The Clearing House on March 16 filed a comment letter in response to the Hong Kong Monetary Authority’s public consultation on how it would set requirements for internal TLAC.  The letter offered support for various aspects of the consultation, including the HKMA’s approach of (i) setting internal TLAC at 75% of external TLAC, at least as a starting point (75% is the low end of the range suggested by the FSB, and compares favorably to Fed’s approach of starting at 90%); and (ii) excluding branches from internal TLAC requirements.  The letter recommended the HKMA consider several improvements to the consultation, including (i) bringing the criteria for designating “material subsidiaries” into closer alignment with the FSB Term Sheet; (ii) eliminating the requirement that a certain portion of internal TLAC be comprised of debt; and (iii) allowing for more favorable treatment of secured support agreements, among other things.