A proposed class action lawsuit has been filed against Toronto-Dominion Bank alleging that more than 1,000 TD mobile mortgage specialists across Canada did not receive their proper vacation and holiday pay.

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

It alleges the money was owed, but not paid, on top of the set commissions and other non-salary compensation.

The allegations have yet to be tested or proven in court.

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

TD did not immediately respond to requests for comment, but lawyers for the plaintiff said they expected TD would deny the allegations and defend the case.