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The Complaint alleges that during the Class Period, Defendants provided investors with material information concerning the scope of the issues surrounding TD’s anti-money laundering (“AML”) program employed to comply with the United States’ Bank Secrecy Act (‘BSA”), the ability for Defendants to “fix” those issues, and the punitive and remedial compliance measures likely to be imposed upon TD through the resolution of these investigations. Defendants’ statements included, among other things, confidence in the Company’s optimistic claims of updating and fixing the existing AML program, alleging a full understanding of the scope of the issues the program was facing, and setting aside specific provisional estimates as to the monetary impact of the punitive and compliance measures believed to be imposed. The Complaint further alleges that Defendants provided these overwhelmingly positive statements to investors while, at the same time, disseminating materially false and misleading statements and/or concealing material adverse facts concerning the true state of TD’s AML program; pertinently, TD concealed or otherwise minimized the significance of the failures of the Company’s AML program and made no indication that the imposition of an asset cap or other punitive or compliance measures would be imposed that would undermine TD’s continued growth for the foreseeable future. The Complaint maintains that such statements caused shareholders to purchase the Company’s securities at artificially inflated prices during the Class Period.

Toronto Dominion Bank (The) Common Stock (NYSE: TD) Claim Form