Cibc Asset Management Inc.

Allegations: THE SOUTH KOREAN SECURITIES AND FUTURES COMMISSION (SKSFC) ISSUED A NOTICE OF PENALTY INDICATING THAT CIBC WORLD MARKETS INC. (CWMI) EXECUTED AN IMPERMISSIBLE NAKED SHORT SALE. ON FEBRUARY 5, 2021, CWMI ATTEMPTED TO SELL SHARES HELD BY A CLIENT ON THE KOREA EXCHANGE, AND DUE TO AN ADMINISTRATIVE ERROR, PROVIDED AN INCORRECT ACCOUNT NUMBER FOR THE SETTLEMENT OF THE TRADE. UPON DISCOVERY, THE CORRECT ACCOUNT NUMBER WAS PROVIDED. BECAUSE THE INITIAL INCORRECT ACCOUNT NUMBER DID NOT CONTAIN THE SHARES TO BE SOLD, THE SKSFC VIEWED THE TRANSACTION TO BE AN IMPERMISSIBLE NAKED SHORT SALE. Status: Final Sanction Detail: FINE OF $36,000,000 SOUTH KOREAN WON (APPROX. $26,000 USD) Summary: THE SOUTH KOREAN SECURITIES AND FUTURES COMMISSION ISSUED A NOTICE OF PENALTY ON JULY 17, 2024, IMPOSING AN ADMINISTRATIVE FEE OF $36,000,000 SOUTH KOREAN WON ON CIBC WORLD MARKETS, INC.THE ADMINISTRATIVE FEE WAS PAID ON AUGUST 21, 2024.

Allegations: THE ARIZONA CORPORATION COMMISSION (ACC) DETERMINED THAT CIBC WORLD MARKETS, INC. (CWMI) VIOLATED A.R.S. § 44-1841 IN 2023, WHEN IT FAILED TO MAINTAIN ITS REGISTRATION EXEMPTION STATUS BY FAILING TO FILE THE REQUIRED EXEMPTION AND PAY THE REQUISITE FEE FOR OFFERING AND SELLING SECURITIES WITHIN OR FROM ARIZONA WITH THE MEANING OF A.R.S § 44-1801(16), 44-1801(22) AND 44-1801(27). AS A RESULT, THE ACC DETERMINED THAT CWMI FROM 2023 TO THE PRESENT ENGAGED IN SECURITIES RELATED ACTIVITIES WITHOUT APPROPRIATE REGISTRATION WITH THE ARIZONA CORPORATION. Status: Final Sanction Detail: FINE OF $50,000 USD Summary: AT A PROCEEDING BEFORE THE ARIZONA CORPORATION COMMISSION ON SEPTEMBER 13, 2024, DURING WHICH CWMI NEITHER ADMITTED NOR DENIED THE FINDINGS OF FACTS AND CONCLUSIONS OF LAW, THE ARIZONA COMMISSION CORPORATION ORDERED CWMI TO PAY AN ADMINISTRATIVE PENALTY OF $50,000 AND TO CEASE AND DESIST FROM VIOLATING THE SECURITIES ACT. CWMI PAID THE FINE ON SEPTEMBER 18, 2024. CWMI IS IN THE PROCESS OF REMEDIATING ITS REGISTRATION STATUS WITH THE ARIZONA CORPORATION COMMISSION.

