Sustainable Finance Lobbying Overview: TD Bank Group (TD) and its asset management subsidiary TD Asset Management appear to have had limited engagement on sustainable finance policy but have taken broadly positive positions on sustainable finance overall.

Top-Line Messaging on Sustainable Finance: TD has recognized climate change as a systemic risk but it is unclear whether it supports systemic reforms to address this risk. TD has stated support for keeping global temperature rise to 1.5C and has advocated for broader action to achieve the goals of the Paris Agreement. In October 2021, TD Bank joined the Glasgow Financial Alliance for Net Zero's banking arm, the Net-Zero Banking Alliance, signaling a commitment to the goal of net zero emissions by 2050. Also in October 2021, TD Asset Management signed onto joint statements supporting the goal and calling on governments to limit temperature rise to 1.5C. However, a letter submitted to the Municipal Advisory Council of Texas in December 2022 shows evidence of TD Securities’ support for continued investments in fossil fuels. In its 2021 Public Policy and Political Contributions report TD mentioned engaging with Canadian and US governments on sustainable finance policy, but did not outline details of this engagement. TD Asset Management and TD Insurance have also mentioned engagement on sustainable finance policies but details are similarly unclear.

Position on Regulated Corporate ESG Disclosure: In a 2020 whitepaper, TD advocated for ESG disclosures to be included in securities filings. In its 2021 Climate Action Plan, TD described mandatory climate disclosure requirements moving forward in the US and Canada but did not take a clear position on these policies. In October 2021, TD Asset Management signed onto a joint statement calling for governments to implement mandatory disclosure requirements aligned with the TCFD. TD Asset Management’s 2021 TCFD Report outlines broad support for ESG disclosure requirements. TD Bank’s Q4 2022 Lobbying Report discloses engagement on climate-related disclosures but details of this engagement are unclear.

Position on Taxonomies: In its 2019 ESG report, TD appeared to support the need for a green and transition taxonomy for Canada, but it is unclear what would be characterized as "green" or "transition."

Position on Incorporating ESG Factors Into Risk Management/Prudential Regulation: In its 2021 Climate Action Plan, TD described ongoing efforts by financial regulators in the US and Canada to embed climate risk into regulation and supervision of financial institutions, but did not take a position on these efforts. A memo from the Office of the Comptroller of the Currency (OCC) details a March 2022 meeting with the Bank Policy Institute and its constituents, including representatives from TD Bank, where BPI and its constituents outlined the “challenges” of implementing the OCC’s proposed Principles for Climate-Related Financial Risk Management for Large Banks.

Industry Association Governance: TD has disclosed some of its industry association memberships, including through subsidiaries, but has not given details of the sustainable finance policy positions of these associations and has omitted membership to some European associations including AFME and UK Finance.