Hsbc Securities (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
No Information Filed
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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY
2.
Principal Sanction:
Other
Other Sanctions: 
OTHER TO INCLUDE THE FOLLOWING PRINCIPAL SANCTION: FINE, CENSURE AND UNDERTAKING.
3.
Date Initiated (MM/DD/YYYY): 
01/19/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2013035716601
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT UTILIZED AN ORDER MANAGEMENT SYSTEM (OMS)
WHICH ALLOWED THE FIRM TO DESIGNATE CERTAIN ACCOUNTS TO AUTOMATICALLY TRANSMIT TRADE VOLUME TO BLOOMBERG FOR ADVERTISEMENT. THE FINDINGS STATED THAT THE
FIRM OPENED A NUMBER OF ACCOUNTS WITH A DEFAULT SETTING THAT RESULTED IN CERTAIN TRADE ACTIVITY BEING SENT TO BLOOMBERG TWICE FOR ADVERTISING. THE FIRM'S
PROGRAMMING ERROR CAUSED IT TO OVER-ADVERTISE TRADE VOLUME EXECUTED IN AT LEAST 30 SEPARATE AFFECTED TRADING BOOKS. ONE OF THE FIRM'S TRADERS MANUALLY
ENTERED TRADE VOLUME IN CERTAIN SECURITIES FOR ADVERTISING ON BLOOMBERG. THOSE SECURITIES, HOWEVER, WERE ALSO BEING SENT TO BLOOMBERG FOR AUTOMATIC
ADVERTISING THROUGH THE FIRM'S OMS. BY VIRTUE OF THE TRADER'S ERRONEOUS MANUAL ADVERTISEMENTS, THE FIRM OVER-ADVERTISED ITS EXECUTED TRADE VOLUME. THE
FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE
APPLICABLE SECURITIES LAWS AND REGULATIONS, AND FINRA RULES, CONCERNING THE ADVERTISEMENT OF TRADE VOLUME.
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:
N/A
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
01/19/2017
 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: $ 575,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING: REQUIRED TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES
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: 
THE FIRM WAS CENSURED AND THE FIRM PAID A FINE ON FEBRUARY 15,2017 FOR $575,000, AND UNDERTAKES TO REVISE THE FIRM'S SUPERVISORY WRITTEN PROCEDURES. THE
MITIGATED MONETARY SANCTION IN THIS MATTER REFLECTS THE FIRM'S SELF-REPORTING OF THE OVER-ADVERTISING VIOLATIONS.
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).

SEE ABOVE

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 BANK USA. N.A.
(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 COMPTROLLER OF THE CURRENCY ("OCC")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/13/2011
 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 USA N.A.
6.
Principal Product Type:
Banking Products (Other than CD(s))
Other Product Types: 
RESIDENTIAL MORTGAGE SERVICING
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JANUARY 9, 2017, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC") ANNOUNCED THAT IT HAD TERMINATED ITS RESIDENTIAL MORTGAGE SERVICING RELATED CONSENT
ORDER AGAINST HSBC BANK USA, N.A. (THE "BANK"), A SUBSIDIARY OF HSBC USA INC. THE OCC TERMINATED THE CONSENT ORDER HAVING FOUND THAT THE BANK HAD SATISFIED ALL
OF THE REQUIREMENTS OF THE OCC'S ORIGINALLY ISSUED APRIL 2011 CONSENT ORDER, AND THE FEBRUARY 2013 AND JUNE 2015 AMENDMENTS THERETO. WITH TERMINATION OF THE
CONSENT ORDER, THE BUSINESS RESTRICTIONS IMPOSED BY THE OCC ON THE BANK PURSUANT TO THE JUNE 2015 AMENDMENT TO THE CONSENT ORDER ARE ALSO TERMINATED. THE
BANK WILL PAY A $32.5 MILLION CIVIL MONEY PENALTY TO THE U.S. TREASURY FOR DEFICIENCIES IN TIMELY COMPLIANCE WITH THE CONSENT ORDER, INCLUDING IDENTIFIED
DEFICIENCIES ON APPROXIMATELY 1,700 MORTGAGE LOAN ACCOUNTS RELATIVE TO PAYMENT CHANGE NOTIFICATIONS REQUIRED UNDER APPLICABLE BANKRUPTCY RULES. AN
ADDITIONAL CHARGE TO INCOME IN THE AMOUNT OF $27.5 MILLION WAS TAKEN BY THE BANK IN THE FOURTH QUARTER ENDED DECEMBER 31, 2016 RELATED TO THIS MATTER.
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):
01/09/2017
 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: $ 32,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
HSBC BANK USA N.A. IN ACCORDANCE WITH THE SETTLEMENT WILL PAY A FINE IN THE AMOUNT OF $32,500,000
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: 
N/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).
WITHOUT ADMITTING OR DENYING THE VIOLATIONS HSBC BANK USA N.A. IN ACCORDANCE WITH THE SETTLEMENT WILL PAY A FINE IN THE AMOUNT OF $32,500,000

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 HOLDINGS PLC
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 IS CURRENTLY CONSIDERING WHETHER TO APPEAL SUCH DECISION.

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):
12/07/2016
 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: $ 35,958,420.00
 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: 
HSBC HOLDINGS PLC. IN ACCORDANCE WITH THE SETTLEMENT WILL PAY A FINE IN THE AMOUNT OF 33,606,000, EUROS, SUBJECT TO A POSSIBLE APPEAL. THE FINE IS CONVERTED
TO $ 35,958,420 US DOLLARS 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).
WITHOUT ADMITTING OR DENYING THE VIOLATIONS, HSBC HOLDINGS PLC. IN ACCORDANCE WITH THE SETTLEMENT WILL PAY A FINE IN THE AMOUNT OF 33,606,000, EUROS, SUBJECT
TO A POSSIBLE APPEAL.

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
No Information Filed

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) 
NASD REGULATION, INC. ("NASD")
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/17/1999
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
C8A990038-AWC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Government
Other Product Types: 
DEBT CORPORATE, EQUITY-OTC, FUTURES-FINANCIAL, EQUITY LISTED(COMMON & PREFERRED STOCK)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD REGULATION, INC. ALLEGED THAT HSBC SECURITIES (USA) INC. VIOLATED: MARKETPLACE RULES 4632(A), 4620(A)AND 4642(A): MARKETPLACE RULES 4632(A), 6420(A) AND
4642(A); MARKETPLACE RULES 6130(D); CONDUCT RULE 3370; CONDUCT RULE 3360; CONDUCT RULE 2110; CONDUCT RULES 2110 AND 301(B).
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
05/03/1999
 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: $ 7,500.00
 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: 
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC WAS FINED $7,500.00.
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).

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
No Information Filed
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) 
STATE OF WISCONSIN (COMMISSIONER OF SECURITIES)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 

3.
Date Initiated (MM/DD/YYYY): 
06/25/1996
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
S-96053(L)
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Government
Other Product Types: 
DEBT CORPORATE, EQUITY-OTC, FUTURES-FINANCIAL, EQUITY LISTED(COMMON & PREFERRED STOCK)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
VIOLATION OF SECTION 551.63. OF THE WISCONSIN STATUES.
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):
07/24/1996
 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: $ 4,000.00
 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: 
HSBC SECURITIES (USA) INC. WAS ORDERED TO PAY $4,000.00 AS AN ADMINISTRATIVE ASSESSMENT PURSUANT TO SECTION 551.605 OF THE WISCONSIN STATUES.
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).

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
No Information Filed
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) 
NASD REGULATION, INC. ("NASD")
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/03/1996
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS960167
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Government
Other Product Types: 
DEBT CORPORATE, EQUITY OTC, FUTURES FINANCIAL, EQUITY LISTED (COMMON & PREFERRED)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED THAT ON JULY 22,23, 24, 19, AND 31, HSBC ENTERED QUOTATIONS IN THE NASDAQ STOCK MARKET SECURITIE, EXCEEDING THE PARMETERS FOR MAXINUM
ALLOWABLE SPREADS PURSUANT TO MARKETPLACE RULE 4613(D).
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):
07/11/1997
 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: $ 1,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, TO THE ENTRY OF FINDINGS BY NASD REGULATION, INC., HSBC SECURITIES, INC. AGREED TO PAY A FINE OF $1,000.00.
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).

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
No Information Filed
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) 
CHICAGO BOARD OF TRADE ("CBOT")
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/01/1998
 Exact
 Explanation
If not exact, provide explanation:
DATE INITIATED IS AN APPROXIMATE DATE.
4.
Docket/Case Number:
98-RFT-187
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
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):
THE CBOT ALLEGATED THAT HSBC VIOLATED REGULATION 332.08 IN THAT THE FIRM FAILED TO MAKE ALL TRADE DATA SUBMISSIONS IN A CORRECT MANNER.
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):
03/01/1999
 Exact
 Explanation
If not exact, provide explanation:
RESOLUTION DATE IS AN APPROXIMATE DATE.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 500.00
 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: 
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC WAS ORDERED TO PAY A FINE IN THE AMOUNT OF $500.00.
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).

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
No Information Filed
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) 
CHICAGO BOARD OF TRADE ("CBOT")
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/06/1998
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
98-INV-4A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:

Debt - Government
Other Product Types: 
DEBT CORPORATE, EQUITY OTC, FUTURES FINANCIAL, EQUITY LISTED (COMMON & PREFERRED STOCK)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
VIOLATION OF REGULATION 9B.16, BY VITUE OF REGULATION 9B.07 IN THAT PROJECT A TERMINAL OPERATORS EMPLOYED BY HSBC KNOWINGLY CAUSED TRANSACTIONS TO BE ENTERED
INTO THE PROJECT A SYSTEM IN WHICH A PROPRIETARY ACCOUNT ASSUME THE OPPOSITE SIDE OF CUSTOMER ORDERS AND THE PROPRIETARY ORDERS WERE ENTERED PRIOR TO THE
ORDERS; AND RULE 504.00, IN THAT, BY VIRTUE OF THE ABOVE-REFERENCE VIOLATION.
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):
02/26/1999
 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: $ 20,000.00
 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: 
WITHOUT ADMITTING OR DENYING ANY VIOLATION OF REGULATION 9B.16 AND RULE 504.00, AS CITED IN THE PRELIMINARY CHANGES, HSBC AGREED TO PAY A FINE OF $20,000 IN
SETTLEMENT OF THIS MATTER.
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).

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
No Information Filed
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) 
NASD REGULATION, INC.
2.
Principal Sanction:
Other
Other Sanctions: 
MONETARY SANCTION
3.
Date Initiated (MM/DD/YYYY): 
03/02/2001
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
COMPLAINT NUMBER CMS 020140
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
34 BACKING AWAY INCIDENTS DURING THE FOURTH QUARTER OF 2000.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
08/06/2002
 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: $ 10,000.00
 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: 
FINED $10,000.00.
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).

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
No Information Filed
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) 

NEW YORK STOCK EXCHANGE, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
10/29/2003
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
04-190
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
E:MAIL RETENTION
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FAILURE TO PRESERVE ELECTRONIC COMMUNICATION FOR A PERIOD OF THREE YEARS. FAILURE TO REASONABLY SUPERVISE OPERATIONAL AND TECHNOLOGICAL ACTIVES RELATING TO
RETENTION OF ELECTRONIC COMMUNICATIONS. NOT PROMPTLY REPORTING FAILURE TO RETAIN ELECTRONIC COMMUNICATIONS.
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:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
12/15/2004
 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: $ 500,000.00
 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: 
FINED $500,000.00. RESOLUTION DATE: 12/15/2004.
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).

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
No Information Filed
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) 
CHICAGO BOARD OF TRADE ("CBOT")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/14/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
06-MSI-34B
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED REGULATION 3242.01 IN THAT THE FIRM FAILED TO MAKE DELIVERY OF
CONTRACT GRADE TWO-YEAR U.S. TREASURY NOTES BY 1:00 P.M., CHICAGO TIME, ON DELIVERY DAY.

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:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
03/14/2007
 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: $ 60,000.00
 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: 
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED REGULATION 3242.01 IN THAT THE FIRM FAILED TO MAKE DELIVERY OF
CONTRACT GRADE TWO-YEAR U.S. TREASURY NOTES BY 1:00 P.M., CHICAGO TIME, ON DELIVERY DAY. HSBC WAS FINED $60,000.00.
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).

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
No Information Filed
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) 
CHICAGO BOARD OF TRADE ("CBOT")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/07/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
06-RFT-052
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED REGULATION 332.08. TRADE DATE FOR THE TRADE DATES OF OCTOBER 1, 2006
THROUGH DECEMBER 27, 2006 REFLECTED AN UNACCEPTABLE CTR ERROR RATE. HSBC WAS FINED $1,000.00.
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:
Other
11. Resolution Date (MM/DD/YYYY):
03/08/2007
 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: $ 1,000.00
 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: 
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED REGULATION 332.08. TRADE DATE FOR THE TRADE DATES OF OCTOBER
1, 2006 THROUGH DECEMBER 27, 2006 REFLECTED AN UNACCEPTABLE CTR ERROR RATE. HSBC WAS FINED $1,000.00.
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).

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
No Information Filed
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) 
NASD REGULATION, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 

06/12/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20060055677-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED THE FOLLOWING: SEC RULES 10B-10, 17A-3, A7A-4, 200(G) OF REGULATION SHO, 203(B)(1) OF REGULATION SHO, NASD RULES 3010, 3110, 6130, 6955(A) - HSBC
SECURITIES (USA) INC. ("HSBC") ACCEPTED SHORT SALE ORDERS IN AN EQUITY SECURITY FROM ANOTHER PERSON, OR AFFECTED A SHORT SALE IN AN EQUITY SECURITYFOR ITS OWN
ACCOUNT, WITHOUT DOCUMENTING THAT IT BORROWED THE SECURITY, OR ENTERED INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY, OR THAT IT HAD REASONABLE
GROUNDS TO BELIEVE THAT THE SECURITY COULD BE BORROWED SO THAT IT COULD BE DELIVERED ON THE DATE DELIVERY IS DUE. THE FINDINGS STATED THAT THE FIRM FAILED TO
CORRECTLY REPORT SALE TRANSACTIONS TO ACT AS LONG, SHORT OR SHORT EXEMPT, FAILED TO REPORT THE CORRECT EXECUTION TIME AND IN ONE INSTANCE, THE FIRM REPORTED
ITS CAPACITY AS PRINCIPAL WHEN IT WAS ACTING AS AGENT. THE FINDINGS ALSO STATED THAT THE FIRM REPORTED TO OATS EXECUTION REPORTS THAT CONTAINED INACCURATE,
INCOMPLETE OR IMPROPERLY FORMATTED DATA AND EXECUTED SHORT SALE ORDERS AND FAILED TO PROPERLY MARK THE ORDER TICKETS AS SHORT FOR THESE ORDERS. THE FINDINGS
ALSO INCLUDED THAT THE FIRM FAILED TO PRESERVE FOR A PERIOD OF NOT LESS THAN THREE YEARS, THE FIRST TWO IN AN ACCESSIBLE PLACE, THE MEMORANDUM OF BROKERAGE
ORDERS, A CUSTOMER CONFIRMATION AND FAILED TO SHOW THE TIME OF RECEIPT ON THE MEMORANDUM OF A BROKERAGE ORDER. THE NASD FOUND THAT THE FIRM FAILED TO
DISCLOSE THE CORRECT CAPACITY AND TO DISCLOSE AVERAGE PRICE ON CUSTOMER CONFIRMATIONS. THE NASD ALSO FOUND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT
PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES RELATING TO COMPLIANCE
WITH ORDER HANDLING, BEST EXECUTION, ANTI-INTIMIDATION AND COORDINATION, SALES TRANSACTIONS, BOOKS AND RECORDS AND FOR MONITORING USE OF FIRM'S BANK.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/12/2007
 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: $ 27,500.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC SECURITIES (USA) INC. ("HSBC"), CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC
WAS CENSURED AND FINED $27,500.00.
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).
THE NASD ALLEGED THE FOLLOWING: SEC RULES 10B-10, 17A-3, A7A-4, 200(G) OF REGULATION SHO, 203(B)(1) OF REGULATION SHO, NASD RULES 3010, 3110, 6130, 6955(A) - HSBC
SECURITIES (USA) INC. ("HSBC") ACCEPTED SHORT SALE ORDERS IN AN EQUITY SECURITY FROM ANOTHER PERSON, OR AFFECTED A SHORT SALE IN AN EQUITY SECURITYFOR ITS OWN
ACCOUNT, WITHOUT DOCUMENTING THAT IT BORROWED THE SECURITY, OR ENTERED INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY, OR THAT IT HAD REASONABLE
GROUNDS TO BELIEVE THAT THE SECURITY COULD BE BORROWED SO THAT IT COULD BE DELIVERED ON THE DATE DELIVERY IS DUE. THE FINDINGS STATED THAT THE FIRM FAILED TO
CORRECTLY REPORT SALE TRANSACTIONS TO ACT AS LONG, SHORT OR SHORT EXEMPT, FAILED TO REPORT THE CORRECT EXECUTION TIME AND IN ONE INSTANCE, THE FIRM REPORTED
ITS CAPACITY AS PRINCIPAL WHEN IT WAS ACTING AS AGENT. THE FINDINGS ALSO STATED THAT THE FIRM REPORTED TO OATS EXECUTION REPORTS THAT CONTAINED INACCURATE,
INCOMPLETE OR IMPROPERLY FORMATTED DATA AND EXECUTED SHORT SALE ORDERS AND FAILED TO PROPERLY MARK THE ORDER TICKETS AS SHORT FOR THESE ORDERS. THE FINDINGS
ALSO INCLUDED THAT THE FIRM FAILED TO PRESERVE FOR A PERIOD OF NOT LESS THAN THREE YEARS, THE FIRST TWO IN AN ACCESSIBLE PLACE, THE MEMORANDUM OF BROKERAGE
ORDERS, A CUSTOMER CONFIRMATION AND FAILED TO SHOW THE TIME OF RECEIPT ON THE MEMORANDUM OF A BROKERAGE ORDER. THE NASD FOUND THAT THE FIRM FAILED TO
DISCLOSE THE CORRECT CAPACITY AND TO DISCLOSE AVERAGE PRICE ON CUSTOMER CONFIRMATIONS. THE NASD ALSO FOUND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT

PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES RELATING TO COMPLIANCE
WITH ORDER HANDLING, BEST EXECUTION, ANTI-INTIMIDATION AND COORDINATION, SALES TRANSACTIONS, BOOKS AND RECORDS AND FOR MONITORING USE OF FIRM'S BANK.

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
No Information Filed
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) 
NASD REGULATION INC. ("NASD")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/27/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20050026982-01

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
NO PRODUCT TYPE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD REGULATION INC. ("NASD") ALLEGED THAT HSBC SECURITIES (USA) INC. VIOLATED NASD RULE 2110 - RESPONDENT MEMBER FAILED WITHIN 90 SECONDS AFTER EXECUTION
TO TRANSMIT TO THE NASDAQ MARKET CENTER (NMC) LAST SALE REPORTS OF TRANSACTION IN CQS SECURITIES.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
07/27/2007
 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: $ 5,000.00
 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: 
THE NASD REGULATION INC. ("NASD") ALLEGED THAT HSBC SECURITIES (USA) INC. VIOLATED NASD RULE 2110 - RESPONDENT MEMBER FAILED WITHIN 90 SECONDS AFTER
EXECUTION TO TRANSMIT TO THE NASDAQ MARKET CENTER (NMC) LAST SALE REPORTS OF TRANSACTION IN CQS SECURITIES.
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).
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC SECURITIES (USA) INC. WAS FINED $5,000.00.

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
No Information Filed
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) 
NEW YORK STOCK EXCHANGE REGULATION - DIVISION OF ENFORCEMENT
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE AND UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
07/27/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NYSE HEARING BOARD DECISION 07-150
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
CALLABLE RANGE ACCRUAL CERTIFICATES OF DEPOSIT.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
(1) VIOLATION OF NYSE RULE 476(A)(6) FOR ENGAGING IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE BY: (A) RECOMMENDING AND SELLING LIBOR CDS
TO CUSTOMERS FOR WHOM SUCH PRODUCTS WERE UNSUITABLE; (B) FAILING TO ACCURATELY ADVISE CUSTOMERS ABOUT THE RISKS ASSOCIATED WITH THE LIBOR CDS; AND/OR (C)
MAKING MATERIAL MISREPRESENTATIONS REGARDING CERTAIN MATERIAL FEATURES OF THE LIBOR CDS AND/OR THE MANNER IN WHICH THE PRODUCTS WERE LIKELY TO PERFORM. (2)
VIOLATION OF NYSE RULE 401(A) BY FAILING TO ADHERE TO PRINCIPLES OF GOOD BUSINESS PRACTICE BY RECOMMENDING AND SELLING THE LIBOR CD PRODUCTS TO CLIENTS FOR
WHOM THEY WERE NOT SUITABLE. (3) VIOLATION OF NYSE RULE 342(A) AND (B) BY: (A) FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES TO REASONABLY SUPERVISE
WHETHER THE SALE OF CALLABLE LIBOR CDS WERE SUITABLE FOR ITS CUSTOMERS, AND (B) FAILING TO ADEQUATELY SUPERVISE ITS PERSONNEL IN ORDER TO REASONABLY DETECT
AND PREVENT MISREPRESENTATIONS REGARDING MATERIAL FEATURES OF LIBOR CDS, AND/OR THE MANNER IN WHICH THEY WERE LIKELY TO PERFORM.
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:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
10/08/2007
 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: $ 500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE FIRM MUST ENGAGE IN AN UNDERTAKING REQUIRING THE FIRM TO REVIEW THE PURCHASES OF THE OUTSTANDING LIBOR CDS (THAT EXISTED AS OF JUNE 1, 2007) AND OFFER
A REMEDIATION PLAN REVIEWED AND APPROVED BY NYSE ENFORCEMENT, IN ACCORDANCE WITH THE TERMS OF THE STIPULATION AND CONSENT TO PENALTY.
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: 
CENSURE AND FINE IN THE AMOUNT OF $500,000 AND AN UNDERTAKING REQUIRING THE FIRM TO REVIEW THE PURCHASES OF THE OUTSTANDING LIBOR CDS (THAT EXISTED AS OF
JUNE 1, 2007) AND OFFERA REMEDIATION PLAN, REVIEWED AND APPROVED BY NYSE ENFORCEMENT, IN ACCORDANCE WITH THE TERMS OF THE STIPULATION AND COSENT TO
PENALTY.
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).
THE NYSE HEARING BOARD RENDERED A DECISION ON SEPTEMBER13, 2007 WITH REGARD TO THE STIPULATION OF FACTS AND CONSENT TO PENALTY ENTERED INTO BETWEEN THE FIRM
AND THE DIVISION OF ENFORCEMENT OF NYSE REGULATION. THE DECISION BECAME FINAL AT THE CLOSE OF BUSINESS ON OCTOBER 8, 2007. THE FIRM MUST OFFER ITS REMEDIATION
PLAN TO NYSE ENFORCEMENT WITHIN 30 DAYS OF THE THE DATE ON WHICH THE DECISION BECAME FINAL. THE FIRM IS REQUIRED TO PAY ITS FINE WITHIN 45 DAYS OF THE DATE ON
WHICH THE DECISION BECAME FINAL.

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
No Information Filed
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) 
CHICAGO BOARD OF TRADE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/19/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
07-MSR-05
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
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):
CHICAGO BOARD OF TRADE ALLEGES THAT HSBC SECURITIES (USA) INC. (A) ENGEGED IN THE EXECUTION OF AN EFP TRANSACTION WITHOUT A BONA FIDE CASH COMPONENT AND (B)
THE FIRM EXECUTED TWO CONTINGENT EFP TRANSACTIONS,, IN WHICH THE CASH EXCHAGED CORRELATED TO THE NET OF TWO FUTURES TRANSACTIONS.
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):
09/22/2007
 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: $ 30,000.00
 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: 
HSBC SECURITIES (USA) INC. WAS FINED IN THE AMOUNT OF $30,000. THE FIRM WAS REQUIRED TO PAY ITS FINE WITHIN 30 DAYS OF THE DATE ON WHICH THE DECISION BECAME
FINAL.
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 ORDER TO ENSURE THAT THE TRADING STAFF ("THE STAFF") ARE KNOWLEDGEABLE ABOUT CBOT EFP RULES, THE FIRM HAS IMPLETMENTED AN EFP TRAINING.

