(Toronto) A proposed class action has been filed against TD Bank, alleging that more than 1,000 of the institution’s mobile mortgage specialists across Canada have not been paid for vacation and time off.

The case alleges that the bank failed to pay or properly remit vacation and/or holiday pay to its mobile mortgage specialists on their commissions, volume bonuses and other variable payments.

The document alleges that money was owed but not paid, in addition to fixed commissions and other non-salary compensation.

The allegations have not yet been tested or proven in court.

Jason Chiang, who worked for TD Bank in Vancouver for almost 13 years, is the proposed representative for the case filed in the Ontario Superior Court of Justice.

TD spokeswoman Ashleigh Murphy said the bank was investigating the allegations and would take appropriate action through the legal process.