One is timing: it is hard to roll out internal TLAC for a group until TLAC requirements are in place in all the jurisdictions relevant for the material subsidiaries. The Bank is in the middle of consulting on its internal 10  MREL policy but many other jurisdictions – notably the Banking Union, Switzerland and Japan – have still not set policy. Another challenge is arithmetic: to the extent that there are financial dependencies between legal entities within a group the sum of solo RWAs is likely to be greater than consolidated RWAs. If a full TLAC requirement were applied to each subsidiary then the sum of the internal TLAC would exceed the consolidated TLAC requirement for the group as a whole. 9  The Bank of England published loss-absorbing capacity requirements for major UK banks in 2016 shortly after responding to the Treasury Committee’s inquiry into capital. See http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/treasury-committee/capital-andresolution/written/69208.pdf. 10 The Bank of England published a consultation paper on its approach to setting a minimum requirement for own funds and eligible liabilities (MREL) within groups on 2 October 2017. See https://www.bankofengland.co.uk/-/media/boe/files/financialstability/resolution/internal-mrel-consultation-october-2017.pdf?la=en&hash=33594C3FB3C7F1D129033AFE4E3A2BF20A4F9AA8 . 5  All speeches are available online at www.bankofengland.co.uk/speeches  5  This was addressed in the TLAC term sheet in two ways: -  by limiting internal TLAC only to subgroups and subsidiaries that are material to the group, accounting for more than 5% of RWAs or income.
These include: •  Stable macroeconomic environment as reflected in single digit inflation, reduction in lending interest rates and a stable exchange rates  •  Amendments/Harmonisation of financial sector legislation such as the Development Bank of Zambia (DBZ) Act, the National Savings and Credit Act (NSCA), the Pensions and Insurance Act, the Building Societies Act (BSA) and the Banking and Financial Services Act (BFSA) in 2005. •  Establishment of a credit reference bureau in 2006; and Promulgation of microfinance regulations in 2006. Honourable Minster – The production of market knowledge on the supply and demand for financial services in Zambia was identified as one of the priority areas under the FSDP. In this regard, FinMark Trust of South Africa was contracted by our cooperating partners the Swedish International Development Agency (Sida) and the United Kingdom’s Department for International Development (DFID) to undertake this important activity and subsequently, the FinScope Zambia 2005 Survey, a comprehensive demand-side survey of consumer interactions with financial markets in Zambia, was conducted in November 2005. The main objective of the survey was to measure access to and use of financial services, along with how people manage their finances and what drives their financial behaviour. Honourable Minister and Invited Guests - This morning we are here to share with you, the findings of the FinScope Zambia 2005 Survey. These findings are expected to play an important role in profiling demand for financial services in Zambia.