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY/FINE.
3.
Date Initiated (MM/DD/YYYY): 

05/14/2008
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2007009471401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
FIXED INCOME SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGES THAT HSBC SECURITIES (USA) INC. VIOLATED NASD RULES 2110 AND 3010. DURING THE PERIOD JANUARY 2004 THROUGH JUNE 2006, CUSTOMERS WHO MAINATINED
ESCROW ACCOUNTS WITH THE FIRM'S BANK AFFILIATE WERE CHARGED COMMISSIONS FOR FIXED INCOME SECURITIES TRADES EXECUTED BY THE FIRM ON THEIR BEHALF, WHICH WERE
HIGHER THAN THE COMMISSIONS THEY WERE CHARGED IN THE PAST AND IN CERTAIN INSTANCES, HIGHER THAN INDUSTRY STANDARDS. THE FIRM FAILED TO TAKE ADEQUATE STEPS TO
ASSESS THE FAIRNESS OF THE COMMISSIONS. THE FIRM LACKED ADQUATE WRITTEN GUIDELINES FOR MARK-UPS AND COMMISSIONS ON TRADES FOR FIXED INCOME PRODUCTS, AND
ALSO FAILED TO ESTABLISH AND MAINTAIN ADQUATE PROCEDURES TO MONITOR THE APPROPRIATENESS OF COMMISSIONS CHARGED THESE CUSTOMERS IN THAT THE FIRM (A) FAILED
TO ESTABLISH ADEQUATE WRITTEN GUIDELINES FOR MARK-UPS AND COMMISSIONS ON FIXED INCOME PRODUCTS (B) FAILED TO GIVE ADEQUATE GUIDANCE IN REFERENCE TO
DETRMINING WHAT IS A FAIR MARK-UP OR COMMISSION ON FIXED INCOME PRODUCTS (C) FAILED TO INCLUDE TRADES EXECUTED FOR CUSTOMERS IN BRANCH EXAMINATION REVIEWS
(D) FAILED TO ESTABLISHED REASONABLE PROCEDURES FOR MONITORING FIXED INCOME SECURITY MARK-UPS AND COMMISSIONS.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
05/14/2008
 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: $ 200,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC SECURITIES (USA) INC. WAS CENSURED AND FINED $200,000.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY/FINE.
3.
Date Initiated (MM/DD/YYYY): 
03/19/2008
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20060059732-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
TRACE-ELIGIBLE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGES THAT HSBC SECURITIES VIOLATED SEC RULE 17A-3, NASD RULES 2110, 6230(A), 6230(C)(8) - FAILURE TO REPORT TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES
EXECUTED ON A BUSINESS DAY DURING TRACE SYSTEM HOURS WITHIN 15 MINUTES OF THE TIME OF EXECUTION; FAILED TO REPORT THE CORRECT TIME OF TRADER EXECUTION FOR
TRACE-ELIGIBLE SECURITIES; FAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OF TRACE-ELIGIBLE SECURITIES ORDERS.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
03/19/2008
 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: $ 12,500.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC SECURITIES (USA) INC.("HSBC")WAS CENSURED AND FINED $12, 500.00.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 
02/02/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2007007234501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
TRACE-ELIGIBLE SECURITIES, MUNICIPAL SECURITIES SUBJECT TO MSRB REPORTING REQUIREMENTS, COVERED OPTIONS CONTRACTS.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGES THAT HSBC SECURITIES (USA) INC. ("HSBC")VIOLATED ARTICLE VI, SECTION 2 AND SCHEDULE A, SECTION 1 OF THR NASD BY LAWS AND NASD RULE 2110: FAILURE TO
INCLUDE TRANSACTIONS FOR CERTAIN COVERED SECURITIES, SUCH AS TRACE-ELIGIBLE SECURITIES, MUNICIPAL SECURITIES SUBJECT TO MSRB REPORTING REQUIREMENTS AND
COVERED OPTIONS CONTRACTS, ON ITS TRADING ACTIVITY FEE SELF-REPORTING FORMS FOR CERTAIN ACCOUNTS BETWEEN SEPTEMBER 2003 AND DECEMBER 2006. AS A RESULT, THE
REQUIRED TRADING ACTIVITY FEES WERE NOT PAID FOR THESE TRANSACTIONS, SPECIFICALLY, DURING THIS PERIOD HSBC UNDERPAID APPROXIMATELY $28,00.000 IN TRADING
ACTIVITY FEES. ONCE THE ERROR WAS DISCOVERED BY HSBC, HSBC SUBSEQUENTLY SUBMITTED CORRECT TRADING ACTIVITY FEE SELF-REPORTING FORMS AND LATER SUBMITTTED
AMENDED FORMS AND THE ADDITIONAL FEES TO CORRECT THE PREVIOUS ERRORS.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
02/02/2009
 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: $ 5,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC SECURITIES (USA) INC. WAS FINED $5,000.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY/FINE.

3.
Date Initiated (MM/DD/YYYY): 
04/30/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2007011232101
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
TRACE-ELIGIBLE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASD RULES 2110, 6230(A) - FINRA ALLEGES THAT HSBC SECURITIES (USA) INC. FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN
TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD RULE 6230(A) AND A
PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE 2110.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
04/30/2009
 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: $ 20,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS,HSBC SECURITIES (USA) INC.CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC SECURITIES
(USA)INC. WAS SENSURED AND FINED $20,000.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
01/20/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20080127719-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
NO PRODUCT
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA)INC. ("HSBC") VIOLATED RULE 6955(A): HSBC FAILED TO TIMELY REPORT TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER
EVENTS.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
01/20/2010
 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: $ 12,500.00
 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: 
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC WAS FINED $12,500.00.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
04/22/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2008013863801
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT DURING THE PERIOD FROM MAY 31, 2006 THROUGH FEBRUARY 28, 2008 ("RELEVANT PERIOD"), EXCEPT AS OTHERWISE NOTED, HSBC SECURITIES VIOLATED
CERTAIN NASD, FINRA, AND MSRB RULES BY (1) MAKING NEGLIGENT MISREPRESENTATIONS AND OMISSIONS OF MATERIAL FACTS TO CUSTOMERS CONCERNING THE SAFETY AND
LIQUIDITY OF AUCTION RATE SECURITIES ("ARS"); (2) USING ADVERTISING AND MARKETING MATERIALS THAT WERE NOT FAIR AND BALANCED AND DID NOT PROVIDE A SOUND BASIS FOR
EVALUATING THE FACTS ABOUT PURCHASING ARS; (3) SELLING RESTRICTED, AND THEREFORE UNSUITABLE, ARS TO CERTAIN NON-QUALIFIED CUSTOMERS; (4) FAILING TO RETAIN
CERTAIN EMAILS FROM MAY 2004 TO APRIL 2009, AND FAILING TO RETAIN CERTAIN INTERNAL INSTANT MESSAGES FROM FEBRUARY 2007 TO SEPTEMBER 2008; AND (5) FAILING TO
MAINTAIN ADEQUATE SUPERVISORY PROCEDURES CONCERNING ITS SALES AND MARKETING ACTIVITIES REGARDING ARS AND ITS RETENTION OF CERTAIN EMAILS AND INSTANT
MESSAGES.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
04/22/2010
 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: $ 1,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension

B.
Other Sanctions Ordered:
REPURCHASE OFFER
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: 
WITHOUT ADMITTING OR DENYING FINRA'S FINDINGS AND WITHOUT ADJUDICATION OF ANY ISSUE OF LAW OR FACT, HSBC SECURITIES CONSENTED, SOLELY FOR THE PURPOSE OF
THIS PROCEEDING, TO THE ENTRY OF FINRA'S FINDINGS AND THE FOLLOWING SANCTIONS: A CENSURE AND FINE IN THE AMOUNT OF $1.5 MILLION; OFFERING TO REPURCHASE
ELIGIBLE ARS FROM INVESTORS IN THE RELEVANT CLASS; MAKING BEST EFFORTS TO PROVIDE LIQUIDITY TO INVESTORS WHO PURCHASED ARS DURING THE RELEVANT PERIOD BUT
WHO WERE NOT IN THE RELEVANT CLASS; FOR ANY INVESTOR IN THE RELEVANT CLASS WHO SOLD ELIGIBLE ARS BELOW PAR BETWEEN CERTAIN DATES, PAYING THE DIFFERENCE
BETWEEN PAR AND THE SALE PRICE; ARBITRATING CLAIMS FOR CONSEQUENTIAL DAMAGES FILED BY ELIGIBLE INVESTORS IN THE RELEVANT CLASS UNDER FINRA'S SPECIAL
ARBITRATION PROCEDURES; AND PROVIDING FINRA WITH CERTAIN REPORTS. THE SPECIFIC TERMS OF THE REPURCHASE OFFER ARE DEFINED IN THE AWC.
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 DETERMINING THE SANCTIONS IN THIS MATTER, FINRA TOOK INTO ACCOUNT HSBC SECURITIES' VOLUNTARY REMEDIATION TO CUSTOMERS PRIOR TO THE ENTRY OF THE AWC, WHICH
INCLUDED HSBC SECURITIES' VOLUNTARY REPURCHASE OF ARS FROM ITS CUSTOMERS IN 2008. AS OF JULY 2008, HSBC SECURITIES REPURCHASED MORE THAN 90 PERCENT OF ITS THEN
CURRENT CUSTOMERS' ARS HOLDINGS AND IN OCTOBER 2008 OFFERED TO REPURCHASE ALL OF THE REMAINING ARS HELD IN THOSE CUSTOMERS' HSBC SECURITIES ACCOUNTS.

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
06/10/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2007010582702
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
COLLATERALIZED MORTAGE OBLIGATION ("CMOS")
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MAY 20, 2010, THE FIRM SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT IN WHICH HSI, WITHOUT ADMITTING OR DENYING GUILT, CONSENTED TO FINDINGS THAT IT:
(1) VIOLATED NASD CONDUCT RULES 3010(A) AND (B) AND 2110 BY (A) FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN PROCEDURES REGARDING THE SALE
OF CMOS TO CUSTOMERS THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND WITH FINRA RULES; AND (B)
FAILING TO ESTABLISH AND MAINTAIN A SYSTEM OF WRITTEN PROCEDURES REASONABLY DESIGNED TO SUPERVISE WHETHER THE SALES OF CMOS WERE SUITABLE FOR ITS CUSTOMERS
AND THE ATTENDED RISKS OF THE PRODUCTS WERE FULLY EXPLAINED WHENEVER A REGISTERED REPRESENTATIVE RECOMMENDED A CMO INVESTMENT; (2) DID NOT COMPLY WITH
NASD IM-2210-8 WHICH REQUIRES FIRMS TO OFFER CERTAIN EDUCATIONAL MATERIALS BEFORE THE SALE OF A CMO TO ANY PERSON OTHER THAN AN INSTITUTIONAL INVESTOR AND
WHILE THE FIRM DID OFFER A BROCHURE, THE BROCHURE DID NOT COMPLY WITH THE CONTENTS STANDARDS OF NASD CONDUCT RULE 2210(D)(1) AND IM-2210-8; AND (3) VIOLATED
NASD CONDUCT RULE 2310 AND 2110 BY RECOMMENDING AND SELLING INVERSE FLOATER CMOS TO CUSTOMERS FOR WHOM SUCH PRODUCTS WERE UNSUITABLE. HSI CONSENTED TO
THE IMPOSITION BY FINRA OF A SANCTION OF A CENSURE AND A $375,000 FINE. FINRA ACKNOWLEDGED THAT, INDEPENDENT OF THE IMPOSED SANCTION, IMPACTED CUSTOMERS HAVE
RECEIVED FULL RESTITUTION FROM THE FIRM.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/10/2010
 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: $ 375,000.00
 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: 
ON MAY 20, 2010, THE FIRM SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT IN WHICH HSI, WITHOUT ADMITTING OR DENYING GUILT, CONSENTED TO FINDINGS
THAT IT: (1) VIOLATED NASD CONDUCT RULES 3010(A) AND (B) AND 2110 BY (A) FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN PROCEDURES
REGARDING THE SALE OF CMOS TO CUSTOMERS THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND WITH
FINRA RULES; AND (B) FAILING TO ESTABLISH AND MAINTAIN A SYSTEM OF WRITTEN PROCEDURES REASONABLY DESIGNED TO SUPERVISE WHETHER THE SALES OF CMOS WERE

SUITABLE FOR ITS CUSTOMERS AND THE ATTENDED RISKS OF THE PRODUCTS WERE FULLY EXPLAINED WHENEVER A REGISTERED REPRESENTATIVE RECOMMENDED A CMO
INVESTMENT; (2) DID NOT COMPLY WITH NASD IM-2210-8 WHICH REQUIRES FIRMS TO OFFER CERTAIN EDUCATIONAL MATERIALS BEFORE THE SALE OF A CMO TO ANY PERSON
OTHER THAN AN INSTITUTIONAL INVESTOR AND WHILE THE FIRM DID OFFER A BROCHURE, THE BROCHURE DID NOT COMPLY WITH THE CONTENTS STANDARDS OF NASD CONDUCT
RULE 2210(D)(1) AND IM-2210-8; AND (3) VIOLATED NASD CONDUCT RULE 2310 AND 2110 BY RECOMMENDING AND SELLING INVERSE FLOATER CMOS TO CUSTOMERS FOR WHOM
SUCH PRODUCTS WERE UNSUITABLE. HSI CONSENTED TO THE IMPOSITION BY FINRA OF A SANCTION OF A CENSURE AND A $375,000 FINE. FINRA ACKNOWLEDGED THAT,
INDEPENDENT OF THE IMPOSED SANCTION, IMPACTED CUSTOMERS HAVE RECEIVED FULL RESTITUTION FROM THE FIRM.
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).

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
No Information Filed
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) 
NASD REGULATION INC. ("NASD")
2.
Principal Sanction:
Censure
Other Sanctions: 
FINED; DISGORGEMENT/RESTITUTION; UNDERTAKING.

3.
Date Initiated (MM/DD/YYYY): 
01/17/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20050001900
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Government
Other Product Types: 
DEBT - MUNICIPAL;DEBT - CORPORATE; EQUITY - OTC; EQUITY LISTED (COMMON & PREFERRED STOCK); FUTURES - FINANCIAL; INSURANCE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD REGULATION, INC. ("NASD") ALLEGED THAT HSBC SECURITIES (USA) INC. F/K/A HSBC BROKERAGE (USA) INC. VIOLATED RULE G-30 AND SUPERVISION VIOLATION OF RULE G-
27.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
01/17/2007
 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: $ 17,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC SECURITIES (USA) INC. WAS CENSURED AND FINED $17,500.00, REQUIRED TO PAY $1329.53, PLUS INTEREST, IN
RESTITUTION TO PUBLIC CUSTOMERS AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING FAIR PRICING AND MARKUPS WITHIN THIRTY (30) DAYS OF
ACCEPTANCE OF THIS AWC BY NAC. A REGISTERED PRINCIPAL OF THE FIRM WILL SUBMIT SATISFACTORY PROFF OF PAYMENT OF THE RESTITUTION OT OF REASONABLE AND
DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO NASD NO LATER THAN 60 DAYS AFTER ACCEPTANCE OF THIS AWC. ANY UNDISTRIBUTED RESTITUTION AND
INTEREST WILL BE FORWARDED TO THE APPROPRIATE ECCHEAT, UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LAST RESIDED.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
CENSURED AND FINED.
3.
Date Initiated (MM/DD/YYYY): 
08/19/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2008015260101
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED NASD RULES 2110, 4632, 4632(A) 6130(D): THE FIRM FAILED WITHIN 90 SECONDS AFTER EXECUTION TO
TRANSMIT TO THE FIRM/NASDAQ TRADE REPORTING FACILITY (FINRA/NASDAQ TRF)105 LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES. THE FIRM REPORTED TO THE
FINRA/NASDAQ TRF 23 LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES IT WAS NOT REQUIRED TO REPORT. THE FIRM FAILED TO REPORT TO THE FINRA/NASDAQ TRF
THE CORRECT TIME OF EXECUTION FOR 79 TRANSACTIONS IN REPORTABLE SECURITIES.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
08/19/2010
 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: $ 22,500.00
 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: 
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC WAS FINED $22,500.00.
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).

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 BANK USA, N.A.
(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) 
OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC")
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/06/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AA-EC-10-98
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK USA, N.A.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMPTROLLER OF THE CURRENCY OF THE UNITED STATES OF AMERICA ("COMPTROLLER"), THROUGH HIS NATIONAL BANK EXAMINERS AND OTHER STAFF OF THE OFFICE OF THE
COMPTROLLER OF THE CURRENCY ("OCC"), CONDUCTED AN EXAMINATION AND INVESTIGATION OF THE PAYMENTS AND CASH MANAGEMENT ("PCM"), GLOBAL BANKNOTES, AND FOREIGN
CORRESPONDENT OPERATIONS OF HSBC BANK USA, N.A., MCLEAN, VIRGINIA ("BANK"). THE OCC HAS IDENTIFIED DEFICIENCIES IN THE BANK'S INTERNAL CONTROLS FOR THESE AREAS
AS WELL AS ITS OVERALL PROGRAM FOR BANK SECRECY ACT/ANTI-MONEY LAUNDERING ("BSA/AML") COMPLIANCE.
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):
10/06/2010
 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: $
 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: 
CONSENT CEASE AND DESIST ORDER ISSUED BY THE COMPTROLLER OF THE CURRENCY OF THE UNITED STATES OF AMERICA THROUGH HIS NATIONAL BANK EXAMINERS AND OTHER
STAFF OF THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC"). THE BANK COMMITTED TO TAKING ALL NECESSARY STEPS TO REMEDY THE DEFICIENCIES IDENTIFIED BY
THE OCC, AND ENHANCE THE BANK'S BSA/AML COMPLIANCE PROGRAM.
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).
THE OCC CONDUCTED AN EXAMINATION AND INVESTIGATION OF THE PCM, GLOBAL BANKNOTES, AND FOREIGN CORRESPONDENT OPERATION OF THE BANK AND IDENTIFIED THE
FOLLOWING AS CORRECTIVE ACTIONS TO BE TAKEN: COMPLIANCE COMMITTEE - THE BOARD SHALL MAINTAIN A COMPLIANCE COMMITTEE OF AT LEAST THREE (3) DIRECTORS, OF WHICH
AT LEAST TWO (2) MAY NOT BE EMPLOYEES OR OFFICERS OF THE BANK OR ANY OF ITS SUBSIDIARIES OR AFFILIATES. THE COMMITTEE SHALL BE RESPONSIBLE FOR MONITORING AND
COORDINATING THE BANK'S ADHERENCE TO THE PROVISIONS OF THE ORDER. COMPREHENSIVE BSA/AML ACTION PLAN - WITHIN 60 DAYS OF THE ORDER, THE BANK SHALL SUBMIT TO
THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE A PLAN CONTAINING A COMPLETE DESCRIPTION OF THE ACTIONS THAT ARE NECESSARY AND APPROPRIATE TO ACHIEVE FULL
COMPLIANCE WITH THE ORDER. MANAGEMENT - WITHIN FIFTEEN (15) DAYS OF THE ORDER, THE BOARD SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND EXAMINER-IN-CHARGE A PLAN
TO RECRUIT, HIRE, APPOINT, AND RETAIN A QUALIFIED, PERMANENT REGIONAL COMPLIANCE OFFICER AND A QUALIFIED, PERMANENT BSA OFFICER. REVIEW OF BSA COMPLIANCE
PROGRAM - WITHIN TEN (10) DAYS OF THE ORDER, THE BANK SHALL RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT AN INDEPENDENT REVIEW OF THE BANK'S BSA/AML
COMPLIANCE PROGRAM. BSA COMPLIANCE PROGRAM - WITHIN 90 DAYS OF THE ORDER, THE BOARD AND EXECUTIVE MANAGEMENT SHALL ENSURE THAT A BSA/AML PROGRAM IS IN PLACE
WHICH MEETS SPECIFIC CRITERIA OUTLINED IN THE ORDER. MANAGEMENT INFORMATION - WITHIN 90 DAYS OF THIS ORDER, THE BOARD SHALL ENSURE THAT BANK MANAGEMENT
CONDUCTS A MANAGEMENT INFORMATION SYSTEM ASSESSMENT, AND DEVELOPS A PLAN THAT WILL ENABLE MANAGEMENT TO MORE EFFECTIVELY IDENTIFY, MONITOR, AND MANAGE THE
BANK'S BSA RISKS ON A TIMELY BASIS. CDD AND EDD INFORMATION - THE BANK SHALL DEVELOP AND IMPLEMENT APPROPRIATE POLICIES AND PROCEDURES FOR GATHERING CUSTOMER
DUE DILIGENCE AND ENHANCED DUE DILIGENCE INFORMATION. MONITORING - WITHIN 60 DAYS OF THE ORDER, THE BANK SHALL SUBMIT REVISED POLICIES AND PROCEDURES FOR
WIRE MONITORING USING ITS CURRENT WIRE MONITORING SYSTEM TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE. SUSPICIOUS ACTIVITY REPORTING - THE BANK SHALL
DEVELOP AND MAINTAIN A WRITTEN PROGRAM OF POLICIES AND PROCEDURES TO ENSURE, PURSUANT TO 12 C.F.R. § 21.11, THE TIMELY AND APPROPRIATE REVIEW AND
DISPOSITIONING OF SUSPICIOUS ACTIVITY ALERTS, AND THE TIMELY FILING OF SARS. ACCOUNT/TRANSACTION ACTIVITY REVIEW ("LOOK-BACK") - THE BANK SHALL RETAIN ON OR MORE
INDEPENDENT CONSULTANTS TO CONDUCT AN INDEPENDENT REVIEW OF ACCOUNT AND TRANSACTION ACTIVITY ("LOOK-BACK") COVERING AREAS TO BE SPECIFIED IN WRITING BY THE
EXAMINER-IN-CHARGE. RESTRICTIONS ON GROWTH, NEW PRODUCTS AND HIGH-RISK LINES OF BUSINESS - THE BANK INFORMED THE OCC THAT IT IS EXITING THE GLOBAL BANKNOTES
LINE OF BUSINESS FOR NON-DOMESTIC CUSTOMERS. IF, IN THE FUTURE, THE BANK INTENDS TO RE-ENTER THE INTERNATIONAL BULK CASH LINE OF BUSINESS, THE BANK SHALL NOTIFY
THE EXAMINER-IN-CHARGE OF ITS PLAN IN WRITING AND OBTAIN WRITTEN SUPERVISORY NON-OBJECTION PRIOR TO COMMENCING RE-ENTRY. REMOTE DEPOSIT CAPTURE - THE BANK
SHALL ESTABLISH CONTROLS, COMMENSURATE WITH ITS BSA/AML RISK, OVER THE USAGE OF RDC BY FOREIGN CORRESPONDENT CUSTOMERS, AND THE BANK'S MONITORING OF RDC
TRANSACTIONS. BSA TRAINING - WITHIN 90 DAYS OF THIS ORDER, THE BANK SHALL DEVELOP, IMPLEMENT, AND THEREAFTER ADHERE TO A COMPREHENSIVE TRAINING PROGRAM FOR ALL
APPROPRIATE OPERATIONAL AND SUPERVISORY PERSONNEL TO ENSURE THEIR AWARENESS OF THEIR RESPONSIBILITY FOR COMPLIANCE WITH THE REQUIREMENTS OF THE OFFICE OF
FOREIGN ASSETS CONTROL ("OFAC") AND THE BSA, INCLUDING REPORTING REQUIREMENTS ASSOCIATED WITH SARS, PURSUANT TO 12 C.F.R. PART 21, SUBPART B, REGARDLESS OF THE
SIZE OF THE RELATIONSHIP OR TYPE OF CUSTOMER INVOLVED. BSA INDEPENDENT TESTING AND AUDIT - THE BANK SHALL DEVELOP AND MAINTAIN AN EFFECTIVE PROGRAM TO AUDIT
THE BANK'S BSA/AML COMPLIANCE PROGRAM.

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 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) 
FEDERAL RESERVE BANK OF CHICAGO
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/04/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
10-202-B-HC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC NORTH AMERICA HOLDINGS, INC.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FEDERAL RESERVE BANK OF CHICAGO (THE "RESERVE BANK") REVIEWED AND ASSESSED THE EFFECTIVENESS OF HSBC NORTH AMERICA HOLDINGS, INC'S. ("HNAH") CORPORATE
GOVERNANCE AND COMPLIANCE RISK MANAGEMENT PRACTICES, POLICIES, AND INTERNAL CONTROLS, AND IDENTIFIED DEFICIENCIES. HNAH AND THE BOARD OF GOVERNORS MUTUALLY
AGREED TO ENTER INTO A CONSENT CEASE AND DESIST ORDER (THE "ORDER"). PURSUANT TO SECTIONS 8(B)(1) AND (3) OF THE FDI ACT (12U.S.C. §§1818(B)(1) AND 1818(B)(3)), HNAH
AND ITS INSTITUTION-AFFILIATED PARTIES SHALL CEASE AND DESIST AND TAKE AFFIRMATIVE ACTION WITH RESPECT TO THE DEFICIENCIES DOCUMENTED IN THE 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):
10/04/2010
 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: $
 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: 
CONSENT CEASE AND DESIST ORDER REQUIRING COMPLIANCE WITH THE PROVISIONS LISTED IN THE SUMMARY SECTION OF THIS DRP.
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).
THE RESERVE BANK REVIEWED AND ASSESSED THE EFFECTIVENESS OF HNAH'S CORPORATE GOVERNANCE AND COMPLIANCE RISK MANAGEMENT PRACTICES, POLICIES, AND INTERNAL
CONTROLS, AND IDENTIFIED THE FOLLOWING AS CORRECTIVE ACTIONS TO BE TAKEN: SOURCE OF STRENGTH - THE BOARD OF DIRECTORS OF HNAH SHALL TAKE STEPS TO FULLY UTILIZE
HNAH'S FINANCIAL AND MANAGERIAL RESOURCES, PURSUANT TO SECTION 225.4(A) OF REGULATION Y OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (12 C.F.R.
§225.4(A)), TO SERVE AS A SOURCE OF STRENGTH TO THE BANKS. BOARD OVERSIGHT - WITHIN 30 DAYS OF THE ORDER, HNAH'S BOARD OF DIRECTORS SHALL SUBMIT TO THE RESERVE
BANK AN ACCEPTABLE WRITTEN PLAN TO STRENGTHEN BOARD OVERSIGHT OF HNAH'S COMPLIANCE RISK MANAGEMENT PROGRAM. REGIONAL COMPLIANCE OFFICER - WITHIN 60 DAYS OF
THE ORDER, HNAH'S BOARD OF DIRECTORS SHALL TAKE SUCH ACTIONS AS ARE NECESSARY TO EMPLOY A PERMANENT FULL-TIME REGIONAL COMPLIANCE OFFICER WITH DEMONSTRATED
KNOWLEDGE AND EXPERIENCE IN MANAGING A COMPLIANCE RISK MANAGEMENT PROGRAM AT AN ENTITY WITH A COMPLEX COMPLIANCE PROFILE. COMPLIANCE RISK ASSESSMENT -
WITHIN 30 DAYS OF THE ORDER, HNAH'S BOARD OF DIRECTORS SHALL SUBMIT TO THE RESERVE BANK A WRITTEN FIRMWIDE COMPLIANCE RISK ASSESSMENT. COMPLIANCE RISK
MANAGEMENT PROGRAM - WITHIN 60 DAYS OF THE SUBMISSION OF THE FIRMWIDE COMPLIANCE RISK ASSESSMENT, HNAH'S BOARD OF DIRECTORS SHALL SUBMIT AN ACCEPTABLE
WRITTEN PLAN TO THE RESERVE BANK TO IMPROVE GOVERNANCE, STRUCTURE, AND OPERATIONS OF THE COMPLIANCE RISK MANAGEMENT PROGRAM. BSA/AML COMPLIANCE - WITHIN 10
DAYS OF THE ORDER, HNAH'S BOARD OF DIRECTORS SHALL RETAIN AN INDEPENDENT CONSULTANT ACCEPTABLE TO THE RESERVE BANK TO COMPLETE A REVIEW OF THE EFFECTIVENESS
OF THE FIRMWIDE BSA/AML COMPLIANCE PROGRAM ADOPTED BY HNAH AND PREPARE A WRITTEN REPORT OF FINDINGS AND RECOMMENDATIONS. SUSPICIOUS ACTIVITY MONITORING
AND REPORTING - WITHIN 60 DAYS OF COMPLETION OF THE BSA/AML COMPLIANCE REVIEW, HNAH SHALL SUBMIT TO THE RESERVE BANK AN ACCEPTABLE WRITTEN PROGRAM DESIGNED
TO REASONABLY ENSURE PROPER REPORTING BY HNAH AND ITS SUBSIDIARIES OF ALL KNOWN OR SUSPECTED VIOLATIONS OF LAW OR SUSPICIOUS TRANSACTIONS TO LAW
ENFORCEMENT AND SUPERVISORY AUTHORITIES. PROGRESS REPORTS - WITHIN 30 DAYS AFTER THE END OF EACH CALENDAR QUARTER FOLLOWING THE DATE OF THE ORDER, HNAH'S
BOARD OF DIRECTORS SHALL SUBMIT TO THE RESERVE BANK WRITTEN PROGRESS REPORTS DETAILING THE FORM AND MANNER OF ALL ACTIONS TAKEN TO SECURE COMPLIANCE WITH
THE ORDER. APPROVAL AND IMPLEMENTATION OF PLANS, PROGRAM, AND ENGAGEMENT LETTER - HNAH SHALL SUBMIT WRITTEN PLANS AND A PROGRAM THAT ARE ACCEPTABLE TO THE
RESERVE BANK WITHIN THE APPLICABLE TIME PERIODS SET FORTH IN THE 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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 
12/20/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2009019187301
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
TRACE-ELIGIBLE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. VIOLATED FINRA RULES 2010, 6730(A), NASD RULES 6230(B), 6230(C)(6): - HSBC SECURITIES (USA) INC. FAILED TO REPORT TO THE
TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES; THE FIRM REPORTED INTER-
DEALER TRANSACTIONS AS CUSTOMER TRANSACTIONS. THE FIRM FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT. THE
FIRM FAILED TO REPORT NUMEROUS TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES TO TRACE WITHIN 15 MINUTES OF THE EXECUTION TIME. THIS CONDUCT CONSTITUTES SEPARATE
AND DISTINCT VIOLATIONS OF FINRA RULE 6730(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
12/20/2010
 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: $ 30,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED
$30,000.00.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Other

Other Sanctions: 
CENSURE AND FINE.
3.
Date Initiated (MM/DD/YYYY): 
09/06/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2009020565101
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
REPORTABLE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. FAILED TO REPORT TO THE FINRA/NASDAQ TRADE REPORTING FACILITY THE CORRECT SYMBOL INDICATING WHETHER THE
TRANSACTION WAS A BUY, SELL, SELL SHORT OR CROSS FOR TRANSACTIONS IN REPORTABLE SECURITIES. FINRA RULE 7230A(D).
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
09/06/2011
 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: $ 10,000.00
 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: 
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC SECURITIES (USA) INC. WAS FINED $10,000.00.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 
06/01/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2008015436301
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
DESIGNATED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC")VIOLATED FINRA RULES 6380(A), 6622(B), 7450(A), NASD RULE 6955(A) - HSBC SECURITIES (USA)INC. FAILED TO TIMELY
REPORT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS); REPORTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT CONTAINED
INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA; TRANSMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS TO OATS THAT OATS WAS UNABLE TO LINK TO THE RELATED
ORDER ROUTED TO NASDAQ OR THE CORRESPONDING NEW ORDER TRANSMITTED BY THE DESTINATION MEMBER FIRM DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED
DATA. FINRA ALLEGED THAT HSBC FAILED TO TRANSMIT ROES TO OATS; TRANSMITTED REPORTS TO OATS THAT CONTAINED INACCURATE DESTINATION CODES. HSBC FAILED, WITHIN 90
SECONDS AFTER EXECUTION, TO TRANSMIT LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES TO THE FINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) AND FAILED,

WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES TO THE OTC REPORTING FACILITY.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/01/2012
 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: $ 45,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED $45,000.
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).

