CIBC Asset Management Inc. and The Funds

Headnote

National Policy 11-203 Process for Exemptive Relief Applications in Multiple Jurisdictions -- Relief granted under subsection 62(5) of the Securities Act to permit the extension of a prospectus lapse date by 57 days to facilitate the consolidation of the funds' prospectus with the prospectus of other funds under common management -- No conditions.

Applicable Legislative Provisions

Securities Act, R.S.O. 1990, c. S.5, as am., s. 62(5).

March 4, 2025

IN THE MATTER OF THE SECURITIES LEGISLATION OF ONTARIO (the Jurisdiction) AND IN THE MATTER OF THE PROCESS FOR EXEMPTIVE RELIEF APPLICATIONS IN MULTIPLE JURISDICTIONS AND IN THE MATTER OF CIBC ASSET MANAGEMENT INC. (the Filer) AND IN THE MATTER OF THE FUNDS LISTED IN SCHEDULE "A" (each, a Fund, and collectively, the Funds)

DECISION

Background

The principal regulator in the Jurisdiction has received an application from the Filer on behalf of the Funds for a decision under the securities legislation of the Jurisdiction (the Legislation) that the time limits for the renewal of July Prospectus (as defined below) be extended to those time limits that would apply if the lapse date of the July Prospectus was August 28, 2025 (the Exemption Sought).

Under the Process for Exemptive Relief Applications in Multiple Jurisdictions (for a passport application):

(a) the Ontario Securities Commission is the principal regulator for this application; and

(b) the Filer has provided notice that subsection 4.7(1) of Multilateral Instrument 11-102 -- Passport System (MI 11-102) is intended to be relied upon in each of the other provinces and territories of Canada (together with Ontario, the Canadian Jurisdictions).

Interpretation

Terms defined in National Instrument 14-101 -- Definitions, NI 81-101 -- Mutual Fund Prospectus Disclosure and MI 11-102 have the same meaning if used in this decision, unless otherwise defined.

Representations

This decision is based on the following facts represented by the Filer:

The Filer and the Funds

1. The Filer is a corporation incorporated under the laws of Canada and has its head office located in Toronto, Ontario.

2. The Filer is registered as follows: (i) as an investment fund manager in each of the provinces of Quebec, Ontario, and Newfoundland and Labrador, (ii) as a portfolio manager in all Canadian Jurisdictions, (iii) as a commodity trading manager in Ontario and (iv) as a derivatives portfolio manager in Quebec.

3. The Filer is the investment fund manager, portfolio advisor and trustee of the Funds.

4. Neither the Filer nor any of the Funds is in default of securities legislation in any of the Canadian Jurisdictions.

5. Each Fund is a mutual fund for the purposes of National Instrument 81-102-Investment Funds established as an open-ended mutual fund trust under the laws of the Jurisdiction and is a reporting issuer as defined in the securities legislation in each of the Canadian Jurisdictions.

6. The Fund currently distributes securities in the Canadian Jurisdictions under a simplified prospectus dated July 2, 2024, as amended on August 21, 2024 (the July Prospectus). Series ETF units of the Funds trade on the Cboe Canada.

7. Pursuant to subsection 62(1) of the Securities Act (Ontario) (the Act), the lapse date of the Current Prospectus is July 2, 2025 (the July Prospectus Lapse Date). Accordingly, under subsection 62(2) of the Act, the distribution of securities of each Fund would have to cease on the July Prospectus Lapse Date unless each Fund: (i) files a pro forma prospectus at least 30 days prior to the July Prospectus Lapse Date; (ii) files a final simplified prospectus no later than 10 days after the July Prospectus Lapse Date; and (iii) obtains a receipt for the final prospectus within 20 days after the July Prospectus Lapse Date.

8. The Filer is also the investment fund manager of 76 other mutual funds listed in Schedule "B" (the Other Funds), which are offered in each of the Canadian Jurisdictions under a simplified prospectus dated August 28, 2024, as amended (the August Prospectus) and so have a lapse date of August 28, 2025.

Reasons for the Lapse Date Extension

9. The Filer wishes to combine the July Prospectus with the August Prospectus to reduce renewal, printing and related costs.

10. Offering the Funds and the Other Funds under one prospectus would facilitate the distribution of the Funds and the Other Funds in the Canadian Jurisdictions and enable the Filer to streamline disclosure across the Filer's fund platform.

11. The Funds and the Other Funds share many common operational and administrative features and combining them under one prospectus will allow investors to compare their features more easily.

12. It would be impractical to alter and modify all the dedicated systems, procedures and resources required to prepare the August Prospectus and unreasonable to incur the costs and expenses associated therewith, so that the August Prospectus can be filed earlier with the July Prospectus.

13. If the Exemption Sought is not granted, it will be necessary to renew the July Prospectus twice within a short period of time in order to consolidate the July Prospectus with the August Prospectus and it would be unreasonable for the Filer to incur the costs and expenses associated therewith, given investors would not be prejudiced by the Exemption Sought.

14. The Filer may make minor changes to the features of the Funds as part of its renewal. The ability to file the July Prospectus with the August Prospectus will ensure that the Filer can make the operational and administrative features of the Funds and Other Funds consistent with each other, if necessary.

