The Complaint alleges, that defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that:

• TD Bank had deficient controls over AML and suspicious transaction reporting;
• the lack of controls posed a significant risk to the closing of the First Horizon acquisition;
• failed to disclose several material weaknesses in TD Bank’s internal control over financial reporting;
• the deficient AML controls actually caused delay in obtaining the regulatory approvals for the First Horizon acquisition; and
• as a result, defendants’ positive statements about TD Bank’s risk culture and its ability to timely close the First Horizon transaction were materially false and misleading and/or lacked a reasonable basis at all relevant times.

No Class Has Been Certified. Until a class is certified, you are not represented by counsel unless you retain one. You may select counsel of your choice. You may also remain an absent class member and do nothing at this point. An investor’s ability to share in any potential future recovery is not dependent upon serving as lead plaintiff.

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