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
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.

y
( )
g
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) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 
09/20/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2010024139801
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
TRACE-ELIGIBLE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED FINRA RULES 2010, 6730(A), 6760(B), NASD RULE 3010 - HSBC SECURITIES (USA) INC. SERVED AS THE MANAGING
UNDERWRITER OF A DISTRIBUTION OR OFFERING, OTHER THAN A SECONDARY OFFERING, AND FAILED TO REPORT SUCH DISTRIBUTION OR OFFERING TO FINRA MARKET OPERATIONS
WITHIN THE PRESCRIBED TIME FRAME. HSBC'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE
SECURITIES LAWS, REGULATIONS AND FINRA RULES CONCERNING FINRA RULE 6760(B). FINRA ALLEGED THAT HSBC FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE
ENGINE (TRACE) S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE EXECUTION TIME. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS
OF FINRA RULE 6730(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATIONS OF FINRA RULE 2010.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
09/20/2012
 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: $ 70,000.00

 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERWRITING
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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED $70,000
AND WILL REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING FINRA RULE 6760(B) WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.
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).

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 BANK USA, N.A.
(For individuals, Last, First, Middle)
CRD Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HSBC NORTH AMERICA HOLDINGS
(For individuals, Last, First, Middle)
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) 
OFFICE OF THE COMPTROLLER OF CURRENCY ("OCC"), BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 
12/11/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
12-062-B-FB-; 12-062-B-FB; 12-062-CMP-HC; AA-EC-12-112; AA-EC-2012-140
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK USA, N.A., HSBC NORTH AMERICA HOLDINGS AND HSBC HOLDINGS PLC
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
US REGULATORY AUTHORITIES' INVESTIGATIONS REGARDING INADEQUATE COMPLIANCE WITH ANTI-MONEY LAUNDERING AND SANCTIONS LAWS.
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:
N/A
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):
12/11/2012
 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: $ 1,921,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
ON DECEMBER 11, 2012, HSBC HOLDINGS PLC ANNOUNCED THAT HSBC BANK USA, N.A., HAD IN RELATION TO INVESTIGATIONS REGARDING INADEQUATE COMPLIANCE WITH ANTI-
MONEY LAUNDERING AND SANCTIONS LAWS ENTERED INTO (I) AN AGREEMENT AND CONSENT ORDERS WITH THE OCC,(II) A CONSENT AND ASSESSMENT WITH THE UNITED STATES
DEPARTMENT OF THE TREASURY'S FINANCIAL CRIMES ENFORCEMENT NETWORK, (III) A DEFERRED PROSECUTION AGREEMENT AMONG HSBC BANK USA, N.A., HSBC HOLDINGS PLC,
THE UNITED STATES DEPARTMENT OF JUSTICE, THE UNITED STATES ATTORNEY'S OFFICE FOR THE EASTERN DISTRICT OF NEW YORK, AND THE UNITED STATES ATTORNEY'S OFFICE
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA; AND, HSBC HOLDINGS PLC ENTERED IN TO A DEFERRED PROSECUTION AGREEMENT WITH THE DISTRICT ATTORNEY OF THE

COUNTY OF NEW YORK, (II) CONSENTED TO A CEASE AND DESIST ORDER AND ALONG WITH HSBC NORTH AMERICA HOLDINGS CONSENTED TO A MONETARY PENALTY ORDER WITH
THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM. UNDER THESE AGREEMENTS, HSBC HOLDINGS PLC AND ITS SUBSIDIARIES HAVE MADE PAYMENTS TOTALING $1.921
BILLION, CONTINUE TO COOPERATE FULLY WITH REGULATORY AND LAW ENFORCEMENT AUTHORITIES, AND TAKE FURTHER ACTION TO STRENGTHEN ITS COMPLIANCE POLICIES
AND PROCEDURES. HSBC BANK USA, N.A. MAY NOT DIRECTLY OR INDIRECTLY ACQUIRE CONTROL OF, OR HOLD AN INTEREST IN, ANY NEW FINANCIAL SUBSIDIARY, NOR COMMENCE
A NEW ACTIVITY IN ITS EXISTING FINANCIAL SUBSIDIARY, UNLESS IT RECEIVES PRIOR APPROVAL FROM THE OCC.
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: 
ON DECEMBER 11, 2012, HSBC HOLDINGS PLC ANNOUNCED THAT HSBC BANK USA, N.A., HAD IN RELATION TO INVESTIGATIONS REGARDING INADEQUATE COMPLIANCE WITH ANTI-
MONEY LAUNDERING AND SANCTIONS LAWS ENTERED INTO (I) AN AGREEMENT AND CONSENT ORDERS WITH THE OCC,(II) A CONSENT AND ASSESSMENT WITH THE UNITED STATES
DEPARTMENT OF THE TREASURY'S FINANCIAL CRIMES ENFORCEMENT NETWORK, (III) A DEFERRED PROSECUTION AGREEMENT AMONG HSBC BANK USA, N.A., HSBC HOLDINGS PLC,
THE UNITED STATES DEPARTMENT OF JUSTICE, THE UNITED STATES ATTORNEY'S OFFICE FOR THE EASTERN DISTRICT OF NEW YORK, AND THE UNITED STATES ATTORNEY'S OFFICE
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA; AND, HSBC HOLDINGS PLC ENTERED IN TO A DEFERRED PROSECUTION AGREEMENT WITH THE DISTRICT ATTORNEY OF THE
COUNTY OF NEW YORK, (II) CONSENTED TO A CEASE AND DESIST ORDER AND ALONG WITH HSBC NORTH AMERICA HOLDINGS CONSENTED TO A MONETARY PENALTY ORDER WITH
THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM. UNDER THESE AGREEMENTS, HSBC HOLDINGS PLC AND ITS SUBSIDIARIES HAVE MADE PAYMENTS TOTALING $1.921
BILLION, CONTINUE TO COOPERATE FULLY WITH REGULATORY AND LAW ENFORCEMENT AUTHORITIES, AND TAKE FURTHER ACTION TO STRENGTHEN ITS COMPLIANCE POLICIES
AND PROCEDURES. HSBC BANK USA, N.A. MAY NOT DIRECTLY OR INDIRECTLY ACQUIRE CONTROL OF, OR HOLD AN INTEREST IN, ANY NEW FINANCIAL SUBSIDIARY, NOR COMMENCE
A NEW ACTIVITY IN ITS EXISTING FINANCIAL SUBSIDIARY, UNLESS IT RECEIVES PRIOR APPROVAL FROM THE OCC.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 
01/07/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2011027202401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
UNSPECIFIED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED THE SECURITIES EXCHANGE ACT OF 1934 RULE 17A-4(B)(4), FINRA RULES 2010, 8211, 8213, NASD RULES 2110,
2711(H)(2), 3110, 8211, 8213: THE HSBC'S MIDDLE OFFICE SYSTEM ERRONEOUSLY LEFT OFF SHORT SALE INDICATORS WHEN COMMUNICATING WITH ITS BACK OFFICE SYSTEM, WHICH
REPORTED HSBC'S BLUE SHEETS. AS A RESULT, HSBC MISREPORTED SHORT SALE TRANSACTIONS AS LONG SALES ON ITS BLUE SHEETS DURING A FOUR-YEAR PERIOD. HSBC FAILED TO
DELIVER PROSPECTUSES OR OFFERING MEMORANDA THAT WERE REQUIRED TO BE DELIVERED IN CONNECTION WITH FIXED INCOME TRANSACTIONS. HSBC EXPERIENCED A BREAKDOWN
IN ITS AUTOMATED FEEDS, RESULTING IN FAILURE TO APPEND CERTAIN INVESTMENT BANKING DISCLOSURES TO ITS RESEARCH REPORTS. IN ADDITION, HSBC LEARNED THAT IT HAD
ALSO FAILED TO INCLUDE CERTAIN DEBT OFFERINGS IN THE DEFINITION OF INVESTMENT BANKING THAT WAS USED TO DETERMINE THE APPROPRIATE DISCLOSURES FOR ITS RESEARCH
REPORTS UP UNTIL THAT TIME. AS A RESULT OF THESE DEFICIENCIES, HSBC ISSUED EQUITY RESEARCH REPORTS WITHOUT REQUIRED DISCLOSURES. MOREOVER, DUE TO INCORRECT
MAPPING OF COMPANY IDENTIFIERS, SOME OF THE RESEARCH REPORTS INITIALLY FAILED TO CONTAIN PROPER DISCLOSURES. DESPITE ITS POLICY OF DISABLING TEXT MESSAGING ON
EMPLOYEE BLACKBERRIES, CERTAIN NON-TECHNOLOGY EMPLOYEES HAD BLACKBERRIES WITH INBOUND TEXTING FUNCTIONALITY. HSBC LATER TOOK STEPS TO ELIMINATE THIS
FUNCTIONALITY. HOWEVER, SOME REGISTERED EMPLOYEES STILL HAD BLACKBERRIES WITH TEXTING CAPABILITY. HSBC FAILED TO RETAIN BLACKBERRY TEXT MESSAGES RECEIVED BY
CERTAIN EMPLOYEES.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
01/07/2013
 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: $ 250,000.00
 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: 

WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED $250,000.
HSBC SATISFIED THE CRITERIA NECESSARY TO RECEIVE CREDIT FOR EXTRAORDINARY COOPERATION. IN LIGHT OF ITS EXTRAORDINARY COOPERATION, HSBC RECEIVED A REDUCED
FINE.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 
01/15/2013
 Exact
 Explanation

If not exact, provide explanation:
4.
Docket/Case Number:
2010021555401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
THRESHOLD SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED SEC RULE 204(A)(2), SEC RULES 200(G), 203(B)(3) OF REGULATION SHO, FINRA RULES 2010, 6624, NASD RULE
3010 - HSBC HAD A FAIL-TO-DELIVER POSITION AT A REGISTERED CLEARING AGENCY IN A THRESHOLD SECURITY FOR 13 CONSECUTIVE SETTLEMENT DAYS AND FAILED TO IMMEDIATELY
THEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY. HSBC CONTINUED TO HAVE A FAIL-TO-DELIVER POSITION IN THE
SECURITY AT THE REGISTERED CLEARING AGENCY ON 79 ADDITIONAL SETTLEMENT DAYS, WHICH FAILED TO CLOSE OUT WHEN REQUIRED. HSBC HAD FAIL-TO-DELIVER POSITIONS AT A
REGISTERED CLEARING AGENCY IN THE SECURITY THAT RESULTED FROM A SALE OF A SECURITY THAT THE SELLER WAS DEEMED TO OWN PURSUANT TO §242.200 AND INTENDED TO
DELIVER ONCE ALL RESTRICTIONS ON DELIVERY HAD BEEN REMOVED, AND DID NOT CLOSE THE FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY
WITHIN THE TIME FRAME PRESCRIBED BY SEC RULE 204(A)(2). HSBC ACCEPTED ORDERS IN DEEMED TO OWN OVER-THE-COUNTER (OTC) EQUITY SECURITIES AND FAILED TO PROPERLY
MARK THE ORDERS AS SHORT AND AS A RESULT, HSBC EXECUTED SHORT SALE TRANSACTIONS AND FAILED TO REPORT EACH OF THESE TRANSACTIONS TO THE OTC REPORTING FACILITY
WITH A SHORT SALE INDICATOR. HSBC'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES
LAWS, REGULATIONS AND FINRA RULES CONCERNING FINRA RULES 6182 AND 6624 (TRADE REPORTING OF SHORT SALES) AND SEC RULES 200(G)(ORDER MARKING), 203(A) (LONG
SALES), 203(B)(1) (LOCATE REQUIREMENT), 203(B)(3) (THRESHOLD CLOSE OUT REQUIREMENT), AND 204 (CLOSE OUT REQUIREMENT).
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
01/15/2013
 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: $ 65,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. HSBC WAS CENSURED, FINED $65,000 AND
REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING FINRA RULES 6182 AND 6624 (TRADE REPORTING OF SHORT SALES) AND SEC RULES 200(G)(ORDER
MARKING), 203(A) (LONG SALES), 203(B)(1) (LOCATE REQUIREMENT), 203(B)(3) (THRESHOLD CLOSE OUT REQUIREMENT), AND 204 (CLOSE OUT REQUIREMENT) WITHIN 30
BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.
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).

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
No Information Filed
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) 
NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES
2.
Principal Sanction:
Other
Other Sanctions: 
FINED
3.
Date Initiated (MM/DD/YYYY): 
12/04/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2012-0233-S
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Insurance
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ALLEGED THAT HSBC VIOLATED SECTION 2110(A)(2) OF THE INSURANCE LAW IN ITS RENEWAL APPLICATIONS FOR AGENT'S

LICENSE UNDER SECTION 2103(A) OF THE INSURANCE LAW FOR FAILING TO DISCLOSE CERTAIN REGULATORY MATTERS AND ARBITRATION AWARDS ENTERED AGAINST HSBC.
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:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
12/04/2012
 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: $ 27,500.00
 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: 
HSBC SECURITIES (USA) INC. WAIVED ITS RIGHT TO NOTICE AND A HEARING ON SAID CHARGE AND AGREED, IN LIEU OF ANY OTHER DISCIPLINARY ACTION WHICH MIGHT BE TAKEN
BY THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES. HSBC AGREED TO FINE OF $27,500.00 AND TO TAKE ALL NECESSARY STEPS TO PREVENT THE RECURRENCE OF ANY
SIMLIAR VIOLATIONS.
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).

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 BANK USA N.A.
(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) 
OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC")
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/13/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AA-EC-11-14
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
MORTGAGE SERVICING AND FORECLOSURE PRACTICES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMPTROLLER OF THE CURRENCY OF THE UNITED STATES OF AMERICA ("COMPTROLLER"), THROUGH HIS NATIONAL BANK EXAMINERS AND OTHER STAFF OF THE OFFICE OF THE
COMPTROLLER OF THE CURRENCY ("OCC"), AS PART OF AN INTERAGENCY HORIZONTAL REVIEW OF MAJOR RESIDENTIAL MORTGAGE SERVICERS, CONDUCTED AN EXAMINATION OF THE
RESIDENTIAL REAL ESTATE MORTGAGE FORECLOSURE PROCESSES OF HSBC BANK USA, N.A., MCLEAN, VIRGINIA ("BANK"). THE OCC IDENTIFIED CERTAIN DEFICIENCIES AND UNSAFE OR
UNSOUND PRACTICES IN RESIDENTIAL MORTGAGE SERVICING AND IN THE BANK'S INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS. THE BANK, BY AND THROUGH ITS DULY
ELECTED AND ACTING BOARD OF DIRECTORS ("BOARD"), EXECUTED A "STIPULATION AND CONSENT TO THE ISSUANCE OF A CONSENT ORDER," DATED APRIL 13, 2011 ("STIPULATION
AND CONSENT"). BY THIS STIPULATION AND CONSENT, THE BANK HAS CONSENTED TO THE ISSUANCE OF THE CONSENT CEASE AND DESIST ORDER ("ORDER") BY THE COMPTROLLER. THE
BANK COMMITTED TO TAKING ALL NECESSARY AND APPROPRIATE STEPS TO REMEDY THE DEFICIENCIES AND UNSAFE OR UNSOUND PRACTICES IDENTIFIED BY THE OCC, AND TO ENHANCE
THE BANK'S RESIDENTIAL MORTGAGE SERVICING AND FORECLOSURE PROCESSES. ON JANUARY 9, 2017, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC") ANNOUNCED THAT
IT HAD TERMINATED ITS RESIDENTIAL MORTGAGE SERVICING RELATED CONSENT ORDER AGAINST HSBC BANK USA, N.A. (THE "BANK"), A SUBSIDIARY OF HSBC USA INC. THE OCC
TERMINATED THE CONSENT ORDER HAVING FOUND THAT THE BANK HAD SATISFIED ALL OF THE REQUIREMENTS OF THE OCC'S ORIGINALLY ISSUED APRIL 2011 CONSENT ORDER, AND THE
FEBRUARY 2013 AND JUNE 2015 AMENDMENTS THERETO. WITH TERMINATION OF THE CONSENT ORDER, THE BUSINESS RESTRICTIONS IMPOSED BY THE OCC ON THE BANK PURSUANT TO
THE JUNE 2015 AMENDMENT TO THE CONSENT ORDER ARE ALSO TERMINATED. THE BANK PAID $32.5 MILLION CIVIL MONEY PENALTY TO THE U.S. TREASURY FOR DEFICIENCIES IN TIMELY
COMPLIANCE WITH THE CONSENT ORDER, INCLUDING IDENTIFIED DEFICIENCIES ON APPROXIMATELY 1,700 MORTGAGE LOAN ACCOUNTS RELATIVE TO PAYMENT CHANGE NOTIFICATIONS
REQUIRED UNDER APPLICABLE BANKRUPTCY RULES. THE ORDER WAS TERMINATED IN JANUARY OF 2017.
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):
01/09/2017
 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: $ 32,500,000.00
 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 FRB AND OCC AMENDED CONSENT ORDERS DATED FEBRUARY 28, 2013, HSBC WILL MAKE CASH PAYMENTS TOTALLING $249,901,413. SUCH PAYMENTS WILL BE
APPLIED TO A SETTLEMENT FUND AND ALSO BE USED TO PROVIDE OTHER ASSISTANCE TO HELP MORTGAGE BORROWERS. - HSBC BANK USA N.A. IN ACCORDANCE WITH THE
SETTLEMENT PAID THE FINE IN THE AMOUNT OF $32,500,000 AND THE ORDER WAS TERMINATED IN JANUARY OF 2017.
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).
THE APRIL 2011 OCC AND FRB CONSENT ORDERS WERE AMENDED, REQUIRING HNAH, HBIO AND HSBC BANK TO PAY $96,540,359 INTO A QUALIFIED SETTLEMENT FUND, ESTABLISHED
PURSUANT TO THE AMENDMENT, FROM WHICH PAYMENTS WILL BE MADE ACCORDING TO A DISTRIBUTION PLAN DEVELOPED BY THE FRB AND THE OCC. HNAH, HBIO AND HSBC BANK
SHALL ALSO PROVIDE LOSS MITIGATION AND FORECLOSURE PREVENTION TOTALLING $153,361,054. WITHOUT ADMITTING OR DENYING THE VIOLATIONS HSBC BANK USA N.A. IN
ACCORDANCE WITH THE SETTLEMENT PAID A FINE IN THE AMOUNT OF $32,500,000 AND THE ORDER WAS TERMINATED IN JANUARY OF 2017.

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 BANK USA, N.A.
(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) 
OFFICE OF THE COMPTROLLER OF THE CURRENCY ("OCC")
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/13/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AA-EC-11-14
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
MORTGAGE SERVICING AND FORECLOSURE PRACTICES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OCC ALLEGES THAT HSBC ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES IN CONNECTION WITH ITS MORTGAGE LOAN SERVICING AND FORECLOSURE PRACTICES.
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):
04/13/2011
 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: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:

HSBC WAS ORDERED TO REMEDIATE ITS MORTGAGE AND FORECLOSURE PRACTICES.
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 AGREED TO ENTER INTO CEASE AND DESIST ORDERS WITH THE FEDERAL RESERVE BOARD AND OFFICE OF THE COMPTROLLER OF THE CURRENCY ON APRIL 13, 2011, TO
REMEDIATE ITS MORTGAGE AND FORECLOSURE PRACTICES.
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 BRIEF, THE OCC CONSENT ORDER REQUIRES THE FOLLOWING: THE HSBC BOARD OF DIRECTORS MAINTAIN A COMPLIANCE COMMITTEE WHICH SHALL SUBMIT A PROGRESS REPORT TO
THE BOARD DETAILING ACTIONS TAKEN TO COMPLY WITH THIS ORDER, AND THE RESULTS AND STATUS OF THOSE ACTIONS. WITHIN SIXTY DAYS, THE BANK SHALL SUBMIT TO THE DEPUTY
COMPTROLLER AND THE EXAMINER-IN-CHARGE A PLAN DESCRIBING THE ACTIONS NECESSARY AND APPROPRIATE TO ACHIEVE COMPLIANCE WITH THIS ORDER. WITHIN SIXTY DAYS, THE
BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE A COMPLIANCE PROGRAM TO ENSURE THAT THE MORTGAGE SERVICING AND FORECLOSURE
OPERATIONS COMPLY WITH ALL APPLICABLE LEGAL REQUIREMENTS, OCC SUPERVISORY GUIDANCE, AND THE REQUIREMENTS OF THIS ORDER AND ARE CONDUCTED IN A SAFE AND
SOUND MANNER. WITHIN SIXTY DAYS, THE BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE POLICIES AND PROCEDURES FOR OUTSOURCING
FORECLOSURE OR RELATED FUNCTIONS AND PROPERTY MANAGEMENT FUNCTIONS FOR RESIDENTIAL REAL ESTATE ACQUIRED THROUGH OR IN LIEU OF FORECLOSURE, TO ANY AGENT,
INDEPENDENT CONTRACTOR, CONSULTING FIRM, LAW FIRM, PROPERTY MANAGEMENT FIRM, OR OTHER THIRD-PARTY. WITHIN SIXTY DAYS, THE BANK SHALL SUBMIT TO THE DEPUTY
COMPTROLLER AND THE EXAMINER-IN-CHARGE A PLAN TO ENSURE APPROPRIATE CONTROLS AND OVERSIGHT OF THE BANK'S ACTIVITIES WITH RESPECT TO THE MORTGAGE ELECTRONIC
REGISTRATION SYSTEM AND COMPLIANCE WITH MERSCORP'S MEMBERSHIP RULES, TERMS, AND CONDITIONS. WITHIN FORTY-FIVE DAYS, THE BANK SHALL RETAIN AN INDEPENDENT
CONSULTANT TO CONDUCT AN INDEPENDENT REVIEW OF CERTAIN RESIDENTIAL FORECLOSURE ACTIONS REGARDING INDIVIDUAL BORROWERS WITH RESPECT TO THE BANK'S
MORTGAGE SERVICING PORTFOLIO. THE INDEPENDENT CONSULTANT SHALL PREPARE A REPORT DETAILING THE FINDINGS OF THE FORECLOSURE REVIEW, WHICH SHALL BE COMPLETED
WITHIN THIRTY DAYS OF COMPLETION OF THE FORECLOSURE REVIEW. WITHIN FORTY-FIVE DAYS OF SUBMISSION OF THE FORECLOSURE REPORT TO THE DEPUTY COMPTROLLER,
EXAMINER-IN-CHARGE, AND THE BOARD, THE BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE A PLAN, ACCEPTABLE TO THE OCC, TO REMEDIATE ALL
FINANCIAL INJURY TO BORROWERS CAUSED BY ANY ERRORS, MISREPRESENTATIONS, OR OTHER DEFICIENCIES IDENTIFIED IN THE FORECLOSURE REPORT. WITHIN SIXTY DAYS AFTER THE
OCC PROVIDES SUPERVISORY NON-OBJECTION TO THE PLAN, THE BANK SHALL MAKE ALL PAYMENTS AND PROVIDE ALL CREDITS REQUIRED BY SUCH PLAN, AND PROVIDE THE OCC WITH A
REPORT DETAILING SUCH PAYMENTS AND CREDITS. WITHIN SIXTY DAYS, THE BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE AN ACCEPTABLE PLAN
FOR OPERATION OF ITS MANAGEMENT INFORMATION SYSTEMS ("MIS") FOR FORECLOSURE AND LOSS MITIGATION OR LOAN MODIFICATION ACTIVITIES TO ENSURE THE TIMELY DELIVERY
OF COMPLETE AND ACCURATE INFORMATION TO PERMIT EFFECTIVE DECISION-MAKING. WITHIN SIXTY DAYS, THE BANK SHALL SUBMIT TO THE DEPUTY COMPTROLLER AND THE EXAMINER-
IN-CHARGE A PLAN, ALONG WITH A TIMELINE FOR ENSURING EFFECTIVE COORDINATION OF COMMUNICATIONS WITH BORROWERS, RELATED TO LOSS MITIGATION OR LOAN
MODIFICATION AND FORECLOSURE ACTIVITIES. WITHIN NINETY DAYS, THE BANK SHALL CONDUCT A COMPREHENSIVE ASSESSMENT OF THE BANK'S RISKS IN MORTGAGE SERVICING
OPERATIONS. THE BANK SHALL SUBMIT THE PLANS, PROGRAMS, POLICIES, AND PROCEDURES REQUIRED BY THIS ORDER FOR REVIEW AND DETERMINATION OF NO SUPERVISORY
OBJECTION TO THE DEPUTY COMPTROLLER AND THE EXAMINER-IN-CHARGE WITHIN THE APPLICABLE TIME PERIODS. THE BANK SHALL ADOPT THE PLANS, PROGRAMS, POLICIES, AND
PROCEDURES REQUIRED BY THIS ORDER UPON SUBMISSION TO THE OCC, AND SHALL IMMEDIATELY MAKE ANY REVISIONS REQUESTED BY THE DEPUTY COMPTROLLER OR THE EXAMINER-
IN-CHARGE. WITHIN THIRTY DAYS AFTER THE END OF EACH CALENDAR QUARTER FOLLOWING THE DATE OF THIS ORDER, THE BANK SHALL SUBMIT TO THE OCC A WRITTEN PROGRESS
REPORT DETAILING THE FORM AND MANNER OF ALL ACTIONS TAKEN TO SECURE COMPLIANCE WITH THE PROVISIONS OF THIS ORDER AND THE RESULTS THEREOF.

