Hsbc Global Asset Management (USA) Inc..

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HSBC HOLDINGS PLC
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is

registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
THE EUROPEAN COMMISSION ("THE COMMISSION")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/07/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC FRANCE
6.
Principal Product Type:
No Product
Other Product Types: 
EURO INTEREST RATE DERIVATIVE PRICING
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN DECEMBER 2016, THE EUROPEAN COMMISSION (THE 'COMMISSION') ISSUED A DECISION THAT IN EARLY 2007 HSBC, AMONG OTHER BANKS,
COLLUDED ON EURO INTEREST RATE DERIVATIVE PRICING ELEMENTS, AND EXCHANGED RELATED SENSITIVE INFORMATION, IN BREACH OF EU
ANTITRUST RULES. THE COMMISSION DETERMINED THAT THE DURATION OF HSBC'S INFRINGEMENT WAS 1 MONTH AND FINED HSBC 33,606,000
EUROS. HSBC APPEALED THE DECISION TO THE GENERAL COURT OF THE EUROPEAN UNION, WHICH IN 2019 ANNULLED THE FINE FOR FAILURE TO
PROVIDE REASONS, BUT UPHELD HSBC'S LIABILITY. IN 2021 THE EUROPEAN COMMISSION IMPOSED A REVISED FINE OF 31,700,000 EUROS (USD
$37,802,250 WHICH UTILIZES THE CLOSING FX RATE AS OF THE DATE OF ISSUANCE FOR THE AMENDED FINE AND AS REFLECTED IN SECTION 12.A ).
HSBC APPEALED TO THE LIABILITY FINDINGS TO THE COURT OF JUSTICE OF THE EUROPEAN UNION, WHICH UPHELD HSBC'S LIABILITY IN JANUARY
2023. HSBC CONTINUES TO MAINTAIN AN APPEAL BEFORE THE GENERAL COURT AGAINST THE 2021 COMMISSION DECISION IMPOSING A REVISED
FINE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
THE EU GENERAL COURT, IN A JUDGEMENT OF 24 SEPTEMBER 2019, ANNULLED HSBC'S FINE FOR INSUFFICIENT REASONING BUT LARGELY UPHELD THE
COMMISSION'S FINDINGS OF LIABILITY. IN Q4 2019 HSBC AND THE EUROPEAN COMMISSION APPEALED THE GENERAL COURT'S RULING TO THE COURT
OF JUSTICE OF THE EUROPEAN UNION. THE EUROPEAN COMMISSION SUBSEQUENTLY WITHDREW ITS APPEAL AND IMPOSED A REVISED FINE. IN
JANUARY 2023 THE COURT OF JUSTICE DISMISSED HSBC'S APPEAL AGAINST LIABILITY AND IN NOVEMBER 2024 THE GENERAL COURT ALSO DISMISSED
HSBC'S APPEAL AGAINST THE REVISED FINE.
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):

12/07/2016
 Exact
 Explanation
If not exact, provide explanation:
HSBC HAS APPEALED THE COMMISSIONS DECISION.THE AMOUNT OF THE FINE HAS BEEN PROVISIONALLY PAID. DATE OF APPEAL 2/17/17. NOVEMBER
2024 - HSBC'S APPEAL AGAINST THE REVISED FINE WAS DISMISSED BY THE GENERAL COURT.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 37,802,250.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
HSBC CONTINENTAL EUROPE IN ACCORDANCE WITH THE 2021 DECISION PAID A FINE IN THE AMOUNT OF 31,700,000 EUROS. SEE
INFORMATION WITH RESPECT TO THE APPEAL ABOVE. THE FINE IS CONVERTED TO USD $37,802,250 (CLOSING FX RATE AS OF THE DATE OF
ISSUANCE FOR THE AMENDED FINE) AS REPORTED ABOVE IN SECTION 12.A.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
HSBC CONTINENTAL EUROPE IN ACCORDANCE WITH THE 2021 DECISION PAID A FINE IN THE AMOUNT OF 31,700,000 EUROS. SEE
INFORMATION WITH RESPECT TO THE APPEAL ABOVE. THE FINE IS CONVERTED TO USD $37,802,250 (CLOSING FX RATE AS OF THE DATE OF
ISSUANCE FOR THE AMENDED FINE) AS REPORTED ABOVE IN SECTION 12.A.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
HSBC PAID THE REVISED FINE OF 31,700,000 EUROS (USD $37,802,250 WHICH UTILIZES THE CLOSING FX RATE AS OF THE DATE OF ISSUANCE FOR
THE AMENDED FINE AND AS REFLECTED IN SECTION 12.A ) IN 2021. IN NOVEMBER 2024, THE GENERAL COURT DISMISSED HSBC'S APPEAL AGAINST
THE FINE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HSBC HOLDINGS PLC

