Ontario Commission des P.O. Box 55, 19^th^ Floor CP 55, 19e étage Securities valeurs mobilières 20 Queen Street West 20, rue queen ouest Commission de l’Ontario Toronto ON M5H 3S8 Toronto ON M5H 3S8 Web site: www.osc.gov.on.ca

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.

VIA SEDAR

November 28, 2011

Canadian Imperial Bank of Commerce

20 Bay Street, Suite 1402

Toronto, ON M5J 2N8

Attention: Valerie Lockerbie

Dear Sirs/Mesdames:

Re: Imperial Pools (the “Funds”)

Exemptive Relief Application under Part 6 of National Instrument 81-101 Mutual Fund Prospectus Disclosure (NI 81-101)

Application No. 2011/0839; SEDAR Project No. 1814429

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,

“Sonny Randhawa”

Sonny Randhawa

Manager, Investment Funds Branch

ONTARIO SECURITIES COMMISSION