HSBC SECURITIES (USA) INC.

HSBC Securities (USA) Inc. - Form ADV Part 2A Form ADV Part 2A HSBC SPECTRUM AND SPECTRUM II PROGRAM BROCHURE HSBC Securities (USA) Inc. 66 Hudson Boulevard East New York, NY 10001 Tel: 800-662-3343 Website: WWW.US.HSBC.COM January 2026 This managed account program brochure provides information about the qualifications and business practices of HSBC Securities (USA) Inc. (“HSBC Securities”, “We”, “US” or the “Firm”) and its HSBC Spectrum Program (the “Spectrum Program”), HSBC Spectrum II Program (“Spectrum II Program”) and HSBC Offshore Spectrum Program (“Offshore Spectrum”) (collectively, the “Programs”) that should be considered before investing. If you (“Client”, “You”, or “Your”) have any questions about the contents of this brochure, please direct your written inquiry to the address listed above or call 800- 662-3343. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about HSBC Securities is also available on the SEC’s website at www.adviserinfo.sec.gov. HSBC Securities is a federally registered investment adviser with the SEC. Registration with the SEC or with any state securities authority, the use of the term “registered investment adviser”, and descriptions of HSBC Securities and some of our associates as “registered” does not imply a certain level of skill or training. Investment Products: MAY LOSE VALUE ARE NOT FDIC INSURED ARE NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY ARE NOT GUARANTEED BY THE BANK OR ANY OF ITS AFFILIATES ARE NOT A DEPOSIT OR OTHER OBLIGATION OF THE BANK OR ANY OF ITS AFFILIATES All decisions regarding the tax implications of your investment(s) should be made in consultation with your independent tax advisor. 1  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 2: Material Changes to Our Part 2A of Form ADV Firm Brochure There is one material change made to the HSBC Securities Form ADV Part 2A (commonly referred to as the “Brochure”) since the update of the Brochure in September 2025. Item 5: Fee Schedule Update for all Program Accounts HSBC will be implementing a new fee schedule for all Program Accounts effective April 1, 2026. The revised fee schedule is outlined in Item 5 of this document below and will automatically apply to your account beginning on the effective date. 2  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 3: Table of Contents: Page(s): 2 3 4 Section: Item 2: Material Changes to Part 2A of Form ADV Firm Brochure Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation 14 17 Item 6: Performance-Based Fees and Side-By-Side Management 18 Item 7: Types of Clients and Account Requirements 19 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 31 Item 9: Disciplinary Information 32 Item 10: Other Financial Industry Activities and Affiliations 35 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 36 Item 12: Brokerage Practices 38 Item 13: Review of Accounts 39 Item 14: Client Referrals and Other Compensation 42 Item 15: Custody 43 Item 16: Investment Discretion 44 Item 17: Voting Client Securities 45 Item 18: Financial Information 3  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 4: Advisory Business HSBC Securities has been in business as an investment adviser registered with the SEC under the Investment Advisers Act 1940, as amended (the Advisers Act) since 2005. HSBC Securities is also a broker- dealer, which was originally formed in December 1969 under a predecessor name. HSBC Securities is a Delaware corporation headquartered in New York City. HSBC Securities is also a wholly-owned subsidiary of HSBC Markets (USA) Inc. and an indirect wholly-owned subsidiary of HSBC Holdings plc. References to “HSBC” refers to HSBC Holdings plc and any of its global affiliates. HSBC Securities offers a limited range of proprietary investment advisory solutions available to meet certain clients’ particular circumstances. The Firm currently provides investment advisory services to clients through an asset allocation service known as the HSBC Spectrum Account Program (the “Spectrum Program”) and the HSBC Spectrum II Account Program (the “Spectrum II Program”), which offers actively managed mutual funds, Exchange Traded Funds (ETFs) and passively managed index funds (collectively “Funds”). HSBC also offers the Offshore Spectrum Account Program (“Offshore Spectrum”) which is available to qualified Non-Resident Aliens who reside in approved jurisdictions. The Offshore Spectrum Program offers managed funds and Exchange Traded Funds (ETFs) (collectively “Funds”). The funds made available through Offshore Spectrum are not expected to be registered in the United States. The HSBC Spectrum, HSBC Spectrum II and Offshore Spectrum Account Program are collectively defined as (“Programs”). HSBC Securities also offers a wrap fee account program referred to as the Managed Portfolio Account Program (“MPA” or “MPA Program”), which is a multi-product, fee-based separately managed account program. MPA offers two investment account options: Separately Managed Accounts (“SMA”) and Unified Managed Accounts (“UMA”). As of May 2025, HSBC Securities is offering to clients of the HSBC Private Bank Division, the Prism Advisory Program (“Prism”). The Prism program offers discretionary and advisory services which provides Private Bank clients with asset allocation models utilizing mutual funds, ETFs, SMA and UMA models for a fee. Details of this program are described in the Client Relationship Summary (“Form CRS”), HSBC Brokerage Brochure (“HBB”) and Prism Form ADV Part 2A. Collectively all programs offered by HSBC Securities are referred to as “Managed Account Programs.” Clients in the Spectrum, Spectrum II, Offshore Spectrum, MPA and Prism programs have an Investment Adviser Representative (“IARs, Representative and Wealth Relationship Manager”) who is available to discuss updates in the client’s financial situation and handle account updates and changes. Our relationship, legal duties and capacities to you are described in Form CRS and in the HBB. These documents are available at https://www.us.hsbc.com/investments/customer-relationship-summary/ 4  HSBC Securities (USA) Inc. - Form ADV Part 2A Additionally, you may obtain the most current Form ADV Part 2A or Appendix 1 for all programs using the following website under “Important Documents”: https://www.us.hsbc.com/investments/products/asset-allocation/ HSBC Securities has certain fiduciary obligations in providing services under the Program. As a fiduciary, we will act in your best interest and will endeavor to provide you with access to material facts and information relating to the Program services. This Brochure is a key element in meeting this disclosure obligation. The fiduciary standards we aim to follow are established under the Advisers Act and, where applicable, state laws. HSBC Securities does not offer any advisory programs other than those referenced above. The information provided in this Brochure only applies to the Programs. This Brochure is meant to help you understand the nature of the advisory services offered in the Programs, whether those services are right for you, and the potential conflicts of interest associated with your participation in the Programs. You should review it carefully prior to your decision to invest. HSBC Securities is the sponsor of the Programs. Clients participating in the Programs receive asset allocation, discretionary investment management, execution, and custodian services for the assets in their Program accounts (“Accounts”). Written requests for Form ADV Part 2A or Appendix 1 documents should be sent to: HSBC Securities (USA) Inc. P.O. Box 4217 Buffalo, NY 14240-8929 ATTN: HSBC Securities Customer Service Description of the Programs: The Programs have five (5) broad strategies or risk models: 1) Conservative; 2) Moderately Conservative; 3) Moderate; 4) Moderately Aggressive and 5) Aggressive. After the Account is established, HSBC Securities as the investment advisor will have investment discretion, in accordance with the selected investment strategy. The Representative will assist clients in completing information requests designed to elicit personal, financial and investment information concerning the client’s financial circumstances, risk preference and tolerance, liquidity requirements and investment objectives to help determine if a managed account recommendation is in the client’s interest. The Representative scores client responses to risk profile questions to generate a recommended investment risk tolerance and allocation. Spectrum Program Investment Selection In the Spectrum Program, at Account opening (and at any time while an Account is open), the client will be able to select from a variety of Funds, in consultation with the Representative, that have investment objectives and policies corresponding to the client’s investment risk tolerance. 5  HSBC Securities (USA) Inc. - Form ADV Part 2A The Representative will provide the client with a proposal containing a list of the selected Funds and a recommended allocation of the client’s assets for investment that includes various asset classes (the “Proposal”). The client will review the proposed investments, subject to permissible changes, and no Funds will be purchased unless and until the client signs such Proposal noting the client’s acceptance. When HSBC Securities or its delegate recommends a Fund for removal from the Spectrum Program, clients will be notified of the recommendation via a client statement or mailing and provided with information on the selected replacement Fund. Fund Selection within Client Accounts After arriving at a recommended portfolio based on their Risk Profile, clients can work with their Representative to choose approved investment options that are available in the proposal system. Clients may choose ETFs and third-party mutual funds in each asset category which may include HSBC affiliated funds. Though these third-party mutual fund choices generally have higher expenses than passively-managed ETFs, the third-party mutual fund options are typically institutional share classes with relatively low expense ratios. Clients may want to review individual fund information and consider factors such as investment style, risk statistics (such as Sharpe ratios), performance returns, Morningstar rating, and expense ratio, among other items. Account performance will vary based on the Funds the client selects. Past performance is no guarantee of future results. Dividend Reinvestment/Distribution Models In the Spectrum Program, clients can choose to receive dividends, interest, distributions and other income paid on securities held in the Account (collectively “Distributions”) directly or reinvest the Distributions in accordance with the Investment Strategy then in effect for the Account. Clients should reach out to their Representative regarding these options. Please note, the withdrawal and payment of the Distributions directly to the client may affect the performance of the account and will reduce account assets. If a client wishes to reinvest Distributions in the Account, they should choose models that only allow reinvestment. For exchange traded funds any dividends will be invested into the account’s sweep money market funds until the next regularly scheduled rebalance takes place. When applicable the dividends and capital gains paid on mutual funds will be reinvested according to the model chosen. HSBC Securities does not select Funds with particular dividend targets and payment of the income stream can be inconsistent from month to month. Clients should consider legal and/or tax implications when considering their options regarding Distributions. Clients should consult with their attorney or tax advisor. Distribution models are also available in the MPA