“I’m excited we’re getting back to winning.” — Raymund Chun

With that declaration, TD’s leadership kicked off an Investor Day (September 29, 2025) designed to signal a reset and a return to form. It was a masterclass in financial communications. The team framed a necessary overhaul around three universally agreed-upon promises: simpler, faster, and more efficient.

Management set new financial goals, aiming for 7–10% profit growth by 2029. They plan to cut C$2.0–2.5 billion in yearly costs. They also promised to return C$15 billion to shareholders by 2026, using money from the Schwab sale. Addressing their anti-money laundering (AML) issues is the top priority.

It was a credible plan for organizational plumbing: fixing the leaks, improving the flow, and managing the reservoir. The market, understandably focused on near-term EPS and regulatory risk, likely found comfort in the details.

But positioning requires architecture, not just plumbing. And winning requires more than optimization.

The strategy focuses heavily on fixing internal problems like compliance and costs. This is necessary maintenance (plumbing). It is not a strategic redesign (architecture) that changes how customers experience the bank.

Viewed through the lens of Strategic Alchemy, which diagnoses positioning (the claim) and the operating model (the architecture) across four levels — TD’s new strategy is financially serious but positioning-light. It is a plan designed to survive a regulatory crisis (following a guilty plea and approximately US$3B in U.S. AML penalties) and optimize financial performance, rather than a strategy aimed at establishing a mental foothold in the minds of customers.

TD is buying time. It has not yet bought the future.

The Three Forces: Drag, Scaffolding, and the Missing Gravity

To understand the strategy, we must distinguish between the organizational forces at play: Drag (friction), Scaffolding (temporary support), and Gravity (the pull of a differentiated position). TD’s plan is overwhelmingly focused on the first two.

Most of the effort and money is going toward defence (fixing regulatory issues) and financial engineering (stock buybacks). Very little is dedicated to offence —meaningful new ways to attract and keep customers. This imbalance won’t lead to long-term winning.

1. Drag Reduction (The Necessary Non-Strategy)

The dominant forces acting on TD are regulatory in nature. AML costs remain elevated through FY26, and the hard U.S. asset cap (US$434B as of 2025-09-29) restricts organic U.S. growth until it is lifted. This is not a strategy; it is drag reduction.

Spending billions to address Anti-Money Laundering issues is necessary to remain in business. It’s a massive cost that doesn’t make the bank better in the eyes of the customer. It simply brings them up to the expected baseline.

AML compliance is table stakes. Customers expect their bank to be compliant; they do not reward it. While essential for survival and unlocking future U.S. growth (TD’s biggest strategic lever), this spend does not create differentiation. Similarly, the C$2.0–2.5B efficiency program is aimed at reducing internal friction. It improves the P&L but remains invisible to the customer unless translated into a visible sacrifice (e.g., guaranteed service levels or superior pricing), which TD has not committed to.

2. Financial Scaffolding (The EPS Illusion)

The plan to return ~C$15B of excess capital from the Schwab sale by FY’26 is scaffolding. Specifically, a new C$6–7B NCIB (share buyback) in FY’26 (after ~C$8B this year) props up EPS and shareholder sentiment while the heavy lifting on drag reduction occurs.

Returning $15 billion to shareholders makes the stock look good on paper. However, it’s a short-term financial move to keep investors happy. It doesn’t fix the core business or help the bank grow organically.

This is financial engineering designed to manage optics while remediation runs and efficiency programs ramp. It buys patience, but it does not create organizational momentum or pull customers closer.

3. The Missing Gravity (The Positioning Vacuum)

The actual “thrust” (forward momentum driven by a compelling position) is severely limited. The offensive plays are narrow, focused on fee income: +1,200 Wealth advisors (Canada), +500 U.S. retail financial advisors, +835 new Canadian Business Banking frontline FTE, plus 1,000 redeployments into RESL and investment specialists. This is an optimization driven by the asset cap (fee income is less capital-intensive than lending), not a redesign of the core economic engine around a customer-centric noun.

The Diagnosis: The near-term engine is capital returns and cost discipline, not differentiated organic growth. The real unlock is regulatory, not strategic.

