Summary
This is a proposed securities class action against The Toronto-Dominion Bank (“TD”) and certain of its current and former directors and/or officers. This action arises out of misrepresentations made in TD’s disclosure documents and public oral statements regarding deficiencies in TD’s anti-money laundering (“AML”) program.
Specifically, it is alleged that during the Class Period, TD misrepresented that it had effective AML programs in place and complied with all applicable AML laws and regulations, and further omitted to disclose that it had allowed the laundering of large sums of money for criminal organizations and that was it under investigation by the United States Department of Justice for money laundering violations. This led investors to believe, among other things, that TD was abiding with all applicable AML laws and regulations, and was on track to execute its U.S. expansion plans, which artificially inflated TD’s stock price.
It was revealed in a series of public disclosures that TD had permitted the laundering of hundreds of millions of dollars for criminals including drug cartels, that TD’s AML program had significant deficiencies that had resulted in numerous investigations which would lead to large expected fines, and that these AML deficiencies put TD’s U.S. expansion plans at risk and would cost hundreds of millions of dollars to ameliorate. Upon the release of these revelations, TD’s stock price dropped materially on both the TSX and NYSE, thereby wiping out billions of dollars of market value for TD’s shareholders.
Class Membership Criteria
This class action is brought on behalf of:
all persons and entities who, during the period from August 26, 2021 to June 3, 2024, inclusive, acquired TD’s securities whether in a primary market offering or on any secondary market exchange wherever located, and who held some or all of those securities as of August 24, 2023, January 8, 2024, April 30, 2024, May 2, 2024, and/or June 3, 2024, except certain “Excluded Persons”.
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