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 BANK NORTH AMERICA HOLDINGS

PLC
(For individuals, Last, First, Middle)
CRD Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HSBC BANK FINANCE CORP
(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) 
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FRB")
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/13/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
11-022-B-HC 11-022-B-DEO
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
MORTGAGE SERVICING AND FORECLOSURE PRACTICES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FRB ALLEGES THAT HSBC ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES IN CONNECTION WITH ITS MORTGAGE LOAN SERVICING AND FORECLOSURE PRACTICES.
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):
04/13/2011
 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: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
HSBC WAS ORDERED TO REMEDIATE ITS MORTGAGE AND FORECLOSURE PRACTICES.
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 AGREED TO ENTER INTO CEASE AND DESIST ORDERS WITH THE FEDERAL RESERVE BOARD AND OFFICE OF THE COMPTROLLER OF THE CURRENCY ON APRIL 13, 2011, TO
REMEDIATE ITS MORTGAGE AND FORECLOSURE PRACTICES
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 BRIEF, THE FRB CONSENT ORDER REQUIRES THE FOLLOWING: THE BOARD OF DIRECTORS OF HNAH SHALL UTILIZE HNAH'S FINANCIAL AND MANAGERIAL RESOURCES TO SERVE AS A
SOURCE OF STRENGTH TO THE BANK TO ENSURE THAT THE BANK COMPLIES WITH THE CONSENT ORDER ISSUED BY THE OCC. WITHIN 60 DAYS, THE BOARDS OF DIRECTORS OF HNAH AND
HBIO SHALL SUBMIT A PLAN TO STRENGTHEN THE BOARDS' OVERSIGHT OF THE MORTGAGE SERVICING COMPANIES. WITHIN 45 DAYS, HNAH AND HBIO SHALL RETAIN INDEPENDENT
CONSULTANT(S) TO CONDUCT A REVIEW OF CERTAIN RESIDENTIAL MORTGAGE FORECLOSURE ACTIONS REGARDING INDIVIDUAL BORROWERS. WITHIN 60 DAYS, HBIO SHALL SUBMIT A
PLAN, ALONG WITH A TIMELINE, FOR STRENGTHENING COORDINATION OF COMMUNICATIONS BETWEEN THE MORTGAGE SERVICING COMPANIES AND BORROWERS RELATED TO LOSS
MITIGATION AND FORECLOSURE ACTIVITIES. WITHIN 60 DAYS, HBIO SHALL SUBMIT POLICIES AND PROCEDURES FOR THE OUTSOURCING OF ANY RESIDENTIAL MORTGAGE LOAN
SERVICING, LOSS MITIGATION, OR FORECLOSURE FUNCTIONS, BY THE MORTGAGE SERVICING COMPANIES TO ANY THIRD PARTY. WITHIN 60 DAYS, HNAH SHALL SUBMIT A PLAN TO
ENHANCE ITS ENTERPRISE-WIDE COMPLIANCE PROGRAM WITH RESPECT TO ITS OVERSIGHT OF RESIDENTIAL MORTGAGE LOAN SERVICING, LOSS MITIGATION, AND FORECLOSURE
ACTIVITIES AND OPERATIONS. WITHIN 60 DAYS, HBIO SHALL SUBMIT A COMPLIANCE PROGRAM AND TIMELINE TO ENSURE THAT THE OPERATIONS OF THE MORTGAGE SERVICING
COMPANIES COMPLY WITH THE LEGAL REQUIREMENTS, AS WELL AS THE MORTGAGE SERVICING COMPANIES' INTERNAL POLICIES, PROCEDURES, AND PROCESSES AND ARE CONDUCTED
IN A SAFE AND SOUND MANNER. WITHIN 60 DAYS, HBIO SHALL SUBMIT A PLAN TO ENSURE APPROPRIATE CONTROLS AND OVERSIGHT OF THE MORTGAGE SERVICING COMPANIES'
ACTIVITIES WITH RESPECT TO MERS AND COMPLIANCE WITH MERS' MEMBERSHIP RULES, TERMS, AND CONDITIONS. WITHIN 60 DAYS, HBIO SHALL SUBMIT A PLAN AND TIMELINE FOR THE
REVIEW AND REMEDIATION OF THE MORTGAGE SERVICING COMPANIES' MANAGEMENT INFORMATION SYSTEMS. WITHIN 60 DAYS, HBIO SHALL SUBMIT A PLAN AND TIMELINE TO IMPROVE
THE TRAINING OF ALL APPROPRIATE OFFICERS AND STAFF OF THE MORTGAGE SERVICING COMPANIES REGARDING THE LEGAL REQUIREMENTS, SUPERVISORY GUIDANCE OF THE BOARD
OF GOVERNORS, AND THE MORTGAGE SERVICING COMPANIES' INTERNAL POLICIES AND PROCEDURES REGARDING RESIDENTIAL MORTGAGE LOAN SERVICING, LOSS MITIGATION, AND
FORECLOSURE. WITHIN 10 DAYS, HNAH AND HBIO SHALL RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT AN ASSESSMENT OF THE MORTGAGE SERVICING COMPANIES' RISKS. THE
INDEPENDENT CONSULTANT SHALL PREPARE A RISK ASSESSMENT AND PROVIDE IT TO HNAH AND HBIO WITHIN 90 DAYS, AND HNAH AND HBIO SHALL PROVIDE IT TO THE RESERVE BANK
AT THE SAME TIME THAT IT IS PROVIDED TO HNAH AND HBIO. WITHIN 60 DAYS OF SUBMISSION OF THE RISK ASSESSMENT, HNAH SHALL SUBMIT A PLAN TO ENHANCE ITS ERM PROGRAM.
WITHIN 60 DAYS OF SUBMISSION OF THE RISK ASSESSMENT, HNAH AND HBIO SHALL JOINTLY SUBMIT A RISK MANAGEMENT PROGRAM FOR THE MORTGAGE SERVICING COMPANIES.
WITHIN 60 DAYS, HNAH SHALL SUBMIT A PLAN TO ENHANCE THE INTERNAL AUDIT PROGRAM WITH RESPECT TO RESIDENTIAL MORTGAGE LOAN SERVICING, LOSS MITIGATION, AND
FORECLOSURE ACTIVITIES AND OPERATIONS. WITHIN 60 DAYS, HBIO SHALL SUBMIT AN ENHANCED WRITTEN INTERNAL AUDIT PROGRAM TO PERIODICALLY REVIEW COMPLIANCE WITH
APPLICABLE THE LEGAL REQUIREMENTS AND SUPERVISORY GUIDANCE OF THE BOARD OF GOVERNORS AT THE MORTGAGE SERVICING COMPANIES. WITHIN 10 DAYS OF APPROVAL BY THE
RESERVE BANK, HNAH AND HBIO, AS APPLICABLE, SHALL ADOPT THE APPROVED PLANS, PROGRAMS, POLICIES, AND PROCEDURES. WITHIN 30 DAYS AFTER THE END OF EACH CALENDAR
QUARTER, HNAH'S AND HBIO'S BOARDS OF DIRECTORS SHALL JOINTLY SUBMIT PROGRESS REPORTS DETAILING THE FORM AND MANNER OF ALL ACTIONS TAKEN TO SECURE COMPLIANCE
THIS ORDER AND THE RESULTS THEREOF. WITHIN 15 MONTHS AFTER THE DATE OF THIS ORDER, HNAH AND HBIO SHALL SUBMIT A VALIDATION REPORT PREPARED BY AN INDEPENDENT
THIRD-PARTY CONSULTANT WITH RESPECT TO COMPLIANCE WITH THE ORDER DURING THE FIRST YEAR AFTER THE ORDER BECOMES EFFECTIVE.

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 BANK FINANCE CORP
(For individuals, Last, First, Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HSBC BANK NORTH AMERICA 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) 
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FRB")
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/13/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
11-022-B-HC 11-002-B-DEO
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
MORTGAGE SERVICING AND FORECLOSURE PRACTICES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FRB ALLEGES THAT HSBC ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES IN CONNECTION WITH ITS MORTGAGE LOAN SERVICING AND FORECLOSURE PRACTICES.
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):
02/28/2013
 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: $ 249,901,413.00
 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 FRB AND OCC AMENDED CONSENT ORDERS DATED FEBRUARY 28, 2013, HSBC WILL MAKE CASH PAYMENTS TOTALLING $249,901,413. SUCH PAYMENTS WILL BE
APPLIED TO A SETTLEMENT FUND AND ALSO BE USED TO PROVIDE OTHER ASSISTANCE TO HELP MORTGAGE BORROWERS.
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).
THE APRIL 2011 OCC AND FRB CONSENT ORDERS WERE AMENDED, REQUIRING HNAH, HBIO AND HSBC BANK TO PAY $96,540,359 INTO A QUALIFIED SETTLEMENT FUND, ESTABLISHED
PURSUANT TO THE AMENDMENT, FROM WHICH PAYMENTS WILL BE MADE ACCORDING TO A DISTRIBUTION PLAN DEVELOPED BY THE FRB AND THE OCC. HNAH, HBIO AND HSBC BANK
SHALL ALSO PROVIDE LOSS MITIGATION AND FORECLOSURE PREVENTION TOTALLING $153,361,054.

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
No Information Filed
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) 
STATE OF WASHINGTON OFFICE OF INSURANCE COMMISSIONER
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/27/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
11-0152
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Insurance
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF WASHINGTON OFFICE OF INSURANCE COMMISSION ("OIC")ALLEGED THAT HSBC SECURITIES (USA) INC. ("HSBC") VIOLATED RCW48.17.597(1) BY FAILING TO REPORT
ADMINISTRATIVE ACTIONS TAKEN AGAINST IT BY ITS PRIMARY REGULATOR WITH THIRTY DAYS. THE OIC ALSO ALLEGED THAT HSBC VIOLATED RCW 48.17.530 BY REPRESENTING IN ITS
INITIAL APPLICATION THAT IT HAD NOT BEEN NAMED IN ANY FINRA VIOLATIONS AND REPORTABLE ACTIONS. THE OIC ALLEGED THAT HSBC PROVIDED AN INCORRECT CRD NUMBER ON IT
APPLICATION.
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):
08/01/2011
 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: $ 7,000.00
 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: 

WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC WAS FINED $7,000.00.
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).

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 BANK USA NATIONAL ASSOCIATION
("HSBC")
(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 BUSINESS CONDUCT COMMITTEE OF THE NEW YORK MERCANTILE EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
DISGOEGEMENT

3.
Date Initiated (MM/DD/YYYY): 
08/24/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
11-08131-BC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK USA NATIONAL ASSOCIATION ("HSBC")
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NEW YORK MERCANTILE EXCHANGE, INC. ALLEGED THAT ON JANUARY 31, 2011, A DATE SUBJECT TO A SPOT MONTH SPECULATIVE POSITION LIMIT FOR THE FEBRUARY 2011 GOLD
FUTURES CONTRACT, HSBC INADVERTENTLY MAINTAINED A LONG GOLD FUTURES POSITION THAT EXCEEDED THE APPROVED EXPIRATION MONTH HEDGE EXEMPTION OF 5,000
CONTRACTS GRANTED BY THE EXCHANGE ON AUGUST 11, 2010, BY 153 CONTRACTS (3%). UPON BEING INFORMED OF THE EXCESSIVE POSITION, THE NEW YORK MERCANTILE EXCHANGE,
INC. ALLEGED THAT HSBC IMMEDIATELY LIQUIDATED ITS OVERAGE POSITION RESULTING IN PROFITS OF $7,250. THE PANEL FOUND THAT IN SO DOING, HSBC VIOLATED COMEX RULE
562.
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:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
08/26/2011
 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: $ 17,250.00
 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: 
IN ACCORDANCE WITH THE SETTLEMENT OFFER AND IT FINDINGS, THE BCC PANEL ORDERED HSBC TO PAY THE EXCHANGE IN THE AMOUNT OF $10,000 AND DISGORGE $7,250 IN
PROFITS.
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).
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC ACCEPTED AN OFFER OF SETTLEMENT FOR $17,250.00.

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 BANK USA, NATIONAL
ASSOCIATION
(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) 
US DEPARTMENT OF THE TREASURY, OFFICE OF FOREIGN ASSET CONTROL ("OFAC")
2.
Principal Sanction:
Other
Other Sanctions: 
HSBC BANK USA, N.A.(HBUS) SETTLED POTENTIAL CIVIL LIABILITY FOR THREE APPARENT VIOLATIONS OF THE GLOBAL TERRORISM SANCTIONS REGULATIONS, 31 C.F.R. PART 594
3.
Date Initiated (MM/DD/YYYY): 
02/01/2011
 Exact
 Explanation
If not exact, provide explanation:
THIS IS THE DATE OF THE ADMINISTRATIVE SUBPOENA TO HBUS INITIATED BY OFAC IN RELATION TO THE REGULATORY ACTION BEING REPORTED.
4.
Docket/Case Number:
SDGT-548003
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK (USA), N.A.
6.
Principal Product Type:
Other
Other Product Types: 

HBUS IS A FINANCIAL INSTITUTION INCORPORATED UNDER THE LAWS OF THE UNITED STATES AND IS REGULATED BY THE DEPARTMENT OF THE TREASURY'S OFFICE OF THE COMPTROLLER
OF THE CURRENCY.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HBUS ALLEGEDLY PROCESSED 3 FUNDS TRANSFERS FOR THE ECONOMIC BENEFIT OF PARTIES DESIGNATED AS SPECIALLY DESIGNATED GLOBAL TERRORISTS (SDGTS). THE AGGRAVATING
FACTORS IENTIFIED BY OFAC WERE: (1) HBUS DID NOT SCREEN TRANSACTION INSTRUCTIONS APPROPRIATELY AT THE TIME OF THE FIRST APPARENT VIOLATION. (2) HBUS COMPLIANCE
MANAGERS FOR OFAC WERE AWARE OF THE FIRST VIOLATION AND SHOULD HAVE BEEN AWARE OF THE SECOND AND THIRD APPARENT VIOLATIONS. (3) HBUS INITIALLY PROVIDED AN
INCOMPLETE RESPONSE TO AN ADMINISTRATIVE SUBPOENA.
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:
HBUS SETTLED WITH OFAC ALL POTENTIAL CIVIL LIABILITY FOR THE APPARENT VIOLATIONS OF THE GLOBAL TERRORISM SANCTIONS REGULATIONS EFFECTIVE ON DECEMBER 12, 2013.
THE DATE WHEN OFAC SIGNED THE SETTLEMENT AGREEMENT.
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):
12/12/2013
 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: $ 32,400.00
 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: 
DISPOSITION OF THE MATTER RESULTED IN A FINE OF $32400. THE WHOLE FINE WAS LEVIED ON HBUS. PAYMENT OF THE FINE WAS TMADE TIMELY, WITHIN 30 DAYS FROM
DECEMBER 12, 2013.
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).

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 BANK USA N.A.
(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) 
COMMODITY EXCHANGE BUSINESS CONDUCT COMMITTEE ("BCC")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/28/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
COMEX 13-9300-BC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK USA N.A.
6.
Principal Product Type:
Other
Other Product Types: 
EFRP TRANSACTIONS.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
COMMODITY EXCHANGE BUSINESS CONDUCT COMMITTEE ("BCC") FOUND THAT ON JANUARY 28, 2013 HSBC BANK USA N.A. ("HSBC") ENTERED INTO TWO EFRP TRANSACTIONS AND ON
MAY 30, 2012, HSBC ENTERED INTO ONE EFRP TRANSACTION, IN WHICH HSBC WAS ON BOTH SIDES OF THE TRANSACTIONS. THE PANEL FOUND THAT THE TRANSACTIONS DID NOT
CONTAIN DOCUMENTATION OF THE CORRESPONDING CASH POSITIONS AND, THUS, WERE NOT BONA FIDE EFRP TRANSACTIONS. THE PANEL FOUND THAT HSBC VIOLATED NYMEX RULE
538.H AND 534.
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):
03/20/2014
 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: $ 40,000.00
 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: 
HSBC BANK USA N.A. IN ACCORDANCE WITH THE SETTLEMENT PAID A FINE IN THE AMOUNT OF $40,000.
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).
WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, HSBC BANK USA N.A. IN ACCORDANCE WITH THE SETTLEMENT PAID A FINE IN THE
AMOUNT OF $40,000.

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
No Information Filed
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) 
CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE ("PANEL")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/25/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CBOT 11-8572-BC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
FIVE-YEAR US TREASURY NOTE FUTURES CONTRACTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MARCH 25, 2014,A PANEL OF THE CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE ("PANEL") FOUND THAT ON JUNE 3, 2011, HSBC EXECUTED A BLOCK TRADE IN THE
SEPTEMBER 2011 FIVE-YEAR US TREASURY NOTE FUTURES CONTRACTS, AND FAILED TO REPORT THE TRADE TO THE EXCHANGE WITHIN FIVE MINUTES. THE PANEL CONCLUDED THAT
HSBC THEREBY VIOLATED CBOT RULE 526.F.
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):
03/27/2014
 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: $ 25,000.00
 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: 
HSBC SECURITIES (USA) INC. IN ACCORDANCE WITH THE SETTLEMENT PAID A FINE IN THE AMOUNT OF $25,000.

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).
WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, HSBC SECURITIES (USA) INC. IN ACCORDANCE WITH THE SETTLEMENT PAID A FINE IN
THE AMOUNT OF $25,000.

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 BANK USA, NATIONAL
ASSOCIATION
(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) 
EUROPEAN COMMISSION, THE DIRECTOR-GENERAL COMPETITION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
DISGORGEMENT/CEASE AND DESIST

3.
Date Initiated (MM/DD/YYYY): 
07/01/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE AT.39745
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC BANK USA, N.A.
6.
Principal Product Type:
Other
Other Product Types: 
CREDIT DEFAULT SWAPS AND CREDIT DERIVATIVES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATEMENT OF OBJECTIONS IS ADDRESSED TO BANK OF AMERICA MERRILL LYNCH, BARCLAYS, BEAR STEARNS, BNP PARIBAS, CITIGROUP, CREDIT SUISSE, DEUTSCHE BANK, GOLDMAN
SACHS, HSBC, JP MORGAN, MORGAN STANLEY, ROYAL BANK OF SCOTLAND, UBS AS WELL AS THE INTERNATIONAL SWAPS AND DERIVATIVES ASSOCIATION (ISDA) AND DATA SERVICE
PROVIDER MARKIT. THE COMMISSION ALLEGES THAT BETWEEN 2006 AND 2009, DEUTSCHE BÖRSE AND THE CHICAGO MERCANTILE EXCHANGE TRIED TO ENTER THE CREDIT DERIVATIVES
BUSINESS. THE EXCHANGES ALLEGEDLY TURNED TO ISDA AND MARKIT TO OBTAIN NECESSARY LICENSES FOR DATA AND INDEX BENCHMARKS, BUT, ACCORDING TO THE PRELIMINARY
FINDINGS OF THE COMMISSION, THE BANKS CONTROLLING THESE BODIES INSTRUCTED THEM TO LICENSE ONLY FOR "OVER-THE-COUNTER" (OTC) TRADING PURPOSES AND NOT FOR
EXCHANGE TRADING. ALLEGEDLY, SEVERAL OF THE INVESTMENT BANKS ALSO SOUGHT TO SHUT OUT EXCHANGES IN OTHER WAYS, FOR EXAMPLE BY COORDINATING THE CHOICE OF
THEIR PREFERRED CLEARING HOUSE. THE STATEMENT OF OBJECTIONS SEEKS FINES IN AN AMOUNT TO BE DETERMINED BY THE COMMISSION AS WELL AS IMPOSITION OF A CEASE AND
DESIST 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:
Dismissed
11. Resolution Date (MM/DD/YYYY):
12/04/2015
 Exact
 Explanation
If not exact, provide explanation:
HSBC RECEIVED NOTIFICATION THAT THE EUROPEAN COMMISSION CLOSED ITS INVESTIGATION WITH NO FINDINGS.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
NONE
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: 
NONE
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).
ON DECEMBER 04, 2015, THE EUROPEAN COMMISSION CLOSED ITS INVESTIGATION OF 13 INVESTMENT BANKS, INCLUDING HSBC, WITH REGARD TO ALLEGED ANTI-TRUST ACTIVITY IN
THE CREDIT DEFAULT SWAPS MARKET, WITHOUT ANY FINDINGS.

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:

( )
g
p
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:
REPUBLIC NEW YORK SECURITIES
CORPORATION ("RNYSC")
(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) 
UNITED STATES ATTORNEY FOR THE SOUTHERN DISTRICT OF NEW YORK
2.
Principal Sanction:
Revocation
Other Sanctions: 
IN JANUARY, 2002,THE COURT ENTERED A JUDGEMENT AND SENTENCED RNYSC TO AN ORDER OF RESTITUTION TO VARIOUS INVESTORS TOTALING $606 MILLION.
3.
Date Initiated (MM/DD/YYYY): 
08/01/1999
 Exact
 Explanation
If not exact, provide explanation:
DATE INITIATED IS AN APPROXIMATE DATE.
4.
Docket/Case Number:
FILE NO. 3-10653
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Futures - Financial
Other Product Types: 
SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
PURSUANT TO A PLEA AGREEMENT ENTERED INTO WITH THE UNITED STATES ATTORNEY'S OFFICE FOR THE SOUTHERN DISTRICT OF NEW YORK, REPUBLIC NEW YORK SECURITIES
CORPORATION ("RNYSC") PLEADED GUILTY IN DECEMBER, 2001 TO A TWO-COUNT FELONY INFORMATION CHARGING ONE COUNT OF CONSPIRACY TO VIOLATE THE FEDERAL SECURITIES
AND COMMODITIES LAWS AND ONE COUNT OF VIOLATION OF THE SECURITIES LAWS.
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):
12/17/2001
 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: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
"RNYSC" AGREED TO PAY $606 MILLION IN RESTITUTION.
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 CONJUNCTION WITH ITS GUILTY PLEA, "RNYSC" ALSO ENTERED INTO AGREEMENTS WITH EACH OF THE SECURITIES AND EXCHANGE COMMISSION AND THE COMMODITIES
FUTURES TRADING COMMISSION UNDER WHICH THOSE AGENCIES ISSUED ADMINISTRATIVE ORDERS REVOKING THE LICENSES THEY HAD PREVIOUSLY GRANTED TO "RNYSC",AND IN
THE CASE OF THE CFTC IMPOSING A CIVIL MONETARY PENALTY. SEPARATELY, THE COMMISSION ISSUED A TEMPORARY ORDER EXEMPTING "RNYSC'S" NEW PARENT HSBC, AS WELL
AS HSBC ASSET MANAGEMENT FROM THE PROVISIONS OF SECTION 9(A) OF THE INVESTMENT COMPANY ACT. "RNYSC" IS A DORMANT COMPANY AND NO LONGER CONDUCTS
ACTIVITIES.
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).

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
No Information Filed
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) 
CHICAGO MERCANTILE EXCHANGE
2.
Principal Sanction:
Other
Other Sanctions: 
MONETARY FINE
3.
Date Initiated (MM/DD/YYYY): 
03/04/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
14-7876
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
FUTURES - FINANCIAL
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC ASSIGNED INCORRECT CUSTOMER TYPE INDICATOR CODES TO FUTURES ACCOUNTS FOR THE PERIOD 12/1/2013 TO 12/31/2013. THIS WAS A VIOLATION OF CME RULE 536.
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):

03/19/2014
 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: $ 5,000.00
 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: 
HSBC ASSIGNED INCORRECT CUSTOMER TYPE INDICATOR CODES TO FUTURES ACCOUNTS FOR THE PERIOD 12/1 TO 12/31/2013. THIS IS A VIOLATION OF CME RULE 536. AS A
RESULT, THE CME IMPOSED A FINE OF $5,000 ON HSBC ON 3/4/2014. HSBC MADE ADJUSTMENTS TO ITS INTERNAL SYSTEM TO CORRECT THE DISCREPANCIES. HSBC PAID THE FINE
ON 5/19/2014.
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 ASSIGNED INCORRECT CUSTOMER TYPE INDICATOR CODES TO FUTURES ACCOUNTS FOR THE PERIOD 12/1 TO 12/31/2013. THIS IS A VIOLATION OF CME RULE 536. AS A RESULT,
THE CME IMPOSED A FINE OF $5,000 ON HSBC ON 3/4/2014. HSBC MADE ADJUSTMENTS TO ITS INTERNAL SYSTEM TO CORRECT THE DISCREPANCIES. HSBC PAID THE FINE ON 5/19/2014.

