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TD’s Climate Plans – Better than RBC, Worse than BMO

Today the Toronto Dominion Bank (TD) released its next steps on its climate plan as part of its Task Force on Climate-Related Financial Disclosures (TCFD) reporting.

Summary quote:

“Unfortunately, TD has left the door firmly open to financing fossil fuel expansion by setting only weak intensity-based 2030 targets for energy and power generation. It’s unclear how this approach squares with TD’s commitment to reduce its absolute financed emissions to net zero by 2050,” said Matt Price, Director of Corporate Engagement with Investors for Paris Compliance.  


  • Good that TD has attempted to quantify Scope 3 emissions from energy (unlike RBC).
  • TD set intensity-based targets for Scope 3 energy emissions (including oil and gas) and for the power sector. Contrary to absolute targets, intensity targets may allow overall emissions to keep increasing as activity increases. BMO recently set an absolute target, while RBC has yet to set any targets.
  • There is no clarity on how TD will evaluate clients’ decarbonization plans and disclose aggregate progress in this regard, nor is there any statement that TD will ultimately hold any client accountable for failing to progress by ending those business relationships.
  • A positive: TD includes underwriting in its measurement of facilitated emissions, something missing from recent announcements by RBC and BMO.
  • TD’s revised coal policy (p. 33) has major loopholes, including focusing only on “new” clients rather than the many existing coal clients TD is in business with, and with no timeline for coal phase out – accepted to be by 2030 in OECD countries and by 2040 worldwide.
  • Another positive: good to see some initial focus on just transition – again something missing from other banks.

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