It really shouldn't matter as long as you test the drive on the tv first. If it's not in a compatible format then you can have the TV re-format it and be good to go usually. I tend to use the exFat for my external drives as it is very compatible with most systems; Mac, PC's, Android, iphone/ipad, PS4, XB1, most Tv's...
Fat32 usually works as well with drives 2Tb and under but be careful of files that are 4GB or larger, Fat32 will not work with those but exFat will.