To: Ed Clark
President and Chief Executive Officer
Toronto Dominion Bank
cc: Christopher Cox, Chairman SEC
450 Fifth Street N.W.
New York, NY 20549
Simon Townsend, TD
Senior Manager, Corporate Communications
Nicholas Petter, TD
Manager, Corporate Communications
Senior Manager, External Communications
From: Bill Parish, SEC Registered Investment Advisor
Parish & Company
10260 SW Greenburg Rd, Suite 400
Portland, Oregon 97223
cc: Leading business journalists on Wednesday
As a Registered Investment Advisor, I have been using TD Ameritrade as a custodian for client assets since 1995 when it was Waterhouse Securities based in New York. You are fortunate to own such an outstanding franchise yet it is now at risk as a result of an astonishing level of arrogance, lack of a forthright perspective and outright incompetence on the part of the CEO you installed subsequent to the Ameritrade merger, Joe Moglia.
TD Waterhouse had many fine employees, including the current head of TD Institutional, Tom Bradley. In my opinion, you made a very serious error in not making sure they controlled the post merger integration rather than Moglia and his lieutenants.
Those are harsh words yet I value the security of my clients assets and you should also. Clearly, the SEC does.
Moglia made his mark peddling stocks at Ameritrade and clearly does not have the administrative acumen or forthright perspective necessary. Let me cite a few specific examples.
For months now statements have been issued to clients in the US with Canadian treasuries listed in Canadian dollars, not US dollars. Imagine that, with everything else in US dollars. Supposedly a fix will be done this month yet this is too long in coming.
Clients here in the US with maturing Canadian treasuries have been issued confirmations for sales in Canadian dollars, only to be reissued revised confirmations, with no attached letter of explanation, in US dollars to fix the mistake.
As we enter a new rising rate environment, acumen on the bond side will be more critical. This should be a tremendous profit center, both for domestic and foreign bonds, as investors value fixed income more in the future. My advice, develop it rather than focusing mostly on peddling stocks and funds.
The post integration was obviously tough yet there is no excuse for not communicating key admin issues more clearly to advisors like myself, one example being the issuance of zero balance statements, without an adequate explanation in June, only to issue regular statements shortly after for the same ending period. Imagine being a client and getting a statement for your $1.5 million account that has a zero balance.
In any event, I am generally recognized as successful in advancing key corporate governance issues, see my website at http://www.billparish.com for a sampling of articles ranging from Barrons to Bloomberg, and what I clearly see is a franchise with enormous potential at risk.
You may notice that I didn’t even mention the recent security breach in which millions of customers names and email addresses were compromised by an “outside vendor.” Was this a “strategic partner” data mining for advertising purposes? We’ll probably never know.
Regarding Etrade, with a $24 billion portfolio of mortgages, if those mortgages are worth only $20 billion, that erases two thirds of its equity and may even have pure banking considerations in terms of maintaining adequate capital. Think FASB 115 writedowns each quarter as far as you can see. A foolish merger in my opinion.
Rather than avoid the institutional area like Etrade due to its need to now cut costs sharply, I hope you realize that advisors like myself are your most valuable sales arm in that for every client I have at TD Ameritrade, there are probably 100 other investors who have accounts with you who are not my clients because they trust my judgement in selecting a good custodian.
Good luck, and again, I realize these are harsh words. Yet don’t lose site of the fact that my clients entrust me with their and their families financial futures. As custodian, you are part of that trust. Please take a step toward earning it by replacing Moglia immediately.