The substantial financial benefits conferred to TD Bank Group pursuant to this agreement involving Schwab's customers' cash "were part of the consideration that Defendants agreed to pay for their acquisition of TD Ameritrade Holding Corporation from TD Bank Group," according to the suit. Unbeknownst to their fiduciary customers, Schwab "used a substantial portion of their customers' cash to help pay the price of Defendants' acquisition of TD Ameritrade Holding Corporation, in breach of their fiduciary duties," the suit maintains.