Late Friday, The Clearing House, the Securities Industry and Financial Markets Association, the American Bankers Association, the Financial Services Roundtable, and the Financial Services Forum submitted comments to the Federal Reserve in response to its proposal to impose total loss absorbing capacity, long-term debt and related “clean holding company” requirements on global systemically important banking groups (G-SIBs). The associations express the industry’s strong support for a TLAC requirement for G-SIBs, which is a crucial aspect of ending “Too Big to Fail” by helping ensure that these institutions can be resolved in an orderly way at the expense of creditors and shareholders (and not taxpayers). The associations also assert that the proposal contains a number of requirements that are counterproductive or unnecessary to achieving the Fed’s policy objectives. In response, the associations provide a number of suggestions aimed at making the proposal more workable and effective.