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
MONETARY/FINE/CENSURE
3.
Date Initiated (MM/DD/YYYY): 
04/22/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2012033087701
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC VIOLATED FINRA RULE 7450 AND SEC RULE 10B-10. WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE SANCTIONS AND TO THE
ENTRY OF FINDINGS THAT IT TRANSMITTED REPORTABLE ORDER EVENTS (ROES) THAT WERE REJECTED AND REPAIRABLE. AS A RESULT, HSBC FAILED TO REPAIR ROES DURING A REVIEW
PERIOD THAT WERE REJECTED BY THE ORDER AUDIT TRAIL SYSTEM (OATS) FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE; FAILED TO REPAIR A PORTION OF THE REJECTED
ROES WITHIN THE REQUIRED FIVE BUSINESS DAYS; AND FAILED TO POPULATE THE CORRECT REJECTED ROE ID. THE FINDINGS STATED THAT HSBC TRANSMITTED TO OATS ROUTE OR
COMBINED ORDER/ROUTE REPORTS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE CORRESPONDING NEW ORDER TRANSMITTED BY THE DESTINATION MEMBER FIRM DUE TO
INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. HSBC FAILED TO TIMELY REPORT ROES TO OATS; SUBMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS
WHICH OATS WAS UNABLE TO LINK TO THE EXECUTION REPORTS TO THE RELATED TRADE REPORTS DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED INFORMATION;
SUBMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT IT WAS NOT REQUIRED TO REPORT; SUBMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS WHICH OATS
WAS UNABLE TO LINK TO THE RELATED ORDER IN THE NEW YORK STOCK EXCHANGE DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA; SUBMITTED ROUTE OR
COMBINED ORDER/ROUTE REPORTS WITH INCORRECT DESTINATION CODES; SUBMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS WHICH OATS WAS UNABLE TO MATCH WITH THE
IDENTIFIED RECEIVING FIRM'S RELATED NEW ORDER REPORT; FAILED TO PROPERLY APPEND THE SPECIAL HANDLING CODE OF "CNH" (CASH NOT HELD) TO ORDERS; AND FAILED TO
SUBMIT FOR ORDERS A REQUIRED COMBINED ORDER/EXECUTION REPORT TO OATS FOR ORDERS INVOLVING ERROR CORRECTIONS. THE HSBC ALSO FAILED TO PROVIDE WRITTEN
NOTIFICATION DISCLOSING TO ITS CUSTOMER ITS CORRECT CAPACITY IN THE TRANSACTION.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/03/2014
 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: $ 22,500.00
 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: 
FINRA ALLEGED THAT HSBC VIOLATED FINRA RULE 7450 AND SEC RULE 10B-10. WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE SANCTIONS AND TO
THE ENTRY OF FINDINGS THAT IT TRANSMITTED REPORTABLE ORDER EVENTS (ROES) THAT WERE REJECTED AND REPAIRABLE. AS A RESULT, HSBC FAILED TO REPAIR ROES DURING A
REVIEW PERIOD THAT WERE REJECTED BY THE ORDER AUDIT TRAIL SYSTEM (OATS) FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE; FAILED TO REPAIR A PORTION OF
THE REJECTED ROES WITHIN THE REQUIRED FIVE BUSINESS DAYS; AND FAILED TO POPULATE THE CORRECT REJECTED ROE ID. THE FINDINGS STATED THAT HSBC TRANSMITTED TO
OATS ROUTE OR COMBINED ORDER/ROUTE REPORTS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE CORRESPONDING NEW ORDER TRANSMITTED BY THE DESTINATION
MEMBER FIRM DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. HSBC FAILED TO TIMELY REPORT ROES TO OATS; SUBMITTED EXECUTION OR COMBINED
ORDER/EXECUTION REPORTS WHICH OATS WAS UNABLE TO LINK TO THE EXECUTION REPORTS TO THE RELATED TRADE REPORTS DUE TO INACCURATE, INCOMPLETE OR
IMPROPERLY FORMATTED INFORMATION; SUBMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT IT WAS NOT REQUIRED TO REPORT; SUBMITTED ROUTE OR
COMBINED ORDER/ROUTE REPORTS WHICH OATS WAS UNABLE TO LINK TO THE RELATED ORDER IN THE NEW YORK STOCK EXCHANGE DUE TO INACCURATE, INCOMPLETE OR
IMPROPERLY FORMATTED DATA; SUBMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS WITH INCORRECT DESTINATION CODES; SUBMITTED ROUTE OR COMBINED
ORDER/ROUTE REPORTS WHICH OATS WAS UNABLE TO MATCH WITH THE IDENTIFIED RECEIVING FIRM'S RELATED NEW ORDER REPORT; FAILED TO PROPERLY APPEND THE SPECIAL
HANDLING CODE OF "CNH" (CASH NOT HELD) TO ORDERS; AND FAILED TO SUBMIT FOR ORDERS A REQUIRED COMBINED ORDER/EXECUTION REPORT TO OATS FOR ORDERS
INVOLVING ERROR CORRECTIONS. THE HSBC ALSO FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER ITS CORRECT CAPACITY IN THE TRANSACTION.
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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC WAS CENSURE AND FINED $22,500(COMPRISED OF $20,000 FOR OATS VIOLATIONS AND $2,500 FOR THE SEC RULE 10B-10
VIOLATIONS).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
TRACE-ELIGIBLE SECURITIES
3.
Date Initiated (MM/DD/YYYY): 
02/26/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2012033847501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
TRACE-ELIGIBLE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC VIOLATED FINRA RULE 6730(B)(2) AND FINRA RULE 2010. WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE SANCTIONS AND TO
THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) LARGE BLOCK S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES
WITHIN 15 MINUTES OF THE TIME OF EXECUTION, FAILED TO REPORT TO TRACE S1 CUSTOMER TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT, AND
FAILED TO REPORT TO TRACE INTERDEALER TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/03/2014
 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: $ 37,500.00
 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: 
FINRA ALLEGED THAT HSBC VIOLATED FINRA RULE 6730(B)(2) AND FINRA RULE 2010. WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC CONSENTED TO THE SANCTIONS AND
TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) LARGE BLOCK S1 TRANSACTIONS IN TRACE-ELIGIBLE
SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION, FAILED TO REPORT TO TRACE S1 CUSTOMER TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS REQUIRED
TO REPORT, AND FAILED TO REPORT TO TRACE INTERDEALER TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT.
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).

WITHOUT ADMITTING OR DENYING THE FINDINGS,HSBC WAS CENSURED AND FINED $37,500.

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 
01/20/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20120315951

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
EQUITY DERIVATIVES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC VIOLATED NYSE AMEX RULE 980(C) AND NYSE AMEX RULE 320(E). MARKET REGULATION'S REVIEW REVEALED THAT IN VIOLATION OF NYSE AMEX RULE 980(C)
HSBC ACCEPTED AND PROCEDDED AN EED TO EXERCISE 750 AT-THE-MONEY BRCM JANUARY 35 CALLS ON EXPIRATION SATURDAY, JANUARY 21, 2012, AFTER THE 5:30 P.M. ET CUTOFF ON
FRIDAY JANUARY 20, 2012. FURTHERMORE, A REVIEW OF HSBC'S WRITTEN SUPERVISORY PROCEDURES ("WSPS") FOUND THAT HSBC DID NOT HAVE ADEQUATE PROCESS OR PROCEDURES
IN PLACE FOR COMPLIANCE WITH NYSE AMEX RULE 980.
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):
08/07/2012
 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: $ 4,500.00
 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: 
IN VIOLATION OF THE NYSE AMEX RULE 980(C) HSBC ACCEPTED AND PROCESSED CONTRARY EXERCISE INSTRUCTIONS TO EXERCISE 750 AT-THE-MONEY BRCM JANUARY 35 CALLS
ON EXPIRATION SATURADAY, JANUARY 21, 2012, RECEIVED AFTER THE 5:30 P.M. ET CUTOFF ON FRIDAY JANUARY 20, 2012. HSBC CONSENT TO PAY A FINE OF $1,000. IN VIOLATION
OF THE NYSE AMEX RULE 320(E) A REVIEW OF HSBC'S WRITTEN SUPERVISORY PROCEDURES ("WSP") FOUND THAT HSBC DID NOT HAVE ADEQUATE PROCESS OR PROCEDURES IN
PLACE FOR COMPLIANCE WITH NYSE AMEX RULE 980.
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 VIEW OF THE FOREGOING MARKET REGULATION, HSBC WAS ISSUED A FINE FOR MINOR VIOLATION OF RULES DATED AUGUST 7, 2012 IN THE TOTAL AMOUNT OF $4,500 PURSUANT TO
NYSE MKT RULE 476A (IMPOSITION OF FINES FOR MINOR VIOLATION OF RULES) $1,000 FOR HSBC'S VIOLATION OF NYSE AMEX OPTIONS RULE 980(C) AND #3,500 FOR VIOLATING NYSE
AMEX RULE 320(E).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 
02/26/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2011027541201
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT HSBC VIOLATED FINRA RULES 5210 AND 2010, NASD RULES 2110 AND 3010. FINRA ALLEGED THAT HSBC ERRONEOUSLY DESIGNATED TWO ACCOUNTS LOCATED IN
THE FIRM'S LONDON AFFILIATE TO AUTOMATICALLY TRANSMIT TRADE VOLUME IN U.S.-LISTED SECURITIES TO BLOOMBERG CAUSING HSBC TO OVERSTATE ITS EXECUTED TRADE VOLUME.
THE FINDINGS STATED THAT THE HSBC'S SUPERVISORY SYSTEM WITH RESPECT TO THE ADVERTISING OF TRADE VOLUME TO PRIVATE SERVICE PROVIDERS DID NOT PROVIDE FOR
SUPERVISION DESIGNED TO ACHIEVE COMPLIANCE WITH CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/OR FINRA/NASD RULES.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/10/2014
 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: $ 150,000.00
 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: 
FINRA ALLEGED THAT HSBC VIOLATED FINRA RULES 5210 AND 2010, NASD RULES 2110 AND 3010. FINRA ALLEGED THAT HSBC ERRONEOUSLY DESIGNATED TWO ACCOUNTS
LOCATED IN THE FIRM'S LONDON AFFILIATE TO AUTOMATICALLY TRANSMIT TRADE VOLUME IN U.S.-LISTED SECURITIES TO BLOOMBERG CAUSING HSBC TO OVERSTATE ITS
EXECUTED TRADE VOLUME. THE FINDINGS STATED THAT THE HSBC'S SUPERVISORY SYSTEM WITH RESPECT TO THE ADVERTISING OF TRADE VOLUME TO PRIVATE SERVICE
PROVIDERS DID NOT PROVIDE FOR SUPERVISION DESIGNED TO ACHIEVE COMPLIANCE WITH CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/OR FINRA/NASD
RULES.
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).
WITHOUT ADMITTING OR DENYING THE FINDINGS HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED $150,000.

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
No Information Filed
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) 
CHICAGO MERCANTILE EXCHANGE AND CHICAGO BOARD OF TRADE
2.
Principal Sanction:
Other
Other Sanctions: 
MONTERY FINE
3.
Date Initiated (MM/DD/YYYY): 
05/08/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE NUMBER 13-7817
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RECORDKEEPING
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD OF NOVEMBER 1, 2013 THROUGH JANUARY 31, 2014, HSBC SECUITIES (USA) INC. ("HSBC") VIOLATED RULE 576 BY FAILING TO MAINTAIN ACCURATE AND CURRENT
REGISTRATION IN THE EXCHANGE FEE SYSTEM ("EFS"), SUBMITTING ERRONEOUS TAG 50 IDS WITH ORDER MESSAGES, AND SUBMITTING TEST MESSAGES INTO PRODUCTION CME
GLOBEX. HSBC ALSO VIOLATED RULE 512 ("REPORTING INFRACTIONS").
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):
05/23/2014
 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: $ 5,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC PAID $5,000 FINE. THE ALLOCATION OF THE FINE ACROSS BOTH CHICAGO MERCANTILE EXCHANGE AND CHICAGO BOARD
OF TRADE IS BASED UPON THE SAME ACTIVITY OCCURRING AT EACH DESIGNATED CONTACT MARKET. (COMPRISED OF $2,500 FOR FAILING TO MAINTAIN ACCURATE AND CURRENT
REGISTRATION IN THE EXCHANGE FEE SYSTEM (EFS) AND $2,500 FOR REPORTING INFRACTIONS.
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).

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
No Information Filed
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) 
CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY FINE

3.
Date Initiated (MM/DD/YYYY): 
05/27/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 14-0095/ICT#101942
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OPTIONS EXCHANGE, INC.("CBOE"") ALLEGED THAT HSBC SECURITIES (USA) INC.("HSI") VIOLATED EXCHANGE RULE 3.6A, BY FAILING TO REGISTER ITS CHIEF
COMPLIANCE OFFICER AS A PROPRIETARY TRADER COMPLIANCE OFFICER; FAILED TO REGISTER ONE ASSOCIATED PERSON AS A PROPRITARY TRADING PRINCIPAL AND FAILED TO
REGISTER FOUR ASSOCIATED PERSONS AS PROPRIETARY TRADERS.
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:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
09/08/2014
 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: $ 17,500.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS HSBC CONSENTED TO THE DESCRIBED SANCTIONS AND TO ENTRY OF FINDINGS. HSBC WAS CENSURED AND FINED $17,500.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
FINED.
3.
Date Initiated (MM/DD/YYYY): 
08/26/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FINRA MATTER ID:20130359431
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
NYSE MKT RULE 320. OFFICES - APPROVAL, SUPERVISON AND CONTROL.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA) INC. FAILED TO (I) PROPERLY MONITOR AND RECONCILE DISCREPANCIES WITH ITS CUSTOMER OPTIONS POSITIONS ON FILE AT THE OPTIONS CLEARING
CORPORATION ("OCC"), WHICH CAUSED INACCURATE OPEN INTEREST RECORDS FOR 183 BUSINESS DAYS BETWEEN FEBRUARY 24, 2012 AND NOVEMBER 9, 2012, IN ONE INSTANCE, AND
FOR 303 BUSINESS DAYS BETWEEN OCTOBER 6, 2011 AND DECEMBER 14, 2012, IN THE SECOND INSTANCE, UNTIL HSBC WAS INSTRUCTED TO EXERCISE THE SUBJECT POSITIONS AND
(III) MAINATIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES RELATED TO OCC ADJUSTMENTS AND RECONCILATION PROCESSES.
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):
09/22/2014
 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: $ 3,500.00
 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: 
WITHOUT ADMITTING OR DENYING ANY VIOLATION, HSBC WAS FINED $3,500.00.
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).

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 BANK 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.K. FINANCIAL CONDUCT AUTHORITY ("FCA")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/11/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FIRM REFERENCE 114216
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
CURRENCY - OTC
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE U.K. FINANCIAL CONDUCT AUTHORITY ("FCA") ALLEGED FAILINGS IN HSBC BANK PLC'S ("HSBC") SYSTEMS AND CONTROLS IN ITS LONDON G10 SPOT FX VOICE TRADING BUSINESS.
IN PARTICULAR, IT ALLEGED THAT HSBC DID NOT EXERCISE ADEQUATE AND EFFECTIVE CONTROL FROM JANUARY 1, 2008 TO OCTOBER 15, 2013 OVER RISKS ASSOCIATED WITH
CONFIDENTIALITY, CONFLICTS OF INTEREST AND TRADING CONDUCT ARISING FROM THIS BUSINESS.
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):
11/11/2014
 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: $ 344,428,259.70
 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: 
ON NOVEMBER 11, 2014, THE FCA REACHED A SETTLEMENT WITH HSBC BANK PLC ("HSBC") IN CONNECTION WITH ITS INVESTIGATION INTO THE G10 SPOT FX VOICE TRADING
BUSINESS. THE FCA ISSUED A FINAL NOTICE, FIRM REFERENCE NUMBER 114216, FINDING THAT HSBC'S SYSTEM AND CONTROL FAILINGS CONSTITUTED A BREACH OF PRINCIPLE 3
OF THE FCA'S PRINCIPLES FOR BUSINESSES, AND ACCORDINGLY IMPOSED A FINANCIAL PENALTY OF £216,363,000 (£58,863,000 OF WHICH IS ATTRIBUTABLE TO THE BREACH OF
PRINCIPLE 3, AND £157,500,000 OF WHICH IS FOR THE PURPOSES OF "CREDIBLE DETERRENCE"). ON NOVEMBER 11, 2014, THE BLOOMBERG EXCHANGE RATE, GBP HISTORICAL
PRICE WAS 1.5919, WHICH CONVERTS THE £216,363,000 FINE TO APPROXIMATELY $344,428,259.70.
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).
ON NOVEMBER 11, 2014, THE FCA REACHED A SETTLEMENT WITH HSBC BANK PLC ("HSBC") IN CONNECTION WITH ITS INVESTIGATION INTO THE G10 SPOT FX VOICE TRADING BUSINESS.
THE FCA ISSUED A FINAL NOTICE, FIRM REFERENCE NUMBER 114216, FINDING THAT HSBC'S SYSTEM AND CONTROL FAILINGS CONSTITUTED A BREACH OF PRINCIPLE 3 OF THE FCA'S
PRINCIPLES FOR BUSINESSES, AND ACCORDINGLY IMPOSED A FINANCIAL PENALTY OF £216,363,000 (£58,863,000 OF WHICH IS ATTRIBUTABLE TO THE BREACH OF PRINCIPLE 3, AND
£157,500,000 OF WHICH IS FOR THE PURPOSES OF "CREDIBLE DETERRENCE"). ON NOVEMBER 11, 2014, THE BLOOMBERG EXCHANGE RATE, GBP HISTORICAL PRICE WAS 1.5919, WHICH
CONVERTS THE £216,363,000 FINE TO APPROXIMATELY $344,428,259.70.

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 BANK 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. COMMODITY FUTURES TRADING COMMISSION ("CFTC")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST; UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
11/11/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NO. 15-07 ("CFTC ORDER")
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
CURRENCY - OTC
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE U.S. COMMODITY FUTURES TRADING COMMISSION ("CFTC") ALLEGED THAT HSBC BANK PLC ("HSBC"), PRINCIPALLY THROUGH TRADERS IN ITS LONDON G10 SPOT FX VOICE TRADING
BUSINESS, ATTEMPTED TO MANIPULATE AND/OR AIDED TRADERS AT OTHER BANKS IN ATTEMPTING TO MANIPULATE CERTAIN FX BENCHMARKS, INCLUDING THE WM/REUTERS 4 P.M.
LONDON FIX RATE, BETWEEN 2009 AND MID-2012.
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):
11/11/2014
 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: $ 275,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
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: 
ON NOVEMBER 11, 2014, THE CFTC REACHED A SETTLEMENT WITH HSBC BANK PLC ("HSBC") IN WHICH HSBC, WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS
THEREIN, CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING PROCEEDINGS PURSUANT TO SECTIONS 6(C)(4)(A) AND 6(D) OF THE COMMODITY EXCHANGE ACT, MAKING
FINDINGS, AND IMPOSING REMEDIAL SANCTIONS, CFTC DOCKET NO. 15-07 ("CFTC ORDER"). THE CFTC ORDER IMPOSED A MONETARY PENALTY OF $275 MILLION ON HSBC AND
ORDERED HSBC TO CEASE AND DESIST FROM VIOLATING SECTIONS 6(C)(3) AND 9(A)(2) OF THE COMMODITIES EXCHANGE ACT, 7 U.S.C. §§ 9(3) AND 13(A)(2) (2012), AND 17 C.F.R.
§ 180.2 (2014). IN ADDITION TO REMEDIAL ACTIONS IT HAS ALREADY TAKEN, HSBC IS REQUIRED BY THE CFTC ORDER TO UNDERTAKE CERTAIN REMEDIAL ACTIONS OUTLINED
THEREIN AND TO REPORT TO THE CFTC WITHIN 120 AND 365 DAYS OF THE CFTC ORDER ON THE STEPS IT HAS TAKEN TOWARDS UNDERTAKING SUCH REMEDIAL ACTION.
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).

ON NOVEMBER 11, 2014, THE CFTC REACHED A SETTLEMENT WITH HSBC BANK PLC ("HSBC") IN WHICH HSBC, WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS
THEREIN, CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING PROCEEDINGS PURSUANT TO SECTIONS 6(C)(4)(A) AND 6(D) OF THE COMMODITY EXCHANGE ACT, MAKING FINDINGS,
AND IMPOSING REMEDIAL SANCTIONS, CFTC DOCKET NO. 15-07 ("CFTC ORDER"). THE CFTC ORDER IMPOSED A MONETARY PENALTY OF $275 MILLION ON HSBC AND ORDERED HSBC TO
CEASE AND DESIST FROM VIOLATING SECTIONS 6(C)(3) AND 9(A)(2) OF THE COMMODITIES EXCHANGE ACT, 7 U.S.C. §§ 9(3) AND 13(A)(2) (2012), AND 17 C.F.R. § 180.2 (2014). IN
ADDITION TO REMEDIAL ACTIONS IT HAS ALREADY TAKEN, HSBC IS REQUIRED BY THE CFTC ORDER TO UNDERTAKE CERTAIN REMEDIAL ACTIONS OUTLINED THEREIN AND TO REPORT TO
THE CFTC WITHIN 120 AND 365 DAYS OF THE CFTC ORDER ON THE STEPS IT HAS TAKEN TOWARDS UNDERTAKING SUCH REMEDIAL ACTION.

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 PRIVATE BANK (SUISSE), SA
(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) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE, DISGORGEMENT, PREJUDGMENT INTEREST AND CIVIL MONEY PENALTY.

3.
Date Initiated (MM/DD/YYYY): 
11/25/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING FILE NO. 3-16288
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON NOVEMBER 25, 2014, HSBC PRIVATE BANK (SUISSE), SA ("PBRS") ENTERED INTO A SETTLEMENT WITH THE SECURITIES AND EXCHANGE COMMISSION ("SEC") RESULTING IN THE SEC
ISSUING AN ORDER. PBRS CONSENTED TO THE ENTRY OF THE ORDER THAT FINDS THAT PBRS WILLFULLY VIOLATED SECTIONS 15(A) OF THE SECURITIES EXCHANGE ACT OF 1934
("EXCHANGE ACT") AND SECTION 203(A) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") IN CONNECTION WITH PBRS, THROUGH ACTIONS OF CERTAIN RELATIONSHIP
MANAGERS, PROVIDING CROSS-BORDER BROKERAGE AND INVESTMENT ADVISORY SERVICES TO U.S. CLIENTS WITHOUT REGISTERING WITH THE SEC AS A BROKER-DEALER AND
INVESTMENT ADVISER FROM AT LEAST 2003 UNTIL 2011. ("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:
Settled
11. Resolution Date (MM/DD/YYYY):
11/25/2014
 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: $ 2,600,000.00
 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: 
THE ORDER REQUIRES PBRS TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF EXCHANGE ACT SECTION 15(A) OR
ADVISERS ACT SECTION 203(A); CENSURES PBRS, AND REQUIRES PBRS TO PAY DISGORGEMENT OF $5,723,193, PREJUDGMENT INTEREST OF $4,215,543, AND A CIVIL MONETARY
PENALTY OF $2,600,000, WHICH PBRS PAID ON DECEMBER 18, 2014.
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).
SOLELY FOR THE PURPOSE OF SETTLING THESE PROCEEDINGS, PBRS CONSENTED TO THE ORDER ADMITTING THE FACTS SET FORTH IN THE ORDER, ACKNOWLEDGING THAT ITS CONDUCT
VIOLATED THE FEDERAL SECURITIES LAWS, AND ADMITTING THE SEC'S JURISDICTION OVER IT AND THE SUBJECT MATTER. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS
OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 
11/11/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2013035963401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AGENCY DEBT SECURITIES CORPORATE DEBT SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, HSBC SECURITIES (USA)INC. ("HSBC")CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT P1

TRANSACTIONS IN TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)-ELIGIBLE CORPORATE DEBT SECURITIES TO TRACE WITHIN THE TIME PRESCRIBED BY FINRA RULES AND FAILED
TO REPORT S1 TRANSACTIONS IN TRACE-ELIGIBLE AGENCY DEBT SECURITIES TO TRACE WITHIN 15 MINUTES OF THE TIME OF EXECUTION. THE FINDINGS STATED THAT HSBC'S
SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWS AND
REGULATIONS, AND/OR FINRA/NASD RULES.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
03/18/2015
 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: $ 80,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING: HSBC SECURITIES (USA) INC. WILL REVISE ITS WRITTEN SUPERVISORY PROCEDURES.
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 SECURITIES (USA) INC. WAS CENSURED, FINED $80,000 AND WILL BE REVISING ITS WRITTEN SUPERVISORY PROCEDURES.
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).

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 FINANCE CORPORATION
(For individuals, Last, First, Middle)
CRD Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HSBC BANK USA N.A.
(For individuals, Last, First, Middle)
CRD Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HSBC MORTGAGE SERVICES INC.
(For individuals, Last, First, Middle)
CRD Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HSBC NORTH AMERICA HOLDINGS
(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) 
US DOJ, US HUD, CFPB, OTHER FEDERAL AGENCIES AND STATE ATTORNEYS GENERAL.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/05/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CIVIL ACTION NO.: 16-0199
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
HSBC FINANCE CORPORATION, HSBC BANK USA, HSBC MORTGAGE SERVICES INC. AND HSBC NORTH AMERICA HOLDINGS
6.
Principal Product Type:
Other
Other Product Types: 
RESIDENTIAL MORTGAGE LOAN ORIGINATION AND SERVICING.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CERTAIN CIVIL ALLEGATIONS RELATED TO PAST RESIDENTIAL MORTGAGE ORIGINATION, SERVICING AND FORECLOSURE PRACTICES.