program. Please refer to the separate MPA Form ADV Part 2A, Appendix 1 for additional information. Global vs. U.S. Focused Options for Model Portfolios The Spectrum and Spectrum II Programs offers a Global option and a U.S. Focused option for each model portfolio in the Programs. Many factors can influence the performance of a model portfolio, and HSBC Securities cannot guarantee whether a Global option model portfolio or a U.S. Focused option model portfolio will perform better over time. Clients should discuss these options with their Representative. Environmental Social Governance (ESG) Funds 6  HSBC Securities (USA) Inc. - Form ADV Part 2A Effective on or about November 20, 2023 HSBC Securities (USA) Inc. will no longer offer ESG Funds in the Spectrum Program. ESG funds are only available in the Spectrum II Program. Spectrum clients who have ESG funds in their existing portfolios can maintain existing positions and continue to fund additional purchases. However, no new ESG funds can be purchased. Please see additional ESG disclosures in the Spectrum II investment selection section below. Spectrum II Portfolios Spectrum II Program(s) refer to Spectrum II, Spectrum II ESG and Spectrum II ETF portfolios To enroll in the Spectrum II programs, the client must complete the Spectrum II Fully Discretionary Account Addendum(s). Investment Selection In the Spectrum II Program, at Account opening (and at any time while an Account is open), HSBC Securities will select from a variety of actively managed funds, Exchange Traded Funds (ETFs) and passively managed index funds (collectively “Funds”) that have investment objectives and policies corresponding to the client’s investment risk tolerance and allocation. The Spectrum II ESG Models are made up of Funds that offer investors the ability to align their financial goals with their values. Each Fund has one or more socially responsible or environmental objectives and may seek to avoid companies with poor Environmental, Social and Governance (ESG) performance in one or more areas. The Spectrum II ETF portfolios are discretionary portfolios comprised of only Exchange Traded Funds (ETFs). The Spectrum II ETF portfolios are available to U.S. citizens and U.S. residents, and to U.S. citizens living in certain approved foreign jurisdictions. It should be noted that if you move to another jurisdiction that is not approved for investments it may cause your Account to be terminated. If your account is terminated, it will be removed from management and you are only able to place sell orders. Clients should consider legal and/or tax implications when considering their options. Clients should consult with their attorney or tax advisor. Please see additional disclosure below for ESG Funds in Item 8 and Item 10. The Representative will provide the client with a Proposal containing a list of Funds selected by HSBC Securities and a recommended allocation of assets across various asset classes. The client will review the proposed investments, subject to permissible changes, and no purchases will be made unless and until the client signs the Proposal noting the client’s acceptance. As Spectrum II is a fully discretionary program, the client cannot modify or customize the selected model. The client can, however, impose reasonable restrictions on its Account. Once the Account is established, HSBC Securities as the investment adviser will have investment discretion, in accordance with the selected asset allocation model. When HSBC Securities or its delegate recommend a Fund for removal from the Spectrum II Program, HSBC Securities will not notify the client of Fund changes, as the Spectrum II Program is a fully discretionary program. It is also designed to serve the needs of clients who are employed in the financial services industry and are required to have a fully discretionary managed account to avoid conflicts of interest or otherwise comply with their employer’s personal account dealing requirements. 7  HSBC Securities (USA) Inc. - Form ADV Part 2A Offshore Spectrum Account Program To enroll in the Offshore Spectrum program, the client must complete the Offshore Spectrum Account Agreement. The Offshore Spectrum Program is a discretionary offshore fund asset allocation program open to qualified non-resident aliens who reside in certain foreign jurisdictions, as approved by the Firm and in accordance with the local laws of those jurisdictions. It should be noted that if a client moves to another jurisdiction that is not approved for investments it may cause the Account to be terminated. If the account is terminated it will be removed from management and the client will only be able to place sell orders. In addition, if a client moves to a jurisdiction that is not approved by a specific fund company, HSBC Securities will be required to redeem that holding(s) and in the case of certain fund companies, HSBC Securities may cause your Account to be terminated with all account holdings required to be redeemed. Clients should consider legal and/or tax implications when considering their options. Clients should consult with their attorney or tax advisor. Investment Selection In the Offshore Spectrum Program, at Account opening (and at any time while an Account is open), The investments made available through the Offshore Spectrum Program are not registered in the U.S. and are generally not offered for sale or sold in the U.S., except in a transaction exempt from the registration requirements of the Securities Act of 1933, as amended. HSBC Securities will select from a variety of non-U.S. registered funds and Exchange Traded Funds (ETFs) (collectively “Funds”) that have investment objectives and policies corresponding to the client’s investment risk tolerance and allocation. HSBC Securities will not notify the client of Fund changes, as the Offshore Spectrum Program is a fully discretionary program. The only money market option in this program will be an Offshore money market fund advised by HSBC Global Asset Management (USA) Inc. (“AMUS”) or its affiliates who provide investment advisory services. The Representative will provide the client with a Proposal containing a list of Funds selected by HSBC Securities and a recommended allocation of assets across various asset classes. If applicable, clients should refer to the individual fund prospectus/offering documents or Key Investor Information Document (KIID) and Supplementary Information Document (SID) for additional information on underlying charges and fund expenses before investing. The client will review the proposed investments, and no purchases will be made unless and until the client signs the Proposal noting the client’s acceptance. As Offshore Spectrum is a fully discretionary program, the client cannot modify or customize the selected model. The client can, however, impose reasonable restrictions on its Account. Once the Account is established, HSBC Securities as the investment adviser will have investment discretion, in accordance with the selected asset allocation model. When HSBC Securities or its delegate recommend a Fund for removal from the Offshore Spectrum Program, 8  HSBC Securities (USA) Inc. - Form ADV Part 2A HSBC Securities will not notify the client of Fund changes, as the Offshore Spectrum Program is a fully discretionary program. Fund companies may require additional information for clients residing in certain jurisdictions. This can result in trade delays. Administration of the Programs The Firm offers the Spectrum and Spectrum II Programs to U.S. citizens and U.S. residents. The Spectrum II ETF portfolios are available to U.S. citizens, U.S. residents, and to certain U.S. citizens living in certain approved foreign jurisdictions outside of the U.S. The firm also offers the Offshore Spectrum Program to Non-Resident Aliens in certain approved foreign jurisdictions subject to local laws and regulations. The key difference between the Programs is that clients choose their Funds in the Spectrum Program and HSBC Securities chooses the client’s funds in the Spectrum II and the Offshore Spectrum Program. The administration of the Programs will be discussed collectively except where they differ in their level of discretion, which will be specifically described for each Program below. Under all Programs, the Firm decides the ultimate investment selections and strategies employed in the model portfolios. The Firm regularly communicates with clients regarding the overall strategy and provides transparent reporting, so clients are aware of the holdings, performance and characteristics of their portfolio. In the Programs, we use our discretion to periodically rebalance Accounts and to make changes in the investments in the Account where appropriate. The Funds made available through the Programs include both funds advised by Non-HSBC investment advisers (third party Funds) and funds advised by HSBC Global Asset Management (USA) Inc. (“AMUS”) or its affiliates who provide investment advisory services (proprietary Funds). The only money market funds available in the Programs are the proprietary money market funds. Funds used within the Programs are those that have been researched and approved for use by GMS and/or HSBC Alternative Investments Limited (HAIL) and are aligned with the asset classes offered within the Programs’ models. HAIL provides certain services for the Programs related to alternative funds. HSBC Securities compensates GMS and HAIL for these services. GMS and HAIL evaluates Funds included in the Programs on a continuous basis. If they no longer have conviction in the management of the Fund, HSBC Securities can recommend funds for removal from the Programs. Please refer to Item 8: Methods of Analysis, Investment Strategies and Risk of Loss for more details. For the Programs the Firm has entered into an intercompany agreement with its affiliate AMUS to perform certain advisory and administrative services, for compensation, for all of the above referenced Programs. Under that agreement, AMUS provides to HSBC Securities’ Managed Account Programs the following services, (i) advice as to proposed asset allocations, (ii) advice about Funds made available within the Programs, and (iii) various operational and administrative services. HSBC Securities compensates AMUS for these services. HSBC Securities, through the Managed Account Oversight Committee (“Committee”), oversees the operation of the Programs as well as the services provided by AMUS and any other material vendor. The Committee is chaired by HSBC Securities and consists of members and invitees who are employees of 9  HSBC Securities (USA) Inc. - Form ADV Part 2A HSBC Securities and AMUS. Employees of AMUS will have no authority to make decisions or otherwise influence approvals of the Committee. HSBC Securities Client Services HSBC Securities offers the Programs to its clients, and aside from sponsorship, is responsible for Account opening services (including Know Your Client and Anti-Money Laundering reviews), suitability, relationship management, communications, investment advice, trading, trade servicing, Account maintenance, custody of client assets and overall operational support for the Firm’s investment advisory products. For additional information on custody, please see Item 15. Please also refer to the Program Account Agreements for additional terms and conditions related to the Programs. Further to the above services, HSBC Securities provides certain ongoing client services that include the following: 1. Periodic portfolio review and consultation with clients through your IAR. Your dedicated IAR gets to know you on a personal and financial level and works with you to identify your financial goals and objectives. 2. Handling subsequent transactions (additional investments and redemptions). 