April 7, 2017 – Kaplan Fox & Kilsheimer LLP (www.kaplanfox.com) is investigating claims on behalf of investors of The Toronto-Dominion Bank (“TD Bank” or the “Company”) (NYSE:TD). A class action complaint has been filed in the United States District Court for the District of New Jersey on behalf of purchasers of TD Bank securities between December 3, 2015 and March 9, 2017, inclusive (the “Class”), alleging violations of the Securities Exchange Act of 1934 (the “Exchange Act”).
On March 10, 2017, CBC News published a report on TD Bank revealing that unrealistic sales revenue goals have led employees to breaking the law at their customers’ expense in order to meet sales targets and keep their jobs.
The complaint alleges that on this news, TD Bank’s share price fell from $51.77 per share on March 9, 2017 to a closing price of $49.02 per share on March 10, 2017—a $2.75 per share, or more than 5%, decline in the price of TD Bank’s shares.
The complaint alleges that, among other things, TD Bank and its executives violated Sections 10(b) and 20(a) of the Exchange Act by making false and/or misleading statements and/or failing to disclose that: (1) the Company’s wealth asset growth and increased fee-based revenue was spurred by a performance management system that led to its employees breaking the law at their customer’s expense in order to meet sales targets; (2) the Company illicitly increased customer’s lines of credit and overdraft protection amounts without their knowledge, and illicitly upgraded customers to higher-fee accounts without informing them; (3) the Company lied to customers as to the risk of the Company’s products; and (4) as a result, the Company’s statements about its business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis.
If you are a member of the proposed Class, you may move the court no later than May 11, 2017 to serve as a lead plaintiff for the purported class. You need not seek to become a lead plaintiff in order to share in any possible recovery. If you would like to discuss the complaint or our investigation, please contact us by emailing
or by calling 800-290-1952.
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Kaplan Fox & Kilsheimer LLP, with offices in New York, San Francisco, Los Angeles, Chicago and New Jersey, has many years of experience in prosecuting investor class actions. For more information about Kaplan Fox & Kilsheimer LLP, you may visit our website at www.kaplanfox.com. If you have any questions about this Notice, the action, your rights, or your interests, please contact:
Matthew P. McCahill
KAPLAN FOX & KILSHEIMER LLP
850 Third Avenue, 14th Floor
New York, New York 10022
Fax: (212) 687-7714
Laurence D. King
KAPLAN FOX & KILSHEIMER LLP
350 Sansome Street, Suite 400
San Francisco, California 94104
Fax: (415) 772-4707
Attorneys: Laurence D. King, Matthew P. McCahill, Pamela A. Mayer