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OSC v. The Toronto-Dominion Bank (FX supervision and controls, 2019)

Settled

Checked against the primary document on October 3, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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In August 2019 the Ontario Securities Commission approved a settlement with The Toronto-Dominion Bank over weak supervision and controls in its FX trading business from 2011 to 2013, with a voluntary payment of C$9,300,900. The settlement says it makes no allegation of benchmark manipulation or front running.

The record

Structured fields for this action, as recorded in our case library.
Agency OSC
Release number 2019-31
Date filed 2019-08-26
Date resolved 2019-08-30
Court Capital Markets Tribunal (Ontario)
Status settled
Asset class fx
Venue OTC
Criminal parallel No
Defendants The Toronto-Dominion Bank (entity)
Techniques

What was ordered

Civil penalty
—
Disgorgement
—
Prejudgment interest
—
Total relief
—
Alleged gain
—
Penalty as published
C$9.3m

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars. This regulator states penalties in CAD. The figure is recorded as published and is not converted, so it does not appear in the USD totals or medians used elsewhere on this site.

What is alleged to have happened

The Ontario Securities Commission announced this matter on August 26, 2019 as release 2019-31, and the Capital Markets Tribunal approved the settlement on August 30, 2019.

The settlement agreement states that over at least 2011 to 2013 TD failed to supervise its FX traders adequately, so they regularly shared confidential customer order information, such as sizes, timing, prices and stop-loss levels, with traders at other firms, in many hundreds of prohibited disclosures, and that compliance monitoring problems continued into 2015. It describes front running and triggering stops only as general types of misconduct and says staff are not alleging those violations or suggesting evidence of them. It also states there is no evidence or indication that TD took part in any plan or collusion to manipulate the WM/Reuters benchmark or any other benchmark rate.

The record carried benchmark-submission, front-running and FX-fixing tags that the agreement expressly disclaims, so it now carries none. TD agreed to a voluntary payment of C$9,300,900 and costs.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

Timeline

  1. 2019-08-23 Settlement Agreement
  2. 2019-08-26 Notice of Hearing
  3. 2019-08-26 Statement of Allegations
  4. 2019-08-30 Other
  5. 2019-08-30 Reasons and Decision

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Record added September 10, 2026. submit a correction.