TD Direct Investing

TVSM-BR v1.0.1 · custodial-safety model
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85/100
Excellentof scored brokerages
Scored Entity · Canadian view
EntityTD Waterhouse Canada Inc.JurisdictionCanada — no entity mismatch (Canadian-native CIRO/CIPF)RegulatorCIRO (+ OSFI at parent bank level)SchemeCIPF CAD $1M per account category (no excess insurance)
Dimension breakdown
Regulatory StandingPrimary driver9.4/1025%
Investor Protection8.7/1020%
Asset Segregation & CustodyLargest drag7.3/1020%

Asset-segregation composite governed by the weaker axis — (segregation × ) = 7.3, (custody tier) = 10.0. Dimension score = 7.3.

Financial Strength & Stability10.0/1014%
Withdrawal & Account Integrity7.0/1013%

Capped at 7.0/10 no negative-balance protection (jurisdiction not mandating it).

Transparency & Conduct8.0/108%
Withdrawal Integrity — dimension ceiling

No (jurisdiction not mandating it). Withdrawal Integrity is capped at 7.0/10 regardless of other withdrawal performance (it would otherwise be 8.5). Approximate composite impact: 1.9 points.

Verdict

TD Direct Investing scores 85/100 (Excellent) — Canada's largest self-directed brokerage by assets, with C$749B+ AUA under TD Bank Group. Primary driver is D4 Financial Strength (10.0/10): TD Bank Group is a Big Six Canadian bank, NYSE- and TSX-listed, CET1 14.7%, with 40 years of continuous operation as a self-directed platform. The two largest drags are D5 and D3. D5 is capped by the NBP ceiling — Canada is a non-NBP-mandating jurisdiction, and raw D5 8.46 exceeds the 7.0 ceiling, cutting two composite points relative to ceiling-exempt peers. D3 (7.3/10) is constrained by rehypothecation disclosure that lacks explicit daily set-aside language for margin accounts; opt-in securities lending is positive, but the ambiguity pulls Axis A below Axis B (CDS Tier-1 custody, rung 10). L3 disclosed: TD Bank N.A. — a US subsidiary, not TD Waterhouse Canada Inc. — pleaded guilty to BSA/AML violations in October 2024 with a $3.09B penalty; the DOJ compliance monitor and US asset cap are continuing conditions at the parent level. TD Waterhouse Canada Inc. is not named in the consent order and operates independently under CIRO. Disclose to risk-sensitive clients before recommending.

Best for

Canadian investors seeking maximum custodial safety with Big Six bank backing; large-account holders and RRSP/TFSA/RESP/FHSA registered account holders; TD banking customers who value consolidated banking and brokerage access

Skip if

cost-sensitive on commissions — TD Direct is materially more expensive than Questrade or zero-commission alternatives; clients for whom parent-bank AML proximity at any level is disqualifying for risk or compliance policy

TraderVerdict brokerage scores assess custodial safety from a Canadian investor perspective. Scores do not constitute investment advice. Verify all details directly with the broker before opening an account.

Evidence & Sources

Scores are on a 1–10 scale. = one step on the scoring ladder. Source links open primary evidence.

d1 entity tier9/10Source ↗

TD Waterhouse Canada Inc. listed under Integrated Dealers in CIRO December 2025 Dealer Peer Group List; registered as Investment Dealer in all provinces/territories; wholly-owned subsidiary of TD Bank Group.

d1 license status10/10Source ↗

TD Waterhouse Canada Inc. active CIRO Investment Dealer; registered as dealer in all provinces/territories; no conditions noted.

d1 supervision scope10/10Source ↗

CIRO Dealer Members subject to full prudential (capital adequacy, Form 1, segregation) and conduct (best execution, KYC, suitability) supervision; OSFI also supervises TD Bank parent on consolidated basis.

d2 scheme membership10/10Source ↗

TD Waterhouse Canada Inc. listed in CIPF Current CIPF Members directory; website www.tdwaterhouse.ca confirmed.

d2 coverage limit8/10Source ↗

$1 million for all general accounts combined...plus $1 million for all registered retirement accounts combined...plus $1 million for all registered education savings plans (RESPs) combined.

d2 excess insurance6/10Source ↗

No excess CIPF or named private insurer found in any TD Direct Investing public disclosure. CIPF brochure references only base CIPF coverage.

d3 segregation model8/10Source ↗

IIROC Rules provide for the requirement to segregate or hold in trust client securities at acceptable securities locations supported by written custodial agreements. TD Waterhouse confirmed to hold client assets omnibus via Canadian custodian under NI 31-103 s.14.6.

d3 rehypothecation6/10Source ↗

The Canadian Investor Protection Fund (CIPF) does not cover any securities while on loan. To offset this risk, we provide cash collateral updated to market value every day while your securities are on loan. Securities lending is opt-in (Stock Lending Income Program).

d3 custody tier10/10Source ↗

Customer transactions are cleared through the Canadian Depository for Securities (CDS), the Canadian Derivative Clearing Corp. and the Mutual Fund Clearing & Settlement Service.

d4 regulatory capital10/10Source ↗

Common Equity Tier 1 (CET1): 14.7% as of October 31, 2025. Tier 1 Capital ratio: 16.4%. Total assets C$2+ trillion.

d4 operational history10/10Source ↗

TD Direct Investing came a long way since its inception in 1984 as TD Green Line — 40th anniversary celebrated 2024.

d4 parent backing10/10Source ↗

CET1: 14.7%... total assets exceeding a record $1.3 trillion [in Wealth segment]; TD Bank Group is NYSE+TSX listed, investment-grade rated, Big Six Canadian bank.

d4 client scale10/10Source ↗

TD Direct Investing takes top spot in assets for self-directed brokerages in Canada (ISS Market Intelligence, June 2025). TD Bank Group serves 27.5M+ customers; Wealth Management AUA C$749B+.

d5 withdrawal reliability9/10Source ↗

No systemic withdrawal delay complaints documented in regulatory filings or major consumer review platforms. Rated top online brokerage 3 consecutive years (Globe and Mail).

d5 withdrawal friction8/10Source ↗

Partial RRSP withdrawal: $25; Full RRSP withdrawal: $100. No fees for cash withdrawal from non-registered accounts.

d5 extractive fees10/10Source ↗

$0 commission on Select ETFs; equities $9.99/trade flat; maintenance fee waived above $15K; no percentage-of-withdrawal fees.

d5 account erosion7/10Source ↗

$25 per quarter if total assets under $15,000.

d6 ownership transparency10/10Source ↗

TD Waterhouse Canada Inc. is a wholly-owned subsidiary of The Toronto-Dominion Bank (NYSE: TD; TSX: TD); full public financial disclosure quarterly.

d6 enforcement history6/10Source ↗

2020 IIROC fine of $4M for CRM2 reporting failures (failure to include position cost information in ~175,301 client statements); 2018 IIROC fine of $140,000 for supervision failure (individual employee). Both settled.

d6 execution conflict8/10Source ↗

TDWCI is a non-Executing Dealer Member...meets its best execution obligations by engaging TD Securities Inc. (TDSI), an Executing Dealer Member of CIRO, for Canadian and U.S. order flow.

Primary sources

Every TD Direct Investing variable score traces to a public, primary source. The full verbatim extract and verification date for each is in the Evidence tab above; the underlying documents are listed here.

Regulatory registers we cross-check

TVSM cross-checks each firm’s regulatory standing and any disciplinary history against these public registers as part of the stability and transparency assessment.

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