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):
02/05/2016
 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: $ 100,000,000.00
 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: 
TERMS: $100 MILLION TO BE ALLOCATED AMONG PARTICIPATING FEDERAL AND STATEPARTIES, AND $370 MILLION IN CONSUMER RELIEF.
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 2016, HSBC FINANCE CORPORATION, HSBC BANK USA, HSBC MORTGAGE SERVICES INC. AND HSBC NORTH AMERICA HOLDINGS ENTERED INTO AN AGREEMENT WITH THE
U.S. DEPARTMENT OF JUSTICE,THE U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT, THE CONSUMER FINANCIAL PROTECTION BUREAU, OTHER FEDERAL AGENCIES ("FEDERAL
PARTIES") AND THE STATE ATTORNEYS GENERAL OF 49 STATES AND THE DISTRICT OF COLUMBIA ("STATE PARTIES") TO RESOLVE CIVIL CLAIMS RELATED TO PAST RESIDENTIAL
MORTGAGE LOAN ORIGINATION AND SERVICING PRACTICES. THE SETTLEMENT IS SIMILAR TO PRIOR NATIONAL MORTGAGE SETTLEMENTS REACHED WITH OTHER US MORTGAGE
SERVICERS AND INCLUDES THE FOLLOWING TERMS: $100 MILLION TO BE ALLOCATED AMONG PARTICIPATING FEDERAL AND STATEPARTIES, AND $370 MILLION IN CONSUMER RELIEF. IN
ADDITION, THE SETTLEMENT AGREEMENT SETS FOR THE NATIONAL MORTGAGE SERVICING STANDARDS TO WHICH HSBC U.S. AFFILIATES WILL ADHERE.

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

No Information Filed
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) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY / FINE
3.
Date Initiated (MM/DD/YYYY): 
06/30/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2017053137201
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
APPLICANT
6.
Principal Product Type:
Other
Other Product Types: 
EXCHANGE TRADED FUNDS, EQUITIES AND FIXED INCOME PRODUCTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN ELECTRONIC BROKERAGE
RECORDS IN NON-ERASABLE AND NON-REWRITABLE FORMAT KNOWN AS THE "WRITE ONCE, READ MANY" (WORM) FORMAT, THAT IS INTENDED TO PREVENT THE ALTERATION OR
DESTRUCTION OF BROKER-DEALER RECORDS STORED ELECTRONICALLY. THE FINDINGS STATED THAT THESE REQUIREMENTS ARE AN ESSENTIAL PART OF THE INVESTOR PROTECTION
FUNCTION BECAUSE PRESERVATION OF THESE RECORDS IS THE PRIMARY MEANS OF MONITORING COMPLIANCE WITH APPLICABLE SECURITIES LAWS, INCLUDING ANTIFRAUD
PROVISIONS AND FINANCIAL RESPONSIBILITY STANDARDS. THE FIRM FAILED TO RETAIN IN WORM FORMAT BROKERAGE ORDER MEMORANDA RECORDS RELATING TO APPROXIMATELY
12.36 MILLION TRANSACTIONS IN PREFERRED EXCHANGE-TRADED FUNDS, EQUITIES, AND FIXED INCOME PRODUCTS. OTHER AFFECTED RECORDS INCLUDED A LIMITED NUMBER OF THE
FIRM'S GENERAL LEDGER, CERTAIN INTERNAL AUDIT RECORDS, RISK MANAGEMENT CONTROL RECORDS, UNUSUAL ACTIVITY REPORTS AND CERTAIN POLICY MANUALS. THE FINDINGS ALSO
STATED THAT THE FIRM FAILED TO PROVIDE THE REQUIRED 90-DAY NOTICE TO ITS DESIGNATED EXAMINING AUTHORITY (FINRA), PRIOR TO RETAINING A VENDOR TO PROVIDE
ELECTRONIC STORAGE. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO IMPLEMENT AN AUDIT SYSTEM AS REQUIRED FOR THOSE RECORDS IT FAILED TO MAINTAIN IN WORM
FORMAT. FINRA FOUND THAT IN CERTAIN INSTANCES, THE FIRM FAILED TO OBTAIN AN ATTESTATION FROM ITS THIRD-PARTY VENDOR THAT IT WILL SUPPLY ELECTRONICALLY STORED
RECORDS TO REGULATORY AUTHORITIES IN THE EVENT THE FIRM IS UNABLE TO PROVIDE THE ELECTRONICALLY STORED RECORDS. FINRA ALSO FOUND THAT THE FIRM FAILED TO
ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SEC RULE FOR RECORD
RETENTION REQUIREMENTS. THE FIRM'S WSPS FAILED TO SPECIFY HOW THE FIRM WOULD SUPERVISE ITS COMPLIANCE WITH RECORD RETENTION REQUIREMENTS UNDER THE RULE.
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:
NOT APPLICABLE
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:

Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/30/2017
 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: $ 1,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
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: 
THE FIRM WAS CENSURED, FINED $1,500,000 AND REQUIRED TO SUBMIT TO FINRA A WRITTEN PLAN OF HOW IT WILL UNDERTAKE TO CONDUCT A COMPREHENSIVE REVIEW OF THE
ADEQUACY OF THE RELEVANT POLICIES AND PROCEDURES (WRITTEN AND OTHERWISE), INCLUDING A DESCRIPTION OF REMEDIAL MEASURES LEADING TO FULL COMPLIANCE,
RELATING TO THE CONDUCT ADDRESSED IN THE AWC. THEN IF ACCEPTABLE TO FINRA THE FIRM WILL PROMPTLY IMPLEMENT ITS COMPREHENSIVE REVIEW AND CERTIFY IN
WRITING TO FINRA THAT IT HAS ADOPTED AND IMPLEMENTED POLICIES AND PROCEDURES DESIGNED TO ENSURE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND FINRA
RULES ADDRESSED IN THE AWC.
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 SECURITIES (USA) INC. MADE PAYMENT OF $1,500,000 ON JULY 14, 2017.

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) 
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY
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 (FX) TRADING BUSINESS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FEDERAL RESERVE") HAS CONDUCTED AN INVESTIGATION INTO CERTAIN FOREIGN EXCHANGE ("FX") PRACTICES OF
HSBC HOLDINGS PLC ("HOLDINGS"), HSBC NORTH AMERICA HOLDINGS INC. ("HNAH") AND CERTAIN AFFILIATES, COLLECTIVELY REFERRED TO AS "HSBC." THE FEDERAL RESERVE'S
REVIEW IDENTIFIED CERTAIN DEFICIENCIES IN HSBC'S HISTORIC OVERSIGHT OF AND CONTROL OVER ITS FX BUSINESS.
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):
09/29/2017
 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: $ 175,000,000.00
 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).
THE FEDERAL RESERVE REVIEWED AND ASSESSED THE EFFECTIVENESS OF HSBC'S FX PRACTICES DURING THE PERIOD OCTOBER 2008 THROUGH OCTOBER 2013 AND FOUND CERTAIN
DEFICIENCIES IN ITS CONTROL AND OVERSIGHT OVER ITS FX BUSINESS. THE FEDERAL RESERVE FOUND, AMONGST OTHER THINGS, THAT HSBC FAILED TO DETECT AND ADDRESS ITS
TRADERS MISUSE OF CONFIDENTIAL CUSTOMER INFORMATION, AS WELL AS USE OF ELECTRONIC CHATROOMS TO COMMUNICATE WITH COMPETITORS ABOUT TRADING POSITIONS. THE
FEDERAL RESERVE'S ORDER REQUIRES HSBC TO PAY A PENALTY IN THE AMOUNT OF $175,296,000 AND FURTHER IMPROVE ITS CONTROL AND COMPLIANCE RISK MANAGEMENT
CONCERNING CERTAIN MARKETS ACTIVITIES. THIS INCLUDES: -THE SUBMISSION WITHIN 90 DAYS OF THE ORDER OF AN ENHANCED INTERNAL CONTROLS AND COMPLIANCE PROGRAM
AND COMPLIANCE RISK MANAGEMENT PROGRAM FOR DESIGNATED MARKETS ACTIVITIES; -AN ANNUAL REVIEW OF COMPLIANCE PROGRAMS AND PROCEDURES FOR HSBC'S DESIGNATED
MARKETS ACTIVITIES, THE RESULTS OF WHICH WILL NEED TO BE SUBMITTED TO THE FEDERAL RESERVE WITHIN NINETY DAYS OF THE CORRESPONDING ANNIVERSARY DATE OF THE
ORDER; AND THE SUBMISSION WITHIN 90 DAYS OF THE ORDER OF AN ENHANCED WRITTEN INTERNAL AUDIT PROGRAM WITH RESPECT TO HSBC'S COMPLIANCE WITH APPLICABLE U.S.
LAWS AND REGULATIONS AS WELL AS HSBC'S INTERNAL POLICIES AND PROCEDURES IN ITS DESIGNATED MARKETS ACTIVITIES.

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:
Disgorgement
Other Sanctions: 
FINE AND HSBC HOLDINGS TO MONITOR ITS COMPLIANCE WITH THE AGREEMENT'S OBLIGATIONS AND PROVIDE ANNUAL REPORTS TO THE DOJ FOR THE TERM OF THE AGREEMENT. HSBC
HOLDINGS ALSO AGREED TO FURTHER ENHANCE ITS COMPLIANCE PROGRAM AND INTERNAL CONTROLS IN THE GLOBAL MARKETS BUSINESS AND TO SELF-REPORT ANY POTENTIAL
CRIMINAL MISCONDUCT.
3.
Date Initiated (MM/DD/YYYY): 
01/17/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
1:18-CR-00030 EDNY
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):
ON JANUARY 18, 2018, THE U.S. DEPARTMENT OF JUSTICE (DOJ) ANNOUNCED THAT IT HAD ENTERED INTO A THREE-YEAR DEFERRED PROSECUTION AGREEMENT WITH HSBC HOLDINGS
PLC TO RESOLVE THE DOJ'S INVESTIGATION INTO HSBC'S HISTORICAL FOREIGN EXCHANGE SALES AND TRADING ACTIVITIES WITHIN ITS GLOBAL MARKETS BUSINESS. THE AGREEMENT
CONCERNS IMPROPER TRADING AND THE MISAPPROPRIATION OF CONFIDENTIAL CLIENT INFORMATION IN CONNECTION WITH TWO FOREIGN EXCHANGE TRANSACTIONS IN 2010 AND
2011.
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):
01/17/2018
 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. AMONG OTHER REQUIREMENTS, HSBC HOLDINGS ALSO
AGREED TO FURTHER ENHANCE ITS COMPLIANCE PROGRAM AND INTERNAL CONTROLS IN THE GLOBAL MARKETS BUSINESS AND TO SELF-REPORT ANY POTENTIAL CRIMINAL
MISCONDUCT.
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: 
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. HSBC HOLDINGS MADE THE $63.1 MILLION FINE PAYMENT ON JANUARY 23, 2018, AND IS REQUIRED TO PAY THE RESTITUTION WITHIN 30 DAYS AFTER EXECUTION OF
THE AGREEMENT.
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).
ON JANUARY 18, 2018, THE U.S. DEPARTMENT OF JUSTICE (DOJ) ANNOUNCED THAT IT HAD ENTERED INTO A THREE-YEAR DEFERRED PROSECUTION AGREEMENT WITH HSBC HOLDINGS
PLC TO RESOLVE THE DOJ'S INVESTIGATION INTO HSBC'S HISTORICAL FOREIGN EXCHANGE SALES AND TRADING ACTIVITIES WITHIN ITS GLOBAL MARKETS BUSINESS. THE AGREEMENT
CONCERNS IMPROPER TRADING AND THE MISAPPROPRIATION OF CONFIDENTIAL CLIENT INFORMATION IN CONNECTION WITH TWO FOREIGN EXCHANGE TRANSACTIONS IN 2010 AND
2011. 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. HSBC HOLDINGS MADE THE $63.1 MILLION FINE PAYMENT ON JANUARY 23, 2018, AND IS REQUIRED TO PAY THE RESTITUTION WITHIN 30 DAYS AFTER EXECUTION OF THE
AGREEMENT.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. AMONG OTHER REQUIREMENTS, HSBC HOLDINGS ALSO AGREED TO
FURTHER ENHANCE ITS COMPLIANCE PROGRAM AND INTERNAL CONTROLS IN THE GLOBAL MARKETS BUSINESS AND TO SELF-REPORT ANY POTENTIAL CRIMINAL MISCONDUCT.

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
No Information Filed
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) 
US COMMODITY FUTURES TRADING COMMISSION (CFTC)
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CIVIL MONETARY PENALTY
3.
Date Initiated (MM/DD/YYYY): 
01/29/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CFTC 18-08
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JANUARY 29, 2018, THE U.S. COMMODITY FUTURES TRADING COMMISSION (CFTC) ANNOUNCED A SETTLEMENT WITH HSBC SECURITIES (USA) INC. (HSI) TO RESOLVE THE CFTC'S
INVESTIGATION INTO HSBC'S PRECIOUS METALS OPERATIONS AND TRADING. THE CFTC'S INVESTIGATION CONCLUDED THAT BETWEEN JULY 2011 THROUGH AUGUST 2014, A TRADER IN
HSBC'S NEW YORK OFFICE ENGAGED IN THE DISRUPTIVE TRADING PRACTICE OF SPOOFING (BIDDING OR OFFERING WITH THE INTENT TO CANCEL THE BID OR OFFER BEFORE
EXECUTION) WITH RESPECT TO CERTAIN PRODUCTS IN GOLD AND OTHER PRECIOUS METALS TRADED IN COMEX.
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):
01/29/2018
 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: $ 1,600,000.00
 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 ORDER, HSI AGREED TO PAY A $1.6 MILLION CIVIL MONETARY PENALTY AND AGREED TO CEASE AND DESIST FROM SPOOFING. HSI MADE THE PAYMENT ON
FEBRUARY 12, 2018.
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).
ON JANUARY 29, 2018, THE U.S. COMMODITY FUTURES TRADING COMMISSION (CFTC) ANNOUNCED A SETTLEMENT WITH HSBC SECURITIES (USA) INC. (HSI) TO RESOLVE THE CFTC'S
INVESTIGATION INTO HSBC'S PRECIOUS METALS OPERATIONS AND TRADING. THE CFTC'S INVESTIGATION CONCLUDED THAT BETWEEN JULY 2011 THROUGH AUGUST 2014, A TRADER IN
HSBC'S NEW YORK OFFICE ENGAGED IN THE DISRUPTIVE TRADING PRACTICE OF SPOOFING (BIDDING OR OFFERING WITH THE INTENT TO CANCEL THE BID OR OFFER BEFORE
EXECUTION) WITH RESPECT TO CERTAIN PRODUCTS IN GOLD AND OTHER PRECIOUS METALS TRADED IN COMEX. PURSUANT TO THE ORDER, HSI AGREED TO PAY A $1.6 MILLION CIVIL

MONETARY PENALTY AND TO CEASE AND DESIST FROM SPOOFING. HSI MADE THE PAYMENT ON FEBRUARY 12,2018. HSI NEITHER ADMITTED NOR DENIED LIABILITY. THE CFTC'S ORDER
NOTES THAT HSI AND ITS AFFILIATES CONDUCTED AN INTERNAL REVIEW INCLUDING ANALYZING THE TRADING ACTIVITY OF CERTAIN TRADERS FOR POTENTIAL SPOOFING MISCONDUCT
AND SUBSTANTIALLY ASSISTED THE DIVISION'S INVESTIGATION, INCLUDING IDENTIFYING THE TRADER'S MISCONDUCT AND PROMPTLY REPORTING IT TO THE DIVISION. IN ADDITION, THE
TRADER'S EMPLOYMENT WAS TERMINATED ONCE THE CONDUCT WAS IDENTIFIED. FURTHER, HSI HAS INITIATED AN OVERHAUL OF ITS SYSTEMS AND CONTROLS AND IMPLEMENTED A
VARIETY OF ENHANCEMENTS TO DETECT AND DETER SIMILAR CONDUCT.

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
No Information Filed
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. SECURITIES AND EXCHANGE COMMISSION ("SEC")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST AND CENSURE
3.
Date Initiated (MM/DD/YYYY): 
03/16/2020
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
FILE NO. 3-19730
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ALLEGED THAT BETWEEN NOVEMBER 2015 AND AUGUST 2017, HSBC SECURITIES (USA) INC. ("HSI") MADE FALSE AND MISLEADING STATEMENTS TO CURRENT AND PROSPECTIVE
ADVISORY CLIENTS AND FAILED TO DISCLOSE CONFLICTS OF INTEREST CONCERNING THE FACTORS HSI USED TO DETERMINE COMPENSATION FOR ITS INVESTMENT ADVISER
REPRESENTATIVES ("IARS"). THE SEC ALLEGED THAT, CONTRARY TO STATEMENTS IN ITS FORM ADV BROCHURES, HSI CONSIDERED SEVERAL FINANCIAL FACTORS RELATED TO CLIENT
ACCOUNTS TO DETERMINE ITS IARS' COMPENSATION, INCLUDING THE AMOUNT OF ADVISORY FEES CLIENTS PAID TO HSI. THE SEC ALSO ALLEGED THAT, HSI FAILED TO ADOPT AND
IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THERE UNDER IN CONNECTION WITH ITS
REPRESENTATIONS ON IAR COMPENSATION.
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):
03/16/2020
 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: $ 725,000.00
 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: 
AS PART OF THE SETTLEMENT, THE SEC ORDERED THAT HSI (I) CEASE AND DESIST FROM VIOLATING SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THERE
UNDER (II) BE CENSURED; AND (III) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $725,000. THE CIVIL MONETARY PENALTY WAS PAID ON MARCH 23, 2020.
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).
ON MARCH 16, 2020, HSI ENTERED INTO A SETTLEMENT WITH THE SEC CONCERNING HSI'S DISCLOSURES TO ADVISORY CLIENTS AND PROSPECTIVE CLIENTS FROM NOVEMBER 2015
THROUGH AUGUST 2017 REGARDING HOW IT COMPENSATES ITS DUALLY REGISTERED INVESTMENT ADVISER AND BROKER REPRESENTATIVES ("IARS"). THE SEC DETERMINED THAT HSI'S
DISCLOSURES WERE FALSE AND MISLEADING BECAUSE THEY FAILED TO DISCLOSE CONFLICTS OF INTEREST ABOUT HOW IARS' COMPENSATION WAS DETERMINED. THE SEC'S ORDER
RECOGNIZES THAT HSI DISCLOSED TO ALL BROKERAGE CUSTOMERS IN ITS CUSTOMER AGREEMENT THAT CONFLICTS OF INTEREST BETWEEN CUSTOMERS AND IARS MAY ARISE WITH
RESPECT TO RECURRING INCOME HSI RECEIVES. BUT IN SEPARATE DISCLOSURES TO ADVISORY CUSTOMERS, HSI STATED THAT IARS WERE COMPENSATED BASED SOLELY ON NON-
FINANCIAL FACTORS, AND NOT ON THE FEES PAID TO HSI. THE SEC FOUND THAT HSI DID CONSIDER FINANCIAL FACTORS IN SETTING IAR'S DISCRETIONARY BONUSES, INCLUDING THE
AMOUNT OF QUARTERLY ADVISORY FEES SPECTRUM AND MANAGED PORTFOLIO ACCOUNT ("MPA") PROGRAM CLIENTS PAID TO HSI, WHICH GAVE IARS AN INCENTIVE TO GENERATE THOSE
FEES. THE SEC FURTHER DETERMINED THAT HSI LACKED SUFFICIENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS PERTAINING TO ITS
REPRESENTATIONS ABOUT IARS' COMPENSATION. ON MARCH 16, 2020, WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, HSI AGREED TO CEASE AND DESIST VIOLATING THE
STATUTES AND RULES THE SEC DETERMINED IT VIOLATED, A CENSURE AND TO PAY A FINE OF $725,000. THE CIVIL MONETARY PENALTY WAS PAID ON MARCH 23, 2020.

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
No Information Filed
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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)
2.
Principal Sanction:
Censure
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/02/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2018059528401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
NO PRODUCT
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THEENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A
SUPERVISORY SYSTEM OR WSPSREASONABLY DESIGNED TO SCREEN NON-REGISTERED ASSOCIATED PERSONS FOR STATUTORY DISQUALIFICATION.THE FINDINGS STATED THAT THE
FIRM'S WRITTEN PROCEDURES ONLY ADDRESSED FINGERPRINTING AND SCREENING FOR STATUTORY DISQUALIFICATION OF REGISTERED INDIVIDUALS ORTHOSE REQUIRED TO BE
REGISTERED. THE PROCEDURES DID NOT REQUIRE THAT NON-REGISTERED ASSOCIATED PERSONS BE FINGERPRINTED AND SCREENED FOR STATUTORY DISQUALIFICATION. THE FIRMALSO
FAILED TO ASSIGN PERSONNEL TO IDENTIFY AND SCREEN NON-REGISTERED ASSOCIATED PERSONS.AFTER IDENTIFYING THIS ISSUE, THE FIRM WAS ABLE TO FINGERPRINT AND SCREEN
SOME OF THE NON-REGISTERED ASSOCIATED PERSONS. THROUGH THIS PROCESS THE FIRM DID NOT IDENTIFY ANY INDIVIDUALS WHO WERE SUBJECT TO STATUTORY DISQUALIFICATION.
HOWEVER, THE FIRM WAS UNABLE TOFINGERPRINT AND SCREEN OTHER INDIVIDUALS BECAUSE THEY WERE NO LONGER ASSOCIATED WITH THEFIRM AND THUS COULD NOT DETERMINE
WHETHER THOSE INDIVIDUALS WERE SUBJECT TO STATUTORY DISQUALIFICATION.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
02/02/2021
 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: $ 650,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
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: 
THE FIRM WAS CENSURED, FINED $650,000, AND IS REQUIRED TO REVIEW ITS SYSTEMS AND PROCEDURES REGARDING THE IDENTIFICATION, FINGERPRINTING, AND SCREENING
OF NON-REGISTERED ASSOCIATED PERSONS TO ENSURE THAT CURRENT SYSTEMS AND PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH GOVERNING
SECURITIES LAWS AND REGULATIONS. THE MONETARY PENALTY WAS PAID ON FEBRUARY 25,2021.
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).

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
No Information Filed
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) 
STATE OF WASHINGTON OFFICE OF INSURANCE COMMISSIONER
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/17/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
21-0133
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Insurance
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OFFICE OF THE INSURANCE COMMISSIONER FOR THE STATE OF WASHINGTON FOUND THAT THE FIRM VIOLATED WAC-284-17-473 BY NOT AFFILIATING 4 INSURANCE PRODUCERS
WHO CONDUCTED BUSINESS WITHIN THE STATE. THE FIRM HAS SINCE AFFILIATED ALL AGENTS LICENSED TO SELL INSURANCE IN THE STATE. THE FIRM ENTERED INTO A CONSENT
ORDER LEVYING A FINE AND THE IMPOSITION OF A $10,000 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:
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):
04/22/2021
 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: $ 10,000.00
 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: 
TOTAL FINE- $10,000.00. PORTION AGAINST APPLICANT -$10,000.00 WAS PAID ON 4/22/21.
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).
CONSENT ORDER WAS AGREED TO BY APPLICANT ON 4/22/2021.

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
No Information Filed
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) 
CBOE BZX EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/16/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
STAR NO. 20180577360 / FILE NO. USRI-8018-05
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA) INC. VIOLATED RULES 15C3-5(B) AND (C)(1)(II), AND BZX RULES 3.2 AND 5.1 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY
PROCEDURES WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON
AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS.
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):
04/20/2021
 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: $ 9,000.00
 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: 
A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $9,000. PORTION AGAINST APPLICANT $9,000.00 WAS PAID ON MAY 6, 2021.
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).

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
No Information Filed
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) 
CBOE BYX EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/16/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
STAR NO. 20180577360 / FILE NO. USRI-8018-06
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA) INC. VIOLATED RULES 15C3-5(B) AND (C)(1)(II) AND BYX RULES 3.2 AND 5.1 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY
PROCEDURES WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON

AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS.
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):
04/20/2021
 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: $ 9,000.00
 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: 
A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $9,000. PORTION AGAINST APPLICANT $9,000.00 WAS PAID ON MAY 6, 2021.
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).

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
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.

y
( )
g
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) 
CBOE EDGX EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/16/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
STAR NO. 20180577360 / FILE NO. USRI-8018-07
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA) INC. VIOLATED RULES 15C3-5(B) AND (C)(1)(II), AND EDGX RULES 3.2 AND 5.1 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY
PROCEDURES WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON
AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS.
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):
04/20/2021
 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: $ 9,000.00
 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: 
A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $9,000. PORTION AGAINST APPLICANT $9,000.00 WAS PAID ON MAY 6, 2021.
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).

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
No Information Filed
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) 
CBOE EDGA EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 

04/16/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
STAR NO. 20180577360 / FILE NO. USRI-8018-08
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA) INC. VIOLATED RULES 15C3-5(B) AND (C)(1)(II), AND EDGA RULES 3.2 AND 5.1 IN THAT THE FIRM'S FINANCIAL RISK MANAGEMENT CONTROLS AND SUPERVISORY
PROCEDURES WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS, BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, ON
AN ORDER-BY-ORDER BASIS OR OVER A SHORT PERIOD OF TIME, OR THAT INDICATE DUPLICATIVE ORDERS.
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):
04/20/2021
 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: $ 9,000.00
 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: 
A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $9,000. PORTION AGAINST APPLICANT $9,000.00 WAS PAID ON MAY 6, 2021.
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).

