Canadian Bail-in Regime Update

Canadian Bail-in Regime Update • On April 18, 2018, Department of Finance published the bail-in regulations, and OSFI finalized the guidelines on Total Loss Absorbing Capacity (TLAC) and TLAC holdings. Department of Finance's bank recapitalization (bail-in) conversion regulations Provide statutory powers to CDIC (through Governor in Council) to enact the bail-in regime including the ability to convert specified eligible shares and liabilities of D-SIBS into common shares in the event such bank becomes non-viable • Bail-in eligible liabilities include tradable (with CUSIP/ISIN), unsecured debt with original maturity of over 400 days . Excluded liabilities are covered bonds, consumer deposits, secured liabilities, derivatives, and structured notes1 . Effective on September 23, 2018 OSFI's TLAC Guideline . TLAC liabilities must be directly issued by the D-SIB, satisfy all of the requirements set out in the bail-in regulations, and have residual maturity greater than 365 days Minimum requirements: TLAC ratio = TLAC measure / RWA > 21.5% TLAC leverage ratio = TLAC measure / Leverage exposure > 6.75% • TLAC supervisory target ratio set at 25.00% RWA 2 Effective Fiscal 2022. Public disclosure began in Q1 2019 OSFI's TLAC Holdings • Our investment in other G-SIBS and other Canadian D-SIB's TLAC instruments are to be deducted from our own tier 2 capital if our aggregate holding, together with investments in capital instruments of other Fls, exceed 10% of our own CET1 capital Implementation started in Q1 2019 CIBC 1. As referenced in the Bank Recapitalization (Bail-in) Regulations: http://laws-lois.justice.gc.ca/eng/regulations/SOR-2018-57/FullText.html 2. Increases to 25.00% on November 1, 2023 upon increase of Domestic Stability Buffer to 3.50% (versus the maximum of 4.00%) from 3.00% 53

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