...AML investigations have pointed to weaknesses in risk management and controls. In our view, Toronto-Dominion Bank's (TD Bank's) management failed to live up to standards expected of one of the world's highest rated banks when the bank's AML programs failed. The bank has taken several steps to address the deficiencies identified at its U.S. subsidiary banks, but we think it will take time to improve the risk management culture across the group, overhaul practices, strengthen the organizational structure, and demonstrate the effectiveness of these measures. Recent profitability has weakened due to hefty AML provisions. Reported return on equity (ROE) has fallen to 6.4% compared with the peer average of 10.7% as hefty AML investigations provisions (US$3.1 billion) and restructuring charges (C$566 million year to date) hurt profitability. We expect ROE will improve closer to historical levels (between 2020-2022, ROE was in the range of 13.6%-18.0%) over time, given the strength of the franchise,...