3. Responding to client inquiries about their Accounts and issues pertaining to their Accounts. You access your IAR as needed to update them and HSBC Securities as your financial goals or priorities change or considering market conditions. 4. HSBC Securities or your IAR will at a minimum, annually request an in-person, telephonic or other electronic (e.g., zoom) meeting with clients, or will otherwise meet the regulatory requirements for an annual meeting, to discuss the account and any changes to the client’s investment objectives or reasonable investment restrictions. Please note that financial planning tools can be made available to help clients from time to time working with your Wealth Relationship Manager. Such financial planning tools, and any financial plan generated, are currently offered at no additional cost. However, products or services selected as a result of an implemented plan will result in a cost to you and fees for HSBC Securities. Please note that you are under no obligation to use any HSBC Securities product or service to execute the financial plan generated by the financial planning tool. Unless we indicate otherwise in writing, the financial plan generated does not constitute a solicitation, offer or recommendation to enter into any investment strategy or transaction, or fiduciary investment advice. nor is it intended to be investment advice under the Employee Retirement Income Security Act of 1974 (“ERISA”) or Section 4975 of the Internal Revenue Code of 1986, as amended (“the Code”). HSBC Securities does not intend to act in a fiduciary capacity or provide fiduciary investment advice with respect to financial planning tools. Rollovers We provide educational material regarding the options available to customers in qualified plans, but we do not provide any type of advice or recommendations about a customer’s qualified plan, nor do we make any recommendations or provide advice about whether or not to roll assets out of a plan. HSBC Securities does not provide advice regarding rollover decisions and instead provides only educational material for customers to evaluate and independently consider, and should not be viewed, construed, or relied upon, as investment or fiduciary recommendations or advice under ERISA or the Code. HSBC Securities is not acting as a fiduciary under ERISA or the Code when you decide to engage us in a new service, including with respect to your decision, or the decision of a plan participant, to roll over assets into an individual retirement account (“IRA”) which includes traditional, inherited or ROTH IRAs. If a financial plan is 10  HSBC Securities (USA) Inc. - Form ADV Part 2A generated to a customer with assets in an employer sponsored retirement plan, unless we indicated in writing, the financial plan is not and is not intended to be fiduciary investment advice under ERISA or the Code with respect to the assets in the employer sponsored retirement plan. If you choose to roll assets out of a plan, we will then, at your request, make recommendations about our services and products for investments that the customer can choose to implement in an HSBC Securities IRA brokerage or advisory account or an IRA annuity. Because we will only be paid for our services if you choose to roll over your plan account to an account at HSBC, we have an incentive to encourage you to rollover to an account with us, which we mitigate through our policies and procedures. For more information about rollovers with us, please refer to our online page at https://www.us.hsbc.com/investments/retirement/ira/ for educational material available. To request relevant acknowledgement forms, please contact your Representative, or call our Wealth Services Deck at 800.662.3343 M-F (8am-6pm) ET. Investment Management HSBC Securities is the sponsor, investment adviser and broker/dealer for the Programs, and is authorized in its discretion to manage client assets in accordance with selected asset allocations and investment strategies. HSBC Securities uses the services of third parties, including affiliates, for administrative and operational support in performing its obligations under the Spectrum Account Program Agreement, Spectrum II Fully Discretionary Account Addendum(s) and the Offshore Spectrum Account Agreement. The investments will include Funds that HSBC Securities determines are appropriate and, in the aggregate, consistent with a client’s investment goals, risk preferences and financial needs. All or a portion of an Account may temporarily be held in cash. The only money market funds available will be those managed or advised by an affiliate of HSBC Securities. Clients can fund their account with cash equivalents or shares of Funds acceptable to HSBC Securities or a combination thereof. For the Offshore Spectrum Program securities transferred in are subject to approval. Certain securities may need to be liquidated manually by our custodian Pershing® LLC (BNY Pershing). HSBC cannot control the timing of the liquidation. For the Offshore Spectrum Program, currency deposits will only be accepted in U.S Dollar Currency. HSBC Securities does not take taxes into account in making investment decisions for client Accounts. HSBC Securities will not invest client assets in Funds that impose front-end, contingent, or installment sales charges. However certain fund complexes can charge redemption fees for sales made within a certain number of days after purchase. For these purposes, the term “sales charges” does not include (a) underwriters’ compensation for offerings of closed-end funds, or (b) fees payable by a fund or its distributor, including shareholding servicing fees and Rule 12b-1 (distribution) fees, and HSBC Securities and its affiliates are expressly authorized to accept those fees, where permitted by law. However, when HSBC receives 12b-1 fees, the Firm will credit the Account with the amount of 12b-1 fees received. HSBC Securities does not credit its representatives any 12b-1 fees that are earned in the Programs. HSBC Securities is authorized to make changes to the Funds held in Accounts and/or to reallocate assets at any time (including an allocation into a new asset class), without consulting clients, for any reason it deems appropriate, including, without limitation, to respond to general market or macroeconomic circumstances, or to rebalance the investments periodically to restore the original allocation percentages 11  HSBC Securities (USA) Inc. - Form ADV Part 2A or target weights. HSBC Securities may modify investment allocations to reflect changes such as the introduction of new asset classes or new model options, as well as the removal of asset classes or models. Periodic rebalancing and liquidations may cause certain securities in an Account to be restricted from purchases for a period of 30 days due to wash sale rules. HSBC Securities will not invest contributions that are deposited into Accounts with wash sale restricted securities until the 30-day wash sale restriction has expired. As a result, an Account may have a higher than normal cash position for a period of time. This situation may adversely affect Account performance. Offshore Spectrum accounts that are impacted by a rebalance, model change, contribution or withdrawal may be out of the market for a period of time due to the settlement timing of buying and selling Funds in the account. The timing of trade settlement can have an impact on account performance. Clients should understand that rebalancing can trigger tax consequences as well as redemption fees charged by certain Funds. Accordingly, clients should confer with their tax advisor. From time to time, certain of the Funds in the Program have or can adopt policies and procedures that, although designed to prevent market timing, can delay (or even prevent) a purchase of such Funds for Accounts. HSBC Securities can be delayed in purchasing shares for an Account if the Account sold shares of the same Fund as a result of, for example, rebalancing an Account within a prescribed period of time before the proposed Fund purchase date. Information about market timing policies and procedures, if applicable, can be found in each Fund’s prospectus or fund offering documents. Special Trade Considerations for Offshore Spectrum Due to longer trade settlement times for offshore funds, activities such as liquidations, purchases, and model changes may delay your account from being fully invested until all trading activity has settled. UCIT Mutual Funds will be permitted for deposit into the program. Please be advised that UCIT ETFs will not be permitted. Additionally, contributions in UCIT mutual funds will cause trading delays due to the timing of trade settlement. Securities Backed Line of Credit We do not use leverage as an investment strategy for managed accounts. However, where appropriate, an eligible client, as detailed in the Account Control Agreement and Risk Disclosure statement, may use a Securities-Backed Line of Credit (“SBLOC”), which is a bank line of credit collateralized by the assets of the managed account, as well as other collateral the client may hold at HSBC Bank (USA) NA (“HSBC Bank”) or HSBC Securities (“USA”) Inc. (“HSBC Securities”). SBLOC enables clients to take out a loan that is secured by that client’s brokerage and/or advisory portfolio. The maximum amount of the loan depends on the lending value of the client’s portfolio, as specified in the Credit Agreement entered into with by HSBC Bank. SBLOC creates additional risks for managed account clients including being subject to a collateral call due to a drop in the account’s value caused by downward market movement, market volatility, investment changes and credit exposure. 12  HSBC Securities (USA) Inc. - Form ADV Part 2A All these can lead to collateral shortfalls and may cause HSBC Bank, as the lender to ask the managed account client for additional collateral or to sell assets in the account to satisfy the collateral shortfall. In the event that you are required to sell assets in your account, a drop in an advisory portfolio account’s value could cause the account to fall below the amount required to participate in the Program, resulting in termination of the Account. Any securities-based lending fees and interest are separate and in addition to Program fees. Neither HSBC Securities, its representatives nor its affiliates, will act as an investment adviser to a client as to the sale of securities subject to a collateral shortfall or credit line loan demand. We will make these sales in our capacity as a broker dealer. In addition, as creditors, we and our affiliates at times will have interests that are averse to you. Services Provided by BNY Pershing In support of the Spectrum Program, BNY Pershing provides HSBC Securities with a technology solution for providing client proposals, submitting and tracking service orders and maintenance requests, and creating performance and other reports. BNY Pershing also provides operational services including new Client Account set up; maintenance; order processing; billing (including implementation of fee schedules, inception billing, quarterly billing and contribution and withdrawal billing); mailed and/or electronic performance reporting, quarterly reports and daily on-demand summaries. Assets under Management As of December 31, 2024 the assets under management in the Programs are as follows: The Spectrum Program has approximately $2.28 billion in non-discretionary assets under management, although HSBC Securities serves as the sponsor and the advisor of the program’s management. There was approximately $273 million in discretionary assets under management under the Spectrum II program. For the newly launched Offshore Spectrum program there was approximately $132 million in discretionary assets. As of December 31, 2024 the assets under management in the other advisory programs are as follows: The MPA SMA Program has approximately $270 million in non-discretionary assets under management, although HSBC Securities has discretion over the program management. The MPA UMA Account Program has approximately $189 million in non-discretionary assets under management. 