision maker in such jurisdictions;

5. Each of CIBC AMI, CWMI and CWMC are subsidiariesof CIBC. CWMI and CWMC are issuers in which CIBC (which isalso a substantial securityholder of CIBC AMI) has a significantinterest, such that the Funds are prohibited from making aninvestment in CWMI and CWMC under the Legislation. Therefore,CWMI and CWMC are "related persons" to the Fundsunder the Legislation;

6. As disclosed in the annual informationforms or prospectuses of the Funds, the portfolio advisersor sub-advisers of the Funds appointed by CIBC or CIBC AMI(such portfolio advisers or sub-advisers "PortfolioAdvisers") may allocate brokerage business of theFunds to CWMI and CWMC or other related brokers or dealersthat are members of the CIBC Group of Companies (togetherwith CWMI and CWMC, "Related Companies"),provided such transactions are made on terms and conditionscomparable to those offered by unrelated brokers and dealers;

7. The Portfolio Advisers of the Funds havediscretion to allocate brokerage business in any manner thatthey believe to be in a Fund's best interests. The purchaseor sale of securities effected through CWMI, CWMC or anotherRelated Company represents the business judgment of responsiblepersons uninfluenced by considerations other than the bestinterests of the Funds. In allocating brokerage, considerationis given to commission rates and to research, execution andother services offered;

8. It is disclosed and will continue to bedisclosed in the Funds' interim and annual financial statementsthe amount of brokerage commissions paid by each Fund on tradeswith Related Companies;

9. In the absence of this Decision the Legislationrequires that reports must be filed on a monthly basis inrespect of every purchase or sale of securities effected througha Related Company stating the issuer of the securities purchasedor sold, the class or designation of the securities, the amountor number of securities, the consideration, the name of theRelated Company receiving the fee, the name of the personor company that paid the fee to the Related Company and theamount of the fee received by the Related Company;

10. It would be costly and time consumingto continue to provide the information required by the Legislationon a monthly and segregated basis;

AND WHEREAS under the System, this MRRSDecision Document evidences the decision of each Decision Maker(collectively, the "Decision");

AND WHEREAS each of the Decision Makersis satisfied that the test contained in the Legislation thatprovides the Decision Maker with the jurisdiction to make theDecision has been met;

THE DECISION of the Decision Makers underthe Legislation is that effective as of the date of this Decision,the Reporting Requirement shall not apply to any purchase orsale of securities by the Funds which is effected through CWMI,CWMC, CIBC or any other Related Company and with respect towhich the Related Company received a fee either from the Fundor from the other party to the transaction or both;

PROVIDED THAT the Decision shall onlyapply if the statement of portfolio transactions prepared andfiled for each Fund in accordance with the Legislation discloses,in respect of every class or designation of securities of anissuer bought or sold during the period to which the statementof portfolio transactions relates:

(a) the name of each Related Company;

(b) the amount of fees paid to each RelatedCompany; and

(c) the person or company that paid the fees.

May 27, 2003.

"H. Lorne Morphy"

"Mary Theresa McLeod"