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
No Information Filed
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) 
NASDAQ STOCK MARKET
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/28/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2018057736001
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
UNSPECIFIED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT ENTERED ERRONEOUS ORDERS. THE FINDINGS
STATED THAT ON MARCH 9, 2018, A FOREIGN BANK AFFILIATE SENT TO THE FIRM A MARKET ON CLOSE (MOC) ORDER, WHICH SHOULD NOT HAVE BEEN EXECUTED UNTIL THE CLOSE OF
TRADING, TO BUY 37,000 SHARES OF AN EQUITY SECURITY. THE FIRM'S TRADER ENTERED THE ORDER INTO THE FIRM'S SMART ORDER ROUTER (SOR) USING AN AUTOMATED MOC
"HOTKEY" FUNCTION IN THE FIRM'S ORDER ENTRY SYSTEM. HOWEVER, DUE TO FAULTY HOTKEY PROGRAMMING, THE ORDER WAS ENTERED AS A REGULAR MARKET ORDER. UPON RECEIPT
OF THE ORDER, THE FIRM'S SOR IMMEDIATELY ROUTED CHILD ORDERS TO MARKET WITH LIMIT PRICES UP TO 27.9 PERCENT ABOVE THE NATIONAL BEST OFFER (NBO). AS A RESULT, A
TOTAL OF 18,801 SHARES WERE EXECUTED WITHIN 0.3 SECONDS, REPRESENTING 84 PERCENT OF TOTAL SHARES PURCHASED IN THE SECURITY. THE FINDINGS ALSO STATED THAT THE
FIRM 'S ERRONEOUS PRICE CONTROL FOR OUTBOUND ORDERS SENT FROM THE SOR WAS NOT REASONABLY DESIGNED AND THUS FAILED TO PREVENT ENTRY OF ERRONEOUS ORDERS.
THE CONTROL WAS DESIGNED TO BLOCK ORDERS WITH LIMIT PRICES MORE THAN 10 PERCENT ABOVE THE NBO FOR A SECURITY AT THE TIME THE SOR RECEIVED THE PARENT ORDER.
THE OUTBOUND PRICE CONTROL, HOWEVER, WAS NOT DESIGNED TO BLOCK ORDERS IN THE EVENT THE CONTROL WAS NOT ABLE TO CALCULATE A PRICE THRESHOLD. FOR EXAMPLE, ON
MARCH 9, 2018, THIS CONTROL WAS NOT ABLE TO CALCULATE A PRICE THRESHOLD BECAUSE OF AN INTERRUPTION IN THE QUOTE DATA FEED. THEREFORE, THE CONTROL DID NOT
BLOCK THE ERRONEOUS ORDERS. IN ADDITION, THE FIRM'S WRITTEN DESCRIPTION OF ITS CONTROLS DID NOT REFERENCE OR DESCRIBE THE SOR OUTBOUND PRICE CONTROL. THE
FINDINGS ALSO INCLUDED THAT THE OTHER FIRM ERRONEOUS ORDER CONTROLS WERE NOT REASONABLY DESIGNED. THE FIRM MAINTAINED AN AVERAGE DAILY VOLUME (ADV) LIMIT

CONTROL. FOR TRADER-MANAGED ORDERS SUCH AS THE MARCH 9, 2018 ORDER, WHICH WERE REVIEWED AND HANDLED BY A FIRM TRADER RATHER THAN THROUGH ENTIRELY
AUTOMATED MEANS, THE ADV LIMIT APPLIED WAS 50 PERCENT OF THE SECURITY'S ADV. THE LIMIT WAS NOT REASONABLY DESIGNED FOR THE FIRM'S BUSINESS MODEL. THE 50 PERCENT
LIMIT WAS IMPLEMENTED WHEN TRADER-MANAGED CLIENT ORDERS FREQUENTLY INVOLVED ILLIQUID SECURITIES AND ROUTED EXCLUSIVELY TO OTHER BROKER DEALERS, NOT
DIRECTLY TO EXCHANGES. SINCE THEN, TRADER-MANAGED ORDERS INCREASINGLY INVOLVED LIQUID SECURITIES AND ROUTING DIRECTLY TO EXCHANGES. FURTHER, ACCORDING TO
THE FIRM'S PROCEDURES, IT SHOULD HAVE APPLIED AN ADV LIMIT OF 25 PERCENT TO THE MARCH 9, 2018 ORDER. THE FIRM SELECTED A LOWER ADV LIMIT OF 25 PERCENT IN LATE
2017, AND UPDATED ITS WRITTEN PROCEDURES ACCORDINGLY, BUT THE THRESHOLD WAS NOT UPDATED IN THE FIRM'S SYSTEMS UNTIL APRIL 2018. AS SUCH, THE FIRM'S WRITTEN
DESCRIPTION OF ITS ADV CONTROL AND LIMIT WAS INACCURATE. THE FIRM ALSO DID NOT DOCUMENT ITS RATIONALE FOR SETTING THE TRADER-MANAGED ORDER ADV THRESHOLD AT
50 PERCENT. IN ADDITION, THE FIRM COULD OVERRIDE CERTAIN CONTROL TRIGGERS ON A CASE-BY-CASE BASIS BUT THE FIRM'S WRITTEN POLICIES AND PROCEDURES DID NOT
PROVIDE GUIDANCE CONCERNING THE REVIEW PROCESS OR CRITERIA FOR SUCH OVERRIDES. FURTHERMORE, THE FIRM'S WSPS DID NOT ACCURATELY REFLECT POST-TRADE REVIEWS
OF OVERRIDES. THE FIRM ALSO HAD A NOTIONAL ORDER SIZE CONTROL FOR TRADER-MANAGED CLIENT ORDERS, WHICH APPLIED A UNIQUE THRESHOLD FOR EACH CLIENT. AS OF MARCH
9, 2018, HOWEVER, THE FIRM HAD NOT CONFIGURED THIS CONTROL TO APPLY TO TRADER-MANAGED ORDERS OF THE AFFILIATE CLIENT THAT SENT THE MOC ORDER. NASDAQ FOUND
THAT THE FIRM DID NOT HAVE REASONABLE SUPERVISORY PROCEDURES, INCLUDING WSPS, FOR TECHNOLOGY CHANGE MANAGEMENT RELATING TO THE FIRM'S ORDER ENTRY SYSTEM.
SPECIFICALLY, THE FIRM DID NOT HAVE REASONABLE SUPERVISORY PROCEDURES CONCERNING HOTKEYS USED FOR PROCESSING ORDERS. AS A RESULT, THE FIRM FAILED TO IDENTIFY
THE PROGRAMMING FLAW THAT RESULTED IN THE MOC ORDER BEING ENTERED INTO THE SOR AS A MARKET 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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
04/28/2021
 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: $ 9,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
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: 
THE FIRM WAS CENSURED, FINED A TOTAL OF $45,000, OF WHICH $9,000 IS ALLOCATED TO NASDAQ, WITH THE REMAINDER ALLOCATED TO OTHER REGULATORS, AND REQUIRED
TO REVISE ITS WRITTEN DESCRIPTION OF ITS RISK MANAGEMENT CONTROLS WITH RESPECT TO ITS PRICE CONTROL FOR OUTBOUND ORDERS SENT FROM THE SMART ORDER
ROUTER, AND WRITTEN PROCEDURES WITH RESPECT TO THE FIRM'S ABILITY TO OVERRIDE CERTAIN CONTROL TRIGGERS ON A CASE-BY-CASE BASIS.
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).
WITHOUT ADMITTING OR DENYING THE FINDINGS HSBC CONSENTED TO THE SANCTIONS TO ENTRY OF FINDINGS THAT IT ENTERED ERRONEOUS ORDERS. HSBC WAS CENSURED AND
FINED $9,000.00.

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 HOLDINGS PLC
6.
Principal Product Type:
Other
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 COMMISION ("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. AN APPEALWAS MADE TO THE GENERAL COURT OF THE EUROPEAN UNION, RESULTED IN THE FINE BEING
ANNULLED. BOTH HSBC AND THE COMMISSION ARE APPEALING TO THE COURT OF JUSTICE OF THE EUROPEAN UNION. IN JANUARY 2023 THE EU COURT OF JUSTICE UPHELD THE LIABILITY
FINDINGS OF THE GENERAL COURT. HSBC HAS APPEALLED TO THE GENERAL COURT CHALLENGING THE FINE IMPOSED BY THE COMMISSION. THAT APPEAL REMAINS PENDING.
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. IN JANUARY 2023 THE EU
COURT OF JUSTICE UPHELD THE LIABILITY FINDINGS OFTHE GENERAL COURT AND NO FURTHER LIABILITY CHALLENGE IS POSSIBLE. HSBC MAINTAINS AN APPEAL TO THE GENERAL COURT
CHALLENGING THE FINE IMPOSED BY THE COMMISSION.
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):
01/12/2023
 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: $ 35,958,420.00
 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: 
HSBC HOLDINGS PLC. IN ACCORDANCE WITH THE SETTLEMENT WILL PAY A FINE IN THE AMOUNT OF 31,739,000, EUROS. HSBC MAINTAINS AN APPEAL BEFORE THE EU GENERAL
COURT AGAINST THE FINE. SEE INFORMATION ABOVE REGARDING THE APPEALS BY THE COMMISSION AND HSBC OF THE GENERAL COURT'S SEPTEMBER 2019 JUDGMENT.
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).
THE ORIGINAL FINE ASSESSED AGAINST HSBC WAS ANNULLED. IN JANUARY 2023 THE EUROPEAN COMMISSION RE-IMPOSED A FINE OF 31,739,000 EUROS TO BE PAID BY HSBC,
REPLACING THE PRIOR FINE OF 33,606,000 EUROS. HSBC MAINTAINS AN APPEAL BEFORE THE EU GENERAL COURT 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)
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 HOLDINGS 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 RECENTLY 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 PROVISIONED FOR THE FINE NOTED IN
SECTION RESOLUTION DETAIL.
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 PLC INTENDS TO CAUSE 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 PLC INTENDS TO CAUSE 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
No Information Filed
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) 
CBOE EDGX EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
06/08/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. USRI-8669-07/URE-10-07/STAR NO. 20190634320-03
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA) INC. VIOLATED EDGX RULES 3.2 AND 11.8(C); RULE 611(C) IN THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT THE ISOS IT ROUTED MET
THE REQUIREMENTS SET FORTH IN RULES 600(B)(3) AND 600(B)(31). THE FIRM'S VENDOR RESOLVED THESE TECHNICAL ISSUES IN SEPTEMBER 2020. THE FIRM ALSO VIOLATED EDGX
RULE 5.1 IN THAT THE FIRM'S SUPERVISORY SYSTEM, INCLUDING ITS WSPS, WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RULE 611(C).
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):
06/09/2022
 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: $ 13,250.00
 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: 
A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $13,250.
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 SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN IN THE TIMEFRAME DIRECTED BY THE SRO.

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
No Information Filed
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) 
CBOE EDGA EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/08/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. USRI-8669-08/URE-10-08/STAR NO. 20190634320-08
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA), INC. VIOLATED EDGA RULES 3.2 AND 11.8(C); AND RULE 611(C) IN THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT THE ISOS IT
ROUTED MET THE REQUIREMENTS SET FORTH IN RULES 600(B)(30) AND 600(B)(31). THE FIRM'S VENDOR RESOLVED THESE TECHNICAL ISSUES IN SEPTEMBER 2020. THE FIRM ALSO
VIOLATED EDGA RULE 5.1 IN THAT THE FIRM'S SUPERVISORY SYSTEM, INCLUDING ITS WSPS, WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RULE 611(C).
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):
06/09/2022
 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: $ 6,500.00
 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: 
A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $6,500.
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 SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN IN THE TIMEFRAME DIRECTED BY THE SRO.

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
No Information Filed
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) 
CBOE BYX EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
06/08/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. USRI-8669-06/URE-10-06 / STAR NO. 20190634320-07
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA) INC. VIOLATED BYX RULES 3.2 AND 11.9(D); AND RULE 611(C) IN THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT THE ISOS IT ROUTED
MET THE REQUIREMENTS SET FORTH IN RULES 600(B)(30) AND 600(B)(31). THE FIRM'S VENDOR RESOLVED THESE TECHNICAL ISSUES IN SEPTEMBER 2020. HSBC ALSO VIOLATED BYX
RULE 5.1 IN THAT THE FIRM'S SUPERVISORY SYSTEM, INCLUDING ITS WSPS, WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RULE 611(C).
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):
06/09/2022
 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: $ 9,750.00
 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: 
A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $9,750.
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 SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN IN THE TIMEFRAME DIRECTED BY THE SRO.

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
No Information Filed
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:

g
y
y
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NEW YORK STOCK EXCHANGE
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
06/16/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2019063432005
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
INTERMARKET SWEEP ORDERS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO TAKE REASONABLE STEPS TO ENSURE
THAT INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED TO CERTAIN MARKET CENTERS MET THE REQUIREMENTS SET FORTH IN RULES 600(B)(30) AND 600(B)(31) OF REGULATION
NATIONAL MARKET SYSTEM (NMS) OF THE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS STATED THAT WHEN THE FIRM ROUTED ORDERS TO VARIOUS EXCHANGES THAT IT MARKED
AS ISOS, THREE TECHNICAL ISSUES WITH ITS VENDOR'S SMART ORDER ROUTER RESULTED IN THE FIRM NOT RECOGNIZING, AND THEN ROUTING ADDITIONAL ISOS NECESSARY TO
EXECUTE AGAINST, PROTECTED QUOTES DISPLAYED BY CERTAIN MARKET CENTERS. AS A RESULT, THE FIRM SENT A TOTAL OF 10,265 ISO ORDERS, INCLUDING 1,393 ORDERS TO NYSE,
THAT WERE PRICED THROUGH OTHER MARKET CENTERS' PROTECTED LIQUIDITY BECAUSE THE FIRM DID NOT ROUTE THE ADDITIONAL ISOS NECESSARY TO EXECUTE AGAINST THOSE
PROTECTED QUOTES. THE FIRM DID NOT IDENTIFY THESE ISSUES AND DID NOT CONDUCT A REVIEW DESIGNED TO VERIFY THAT IT ROUTED ALL NECESSARY ISOS TO EXECUTE AGAINST
PROTECTED QUOTATIONS. THE FIRM'S VENDOR HAS SINCE RESOLVED THE TECHNICAL ISSUES IN ITS SMART ORDER ROUTER SYSTEM. AS A RESULT, THE FIRM VIOLATED RULE 611(C) OF
REGULATION NMS AND NYSE RULE 7.31(E)(3). THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN
SUPERVISORY PROCEDURES (WSPS), REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RULE 611(C) OF REGULATION NMS AND NYSE RULE 7.31(E)(3). THE FIRM HAD NO REVIEWS
OR PROCEDURES TO ESTABLISH THAT ISOS IT ROUTED TO COMPLY WITH RULES 600(B)(30) AND 600(B)(31) BY EXECUTING AGAINST PROTECTED QUOTATIONS WERE SENT AND RECEIVED
BY ALL NECESSARY VENUES, ON A TIMELY BASIS, FOR THE CORRECT SIZE AND PRICE, IN COMPLIANCE WITH RULE 611(C) AND NYSE RULE 7.31(E)(3), AND, ACCORDINGLY, ITS WSPS DID
NOT DESCRIBE ANY SUCH REVIEWS OR PROCEDURES. GIVEN THAT THE FIRM CONTINUOUSLY ROUTED VIOLATIVE ISOS, THIS WAS UNREASONABLE. BECAUSE OF THESE SUPERVISORY
DEFICIENCIES, THE FIRM FAILED TO DETECT AND TIMELY REMEDIATE THE THREE TECHNICAL ISSUES WITH ITS VENDOR'S SMART ORDER ROUTER THAT CAUSED THE FIRM TO ROUTE ISOS
THAT WERE PRICED THROUGH MARKET CENTERS' PROTECTED QUOTATIONS. THE FIRM HAS SINCE REMEDIATED THESE DEFICIENCIES. AS A RESULT, THE FIRM VIOLATED NYSE RULES
3110(A) AND (B).
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/16/2022
 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: $ 17,389.00
 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: 
THE FIRM WAS CENSURED AND FINED $17,389, RESOLVED SIMULTANEOUSLY WITH SIMILAR MATTERS FOR A TOTAL FINE OF $125,000. THOSE MATTERS WERE BROUGHT BY CBOE
BYX EXCHANGE, INC. (BYX); CBOE BZX EXCHANGE, INC. (BZX); CBOE EDGA EXCHANGE, INC. (EDGA); CBOE EDGX EXCHANGE, INC. (EDGX); INVESTORS EXCHANGE, LLC (IEX); NYSE
AMERICAN LLC (NYSE AMERICAN) NYSE ARCA, INC. (ARCA); NYSE CHICAGO, INC. (CHX) (COLLECTIVELY, THE EXCHANGES), AND FINRA.
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 SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN IN THE TIMEFRAME DIRECTED BY THE SRO.

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
No Information Filed
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) 
CBOE BZX EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 

06/08/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. USRI-8669-05/URE-10-05/STAR NO. 20190634320-02
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA) INC. VIOLATED BZX RULES 3.2 AND 11.9(D); AND RULE 611(C) IN THAT THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT THE ISOS IT ROUTED
MET THE REQUIREMENTS SET FORTH IN RULES 600(B)(30) AND 600(B)(31). THE FIRM'S VENDOR RESOLVED THESE TECHNICAL ISSUES IN SEPTEMBER 2020. THE FIRM ALSO VIOLATED BZX
RULE 5.1 IN THAT THE FIRM'S SUPERVISORY SYSTEM, INCLUDING ITS WSPS, WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RULE 611(C).
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):
06/09/2022
 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: $ 13,250.00
 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: 
A CENSURE AND A MONETARY FINE IN THE AMOUNT OF $13,250.
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 SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN IN THE TIMEFRAME DIRECTED BY THE SRO.

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
No Information Filed
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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
06/09/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2019063432006
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
INTERMARKET SWEEP ORDERS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THEENTRY OF FINDINGS THAT IT FAILED TO TAKE REASONABLE STEPS TO ENSURE
THAT INTERMARKET SWEEPORDERS (ISOS) IT ROUTED TO CERTAIN MARKET CENTERS MET THE REQUIREMENTS SET FORTH IN RULES600(B)(30) AND 600(B)(31) OF REGULATION NATIONAL
MARKET SYSTEM (NMS) OF THE SECURITIESEXCHANGE ACT OF 1934. THE FINDINGS STATED THAT WHEN THE FIRM ROUTED ORDERS TO VARIOUS EXCHANGES THAT IT MARKED AS ISOS
DURING THIS PERIOD, THREE TECHNICAL ISSUES WITH ITS VENDOR'SSMART ORDER ROUTER RESULTED IN THE FIRM NOT RECOGNIZING, AND THEN ROUTING ADDITIONAL
ISOSNECESSARY TO EXECUTE AGAINST, PROTECTED QUOTES DISPLAYED BY CERTAIN MARKET CENTERS. AS ARESULT, THE FIRM SENT A TOTAL OF 10,265 ISO ORDERS THAT WERE PRICED
THROUGH OTHER MARKETCENTERS' PROTECTED LIQUIDITY BECAUSE THE FIRM DID NOT ROUTE THE ADDITIONAL ISOS NECESSARY TOEXECUTE AGAINST THOSE PROTECTED QUOTES. THE
FIRM'S VENDOR LATER RESOLVED THE TECHNICALISSUES IN ITS SMART ORDER ROUTER SYSTEM. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORYSYSTEM WAS NOT
REASONABLY DESIGNED TO COMPLY WITH RULE 611 OF REGULATION NMS. THE FIRM HADNO REVIEWS OR PROCEDURES TO ESTABLISH THAT ISOS IT ROUTED TO COMPLY WITH RULES
600(B)(30) AND600(B)(31) BY EXECUTING AGAINST PROTECTED QUOTATIONS WERE SENT AND RECEIVED BY ALL NECESSARYVENUES, ON A TIMELY BASIS, FOR THE CORRECT SIZE AND
PRICE. BECAUSE OF THESE SUPERVISORYDEFICIENCIES, THE FIRM FAILED TO DETECT AND TIMELY REMEDIATE THE THREE TECHNICAL ISSUES WITH ITSVENDOR'S SMART ORDER ROUTER

THAT CAUSED THE FIRM TO ROUTE ISOS THAT WERE PRICED THROUGHMARKET CENTERS' PROTECTED QUOTATIONS. THE FIRM HAS SINCE REMEDIATED THESE DEFICIENCIES.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/10/2022
 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: $ 19,197.00
 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: 
THE FIRM WAS CENSURED AND FINED $19,197. RELATED DISCIPLINARY ACTION ON BEHALF OF CBOE BYXEXCHANGE, INC.; CBOE BZX EXCHANGE, INC.; CBOE EDGA EXCHANGE,
INC.; CBOE EDGX EXCHANGE,INC.; INVESTORS EXCHANGE, LLC; THE NEW YORK STOCK EXCHANGE LLC; NYSE AMERICAN LLC; NYSECHICAGO, INC., AND NYSE ARCA, INC. FOR
SIMILAR VIOLATIONS IS BEING TAKEN CONCURRENTLY INCONJUNCTION WITH THIS MATTER.
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 SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN IN THE TIMEFRAME DIRECTED BY THE SRO.

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

No Information Filed
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) 
NYSE ARCA, INC.
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
06/16/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2019063432001
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
INTERMARKET SWEEP ORDERS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO TAKE REASONABLE STEPS TO ENSURE
THAT INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED TO CERTAIN MARKET CENTERS MET THE REQUIREMENTS SET FORTH IN RULES 600(B)(30) AND 600(B)(31) OF REGULATION
NATIONAL MARKET SYSTEM (NMS) OF THE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS STATED THAT WHEN THE FIRM ROUTED ORDERS TO VARIOUS EXCHANGES THAT IT MARKED
AS ISOS, THREE TECHNICAL ISSUES WITH ITS VENDOR'S SMART ORDER ROUTER RESULTED IN THE FIRM NOT RECOGNIZING, AND THEN ROUTING ADDITIONAL ISOS NECESSARY TO
EXECUTE AGAINST, PROTECTED QUOTES DISPLAYED BY CERTAIN MARKET CENTERS. AS A RESULT, THE FIRM SENT A TOTAL OF 10,265 ISO ORDERS, INCLUDING 2,107 ORDERS TO NYSE
ARCA, THAT WERE PRICED THROUGH OTHER MARKET CENTERS' PROTECTED LIQUIDITY BECAUSE THE FIRM DID NOT ROUTE THE ADDITIONAL ISOS NECESSARY TO EXECUTE AGAINST
THOSE PROTECTED QUOTES. THE FIRM DID NOT IDENTIFY THESE ISSUES AND DID NOT CONDUCT A REVIEW DESIGNED TO VERIFY THAT IT ROUTED ALL NECESSARY ISOS TO EXECUTE
AGAINST PROTECTED QUOTATIONS. THE FIRM'S VENDOR HAS SINCE RESOLVED THE TECHNICAL ISSUES IN ITS SMART ORDER ROUTER SYSTEM. ACCORDINGLY, THE FIRM VIOLATED RULE
611(C) OF REGULATION NMS, NYSE ARCA EQUITIES RULE 7.31(E)(2) (PRIOR TO AUGUST 17, 2017), AND NYSE ARCA RULE 7.31-E(E)(3) (ON AND AFTER AUGUST 17, 2017). THE FINDINGS
ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), REASONABLY DESIGNED TO
ACHIEVE COMPLIANCE WITH RULE 611(C) OF REGULATION NMS AND NYSE ARCA EQUITIES RULE 7.31(E)(2) (PRIOR TO AUGUST 17, 2017) AND NYSE ARCA RULE 7.31-E(E)(3) (ON AND
AFTER AUGUST 17, 2017). THE FIRM HAD NO REVIEWS OR PROCEDURES TO ESTABLISH THAT ISOS IT ROUTED TO COMPLY WITH RULES 600(B)(30) AND 600(B)(31) BY EXECUTING
AGAINST PROTECTED QUOTATIONS WERE SENT AND RECEIVED BY ALL NECESSARY VENUES, ON A TIMELY BASIS, FOR THE CORRECT SIZE AND PRICE, IN COMPLIANCE WITH RULE 611(C)
AND NYSE ARCA EQUITIES RULE 7.31(E)(2) AND NYSE ARCA RULE 7.31-E(E)(3), AND, ACCORDINGLY, ITS WSPS DID NOT DESCRIBE ANY SUCH REVIEWS OR PROCEDURES. GIVEN THAT THE
FIRM CONTINUOUSLY ROUTED VIOLATIVE ISOS, THIS WAS UNREASONABLE. BECAUSE OF THESE SUPERVISORY DEFICIENCIES, THE FIRM FAILED TO DETECT AND TIMELY REMEDIATE THE
THREE TECHNICAL ISSUES WITH ITS VENDOR'S SMART ORDER ROUTER THAT CAUSED THE FIRM TO ROUTE ISOS THAT WERE PRICED THROUGH MARKET CENTERS' PROTECTED
QUOTATIONS. THE FIRM HAS SINCE REMEDIATED THESE DEFICIENCIES. ACCORDINGLY, THE FIRM VIOLATED NYSE ARCA EQUITIES RULE 6.18 (PRIOR TO AUGUST 17, 2017) AND NYSE
ARCA RULES 11.18(B) AND (C) (ON AND AFTER AUGUST 17, 2017).
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/16/2022
 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: $ 21,227.00
 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: 
THE FIRM WAS CENSURED AND FINED $21,227, RESOLVED SIMULTANEOUSLY WITH SIMILAR MATTERS FOR A TOTAL FINE OF $125,000. THOSE MATTERS WERE BROUGHT BY CBOE
BYX EXCHANGE, INC. (BYX); CBOE BZX EXCHANGE, INC. (BZX); CBOE EDGA EXCHANGE, INC. (EDGA); CBOE EDGX EXCHANGE, INC. (EDGX); INVESTORS EXCHANGE, LLC (IEX); NYSE
AMERICAN LLC (NYSE AMERICAN); NEW YORK STOCK EXCHANGE LLC (NYSE); NYSE CHICAGO, INC. (CHX) (COLLECTIVELY, THE EXCHANGES), AND FINRA.
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 SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN IN THE TIMEFRAME DIRECTED BY THE SRO.

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
No Information Filed
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) 
INVESTORS' EXCHANGE LLC
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
06/09/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2019063432004
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
INTERMARKET SWEEP ORDERS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THEENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A
SUPERVISORY SYSTEM, AND FAILED TOESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS), REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH
APPLICABLE SECURITIES LAWS AND REGULATIONS, AND IEX RULES,CONCERNING COMPLIANCE WITH RULE 611(C) OF REGULATION NATIONAL MARKET SYSTEM (NMS) OF THE SECURITIES
EXCHANGE ACT OF 1934 AND IEX RULE 11.190(B)(12). THE FINDINGS STATED THAT THE FIRM HADNO REVIEWS OR PROCEDURES TO ESTABLISH THAT INTERMARKET SWEEP ORDERS
(ISOS) IT ROUTED TOCOMPLY WITH RULES 600(B)(30) AND 600(B)(31) BY EXECUTING AGAINST PROTECTED QUOTATIONS WERESENT AND RECEIVED BY ALL NECESSARY VENUES, ON A
TIMELY BASIS, FOR THE CORRECT SIZE AND PRICE, INCOMPLIANCE WITH RULE 611(C). BECAUSE OF THESE SUPERVISORY DEFICIENCIES, THE FIRM FAILED TODETECT AND TIMELY
REMEDIATE THREE TECHNICAL ISSUES WITH ITS VENDOR'S SMART ORDER ROUTER THATCAUSED THE FIRM TO ROUTE ISOS THAT WERE PRICED THROUGH MARKET CENTERS' PROTECTED
QUOTATIONS.THE FIRM HAS SINCE REMEDIATED THESE DEFICIENCIES. ACCORDINGLY, THE FIRM VIOLATED IEX RULES5.110(A), 5.110(B), AND 3.110
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/09/2022
 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: $ 4,569.00
 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: 
THE FIRM WAS CENSURED AND FINED $4,569. RELATED DISCIPLINARY ACTION ON BEHALF OF CBOE BYXEXCHANGE, INC.; CBOE BZX EXCHANGE, INC.; CBOE EDGA EXCHANGE, INC.;
CBOE EDGX EXCHANGE, INC.;FINRA; THE NEW YORK STOCK EXCHANGE LLC; NYSE AMERICAN LLC; NYSE CHICAGO, INC., AND NYSEARCA, INC. FOR SIMILAR VIOLATIONS IS BEING
TAKEN CONCURRENTLY IN CONJUNCTION WITH THISMATTER.
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 SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN IN THE TIMEFRAME DIRECTED BY THE SRO.