13  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 5: Fees and Compensation Fees for all Programs are generally charged and collected in accordance with the Investment Advisory Agreement provided to clients. Fees are generally negotiable. HSBC Securities, in its sole discretion can discount the Program Fee. Negotiated fees including discounts are subject to review and adjustment. This review can occur at any time after account opening. For purposes of determining the Fee Rate, you may request we consider the Account assets held by you and/or others in your designated relationship as determined by us at our discretion. Spectrum, Spectrum II and Offshore Spectrum Program Fees Fees for the Programs are paid in arrears. The fees payable for any calendar quarter will be based on the average daily Account asset value during the prior calendar quarter and the annual fee rate(s) set forth in the following schedule. Clients pay a contractual fee (See Standard Fee Schedule below) for the services provided through the Programs, which include investment advice, brokerage commissions when HSBC Securities buys and sells Funds for the Account, custody, and reporting. HSBC Securities expects that it will perform all trading for Accounts. The current Standard Fee Schedule for Accounts is as follows: Annual Rate Average Assets 1.50% First $250,000 Next $250,000 1.00% Assets in excess of $500,000 0.50% New Fee Schedules (Effective April 1, 2026) HSBC will be implementing a new fee schedule for the Spectrum, Spectrum II and Offshore Spectrum Program fees effective April 1, 2026. The revised fee schedule is outlined below and will automatically apply to your account beginning on the effective date. Unless you are notified otherwise, any existing household or negotiated discounts currently in place will continue to be honored. Annual Rate 1.50% 1.20% Average Assets First $250,000 Next $250,000 Next $500,000 1.00% Next $1,000,000 .90% Next $3,000,000 .80% Next $5,000,000 .65% Above 10,000,000 .55% Fees for the Programs are also described in the Program Account Agreements. On a quarterly basis, fees are debited from Accounts. HSBC Securities pays a portion of these fees to AMUS and the other third- party service providers. 14  HSBC Securities (USA) Inc. - Form ADV Part 2A The Program fee rates are subject to change from time to time, upon notice to you. Your continued use of Program Services will constitute your agreement to the change in the program fee rate. General Fee Information In connection with investments in an HSBC affiliated fund by a retirement account an IRA or an employee benefit plan subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), HSBC Securities will offset any additional compensation it (or an affiliate) receives in connection with such investments by crediting against the account fee an amount that is equal to such additional fees and compensation HSBC Securities (and its affiliates) receive for the applicable billing period with respect to such investment. Program clients, as part of their contractual fee, also pay for administrative services provided to HSBC Securities by AMUS and our custodian BNY Pershing. The contractual fee does not cover miscellaneous fees and expenses that BNY Pershing may charge to the Account such as wire fees, outgoing transfer fees, bank charges and IRA/retirement account fees. In addition to the Program contractual fees, clients pay their share of a Fund’s fees and expenses, which include management fees, administrative fees, operating costs, and all other costs the Fund incurs. If the firm receives 12b-1 fees, the Firm will credit the Account in an amount equal to the amount of the client’s share of any Rule 12b-1 fees paid by the applicable Funds in which the Account is invested. For information regarding the structure, fees, and risks associated with investing in Mutual Funds and ETFs, see applicable SEC’s Investor Bulletins under Investor Alerts and Bulletins | Investor.gov Clients should consider the total fees and expenses, including the contractual Spectrum Program fee, that the client will pay to participate in the Programs. Fees and expenses will reduce the return on investments. Comparison Cost of Service The Programs can cost clients more or less than purchasing such services separately depending on the frequency of trading in the client’s account, commissions charged at other broker-dealers or investment firms (including through other account types available at HSBC Securities) for similar products, advisory fees charged by other investment firms, and other factors. Account Funding Clients can fund their Spectrum Program account(s) with cash equivalents or shares in Funds/Securities that are acceptable to HSBC Securities or a combination thereof. If a prospective client intends to fund a Program account with assets from the redemption of mutual funds, the surrender of an insurance product, early withdrawal from a certificate of deposit, or the sale of any other financial instruments, the client should consider the cost of any possible sales charges or commissions previously paid or to be paid upon the redemption or sale, or any penalties that the client will incur in order to surrender or withdraw from, such an instrument. It can be costly or inappropriate for the client to fund an Account in this manner. For Offshore Spectrum: All assets transferred into this program are subject to review and approval from our custodian BNY Pershing prior to liquidation. In the event an investment cannot be transferred or liquidated for funding into 15  HSBC Securities (USA) Inc. - Form ADV Part 2A the Offshore Spectrum program, BNY Pershing reserves the right to not accept the asset. In addition, there may be situations where our custodian will have to liquidate certain investments manually causing delays in funding of the Offshore Spectrum account. An ACH (automated clearing house) transaction is a bank transfer that occurs between banks at your direction and authorization. Please note there can be limits to the amount of money that you can transfer in electronically from your account. As these limits are subject to change, please contact your Representative for additional information. 16  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 6: Performance-Based Fees and Side by Side Management The Firm does not charge performance fees to clients, nor does it engage in Side by Side Management in the Programs. 17  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 7: Types of Clients and Account Requirements The Spectrum and Spectrum II Programs are offered to retail clients including individuals, trusts, estates or charitable organizations; retirement accounts; and corporations, limited liability companies and/or other business entities. The Firm offers the Spectrum and Spectrum II Programs to U.S. citizens and U.S. residents. The Spectrum II ETF portfolios are available to U.S. citizens and U.S. residents, and to certain U.S. citizens living outside of the U.S. If an account holder moves to a foreign jurisdiction or is no longer considered a U.S citizen or U.S. resident, HSBC Securities in its sole discretion can remove the account from management. A fund company in its sole discretion may decide to no longer offer its fund in a specific foreign jurisdiction which will impact the management of your account. In addition, if a client moves to a jurisdiction that is not approved by a specific fund company, HSBC Securities will be required to redeem that holding(s) and in the case of certain fund companies, HSBC Securities can cause your Account to be terminated with all account holdings required to be redeemed. Offshore Spectrum is currently offered to Non-Resident Aliens who reside in approved jurisdictions. Clients should consider legal and/or tax implications when considering their options. Clients should consult with their attorney or tax advisor. Program Minimums Effective October 16, 2024, the minimum Account opening balances are $100,000 for the Spectrum Program and $50,000 for the Spectrum II Program. The minimum Account opening balance for Offshore Spectrum is $100,000. For all Programs, HSBC Securities reserves the right to increase or decrease the minimum Account size if deemed necessary. HSBC Securities can establish other or lower minimum account sizes for other types of accounts. Accounts that fall below the program minimums can be removed from management at HSBC Securities’ sole discretion. 18  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 8: Methods of Analysis, Investment Strategies and Risk of Loss HSBC Securities has entered into agreements with AMUS, GMS and HAIL to provide certain services for the Programs. The methods of analysis and investment strategies AMUS, GMS and HAIL use in the Spectrum Programs are outlined below. Methods of Analysis for the Programs Asset Allocation Evaluation AMUS oversees the asset allocation models used in the Programs and provides administrative and advisory resources to support the Programs. In providing this service, AMUS collaborates with HSBC Global Asset Management to develop the asset allocation models, considering both its long-term and its short-term tactical views. Over the long-term, Strategic Asset Allocations (“SAA”) take into account expected long- term asset class returns, volatilities and correlations in determining recommended allocations subject to local constraints (e.g., appropriate asset classes and risk tolerance bands). As such, SAAs reflect our long- term expectations for capital markets, balancing expected returns with a reasonable level of volatility for the models in the Program. AMUS reviews SAAs periodically. In the short-term, capital markets will often deviate from our expectations and present the opportunity to adjust our recommended allocations. In periodically reviewing the models, AMUS will refine the asset allocation models using Tactical Asset Allocation (“TAA”) which adjusts allocations considering short-term trends and relative valuations in capital markets. As such, TAA seeks to take advantage of relative valuation opportunities that arise in the short-term and are expected to enhance portfolio performance over the long-term. In making recommendations, AMUS will use the information and tools used in its analysis from both global and local teams, balancing our long-term strategic expectations with short-term tactical opportunities. This means that HSBC Securities, at its discretion, may change the asset allocation models periodically based upon AMUS’s advice. HSBC Securities makes decisions regarding investment strategies leveraging the funds researched by GMS. GMS researches and approves third party investment strategies (mutual funds, ETFs). GMS conducts due diligence based upon both quantitative (e.g., investment performance returns, peer rankings, tracking error, expense ratio, etc.) and qualitative (e.g., firm, people, investment strategy and process, portfolio construction, etc.) factors to approve the investment strategies available through the Spectrum program. As part of the qualitative review, GMS will review performance attribution, analyze portfolio holdings and assess liquidity and capital erosion. Risk metrics and periodic performance comparisons against representative benchmarks and peers are used as part