Allegations: ON SEPTEMBER 24, 2024, THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ANNOUNCED A SETTLEMENT WITH CANADIAN IMPERIAL BANK OF COMMERCE ("CIBC") FOR FAILING TO TIMELY REPORT SWAP TRANSACTIONS TO A REGISTERED SWAP DATA REPOSITORY AS REQUIRED BY THE COMMODITY EXCHANGE ACT (CEA) AND CFTC REGULATIONS SECTIONS 2(A)(13)(F) AND (G) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. §§ 2(A)(13)(F), (G), AND CURRENT COMMISSION REGULATIONS ("REGULATIONS") 43.3(A), 45.3(B)(1), AND 45.4(C), 17 C.F.R. §§ 43.3(A), 45.3(B)(1),45.4(C) (2023), AS WELL AS FORMER COMMISSION REGULATIONS 43.3(A), 43.4(A), 45.3(B) AND 45.4, 17 C.F.R. §§ 43.3(A), 43.4(A), 45.3(B), 45.4 (2020). Status: Final Sanction Detail: CIBC AND ITS SUCCESSORS AND ASSIGNS SHALL CEASE AND DESIST FROM VIOLATING THE APPLICABLE SECTIONS CFTC REGULATIONS AND CIBC SHALL PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF USD$1,250,000 WITHIN FOURTEEN DAYS OF THE DATE OF THE ENTRY OF THIS ORDER. Summary: CIBC HAS SUBMITTED AN OFFER OF SETTLEMENT ("OFFER"), WHICH THE COMMISSION HAS DETERMINED TO ACCEPT, AND ADMITS THE FACTS SET FORTH IN SECTION II BELOW, ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE ACT AND REGULATIONS AND CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING PROCEEDINGS PURSUANT TO SECTION 6(C) AND (D) OF THE COMMODITY EXCHANGE ACT, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS ("ORDER"), AND ACKNOWLEDGES SERVICE OF THE ORDER.

Allegations: THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION") HAS REASON TO BELIEVE THAT FROM AT LEAST SEPTEMBER 2018 TO THE PRESENT ("RELEVANT PERIOD"), CANADIAN IMPERIAL BANK OF COMMERCE ("CIBC") VIOLATED, AS SET FORTH BELOW, SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. §§ 6S(F)(1)(C), 6S(G)(1), (3), 6S(H)(1)(B), AND COMMISSION REGULATIONS ("REGULATIONS") 1.31, 23.201(A),23.202(A)(1) AND (B)(1), AND 23.602(A), 17 C.F.R. §§ 1.31, 23.201(A), 23.202(A)(1), (B) (1), AND 23.602(A) (2023). Status: Final Sanction Detail: MONETARY FINE OF 30 MILLION Summary: DURING THE RELEVANT PERIOD, AS A RESULT OF THE WIDESPREAD EMPLOYEE USE OF UNAPPROVED COMMUNICATION METHODS, CIBC FAILED TO MAINTAIN COMMISSION-REQUIRED TRANSACTION RECORDS AND PRE-EXECUTION COMMUNICATIONS. BY THIS CONDUCT, CIBC VIOLATED SECTIONS 4S(F)(1)(C) AND 4S(G)(1) AND (3) OF THE ACT AND REGULATIONS 23.201(A) AND 23.202(A)(1) AND (B)(1). BY FAILING TO KEEP ALL COMMISSION-REQUIRED RECORDS IN SUCH A MANNER AS TO MAKE THEM "READILY ACCESSIBLE," CIBC VIOLATED REGULATION 1.31. CIBC FAILED TO SUPERVISE ITS SWAP DEALER BUSINESS ACTIVITIES DILIGENTLY DURING THE RELEVANT PERIOD. CIBC FAILED TO MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM TO ENSURE THAT EMPLOYEES DID NOT UTILIZE UNAPPROVED METHODS TO ENGAGE IN COMMUNICATIONS RELATING TO FIRM BUSINESS, INCLUDING THE SWAP DEALER BUSINESS. CIBC'S FAILURE TO SUPERVISE IS DEMONSTRATED BY ITS FAILURE TO DETECT, PREVENT, AND REMEDIATE REPEATED VIOLATIONS OF THE COMMISSION'S RECORDKEEPING REQUIREMENTS AND FIRM POLICIES AND PROCEDURES. SUPERVISORY PERSONNEL FAILED TO ENSURE THAT EMPLOYEES COMPLIED WITH CIBC'S COMMISSION RECORDKEEPING OBLIGATIONS AND FIRM COMMUNICATIONS POLICIES AND IN SOME INSTANCES, THEMSELVES VIOLATED THE POLICIES. THESE SUPERVISION FAILURES ALSO RESULTED IN THE FAILURE TO KEEP AND MAINTAIN COMMISSION-REQUIRED RECORDS AND THE FAILURE TO MAINTAIN THE RECORDS IN SUCH A MANNER AS TO MAKE THEM READILY AVAILABLE. BY THIS CONDUCT, CIBC FAILED TO SUPERVISE DILIGENTLY ITS OFFICERS, EMPLOYEES, AND AGENTS, IN VIOLATION OF SECTION 4S(H)(1)(B) OF THE ACT AND REGULATION 23.602(A).