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
No Information Filed
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) 
NYSE CHICAGO, INC.

2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
06/16/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2019063432010
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
INTERMARKET SWEEP ORDERS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NYSE CHICAGO, INC. ("NYSE CHICAGO" OR THE "EXCHANGE"), PURSUANT TO ARTICLE 12, RULE 1(D) OF THE RULES OF EXCHANGE, IN LIEU OF FILING CHARGES, HEREBY ENTERS THIS
ORDER AGAINST RESPONDENT HSBC SECURITIES (USA) INC. ("HSBC," "RESPONDENT," OR THE "FIRM") INSTITUTING PROCEEDINGS, ACCEPTING AN OFFER OF SETTLEMENT, MAKING
FINDINGS, AND IMPOSING SANCTIONS. NYSE CHICAGO FINDS THAT BETWEEN JULY 2017 AND SEPTEMBER 2020, HSBC FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT THE
INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THE REQUIREMENTS SET FORTH IN RULES 600(B)(30) AND 600(B)(31) OF REGULATION NATIONAL MARKET SYSTEM (NMS) OF THE
SECURITIES EXCHANGE ACT OF 1934. SPECIFICALLY, WHEN HSBC ROUTED ORDERS TO VARIOUS EXCHANGES THAT IT MARKED AS ISOS DURING THIS PERIOD, THREE TECHNICAL ISSUES
WITH ITS VENDOR'S SMART ORDER ROUTER RESULTED IN THE FIRM NOT RECOGNIZING, AND THEN ROUTING ADDITIONAL ISOS NECESSARY TO EXECUTE AGAINST, PROTECTED QUOTES
DISPLAYED BY CERTAIN MARKET CENTERS. AS A RESULT, HSBC SENT A TOTAL OF 10,265 ISO ORDERS, INCLUDING 17 ORDERS TO NYSE CHICAGO, THAT WERE PRICED THROUGH OTHER
MARKET CENTERS' PROTECTED LIQUIDITY BECAUSE THE FIRM DID NOT ROUTE THE ADDITIONAL ISOS NECESSARY TO EXECUTE AGAINST THOSE PROTECTED QUOTES. HSBC DID NOT
IDENTIFY THESE ISSUES AND DID NOT CONDUCT A REVIEW DESIGNED TO VERIFY THAT IT ROUTED ALL NECESSARY ISOS TO EXECUTE AGAINST PROTECTED QUOTATIONS. ACCORDINGLY,
HSBC FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT THE ISOS IT ROUTED MET THE REQUIREMENTS SET FORTH IN RULES 600(B)(30) AND 600(B)(31). THE FIRM'S VENDOR
RESOLVED THE TECHNICAL ISSUES IN ITS SMART ORDER ROUTER SYSTEM IN SEPTEMBER 2020. ADDITIONALLY, PRIOR TO JULY 2017, HSBC ROUTED ISOS ONLY TO EXECUTING BROKERS.
WHEN HSBC BEGAN ROUTING ISOS DIRECTLY TO EXCHANGES, THE FIRM DID NOT UPDATE ITS SUPERVISORY SYSTEMS TO INCLUDE A REVIEW OF ISOS FOR COMPLIANCE WITH RULE 611
OR RELATED EXCHANGE RULES. SPECIFICALLY, HSBC HAD NO REVIEWS OR PROCEDURES TO ESTABLISH THAT ISOS IT ROUTED TO COMPLY WITH RULES 600(B)(30) AND 600(B)(31) OF
REGULATION NMS BY EXECUTING AGAINST PROTECTED QUOTATIONS WERE SENT AND RECEIVED BY ALL NECESSARY VENUES, ON A TIMELY BASIS, FOR THE CORRECT SIZE AND PRICE, IN
COMPLIANCE WITH RULE 611(C) AND RELATED EXCHANGE RULES, AND, ACCORDINGLY, ITS WRITTEN SUPERVISORY PROCEDURES DID NOT DESCRIBE ANY SUCH REVIEWS OR
PROCEDURES. GIVEN THAT HSBC CONTINUOUSLY ROUTED VIOLATIVE ISOS BETWEEN JULY 2017 AND SEPTEMBER 2020, THIS WAS UNREASONABLE. HSBC HAS SINCE REMEDIATED THESE
DEFICIENCIES. AS A RESULT OF THE CONDUCT DESCRIBED HEREIN, HSBC VIOLATED RULE 611(C) OF REGULATION NMS, NYSE CHICAGO RULE 7.31(E)(3), AND NYSE CHICAGO ARTICLE 6,
RULES 5(A) AND (C).
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:
Order
11. Resolution Date (MM/DD/YYYY):
06/16/2022
 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: $ 9,804.00
 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: 
THE FIRM WAS CENSURED AND FINED $9,804.00, RESOLVED SIMULTANEOUSLY WITH SIMILAR MATTERS FOR A TOTAL FINE OF $125,000. THOSE MATTERS WERE BROUGHT BY CBOE

BYX EXCHANGE, INC. (BYX); CBOE BZX EXCHANGE, INC. (BZX); CBOE EDGA EXCHANGE, INC. (EDGA); CBOE EDGX EXCHANGE, INC. (EDGX); INVESTORS EXCHANGE, LLC (IEX); NEW
YORK STOCK EXCHANGE LLC (NYSE); NYSE ARCA, INC. (ARCA); NYSE AMERICAN LLC (NYSE AMERICAN) (COLLECTIVELY, THE EXCHANGES), AND FINRA.
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).
RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT ("OFFER") TO NYSE CHICAGO, WHICH NYSE CHICAGO HAS DETERMINED TO ACCEPT. AS A RESULT OF THE CONDUCT DESCRIBED
HEREIN, HSBC VIOLATED RULE 611(C) OF REGULATION NMS AND NYSE CHICAGO RULE 7.31(E)(3), AND NYSE CHICAGO ARTICLE 6, RULES 5(A) AND (C). IN VIEW OF THE FOREGOING, THE
EXCHANGE DEEMS IT APPROPRIATE TO CENSURE AND FINE HSBC NINE THOUSAND EIGHT HUNDRED AND FOUR DOLLARS ($9,804.00), RESOLVED SIMULTANEOUSLY WITH SIMILAR
MATTERS FOR A TOTAL FINE OF $125,000. HSBC SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN IN THE TIMEFRAME DIRECTED BY THE SRO.

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
No Information Filed
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) 
NYSE AMERICAN LLC
2.
Principal Sanction:
Other
Other Sanctions: 
N/A

3.
Date Initiated (MM/DD/YYYY): 
06/16/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2019063432009
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
INTERMARKET SWEEP ORDERS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO TAKE REASONABLE STEPS TO ENSURE
THAT INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED TO CERTAIN MARKET CENTERS MET THE REQUIREMENTS SET FORTH IN RULES 600(B)(30) AND 600(B)(31) OF REGULATION
NATIONAL MARKET SYSTEM (NMS) OF THE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS STATED THAT WHEN THE FIRM ROUTED ORDERS TO VARIOUS EXCHANGES THAT IT MARKED
AS ISOS DURING THIS PERIOD, THREE TECHNICAL ISSUES WITH ITS VENDOR'S SMART ORDER ROUTER RESULTED IN THE FIRM NOT RECOGNIZING, AND THEN ROUTING ADDITIONAL ISOS
NECESSARY TO EXECUTE AGAINST, PROTECTED QUOTES DISPLAYED BY CERTAIN MARKET CENTERS. AS A RESULT, THE FIRM SENT A TOTAL OF 10,265 ISO ORDERS, INCLUDING 47 ORDERS
TO NYSE AMERICAN, THAT WERE PRICED THROUGH OTHER MARKET CENTERS' PROTECTED LIQUIDITY BECAUSE THE FIRM DID NOT ROUTE THE ADDITIONAL ISOS NECESSARY TO EXECUTE
AGAINST THOSE PROTECTED QUOTES. THE FIRM DID NOT IDENTIFY THESE ISSUES AND DID NOT CONDUCT A REVIEW DESIGNED TO VERIFY THAT IT ROUTED ALL NECESSARY ISOS TO
EXECUTE AGAINST PROTECTED QUOTATIONS. THE FIRM'S VENDOR HAS SINCE RESOLVED THE TECHNICAL ISSUES IN ITS SMART ORDER ROUTER SYSTEM. ACCORDINGLY, THE FIRM
VIOLATED RULE 611(C) OF REGULATION NMS AND NYSE AMERICAN RULE 7.31E(E)(3). THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY
SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RULE 611(C) OF REGULATION NMS AND NYSE AMERICAN
RULE 7.31E(E)(3). THE FIRM HAD NO REVIEWS OR PROCEDURES TO ESTABLISH THAT ISOS IT ROUTED TO COMPLY WITH RULES 600(B)(30) AND 600(B)(31) OF REGULATION NMS BY
EXECUTING AGAINST PROTECTED QUOTATIONS WERE SENT AND RECEIVED BY ALL NECESSARY VENUES, ON A TIMELY BASIS, FOR THE CORRECT SIZE AND PRICE, IN COMPLIANCE WITH
RULE 611(C) AND NYSE AMERICAN RULE 7.31E(E)(3), AND, ACCORDINGLY, ITS WSPS DID NOT DESCRIBE ANY SUCH REVIEWS OR PROCEDURES. GIVEN THAT THE FIRM CONTINUOUSLY
ROUTED VIOLATIVE ISOS, THIS WAS UNREASONABLE. BECAUSE OF THESE SUPERVISORY DEFICIENCIES, THE FIRM FAILED TO DETECT AND TIMELY REMEDIATE THE THREE TECHNICAL
ISSUES WITH ITS VENDOR'S SMART ORDER ROUTER THAT CAUSED THE FIRM TO ROUTE ISOS THAT WERE PRICED THROUGH MARKET CENTERS' PROTECTED QUOTATIONS. THE FIRM HAS
SINCE REMEDIATED THESE DEFICIENCIES. ACCORDINGLY, THE FIRM VIOLATED NYSE MKT RULE 3110 (PRIOR TO JULY 24, 2017) AND NYSE AMERICAN RULES 3110(A) AND (B) (ON AND
AFTER JULY 24, 2017).
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/16/2022
 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: $ 10,064.00
 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: 
THE FIRM WAS CENSURED AND FINED $10,064, RESOLVED SIMULTANEOUSLY WITH SIMILAR MATTERS FOR A TOTAL FINE OF $125,000. THOSE MATTERS WERE BROUGHT BY CBOE
BYX EXCHANGE, INC. (BYX); CBOE BZX EXCHANGE, INC. (BZX); CBOE EDGA EXCHANGE, INC. (EDGA); CBOE EDGX EXCHANGE, INC. (EDGX); INVESTORS EXCHANGE, LLC (IEX); NEW
YORK STOCK EXCHANGE LLC (NYSE); NYSE ARCA, INC. (ARCA); NYSE CHICAGO, INC. (CHX) (COLLECTIVELY, THE EXCHANGES), AND FINRA.
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 SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN IN THE TIMEFRAME DIRECTED BY THE SRO.

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
No Information Filed
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) 
DEPOSITORY TRUST & CLEARING CORPORATION (DTC)
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/29/2022
 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):
6.
Principal Product Type:

Other
Other Product Types: 
FINE FOR FAILURE TO NOTIFY AND SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE BY HSBC SECURITIES (USA) INC. (DTC/NSCC#0816 AND GSD#9573)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA), INC. FAILED TO NOTIFY AND SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE (CHANGE IN THE COO) ON FEBRUARY 16, 2022. THEREFORE, PURSUANT TO
THEIR RESPECTIVE RULES AND PROCEDURES, DTC, NSCC AND GSC (COLLECTIVELY THE "CLEARING AGENCIES) ARE IMPOSING A SINGLE FINE OF $5000.00 FOR FAILURE TO NOTIFY AND
SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE. THE FINE WAS ALLOCATED AMONGST THE CLEARING AGENCIES AS SET FORTH, DTC $1,666.67, NSCC $1,666.67 AND GSD $1,666.66.
HSBC SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN THE TIMEFRAME DIRECTED BY THE SRO.
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):
07/29/2022
 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: $ 1,666.67
 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: 
HSBC SECURITIES (USA), INC. FAILED TO NOTIFY AND SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE (CHANGE IN THE COO) ON FEBRUARY 16, 2022. THEREFORE, PURSUANT
TO THEIR RESPECTIVE RULES AND PROCEDURES, DTC, NSCC AND GSC (COLLECTIVELY THE "CLEARING AGENCIES) ARE IMPOSING A SINGLE FINE OF $5000.00 FOR FAILURE TO
NOTIFY AND SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE. THE FINE WAS ALLOCATED AMONGST THE CLEARING AGENCIES AS SET FORTH, DTC $1,666.67, NSCC $1,666.67
AND GSD $1,666.66. HSBC SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN THE TIMEFRAME DIRECTED BY THE SRO.
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 SECURITIES (USA), INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN THE TIMEFRAME DIRECTED BY THE SRO.

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
No Information Filed
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) 
GOVERNMENT SECURITIES DIVISION (GSD)
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/29/2022
 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):
6.
Principal Product Type:
Other
Other Product Types: 
FINE FOR FAILURE TO NOTIFY AND SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE BY HSBC SECURITIES (USA) INC. (DTC/NSCC#0816 AND GSD#9573)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA), INC. FAILED TO NOTIFY AND SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE (CHANGE IN THE COO) ON FEBRUARY 16, 2022. THEREFORE, PURSUANT TO
THEIR RESPECTIVE RULES AND PROCEDURES, DTC, NSCC AND GSC (COLLECTIVELY THE "CLEARING AGENCIES) ARE IMPOSING A SINGLE FINE OF $5000.00 FOR FAILURE TO NOTIFY AND
SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE. THE FINE WAS ALLOCATED AMONGST THE CLEARING AGENCIES AS SET FORTH, DTC $1,666.67, NSCC $1,666.67 AND GSD $1,666.66.
HSBC SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN THE TIMEFRAME DIRECTED BY THE SRO.
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):

07/29/2022
 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: $ 1,666.67
 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: 
HSBC SECURITIES (USA), INC. FAILED TO NOTIFY AND SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE (CHANGE IN THE COO) ON FEBRUARY 16, 2022. THEREFORE, PURSUANT
TO THEIR RESPECTIVE RULES AND PROCEDURES, DTC, NSCC AND GSC (COLLECTIVELY THE "CLEARING AGENCIES) ARE IMPOSING A SINGLE FINE OF $5000.00 FOR FAILURE TO
NOTIFY AND SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE. THE FINE WAS ALLOCATED AMONGST THE CLEARING AGENCIES AS SET FORTH, DTC $1,666.67, NSCC $1,666.67
AND GSD $1,666.66. HSBC SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN THE TIMEFRAME DIRECTED BY THE SRO.
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 SECURITIES (USA), INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN THE TIMEFRAME DIRECTED BY THE SRO.

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
No Information Filed
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) 
NATIONAL SECURITIES CLEARING CORPORATION (NSCC)
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/29/2022
 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):
6.
Principal Product Type:
Other
Other Product Types: 
FINE FOR FAILURE TO NOTIFY AND SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE BY HSBC SECURITIES (USA) INC. (DTC/NSCC#0816 AND GSD#9573)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
HSBC SECURITIES (USA), INC. FAILED TO NOTIFY AND SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE (CHANGE IN THE COO) ON FEBRUARY 16, 2022. THEREFORE, PURSUANT TO
THEIR RESPECTIVE RULES AND PROCEDURES, DTC, NSCC AND GSC (COLLECTIVELY THE "CLEARING AGENCIES) ARE IMPOSING A SINGLE FINE OF $5000.00 FOR FAILURE TO NOTIFY AND
SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE. THE FINE WAS ALLOCATED AMONGST THE CLEARING AGENCIES AS SET FORTH, DTC $1,666.67, NSCC $1,666.67 AND GSD $1,666.66.
HSBC SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN THE TIMEFRAME DIRECTED BY THE SRO.
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):
07/29/2022
 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: $ 1,666.67
 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: 
HSBC SECURITIES (USA), INC. FAILED TO NOTIFY AND SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE (CHANGE IN THE COO) ON FEBRUARY 16, 2022. THEREFORE, PURSUANT
TO THEIR RESPECTIVE RULES AND PROCEDURES, DTC, NSCC AND GSC (COLLECTIVELY THE "CLEARING AGENCIES) ARE IMPOSING A SINGLE FINE OF $5000.00 FOR FAILURE TO
NOTIFY AND SUPPLY REQUIRED DATA AS TO A MATERIAL CHANGE. THE FINE WAS ALLOCATED AMONGST THE CLEARING AGENCIES AS SET FORTH, DTC $1,666.67, NSCC $1,666.67
AND GSD $1,666.66. HSBC SECURITIES (USA) INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN THE TIMEFRAME DIRECTED BY THE SRO.

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 SECURITIES (USA), INC. INTENDS TO CAUSE THE FINE TO BE PAID WITHIN THE TIMEFRAME DIRECTED BY THE SRO.

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
No Information Filed
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) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/11/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-21408

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") AND SECURITIES AND EXCHANGE COMMISSION ("SEC") ISSUED ORDERS FINDING THAT CERTAIN MEMBERS OF THE HSBC
GROUP VIOLATED RECORD-KEEPING RULES UNDER THE SECURITIES EXCHANGE ACT AND COMMODITIES EXCHANGE ACT BY FAILING TO PREVENT EMPLOYEES FROM USING UNAPPROVED
COMMUNICATIONS CHANNELS (INCLUDING WHATSAAPP AND TEXT MESSAGING) THAT WERE NOT PRESERVED, SURVEILLED OR RETAINED. THE RESOLUTIONS, WHICH COLLECTIVELY
INVOLVE HSBC SECURITIES (USA) INC., HSBC BANK USA, N.A. AND HSBC BANK PLC, FOLLOW SETTLEMENTS WITH MORE THAN A DOZEN OTHER FINANCIAL INSTITUTIONS FOLLOWING
STREET-WIDE INVESTIGATION. THE FINDINGS, WHICH THE HSBC ENTITIES ADMITTED, WERE BASED ON FAILURE TO RETAIN REQUIRED RECORDS AND NOT ON ANY ALLEGATIONS OF
MISCONDUCT BY ANY HSBC EMPLOYEE. THE CFTC ASSESSED A $30 MILLION PENALTY ON THE HSBC ENTITIES COLLECTIVELY, AND THE SEC ASSESSED A PENALTY OF $15 MILLION ON
HSBC SECURITIES (USA) INC. EACH AGENCY ALSO REQUIRED VARIOUS ONGOING REMEDIAL UNDERTAKINGS.
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):
05/11/2023
 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: $ 15,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
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: 
THE FIRM IS ORDERED TO CEASE AND DESIST; IS CENSURED, SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER, AND SHALL PAY A CIVIL MONEY PENALTY IN
THE AMOUNT OF $15,000,000.00.
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).

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
No Information Filed
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 COMMODITY FUTURES TRADING COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/11/2023
 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):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") AND SECURITIES AND EXCHANGE COMMISSION ("SEC") ISSUED ORDERS FINDING THAT CERTAIN MEMBERS OF THE HSBC
GROUP VIOLATED RECORD-KEEPING RULES UNDER THE SECURITIES EXCHANGE ACT AND COMMODITIES EXCHANGE ACT BY FAILING TO PREVENT EMPLOYEES FROM USING UNAPPROVED
COMMUNICATIONS CHANNELS (INCLUDING WHATSAAPP AND TEXT MESSAGING) THAT WERE NOT PRESERVED, SURVEILLED OR RETAINED. THE RESOLUTIONS, WHICH COLLECTIVELY
INVOLVE HSBC SECURITIES (USA) INC., HSBC BANK USA, N.A. AND HSBC BANK PLC, FOLLOW SETTLEMENTS WITH MORE THAN A DOZEN OTHER FINANCIAL INSTITUTIONS FOLLOWING
STREET-WIDE INVESTIGATION. THE FINDINGS, WHICH THE HSBC ENTITIES ADMITTED, WERE BASED ON FAILURE TO RETAIN REQUIRED RECORDS AND NOT ON ANY ALLEGATIONS OF
MISCONDUCT BY ANY HSBC EMPLOYEE. THE CFTC ASSESSED A $30 MILLION PENALTY ON THE HSBC ENTITIES COLLECTIVELY, AND THE SEC ASSESSED A PENALTY OF $15 MILLION ON
HSBC SECURITIES (USA) INC. EACH AGENCY ALSO REQUIRED VARIOUS ONGOING REMEDIAL UNDERTAKINGS.
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):
05/11/2023
 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: $ 30,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
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: 
THE FIRM IS ORDERED TO CEASE AND DESIST; IS CENSURED, SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER, AND SHALL PAY A CIVIL MONEY PENALTY IN
THE AMOUNT OF $30,000,000.00.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/09/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2021073545201
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT PUBLISHED EQUITY AND DEBT RESEARCH REPORTS
THAT CONTAINED INACCURATE DISCLOSURES ABOUT ITS CONFLICTS OF INTEREST. THE FINDINGS STATE THAT THE FIRM'S DISCLOSURE INACCURACIES COMPRISED OF BOTH FAILURES
TO DISCLOSE CONFLICTS AS WELL AS DISCLOSURE OF CONFLICTS THAT DID EXIST, WITH MOST BEING OVER-DISCLOSURE. THE FIRM'S DISCLOSURE INACCURACIES STEMMED FROM
SEVERAL ISSUES WITH THE DATA FEEDS IT USED TO GENERATE CONFLICTS DISCLOSURES IN RESEARCH REPORTS. THE FIRM ALSO APPLIED A DEFINITON OF INVESTMENT BANKING
SERVICES THAT INCORRECTLY EXCLUDED SUCH SERVICE IN CONNECT WITH ASSET-BACKED SECURITIES, PRIVATE PLACEMENT BONDS, AND CERTAIN STRUCTURED PRODUCTS. AS A
RESULT, THE FIRM DID NOT INCLUDE DATA FROM THOSE PRODUCTS IN ITS DATA FEEDS, CAUSING FAILURE TO DISCLOSE INVESTMENT BANKING RELATED CONFLICTS INVOLVING THOSE
OFFERINGS AND PRODUCTS. IN ADDITION, THE FIRM BASED ITS DISCLOSURES OF INVESTMENT BANKING REVENUE ON TWO YEARS OF DATA EVEN THOUGH THE APPLICABLE RULES LIMIT
THE SCOPE OF THE DATA TO ONE YEAR, RESULTING IN OVER DISCLOSURE. FURTHER, THE FIRM AT TIMES DID NOT TIMELY ADD NEW CLIENT RELATIONSHIPS TO THE DATA FEEDS OR USED
INCONSISTENT NAMING CONVENTIONS FOR THE SAME CLIENT, RESULTING IN A LACK OF REQUIRED DISCLOSURES OR INACCURATE DISCLOSURES. THE FINDINGS ALSO STATED THAT THE
FIRM DID NOT ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WSPS, THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE DISCLOSURE
REQUIREMENTS OF FINRA RULES 2241(C) AND 2242(C) AND NASD RULE 2711(H). THE FIRM HAD NO PROCEDURES, TESTING, OR OTHER SYSTEM TO CONFIRM THAT THE INFORMATION IN
THE DATA FEEDS WAS ACCURATE AND COMPLETE, NOR DID THE FIRM ASSIGN RESPONSIBILITY FOR CONFIRMING THE ACCURACY AND COMPLETENESS OF ITS DATA FEEDS TO ANY
INDIVIDUALS OR GROUPS. CONSEQUENTLY, THE FIRM WAS UNABLE TO DETECT THE DATA FEED DEFICIENCIES, CAUSING THE DISCLOSURE INACCURACIES TO OCCUR OVER ALMOST NINE
YEARS.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
10/09/2023
 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: $ 2,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction

 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
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: 
THE FIRM WAS CENSURED, FINED $2,000.000 AND REQUIRED TO REMEDIATE THE ISSUES IDENTIFIED IN THE AWC AND IMPLEMENT A SUPERVISORY SYSTEM, INCLUDING WSPS,
REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULES.
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).

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
No Information Filed
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) 
FINRA
2.
Principal Sanction:

Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/29/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2021071423301
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Corporate
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THEENTRY OF FINDINGS THAT IT FAILED TO TIMELY REPORT TO TRACE
TRANSACTIONS IN TRACE-ELIGIBLECORPORATE DEBT SECURITIES. THE FINDINGS STATED THAT THE FIRM'S LATE REPORTING WAS CAUSED BY,AMONG OTHER THINGS, DELAYS
ASSOCIATED WITH THE MANUAL HANDLING OF ORDERS, SUCH AS FIRMEMPLOYEES ENTERING TRADES LATE AND MAKING UNTIMELY AMENDMENTS AND CORRECTIONS TOTRANSACTION
TERMS, AND ISSUES RELATED TO THE MANUAL PROCESS REQUIRED TO REPORT TRANSACTIONS IN CERTAIN FOREIGN DEBT SECURITIES. THE FINDINGS ALSO STATED THAT THE FIRM
FAILED TO ESTABLISHAND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH TRACE REPORTING REQUIREMENTS.
SPECIFICALLY, THE FIRM'S WSPS LACKED REASONABLE GUIDANCEFOR SUPERVISORS TO ADDRESS TRADERS' REPEATED INSTANCES OF LATE REPORTING. THE FIRM IDENTIFIEDSPECIFIC
TRADERS RESPONSIBLE FOR THE LATE REPORTING BUT FAILED TO EFFECTIVELY ADDRESS THEIRPATTERN OF LATE REPORTING. THE FIRM'S WSPS REQUIRED SUPERVISORS TO ADDRESS
AND RESOLVE ISSUESWITH SUCH REPEAT OFFENDERS BUT PROVIDED NO GUIDANCE ON HOW TO DO SO.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
10/29/2024
 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: $ 125,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
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: 
THE FIRM WAS CENSURED, FINED $125,000, AND REQUIRED TO CERTIFY THAT IT HAS REMEDIATED THE ISSUES IDENTIFIED IN THE AWC AND IMPLEMENTED A REASONABLY
DESIGNED SUPERVISORY SYSTEM,INCLUDING WSPS.
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).