of the quantitative process. GMS also conducts ongoing monitoring of the Funds using similar criteria as the initial review process. Certain funds available within the Spectrum Program that are not labeled as sustainable investment funds can include sustainability considerations in their investment processes, but any such funds (outside of Spectrum II ESG) are not included for their sustainability considerations but instead for other qualities of their investment focus or strategies. The Spectrum advisory portfolio allows clients the option to customize their fund selections using the Spectrum fund menu. Based upon its findings during the ongoing monitoring, GMS may change the status of a Fund to “Hold”. If the factors that led to hold status remain unresolved, GMS will change the status of the Fund to “Not Approved/Not Recommended.” A Fund’s status may change directly to “Not Approved/Not 19  HSBC Securities (USA) Inc. - Form ADV Part 2A Recommended” in case the concerns are material requiring immediate action by HSBC Securities after evaluating GMS’s assessments. For the Spectrum Program: Clients are notified via a client statement or mailing and provided with information on the selected replacement Fund. In certain cases, where there is a change affecting the Fund, HSBC Securities can recommend the immediate removal without a hold period. Affected clients will be notified of the alternative Fund recommendation. For Spectrum II and Offshore Spectrum: HSBC Securities will not notify the client of Fund changes, as the Spectrum II and Offshore Spectrum Programs are fully discretionary programs. The Funds made available through the Programs include both funds advised by Non-HSBC investment advisers (third party Funds) and funds advised by HSBC Global Asset Management (USA) Inc. or its affiliates who provide investment advisory services (proprietary Funds). The third party and proprietary Funds used in the Programs are aligned with the asset classes offered within the asset allocation models. Third party Funds are selected from Funds offered by globally approved unaffiliated fund companies. HSBC Global Asset Management (USA) Inc. receives investment advisory fees from the proprietary Funds used in the Programs. Alternative Funds used within the Spectrum Programs: HSBC Securities makes decisions regarding investment strategies leveraging the alternative funds researched by HAIL. HAIL researches and approves alternative Funds using a variety of qualitative and quantitative criteria. HAIL conducts due diligence based upon both quantitative (e.g., investment performance returns, peer rankings, etc.) and qualitative (e.g., firm, people, investment strategy and process, portfolio construction, etc.) factors to approve the investment strategies available through the Spectrum program. Performance comparisons against representative benchmarks and peers are used as part of the quantitative process. HAIL also conducts ongoing monitoring of the Funds using similar criteria as the initial review process and may place a fund on Hold or move a fund to Not Approved similar to the GMS process described above. HSBC Securities will take the appropriate action after evaluating HAIL’s assessments. Review process for Environmental, Social and Governance (ESG) Funds:  GMS conducts due diligence on ESG/sustainable funds to assess their ESG characteristics, evaluating their ESG intentionality and ensuring this is reflected in the resultant portfolio.  On a fund-specific level, GMS applies HSBC Group’s Sustainable Investment (SI) definitions to determine if a fund is an ESG fund. In addition to the alignment to SI definitions, GMS undertakes a qualitative evaluation of ESG considerations, with a deep dive into the sustainable investment philosophy, style, proprietary ESG frameworks and voting policy; and an-evidence-based assessment that ensures the approach consistently reflects in the portfolio holdings.  The ESG assessment is documented, discussed and approved through various committees. The committees will review new ESG fund additions as well as fund downgrades / upgrades and will take note of completed fund reviews where the status remains unchanged. HSBC Securities (USA) Inc. makes available Environmental Social Governance (ESG) funds for selection within the Spectrum II Program. Each fund manager may use different metrics such as ESG rating and carbon 20  HSBC Securities (USA) Inc. - Form ADV Part 2A intensity to measure the environmental or social impact of their strategies. The criteria used can be highly subjective and may vary significantly across and within sectors. HSBC Securities through Global Manager Selection – Funds & ETFs (“GMS”) undertakes its own due diligence when selecting managers for ESG consideration. While GMS conducts its own due diligence, GMS is still reliant on the underlying proprietary ESG measurement criteria used by fund managers and does not conduct its own due diligence into a manager’s proprietary ESG measurement scoring or criteria. There is no guarantee that the nature of the ESG characteristics of an investment will be aligned with any particular investor’s ESG objectives or that the stated level or target level of ESG goals will be achieved. Share Class Evaluation While we seek to provide you with the lowest cost share class of a Fund, whether we offer the lowest cost share class to clients depends on several factors. First, a fund may not make its lowest cost share class available in the Programs. Second, some institutional share classes are not available to retail investors, in or outside of the Programs. Third, if BNY Pershing charges us a fee to trade lowest-cost share classes for your Account, we will not use that share class for your account. When we offer a higher-cost share class because BNY Pershing charges us a fee to trade the lowest-cost class, we have a conflict of interest, because we are avoiding paying a fee while causing your Account to pay higher Fund fees and expenses. When we offer a share class in the Programs that is not the lowest cost class, you will pay higher Fund fees and expenses, which will reduce your returns and lower the performance of your Account. Some lower cost share classes are available outside the Programs, but you will not receive the Programs’ services and benefits. There will be no cost to you if HSBC Securities initiates a share class conversion; however, there may be tax consequences. Any share class conversions will occur as deemed necessary by HSBC Securities and will be reflected on your Account statements. Risks Investing in securities involves risk of loss that clients should be prepared to bear. While the market may increase in value and your account(s) could enjoy a gain, it is also possible that the securities markets may decrease in value and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the market, are appropriately diversified in your investments, and ask us any questions you may have. The Programs, and shares of Funds including money market funds, are: not a deposit or other obligation of HSBC Bank USA, N.A. (“HSBC Bank”) or any of its affiliates; not FDIC insured or insured by any federal government agency of the United States; not guaranteed by HSBC Bank or any of its affiliates; and are subject to investment risk, including possible loss of the principal amount invested. Set forth below are certain material risk factors that are often associated with the risks of investing in an advisory program that uses models, and with the risks of investing in securities (Funds) relevant to most of HSBC Securities’ clients. The information included in this Brochure does not include every potential risk associated with each model or that applies to a particular client account. Not all risks apply to all models. Clients are urged to ask questions regarding risk factors for a particular strategy or Fund, read all Fund prospectuses and fund offering documents and determine whether a particular model or type of Fund is suitable for their account in light of their circumstances, investment objectives and financial situation. Risks of Investing in a Model Program Allocation Risk: This is the risk that HSBC Securities target asset and sector allocations and changes in 21  HSBC Securities (USA) Inc. - Form ADV Part 2A target asset and sector allocations cause the model to underperform other similar models, and that the model may not achieve its target asset and sector allocations. Cyber Security Risk: With the increased use of technology such as the Internet to conduct business, HSBC Securities, as with all businesses and digital platforms that store, process, transmit or transact information via networked technology, is susceptible to a breach of confidentiality, loss of data integrity or disruption in availability of its networked systems. Cyber vulnerability continues to be leveraged by criminals to perpetrate crimes at an increasing rate and poses a significant threat to economic, social and geopolitical stability for private firms and countries. HSBC Securities faces sophisticated cyber threats from state-sponsored attackers, hackers for hire, organized cyber syndicates, and other threat actors seeking our critical corporate and client information. Cyber incidents can result from deliberate internal or external attacks. Cyber-attacks can include, but are not limited to, gaining unauthorized access to computer systems (e.g., through “hacking” or malicious software (aka Malware) denial-of-service attacks on websites (i.e., efforts to make network services unavailable to intended users). Unintentional cyber incidents can occur, such as the inadvertent release of confidential information that could result in the violation of applicable privacy laws. A failure in or a breach of our operational or security systems or infrastructure, or those of our third party vendors and other service providers, including as a result of cyber-attacks, could disrupt our businesses, result in the disclosure or misuse of confidential or proprietary information, and may adversely impact our businesses. Data quality and integrity are critical for decision making, enterprise risk management and operational processes, as well as for complying with applicable regulation. Our businesses are dependent on our ability to process a large number of complex transactions, most of which involve, in some fashion, networked computing devices. If any of our financial, accounting, data processing or other recordkeeping systems and management controls fail, or are subject to cyber-attack that could compromise integrity, availability or confidentiality of our systems or data, we could be materially adversely affected. Cyber security failures or breaches at HSBC Securities or at service providers (including, but not limited to, sub-advisers, accountants, custodians, transfer agents and administrators), and the issuers of securities in which HSBC Securities invests on behalf of its clients, could result in the loss or theft of client data or funds, the inability to access electronic systems, loss or theft of proprietary information or corporate data, physical damage to a computer or network system, or costs associated with system repairs. Cyber security failures or breaches can result in financial losses, interfere with our ability to calculate a fund’s net asset value, impede our trading, and prevent clients and shareholders from transacting business. These failures or breaches can cause violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. In addition, we could incur substantial costs to prevent any cyber incidents in the future. HSBC Securities relies on cybersecurity risk controls that are managed enterprise wide for HSBC Holdings plc in order to ensure that threats are identified