The Four-Level Positioning Audit: Theatre vs. Commitment

TD is implicitly trying to reclaim its historical ownership of “Convenience” or “Experience” with the words “simpler” and “faster.” However, by 2025, convenience will be achieved through digital parity. Without a painful, visible sacrifice, it remains Level 1/2 (slogans and features), not Level 3/4 (painful choices and business design).

Every bank claims to be simple and fast today. To make this real, TD needs to make a costly decision that proves they mean it. Without a visible sacrifice, it’s just marketing talk.

Level	Description	TD’s Evidence	Diagnosis
L1: Saying It	Messages and goals	“Simpler, faster, efficient.” “Getting back to winning.”	Strong Theater. The words are clear, but the claims are generic.
L2: Proving It	Evidence customers notice	Tech rollouts (TD AI Prism), AI initiatives (Layer 6 NYC office), hiring in advice, process streamlining.	Parity Proof. Improving, but these are table-stakes investments easily copied by peers.
L3: Living It	A painful decision	Where is the customer-facing sacrifice?	Missing. The major sacrifices are internal (costs, AML spend) and shareholder-facing (buybacks). There is no customer-visible pain that proves commitment.
L4: Owning It	Business model lock	The business model remains unchanged.	Not Yet. The economic engine has not been rewired around a differentiating noun.

A Level 3 commitment requires a sacrifice that hurts. Something competitors would be unwilling to match. Examples could include a permanent ban on teaser-rate cliffs, an “advice explainability” standard for AI, or service-level guarantees with credits when TD misses targets.

Currently, TD is performing strongly in theatre and executing necessary plumbing. It lacks the commitment that turns a word into a moat.

The Operating Model Disconnect: Architecture vs. Aspiration

If positioning defines the gravitational core, the Operating Model (OM) turns that into architecture. When I audit TD’s plan using the 4-Level OM Canvas, the disconnect between aspiration and reality becomes stark.

The Reality Check: TD’s Operating Model is coherent for the actual strategy (regulatory fix + EPS support) but entirely disconnected from the claimed strategy (client experience leadership).

Look at where the money is actually going. The biggest investments are in compliance and shareholder returns. This reveals that protecting the bank and the stock price is the priority, not improving the customer experience.

Level	Operating Model Focus	TD’s Funded Reality	Alignment with “Simpler/Faster”
L1: Structure	Org design, roles	3,500+ front-line hires/redeployments (Wealth, SMB, Specialists).	Weak. Signals intent, but hires are bolted onto existing incentive models. Scaling the old way.
L2: Systems	Workflows, measurement	AI deployed heavily for AML surveillance (defense); modernization focused on efficiency and personalization (offense via TD AI Prism, Layer 6 NYC expansion).	Weak. Systems are primarily optimized for defense (compliance) and cost, not differentiated customer speed or simplicity.
L3: Resource Allocation	Budgets, capital bets	Dominated by AML spend and C$15B capital returns.	Conflicted. The largest commitments pull toward Defense and Finance, outweighing offensive bets.
L4: Value Architecture	Business model lock-in	Unchanged. Reliance on fee income is an optimization due to the asset cap, not a redesign.	None. The architecture is optimized for regulatory resilience and EPS protection.

The “Coach” Delusion

I have argued that TD’s credible future noun could be “Coach” (human + AI advice you can see and trust). The investor deck gestures at this with the hiring of 1,700+ advisors.

However, TD is confusing headcount with architecture.

TD is hiring thousands of advisors to position themselves as a “Coach.” But if these advisors are still paid commissions to push products, they are just salespeople. To be a real coach, the incentives have to change to focus on client outcomes.

Hiring advisors is a Level 1 (Structure) and Level 3 (Resource Allocation) move. It does not equate to owning “Coach” (Level 4). To achieve Level 4 ownership, “Coach” must become the organizing principle of the bank, requiring fundamental architectural shifts:

1. Value Architecture (L4 OM) – The Economic Engine: Advice must be the economic center, not the cross-sell mechanism. This requires redesigning the P&L away from product-pushing toward outcome alignment (e.g., subscription fees for advice, or fees tied to achieving client goals, not AUM).
2. Systems (L2 OM) – The Incentives: Advisor pay must equal client outcomes. If advisors are still primarily paid and promoted on product volume, they are salespeople, not coaches. The operating system hasn’t changed.
3. Information Architecture (L4 OM) – Radical Transparency: Owning “Coach” in the AI era requires an “Advice Trace,” exposing the data and AI reasoning behind recommendations by default. This is expensive and runs counter to the industry practice of optimizing AI for sales conversion.