15. There have been no material changes in the affairs of the Funds since the date of the July Prospectus (i.e. July 2, 2024) other than as described in the amendment no. 1 to the July Prospectus dated August 21, 2024. Accordingly, the July Prospectus, current fund facts and current ETF facts document(s) represent current information regarding the Funds.

16. Given the disclosure obligations of the Filer and the Funds, should any material change in the business, operations, or affairs of any of the Funds occur, the July Prospectus, related fund facts and/or ETF facts document(s) of the impacted Fund(s) will be amended as required under the Legislation.

17. New investors of the Funds will receive delivery of the most recently filed fund facts and/or ETF facts document(s) of the applicable Fund(s). The July Prospectus of the Funds will remain available to investors upon request.

18. The Exemption Sought will not affect the accuracy of the information contained in the July Prospectus, fund facts or ETF facts document(s) of the Funds and will therefore not be prejudicial to the public interest.

Decision

The principal regulator is satisfied that the decision meets the test set out in the Legislation for the principal regulator to make the decision.

The decision of the principal regulator under the Legislation is that the Exemption Sought is granted.

Application File #: 2025/0098

SEDAR+ File #: 6244202

Schedule "A"

CIBC 2025 INVESTMENT GRADE BOND FUND

CIBC 2026 INVESTMENT GRADE BOND FUND

CIBC 2027 INVESTMENT GRADE BOND FUND

CIBC 2028 INVESTMENT GRADE BOND FUND

CIBC 2029 INVESTMENT GRADE BOND FUND

CIBC 2030 INVESTMENT GRADE BOND FUND

CIBC 2025 INVESTMENT GRADE BOND FUND

CIBC 2026 INVESTMENT GRADE BOND FUND

CIBC 2027 INVESTMENT GRADE BOND FUND

Schedule "B"

RENAISSANCE INVESTMENTS FAMILY OF FUNDS

Renaissance Money Market Fund

Renaissance U.S. Money Market Fund

Renaissance Short-Term Income Fund

Renaissance Canadian Bond Fund

Renaissance Corporate Bond Fund

Renaissance U.S. Dollar Corporate Bond Fund

Renaissance High-Yield Bond Fund

Renaissance Floating Rate Income Fund

Renaissance Flexible Yield Fund

Renaissance Global Bond Fund

Renaissance Canadian Balanced Fund

Renaissance U.S. Dollar Diversified Income Fund

Renaissance Optimal Conservative Income Portfolio

Renaissance Optimal Income Portfolio

Renaissance Optimal Growth & Income Portfolio

CIBC Global Growth Balanced Fund

Renaissance Canadian Dividend Fund

Renaissance Canadian Monthly Income Fund

Renaissance Diversified Income Fund

Renaissance High Income Fund

Renaissance Canadian Core Value Fund

Renaissance Canadian Growth Fund

Renaissance Canadian All-Cap Equity Fund

Renaissance Canadian Small-Cap Fund

Renaissance U.S. Equity Income Fund

Renaissance U.S. Equity Value Fund

Renaissance U.S. Equity Growth Fund

Renaissance U.S. Equity Growth Currency Neutral Fund

Renaissance U.S. Equity Fund

Renaissance International Dividend Fund

Renaissance International Equity Fund

Renaissance International Equity Currency Neutral Fund

Renaissance Global Markets Fund

Renaissance Optimal Global Equity Portfolio

Renaissance Global Growth Fund

Renaissance Global Growth Currency Neutral Fund

Renaissance Global Focus Fund

Renaissance Global Small-Cap Fund

Renaissance China Plus Fund

Renaissance Emerging Markets Fund

Renaissance Optimal Inflation Opportunities Portfolio

Renaissance Global Infrastructure Fund

Renaissance Global Infrastructure Currency Neutral Fund

Renaissance Global Real Estate Fund

Renaissance Global Real Estate Currency Neutral Fund

Renaissance Global Health Care Fund

Renaissance Global Science & Technology Fund

AXIOM PORTFOLIOS

Axiom Balanced Income Portfolio

Axiom Diversified Monthly Income Portfolio

Axiom Balanced Growth Portfolio

Axiom Long-Term Growth Portfolio

Axiom Canadian Growth Portfolio

Axiom Global Growth Portfolio

Axiom Foreign Growth Portfolio

Axiom All Equity Portfolio

CIBC PRIVATE POOLS

CIBC Canadian Fixed Income Private Pool

CIBC Multi-Sector Fixed Income Private Pool

CIBC Global Bond Private Pool

CIBC Multi-Asset Global Balanced Income Private Pool

CIBC Multi-Asset Global Balanced Private Pool

CIBC Equity Income Private Pool

CIBC Canadian Equity Private Pool

CIBC U.S. Equity Private Pool

CIBC U.S. Equity Currency Neutral Private Pool

CIBC International Equity Private Pool

CIBC Global Equity Private Pool

CIBC Emerging Markets Equity Private Pool

CIBC Real Assets Private Pool

CIBC FIXED INCOME POOLS

CIBC Conservative Fixed Income Pool

CIBC Core Fixed Income Pool

CIBC Core Plus Fixed Income Pool

CIBC ALTERNATIVE FUNDS

CIBC Multi-Asset Absolute Return Strategy

CIBC Alternative Credit Strategy

CIBC FIXED INCOME FUNDS

CIBC Diversified Fixed Income Fund

CIBC Global Credit Fund

CIBC Emerging Markets Local Currency Bond Fund