and mitigated properly. While HSBC Holdings plc (a corporate parent company of HSBC Securities) has preventative, detective and mitigation technologies in place as well as mature business continuity and resiliency plans in the event of cyber-attacks, it is not possible to identify and create mitigation measures for every type of event that might result in a service 22  HSBC Securities (USA) Inc. - Form ADV Part 2A disruption. Fund Selection Risk: The risk that a model may invest in Funds that underperform other similar Funds or the markets more generally, due to poor investment decisions by the investment adviser(s) for the Funds or otherwise. Funds also have their own expenses, which the client bears in addition to the Program fee. Model Risk: A model is defined as a quantitative method, system, or approach that applies statistical, economic, financial or mathematical theories, techniques, and assumptions to process input data into quantitative estimates. Quantitative methodologies or systems whose inputs are (partially or wholly) qualitative or based on expert judgment may be classified as a model providing that the outputs produced by the model are quantitative in nature. HSBC Securities, in conjunction with AMUS, utilize models to assist in the investment decision making process, to analyze the investment risks borne by a fund or client account, to measure the liquidity in a fund or client account, to conduct stress tests and for other reasons. Model risk is defined as the risk of Funds or HSBC Securities and/or affiliates experiencing an actual or potential financial loss, or the breach of a regulation or client restriction, owing to the misspecification or misapplication of a model in relation to its intended use, or the improper implementation or incorrect execution of a model. Regulatory Risk: US regulators and legislators have amended a wide range of rules and pending and ongoing regulatory reforms (e.g., the Dodd Frank Act) continue to have a material impact on the advisory business. These regulations and reforms may significantly change the operating environment and the ultimate effect cannot be adequately predicted. Any further changes by the SEC or additional legislative developments may affect a Program’s operations and investment strategies. Securities Risks Asset-Backed Security Risk: Asset-backed securities are debt instruments that are secured by interests in pools of financial assets, such as credit card or automobile receivables. The value of these securities will be influenced by the factors affecting the assets underlying such securities, changes in interest rates, changes in default rates of borrowers and private insurers or deteriorating economic conditions. During periods of declining asset values, asset-backed securities may be difficult to value or become more volatile and/or illiquid. Asset-backed securities may not have the benefit of a security interest in collateral comparable to that of mortgage assets, resulting in additional credit risk. Banking Risk: Investments in securities issued by U.S. and foreign banks can be sensitive to changes in government regulation and interest rates and to economic downturns in the United States and abroad, and susceptible to risks associated with the financial services sector. Capitalization Risk: Some Funds invest in large capitalization companies. Stocks of large capitalization companies may be volatile in the event of earnings disappointments or other financial developments. Medium and smaller capitalization companies may involve greater risks due to limited product lines, market and financial or managerial resources, as well as have more volatile stock prices and the potential for greater declines in stock prices in response to selling pressure. Small capitalization companies generally have more risk than medium capitalization companies. Convertible Bond Risk: Some Funds invest in convertible bonds, which are subject to the risks of equity securities when the underlying stock price is high relative to the conversion price (because more of the security’s value resides in the conversion feature) and debt instruments when the underlying stock price is low relative to the conversion price (because the conversion feature is less valuable). A convertible bond is not as sensitive to interest rate changes as a similar non-convertible debt instrument, and generally has less potential for gain or loss than the underlying equity security. 23  HSBC Securities (USA) Inc. - Form ADV Part 2A Counterparty Risk: The risk that the other party to an investment contract, such as a derivative (e.g., ISDA Master Agreement) or a repurchase or reverse repurchase agreement, will not fulfill its contractual obligations or will not be capable of fulfilling its contractual obligations due to circumstances such as bankruptcy or an event of default. Such risks include the other party's inability to return or default on its obligations to return collateral or other assets as well as failure to post or inability to post margin as required applicable credit support agreement. Commodity Related Investments Risk: The risks of investing in commodities, including investments in companies in commodity-related industries may subject a fund to greater volatility than investments in traditional securities. The potential for losses may result from changes in overall market movements or demand for the commodity, domestic and foreign political and economic events, adverse weather, discoveries of additional reserves of the commodity, embargoes and changes in interest rates or expectations regarding changes in interest rates. Concentration Risk: When a model or client account invests in a concentrated number of asset classes or sectors, a decline in the value of these asset classes or sectors may cause your overall account value to decline to a greater degree than that of a less concentrated model. Models that invest a large percentage of assets in only one asset class or sector (or in only a few) are more vulnerable to price fluctuation than models that diversify among a broad range of asset classes or sectors. Some mutual funds and ETFs focus investments on a small number of stocks, bonds, industries, foreign currencies or particular countries which increases risk. These funds are more susceptible to risks associated with a single economic, political or regulatory occurrence than a more diversified fund might be. Currency Risk: Fluctuations in exchange rates between the U.S. dollar and foreign currencies, or between various foreign currencies, may negatively affect a fund’s investment performance. Custody Risk: Some funds invest in securities markets that are less developed than those in the U.S., which may expose a fund to risks in the process of clearing and settling trades and the holding of securities by foreign banks, agents and depositories. The laws of certain countries may place limitations on the ability to recover assets if a foreign bank, agent or depository enters bankruptcy. In addition, low trading volumes and volatile prices in less developed markets may make trades more difficult to complete and settle, and governments or trade groups may compel local agents to hold securities with designated foreign banks, agents and depositories that may be subject to little or no regulatory oversight or independent evaluation. Local agents are held only to the standards of care of their local markets. Debt Instruments Risk: The risks of investing in debt instruments include: > High-Yield Securities (“Junk Bond”) Risk: Investments in high-yield securities (commonly referred to as “junk bonds”) are often considered speculative investments and have significantly higher credit risk than investment-grade securities and tend to be less marketable (i.e., less liquid) than higher rated securities. The prices of high-yield securities, which may be more volatile and less liquid than higher rated securities of similar maturity, may be more vulnerable to adverse market, economic or political conditions. > Interest Rate Risk: Fluctuations in interest rates may affect the yield and value of investments in income producing or debt instruments. > Credit Risk: A fund could lose money if an issuer or guarantor of a debt instrument fails to 24  HSBC Securities (USA) Inc. - Form ADV Part 2A make timely payments of interest or principal or enters bankruptcy. This risk is greater for lower-quality bonds than for bonds that are investment grade. >Inventory Risk: The market-making capacity in some debt markets has declined as a result of reduced broker-dealer inventories relative to portfolio assets, reduced broker-dealer proprietary trading activity and increased regulatory capital requirements for financial institutions such as banks. Because market makers provide stability to a market through their intermediary services, a significant reduction in dealer market-making capacity has the potential to decrease liquidity and increase volatility in the debt markets. > Prepayment Risk: During periods of falling interest rates, borrowers may pay off their debt sooner than expected, forcing a fund to reinvest the principal proceeds at lower interest rates, resulting in less income. > Extension Risk: The risk that during periods of rising interest rates, borrowers pay off their debt later than expected, preventing a fund from reinvesting principal proceeds at higher interest rates, increasing the sensitivity to changes in interest rates and resulting in less income than potentially available. Depositary Receipts Risk: Investments in depositary receipts, such as ADRs and GDRs, may entail the special risks of international investing, including currency exchange fluctuations, government regulations, and the potential for political and economic instability. Derivatives Risk: Use of derivative instruments involves risks different from, or possibly greater than, the risks associated with investing directly in securities and other traditional investments and could increase the volatility of a fund’s net asset value and cause losses. Risks associated with derivatives include the risk that the derivative is not well correlated with the security, index or currency to which it relates; the risk that derivatives may result in losses or missed opportunities; the risk that the fund will be unable to sell the derivative because of an illiquid secondary market; the risk that a counterparty is unwilling or unable to meet its obligation; and the risk that the derivative transaction could expose the fund to the effects of leverage, which could increase the fund’s exposure to the market and magnify potential losses, particularly when derivatives are used to enhance return rather than offset risk. There is no guarantee that derivatives, to the extent employed, will have the intended effect, and their use could cause lower returns or even losses to the fund. The use of derivatives by the fund to hedge risk may reduce the opportunity for gain by offsetting the positive effect of favorable price movements. Diversification Risk: Diversification is a risk management strategy that mixes a wide array of investments within a portfolio. A diversified portfolio contains a mix of distinct asset types and investment vehicles in an attempt at limiting exposure to any single asset or risk. It does not guarantee a profit or protect against a loss in a declining market. It also cannot eliminate risk of fluctuating prices and uncertain returns. Emerging Markets Risk: Investments in emerging market countries are subject to all of the risks of foreign investing generally, and have additional heightened risks due to a lack of established legal, political, business and social frameworks to support securities markets, including: greater market volatility and illiquidity, lower trading volume, delays in trading or settling portfolio securities transactions; currency and capital controls or other government restrictions or intervention, such as expropriation and nationalization; greater sensitivity to interest rate changes; pervasiveness of corruption and crime; currency exchange rate volatility; and higher levels of inflation, deflation or currency devaluation. The prices of securities in emerging markets 25  HSBC Securities (USA) Inc. - Form ADV Part 2A can fluctuate more significantly than the prices of securities in more developed countries. The less developed the country, the greater effect such risks may have on an investment. Environmental Social Governance (ESG) Investments: HSBC Securities (USA) Inc. makes available Environmental Social Governance (ESG) funds with certain limitations by the program and model type: HSBC Securities (USA) Inc. will only offer the following in respect to ESG funds and investments:  Spectrum Programs/models: o The Spectrum program and models no longer offers ESG Investment options in the Spectrum Program for new investors (please note that Spectrum II is considered a separate program). Existing clients holding ESG exposed positions and investments have the option to continue investing in them.  