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Finance committee  We take an approach similar to that of HSBC. We find that looking simply at the tax laws in a jurisdiction doesn't provide us enough information to determine what the risk of that jurisdiction is from a money laundering and terrorist financing and anti-corruption and anti-bribery

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  If I understand your question, I think it is indisputable that not all countries are as good as Canada is in asking the types of questions that you were asked when you endeavoured to open up an account for an investment property, or whatever it was. There is no question there is

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  I can tell you that from the account opening process and from the regulatory requirements that are embedded in this in Canada, we push that throughout the world. Now, in terms of credit or other types of policies, there may be differences, depending upon where that occurs. I can'

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  Yes, we have enterprise standards in that regard.

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  It's both. I think one of my colleagues said that there is the front line and then there's after-the-fact monitoring. There are activities that occur at the time of the transaction that we may be aware of, that are red flags and may cause us to raise a suspicion. Those front-line

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  Yes, we review them at least on an annual basis. We test them; we don't just change them. We change them based upon where we think they are productive, in terms of providing us with the best information. Then we test below the thresholds to make sure we're not missing anything if

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  As does TD.

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  Yes, in that we file suspicious transaction reports if within the course of the payment we discover there is a financial institution involved in the payment that we think may have done something wrong.

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  I'll be very brief. I think what I say will be universally held by others. From a bank's perspective, of course we have an obligation to our shareholders to operate in a responsible manner and to return to them as best a return on their investments as we can. As a corollary to

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  Well, I think it's a business strategy. You have to look at where you are and how you intend to grow your business. For us, to go into risky areas is not part of our strategy. Our risk appetite is fairly conservative. I think that has served us well over the last so many years. A

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  I think they're very similar, actually. There are some nuances, certainly, that are different. In Canada there are more prescriptive requirements in terms of opening accounts than there are in the U.S. I think it's an often misunderstood notion that the U.S. is more regulated tha

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  We do a number of things upon someone's application in order to determine whether they are worthy of being hired at TD Bank, whether in the U.S. or in Canada. One of the things we do for all employees is to run through the sanctions lists with them. There are multiple lists here

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  Yes, in whatever country. Is there anything else that I missed?

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  I think you've already heard that one of the things we all do, and we have an obligation to do, is to know our customers from the front end. We determine what we expect to be the baseline type of activity as well as the purpose of the account. We look into other aspects of the cu

March 21st, 2013Committee meeting

Carmina Hughes

Finance committee  For what purpose would we identify the customer?

March 21st, 2013Committee meeting

Carmina Hughes