(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HSBC NORTH AMERICA
HOLDINGS INC
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FEDERAL RESERVE")
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
MONETARY FINE
3.
Date Initiated (MM/DD/YYYY): 
09/29/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
17-010-B-FB; 17-010-B-HC; 17-010-CMP-FB; 17-010-CMP-HC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
FOREIGN EXCHANGE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN SEPTEMBER 2017, FOLLOWING THE CONCLUSION OF THE US FEDERAL RESERVE BOARD'S REVIEW OF THE EFFECTIVENESS OF HSBC'S FX PRACTICES
DURING THE PERIOD OF OCTOBER 2008 THROUGH OCTOBER 2013, HSBC HOLDINGS PLC AND HSBC NORTH AMERICA HOLDINGS INC. ENTERED INTO A
CONSENT ORDER REGARDING CERTAIN DEFICIENCIES IN HSBC'S CONTROL AND OVERSIGHT OVER ITS FX BUSINESS. HSBC THROUGH VARIOUS
SUBSIDIARIES OF HOLDINGS, INCLUDING HBEU AND HBUS, LACKED ADEQUATE GOVERNANCE, RISK MANAGEMENT, COMPLIANCE AND AUDIT POLICIES
AND PROCEDURES TO ENSURE THAT HSBC'S COVERED FX ACTIVITIES COMPLIED WITH SAFE AND SOUND BANKING PRACTICES AND APPLICABLE
INTERNAL POLICIES. ON AUGUST 18, 2023, THE FEDERAL RESERVE BOARD CONCLUDED THAT HSBC WAS IN FULL COMPLIANCE AND TERMINATED THE
CONSENT ORDER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
08/18/2023
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 175,296,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
PURSUANT TO THE FEDERAL DEPOSIT INSURANCE ACT, THE FEDERAL RESERVE ISSUED A CONSENT ORDER TO CEASE AND DESIST AND
ASSESSMENT OF A CIVIL MONEY PENALTY (THE "ORDER"). ACCORDINGLY, HSBC SHALL CEASE AND DESIST WITH RESPECT TO THE DEFICIENCIES
DOCUMENTED IN THE ORDER AND TAKE AFFIRMATIVE ACTION RELATING TO INTERNAL CONTROLS AND COMPLIANCE OVERSIGHT OVER CERTAIN
MARKETS ACTIVITY. ON SEPTEMBER 29, 2017, HSBC PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $175,296,000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN SEPTEMBER 2017, FOLLOWING THE CONCLUSION OF THE US FEDERAL RESERVE BOARD'S REVIEW OF THE EFFECTIVENESS OF HSBC'S FX PRACTICES
DURING THE PERIOD OF OCTOBER 2008 THROUGH OCTOBER 2013, HSBC HOLDINGS PLC AND HSBC NORTH AMERICA HOLDINGS INC. ENTERED INTO A
CONSENT ORDER REGARDING CERTAIN DEFICIENCIES IN HSBC'S CONTROL AND OVERSIGHT OVER ITS FX BUSINESS. HSBC THROUGH VARIOUS
SUBSIDIARIES OF HOLDINGS, INCLUDING HBEU AND HBUS, LACKED ADEQUATE GOVERNANCE, RISK MANAGEMENT, COMPLIANCE AND AUDIT POLICIES
AND PROCEDURES TO ENSURE THAT HSBC'S COVERED FX ACTIVITIES COMPLIED WITH SAFE AND SOUND BANKING PRACTICES AND APPLICABLE
INTERNAL POLICIES. ON AUGUST 18, 2023, THE FEDERAL RESERVE BOARD CONCLUDED THAT HSBC WAS INFULL COMPLIANCE AND TERMINATED THE
CONSENT ORDER.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HSBC HOLDINGS PLC
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
U.S. DEPARTMENT OF JUSTICE (DOJ)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/18/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE1:18 CR 00030 LDH
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC HOLDINGS PLC
6.
Principal Product Type:
Futures - Financial
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN JANUARY 2018, FOLLOWING THE CONCLUSION OF THE US DEPARTMENT OF JUSTICE'S (DOJ) INVESTIGATION INTO HSBC'S HISTORICAL FOREIGN
EXCHANGE ACTIVITIES, HSBC HOLDINGS ENTERED INTO A THREE-YEAR DEFERRED PROSECUTION AGREEMENT WITH THE CRIMINAL DIVISION OF THE
DOJ (THE FX DPA), REGARDING FRAUDULENT CONDUCT IN CONNECTION WITH TWO PARTICULAR TRANSACTIONS IN 2010 AND 2011. IN JANUARY 2021,
THE FX DPA EXPIRED AND, IN AUGUST 2021, THE CHARGES DEFERRED BY THE FX DPA WERE DISMISSED.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
08/02/2021
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 101,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE DEFERRED PROSECUTION AGREEMENT REQUIRES HSBC HOLDINGS TO PAY A TOTAL OF $101.5 MILLION, INCLUDING A $63.1 MILLION FINE
AND $38.4 MILLION IN RESTITUTION. THE AGREEMENT, RECOGNIZING THAT HSBC HOLDINGS HAS ALREADY ENGAGED IN REMEDIAL MEASURES,
REQUIRES HSBC HOLDINGS TO MONITOR ITS COMPLIANCE WITH THE AGREEMENT'S OBLIGATIONS AND PROVIDE ANNUAL REPORTS TO THE DOJ
FOR THE TERM OF THE AGREEMENT.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
IN JANUARY 2018, FOLLOWING THE CONCLUSION OF THE US DEPARTMENT OF JUSTICE'S (DOJ) INVESTIGATION INTO HSBC'S HISTORICAL
FOREIGN EXCHANGE ACTIVITIES, HSBC HOLDINGS ENTERED INTO A THREE-YEAR DEFERRED PROSECUTION AGREEMENT WITH THE CRIMINAL
DIVISION OF THE DOJ (THE FX DPA), REGARDING FRAUDULENT CONDUCT IN CONNECTION WITH TWO PARTICULAR TRANSACTIONS IN 2010 AND
2011. IN JANUARY 2021, THE FX DPA EXPIRED AND, IN AUGUST 2021, THE CHARGES DEFERRED BY THE FX DPA WERE DISMISSED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN JANUARY 2018, FOLLOWING THE CONCLUSION OF THE US DEPARTMENT OF JUSTICE'S (DOJ) INVESTIGATION INTO HSBC'S HISTORICAL FOREIGN
EXCHANGE ACTIVITIES, HSBC HOLDINGS ENTERED INTO A THREE-YEAR DEFERRED PROSECUTION AGREEMENT WITH THE CRIMINAL DIVISION OF THE
DOJ (THE FX DPA), REGARDING FRAUDULENT CONDUCT IN CONNECTION WITH TWO PARTICULAR TRANSACTIONS IN 2010 AND 2011. IN JANUARY 2021,
THE FX DPA EXPIRED AND, IN AUGUST 2021, THE CHARGES DEFERRED BY THE FX DPA WERE DISMISSED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.

ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HSBC HOLDINGS PLC
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
THE EUROPEAN COMMISSION ("THE COMMISSION")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/02/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK PLC
6.
Principal Product Type:
Other
Other Product Types: 
FOREIGN EXCHANGE (FOREX) SPOT TRADING
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE EUROPEAN COMMISSION IN DECEMBER 2021 COMPLETED A CARTEL INVESTIGATION INTO THE FOREIGN EXCHANGE ('FOREX') SPOT TRADING
MARKET BY IMPOSING FINES ON FIVE FINANCIAL INSTITUTIONS, INCLUDING HSBC HOLDINGS PLC. THE COMMISSION'S INVESTIGATION FOCUSED ON
THE TRADING OF THE G10 CURRENCIES. THE COMMISSION'S INVESTIGATION REVEALED THAT SOME TRADERS IN CHARGE OF THE FOREX SPOT TRADING
OF G10 CURRENCIES, ACTING ON BEHALF OF THE FINED BANKS, EXCHANGED SENSITIVE INFORMATION AND TRADING PLANS, AND OCCASIONALLY
COORDINATED THEIR TRADING STRATEGIES THROUGH AN ONLINE PROFESSIONAL CHATROOM. THE COMMISSION FOUND THAT THESE INFORMATION
EXCHANGES ENABLED THE TRADERS TO MAKE INFORMED MARKET DECISIONS ON WHETHER AND WHEN TO SELL OR BUY THE CURRENCIES THEY HAD IN
THEIR PORTFOLIOS, AS OPPOSED TO A SITUATION WHERE TRADERS ACTING INDEPENDENTLY FROM EACH OTHER TAKE AN INHERENT RISK IN TAKING
THESE DECISIONS. OCCASIONALLY, THESE INFORMATION EXCHANGES ALSO ALLOWED THE TRADERS TO IDENTIFY OPPORTUNITIES FOR
COORDINATION, FOR EXAMPLE THROUGH A PRACTICE CALLED "STANDING DOWN", WHEREBY SOME OF THEM WOULD TEMPORARILY REFRAIN FROM
TRADING TO AVOID INTERFERING WITH ANOTHER TRADER. HSBC COOPERATED WITH THE INVESTIGATION AND HAS PAID THE FINE NOTED BELOW.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
12/02/2021
 Exact
 Explanation
If not exact, provide explanation:
FINE ANNOUNCED BY COMMISSION ON 12/2/21. HSBC HOLDINGS CAUSED THE FINE TO BE PAID WITHIN IN THE TIMEFRAME DIRECTED BY THE
COMMISSION.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 196,954,958.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
FINE ANNOUNCED BY THE COMMISSION ON 12/2/21.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
HSBC HOLDINGS CAUSED THE FINE TO BE PAID WITHIN IN THE TIMEFRAME DIRECTED BY THE COMMISSION.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual

Registered:
Yes
No
Name:
HSBC HOLDINGS PLC
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
UK COMPETITION AND MARKETS AUTHORITY (CMA)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/24/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK PLC
6.
Principal Product Type:
Other
Other Product Types: 
UK GILTS AND GILT-ASSET SWAPS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN MAY 2023 THE COMPETITION AND MARKETS AUTHORITY ISSUED A STATEMENT OF OBJECTIONS TO FIVE BANKS (DEUTSCHE BANK, MORGAN STANLEY,
ROYAL BANK OF CANADA, CITI, AND HSBC). IN FEBRUARY 2025, THE COMPETITION AND MARKETS AUTHORITY ANNOUNCED THAT IT HAD REACHED A
SETTLEMENT WITH HSBC. HSBC ACCEPTED THAT A SINGLE HSBC TRADER HAD SHARED COMPETITIVELY SENSITIVE INFORMATION ON 12 SEPARATE
OCCASIONS WITH A DEUTSCHE BANK TRADER IN A ONE-TO-ONE CHATROOM FROM OCTOBER 2009 TO JULY 2010. THE INFORMATION CONCERNED THE
ISSUING AND TRADING OF GILTS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):

02/21/2025
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 30,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
N/A
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
IN FEBRUARY 2025, HSBC HOLDINGS (AS PARENT) AND HSBC BANK PLC ACCEPTED THAT A SINGLE HSBC BANK PLC TRADER HAD SHARED
COMPETITVELY-SENSITIVE INFORMATION WITH DEUTSCHE BANK ON 12 OCCASSIONS OVER 2009-2010. HSBC HAS AGREED TO PAY A FINE OF
GBP £23.4M (APPROX USD $30M)
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN FEBRUARY 2025, HSBC HOLDINGS (AS PARENT) AND HSBC BANK PLC ACCEPTED THAT A SINGLE HSBC BANK PLC TRADER HAD SHARED
COMPETITVELY-SENSITIVE INFORMATION WITH DEUTSCHE BANK ON 12 OCCASSIONS OVER 2009-2010. HSBC HAS AGREED TO PAY A FINE OF GBP
£23.4M (APPROX USD $30M)