Spectrum II Programs/models: o The Spectrum II program and models will continue to be open to new investors who desire ESG Investment options with the choice of the ESG related models. Sustainable Investments is a broad term that refers to any form of financial services integrating Environmental, Social and Governance (ESG) criteria that aims to generate long-term financial returns while advancing sustainable solutions and outcomes. As a result of the ESG screening criteria utilized by these funds, the investment opportunities may be more limited than that of other funds, and as a result using an ESG investment approach may produce more modest gains than using another investment approach. There is no guarantee that an investment approach that considers environmental, social and governance (ESG) factors will produce returns similar to those that do not consider these factors. Investment approaches that consider ESG factors may diverge from traditional market benchmarks. Also, some asset classes might not be available in the Spectrum II ESG Program. There is currently no generally adopted industry criteria/standards for what qualifies as an ESG investment, how to measure performance of ESG investments, and the impact of ESG investments on performance. This can result in discrepancies in results and approach in the calculation of ESG data. An ESG portfolio is not guaranteed to outperform (financially) similar investments that do not meet ESG criteria. There is no guarantee that the ESG characteristics a manager uses will be aligned with those of the client’s or that these characteristics will match the client’s expectation of ESG investing. Also, each fund manager can have different ESG assessment criteria and exclusion criteria. ESG investment is an evolving area, and an investment that is considered ESG today may not meet those standards at some point in the future. Therefore, the range of ESG investment strategies that any underlying fund in the Program employs may change in the future. Equity Securities Risk: The prices of equity securities fluctuate from time to time based on changes in a company’s financial condition or overall market and economic conditions. As a result, the value of equity securities may fluctuate drastically from day to day. The risks of investing in equity securities also include: 26  HSBC Securities (USA) Inc. - Form ADV Part 2A > Style Risk: The risk that use of a growth or value investing style may fall out of favor in the marketplace for various periods of time. Growth stock prices reflect projections of future earnings or revenues and may decline dramatically if the company fails to meet those projections. A value stock may not increase in price as anticipated if other investors fail to recognize the company’s value. > Issuer Risk: An issuer’s earnings prospects and overall financial position may deteriorate, causing a decline in a fund’s net asset value.  Exchange Traded Fund Risk: An investment in ETFs involves risk, including the loss of principal. ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent net asset value (‘NAV”), which is generally calculated at least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares.  Financial Services Risk: The adviser’s investments in the financial services group of industries may be particularly affected by economic cycles, interest rate changes, and business developments and regulatory changes applicable to the financial services group of industries. For example, declining economic and business conditions can disproportionately impact companies in the financial services group of industries due to increased defaults on payments by borrowers. Interest rate increases can also adversely affect financial services companies by increasing their cost of capital. In addition, financial services companies are heavily regulated and, as a result, political and regulatory changes can affect the operations and financial results of such companies, potentially imposing additional costs and possibly restricting the businesses in which such companies may engage. Foreign Securities Risk: Investments in foreign securities are generally considered riskier than investments in U.S. securities, and are subject to additional risks, including international trade, political, economic and regulatory risks; fluctuating currency exchange rates; less liquid, developed or efficient trading markets; the imposition of exchange controls, confiscations and other government restrictions; and different corporate disclosure and governance standards. Frontier Market Countries Risk: Frontier market countries generally have smaller economies and even less developed capital markets or legal, regulatory and political systems than traditional emerging markets. As a result, the risks of investing in emerging market countries are magnified in frontier market countries. Frontier market economies are less correlated to global economic fluctuations than developed economies and have low trading volumes and the potential for extreme price volatility and illiquidity. The government of a frontier market country may exercise substantial influence over many aspects of the private sector, including by restricting foreign investment, which could have a significant effect on economic conditions in the country and the prices and yields of securities in a fund’s portfolio. Economies in frontier market countries generally are heavily dependent upon international trade and, accordingly, have been and may continue to be adversely affected by trade barriers, exchange controls, managed adjustments in relative currency values and other protectionist measures imposed or negotiated by the countries with which they trade. These economies also have 27  HSBC Securities (USA) Inc. - Form ADV Part 2A been and may continue to be affected adversely by economic conditions in the countries with which they trade. Brokerage commissions, custodial services and other costs relating to investment in frontier market countries generally are more expensive than those relating to investment in more developed markets. The risk also exists that an emergency situation may arise in one or more frontier market countries as a result of which trading of securities may cease or may be substantially curtailed and prices for investments in such markets may not be readily available. Government Securities Risk: There are different types of U.S. government securities with different levels of credit risk. U.S. government securities issued or guaranteed by the U.S. Treasury and/or supported by the full faith and credit of the United States have the lowest credit risk. A U.S. government sponsored entity, although chartered or sponsored by an Act of Congress, may issue securities that are neither insured nor guaranteed by the U.S. Treasury and are riskier than those that are. Index Fund Risk: The risk that a fund’s performance will not correspond to its benchmark index for any period of time and may underperform the overall stock market. Issuer Risk: The risk that the issuer’s earnings prospects and overall financial position will deteriorate, causing a decline in the value of the fund. Leverage Risk: Leverage created by borrowing or investments, such as derivatives, can diminish the fund’s performance and increase the volatility of the fund’s net value. Liquidity Risk/Illiquid Securities Risk: The risk that the fund could lose money if it is unable to dispose of an investment at a time that is most beneficial or be unable to meet redemption demand. Market Risk: Issuer, political, or economic developments such as a global pandemic can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. In the short term, equity prices can fluctuate dramatically in response to these developments. Different parts of the market and different types of equity securities can react differently to these developments. For example, large-cap stocks can react differently from small-cap or mid-cap stocks, and “growth” stocks can react differently from “value” stocks. Mortgage- and Asset-Backed Securities Risk: Mortgage- and asset-backed securities are debt instruments that are secured by interests in pools of mortgage loans or other financial assets. Mortgage- and asset-backed securities are subject to prepayment, extension, market, and credit risks (market and credit risk are described elsewhere in this section). Prepayment risk reflects the risk that borrowers may prepay their mortgages faster than expected, thereby affecting the investment’s average life and perhaps its yield. Conversely, an extension risk is present during periods of rising interest rates, when a reduction in the rate of prepayments may significantly lengthen the effective durations of such securities. Participatory Note Risk: Even though a participatory note is intended to reflect the performance of the underlying securities on a one-to-one basis so that investors will not normally gain or lose more in absolute terms than they would have made or lost had they invested in the underlying securities directly, the performance results of participatory notes will not replicate exactly the performance of the issuers or markets that the notes seek to replicate due to transaction costs and other expenses. Investments in participatory notes involve risks normally associated with a direct investment in the underlying securities. In addition, participatory notes are subject to counterparty risk. Participatory notes constitute general unsecured, unsubordinated contractual obligations of the banks or broker-dealers that issue them, and an investment in these instruments is relying on the creditworthiness of such banks or broker-dealers and has no rights under the participatory notes against the issuers of the securities underlying such participatory notes. There can be no assurance that the trading price or value of participatory notes will equal the value of the underlying value of the securities they seek to replicate. 