TD is bolting new headcount onto an existing wealth management architecture designed for product distribution, not coaching.

The Sacrifice Ledger: What Would Make Us Believe

To convert this plan from theatre to commitment and truly “get back to winning” through differentiation, TD must make some painful choices. A true Level 3/4 commitment requires both External (Customer-Visible) and Internal (Operating Model) sacrifices.

Real commitment means giving something up. TD needs to make a move that costs them profit but clearly benefits the customer—like eliminating unfair fees or guaranteeing service levels. This is the only way to build a differentiated position.

Here are five concrete moves that would signal true commitment:

External (Customer-Visible) Sacrifices

1. Kill Teaser-Rate Cliffs. Forever. Make all retail rate offers plain and durable. Yes, it costs NIM. It also buys belief in “simpler, faster, fairer.” This is the ultimate step in rebuilding trust.
2. The Advice Trace (AI Explainability). Publish a TD Advice Trace in-app: show the data behind a recommendation and the model’s reasoning. If the advice fails simple clarity tests, the fee is waived. This bridges the current integrity deficit (post-AML) with the future need for transparent advice.
3. Time-to-Money SLA with Credits. Put it in writing: “Funds available in X minutes/hours, or you get a credit.” Money-back SLAs are a customer sacrifice, not a press line.

Internal (Operating Model) Sacrifices

4. The Talent Betrayal (L2 Systems). Rewrite promotion criteria for all VPs and advisors, prioritizing measurable client outcomes (for “Coach”) or process simplicity (for “Simpler”) over P&L size and product volume. This will cause an exodus of traditional bankers. A necessary sacrifice to change the culture.
5. The Open Architecture Mandate (L4 Value Architecture). Mandate that TD advisors must recommend non-TD products if they better serve the client, deliberately cannibalizing internal product revenue. This is how you earn “Coach” structurally.

Do two of these five this fiscal, and the positioning story flips from aspiration to ownership.

The P&L Reality and What to Watch

The near-term P&L reality is clear: EPS lift will be dominated by share count reduction and expense control, not broad-based revenue acceleration. The path to 16% ROE (by FY’29) relies heavily on delivering the C$2.0–2.5B cost program (which is back-end loaded) and the AML costs flattening by FY’26.

The risk is also clear: If AML timelines slip, the U.S. asset cap keeps a lid on the highest-potential P&L lever. If the new advisors don’t produce high-margin inflows quickly, expense growth blunts the efficiency story.

The positive financial outlook is mostly due to cost cuts and stock buybacks, not actual business growth. TD’s biggest opportunity is in the U.S., but they can’t grow there until the regulators lift the asset cap. That is the single most important factor for their future.

What to Watch in the Next 4 Quarters (The Operator’s Dashboard):

1. AML Milestones: Any signpost toward lifting the U.S. asset cap. This is the primary strategic unlock.
2. Operating Leverage: How much of EPS is buybacks vs. organic drivers.
3. Wealth Productivity: Net new assets per advisor and advice satisfaction, not just headcount growth.
4. Client-Visible Sacrifice: Any announcement of fee charter changes, SLAs, or AI transparency artifacts. This is the proof of positioning commitment.

The Verdict: Renting, Not Owning

TD’s reset is credible on financial plumbing and necessary on regulation. It addresses the immediate threats and stabilizes the financial outlook.

But where does this leave TD vs. peers? RBC still wins scale-trust by default. BMO continues to signal “boldness.” Wealthsimple owns “simplicity.”

This strategy stabilizes the bank during a crisis, which buys them time with investors. However, it does not establish a unique position in the market. They are defending their current ground, not claiming new territory.

To truly “get back to winning” by leading on client experience, TD must move beyond optimizing execution and start engineering inevitability. This requires putting a customer-visible sacrifice on the table that others will not match, and redesigning the operating model to make that sacrifice permanent.

Until then, the new strategy is financially serious and positioning-light. The capital plan can buy time. Only a public, painful choice will buy mental territory.

Great theatre. Solid plumbing. Now show us the architecture.