The Obama administration's new Financial Crisis Responsibility Fee could hit Toronto-Dominion Bank, CI Capital Markets Inc. analyst Brad Smith said in a note to clients Thursday morning.

The government is expected to release details about the fee later Thursday, but if it applies to U.S.-based financial institutions with consolidated assets of more than $50-billion (U.S.), it could include TD, Mr. Smith said.

"With approximately $140-billion in consolidated U.S. subsidiary assets, there is a possibility that TD's U.S. subsidiaries may be subject to this levy if it goes into force as envisioned," he wrote in his note. "Royal Bank and Bank of Montreal have roughly $30-billion and $40-billion in U.S. bank subsidiary assets and would therefore fall below the $50-billion threshold amount."

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Mr. Smith estimates that the levy could be as much as $100-million per year for TD, but added that he is still waiting to hear back from the bank's management team with respect to how he calculated that preliminary estimate.