28  HSBC Securities (USA) Inc. - Form ADV Part 2A Political Risk: The risk that an investment’s return could suffer as a result of political changes or instability in a country. Instability affecting investment returns could stem from a change in government, legislative bodies, other foreign policy makers, or military control. Political risk is also known as “geopolitical risk”, and becomes more of a factor as the time horizon of an investment gets longer. Real Estate Risk: Real estate related investments will expose a Fund to risks similar to those associated with direct ownership of real estate, including losses from casualty or condemnation, and changes in local and general economic conditions, supply and demand, interest rates, zoning laws, regulatory limitations on rents, property taxes and operating expenses. Redemption Risk: A fund may experience a redemption(s) resulting in large outflows of cash from time to time. This activity could have adverse effects on performance if the advisor were required to sell securities at times when it otherwise would not do so. This activity could also accelerate the realization of capital gains/losses and increase transaction costs. Regulatory Risk in Other Countries: Disclosure and regulatory standards in emerging market countries are in many respects less stringent than U.S. standards. Therefore, disclosure of certain material information may not be made, and less information may be available. Additionally, regulators in many countries continue to review the regulation of such funds. Any further changes by a regulatory authority or additional legislative developments may affect a fund’s operations, investment strategies, performance and yield. Repurchase Agreement Risk: The use of repurchase agreements, which are agreements where a party buys a security from another party (“seller”) and the seller agrees to repurchase the security at an agreed-upon date and price (which reflects a market rate of interest), involves certain risks. For example, if the seller of the agreements defaults on its obligation to repurchase the underlying securities at a time when the value of these securities has declined, a fund may incur a loss upon disposition of the securities. There is also the risk that the seller of the agreement may become insolvent and subject to liquidation. Short Sale Risk: The risk of entering into short sales, including the potential loss of more money than the actual cost of the investment, and the risk that the third party to the short sale may fail to honor its contract terms, causing a loss to the fund. Sovereign Debt Risk: Sovereign debt instruments, which are instruments issued by foreign governmental entities, are subject to the risk that the governmental entity may be unable or unwilling to repay the principal or interest on its sovereign debt due to, among other reasons, cash flow problems, insufficient foreign currency reserves, political considerations, the relative size of the governmental entity’s debt or its failure to implement economic reforms required by the International Monetary Fund or other multilateral agencies. A governmental entity that defaults can ask for additional loans or for more time to pay its debt. There is no legal process for collecting sovereign debts that a government does not pay nor are there bankruptcy proceedings through which all or part of the sovereign debt that a governmental entity has not repaid may be collected. Stable NAV Risk: The following applies to money market funds that maintain a stable price of $1.00 per share. The fund may not be able to maintain a Net Asset Value (“NAV”) per share of $1.00 (a “Stable NAV”) at all times. The failure of other money market funds to maintain a Stable NAV (or the perceived threat of such a failure) could adversely affect the fund’s NAV. Shareholders of a money market fund should not rely on or expect the Adviser, the fund's adviser or an affiliate to help a fund maintain a Stable NAV. Pending money market fund reform changes may also impact Stable NAV policies of funds. 29  HSBC Securities (USA) Inc. - Form ADV Part 2A Stand-by Commitments Risk: Stand-by commitments are subject to certain risks, which include the ability of the issuer to pay when the commitment is exercised, the fact that the commitment is not marketable, and the fact that the maturity of the underlying obligation generally differs from that of the commitment. Swap Risk: The use of swap agreements, agreements to exchange the return generated by one instrument for the return generated by another instrument (or index), and similar instruments involves risks that are different from those associated with ordinary portfolio securities transactions. For example, the fund bears the risk of loss of the amount expected to be received under a swap agreement in the event of the default or bankruptcy of a swap agreement counterparty. If a counterparty defaults on its payment obligations to the fund, this default will cause the value of the fund to decrease. Swap agreements also may be considered to be illiquid. Underlying Fund Selection Risk: The risk that a portfolio may invest in underlying Funds that underperform other similar Funds or the markets more generally, due to poor investment decisions by the investment adviser(s) for the underlying Funds or otherwise underlying Funds also have their own expenses, which the portfolio bears in addition to its own expenses. Variable Rate Securities Risk: Variable (and floating) rate instruments have interest rates that are periodically adjusted either at set intervals or that float at a margin above a generally recognized rate. Variable (and floating) rate instruments are subject to the same risks as fixed income investments, particularly interest rate risk and credit risk. Due to a lack of secondary market activity for certain variable and floating rate instruments, these securities may be more difficult to sell if an issuer defaults on its financial obligation or when a fund is not entitled to exercise its demand rights.  “When-Issued” Securities: The price and yield of securities purchased on a “when-issued” basis is fixed on the date of the commitment but payment and delivery are scheduled for a future date. Consequently, these securities present a risk of loss if the other party to a “when-issued” transaction fails to deliver or pay for the security. In addition, purchasing securities on a “when- issued” basis can involve a risk that the yields available in the market on the settlement date may actually be higher (or lower) than those obtained in the transaction itself and, as a result, the “when-issued” security may have a lesser (or greater) value at the time of settlement than a fund’s payment obligation with respect to that security. 30  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 9: Disciplinary Information In the past, we have entered into certain settlements with our regulators and other third parties and have been the subject of adverse legal and disciplinary events. Below are summaries of certain events that may be material to your decision of whether to retain us for as an investment adviser. You can find other information on our Form ADV Part 1, available at www.adviserinfo.sec.gov. >On March 16, 2020, HSBC Securities entered into a settlement with the U.S. Securities and Exchange Commission (“SEC”) concerning HSBC Securities’ 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 HSBC Securities’ 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 HSBC Securities disclosed to all brokerage customers in its Customer Agreement that conflicts of interest between customers and IARs may arise with respect to recurring income HSBC Securities receives. But in separate disclosures to advisory customers, HSBC Securities stated that IARs were compensated based solely on non-financial factors, and not on the fees paid to HSBC Securities. The SEC found that HSBC Securities 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 HSBC Securities, which gave IARs an incentive to generate those fees. The SEC further determined that HSBC Securities 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, HSBC Securities agreed to a censure and to pay a fine of $725,000. HSBC Securities amended its disclosures in March 2018 and was not required to engage in any remediation. Disclosures are under Item 14 “Client Referrals and Other Compensation”. >On June 30, 2017, HSBC Securities agreed to a settlement with FINRA regarding allegations 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. HSBC Securities 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 HSBC Securities’ general ledger, certain internal audit records, risk management control records, unusual activity reports and certain policy manuals. The findings also stated that HSBC Securities failed to notify FINRA at least 90 days prior to retaining a vendor to provide electronic storage. HSBC Securities is also alleged to have failed to implement an audit system regarding the inputting of records in electronic storage media. HSBC Securities is alleged to have failed to obtain an attestation from their third-party vendor. Additionally, HSBC Securities failed to establish maintain and enforce written supervisory procedures reasonably designed to achieve compliance with applicable Securities Exchange Commission Rule for record retention requirements. HSBC Securities’ written supervisory procedures failed to specify how the Firm should supervise its compliance with record retention requirements under the rule. On June 30, 2017, without admitting or denying the findings, the Firm agreed to a censure and fine of $1,500,000. The Firm also consented to a written plan of how it will undertake a comprehensive review of the adequacy of its policies and procedures. >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. 31  HSBC Securities (USA) Inc. - Form ADV Part 2A 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 U.S. mortgage servicers and includes the following terms: $100 million to be allocated among participating federal and state parties, and $370 million in consumer relief. In addition, the settlement agreement sets forth national mortgage servicing standards to which HSBC U.S. affiliates will adhere. All except $32 million of the settlement is allocable to HSBC Finance Corporation. This matter was settled within the amount reserved. Item 10: Other Financial Industry Activities and Affiliations Conflicts HSBC Securities has policies and procedures that are reasonably designed to mitigate conflicts of interests and comply with the regulatory requirements in selling securities including mutual funds. The principal business of our Firm aside from investment management is that of a full service broker- dealer. We engage in a full range of primary and secondary securities activity in the U.S. and international markets, including acting as a primary dealer in corporate bonds, U.S. and international equities, and as a broker in futures and options. We are registered with the Securities and Exchange Commission, FINRA, and other regulatory bodies. Our Firm acts as an introducing broker for the Programs (and other clients and programs), using the clearing and execution facilities of our third party clearing agent, BNY Pershing for all securities transactions executed within an Account, subject in all cases to best execution obligations and applicable law. HSBC Securities is registered as a futures commission merchant, and some of our management persons are associated persons of that entity. Therefore, clients can have similar securities in their commission-based brokerage accounts as they do in their Program Account. Money Market Funds Used in the Spectrum Programs The only money market fund option available will be a money market fund for which HSBC Global Asset Management (USA) Inc. receives compensation related to investment advisory and other services. To the extent that HSBC Securities selects the funds in which your Account will be invested, the receipt of such additional compensation by HSBC Securities and its affiliates could create a conflict of interest for HSBC Securities. It should be also understood that the fee for the Service and any such additional compensation may be higher than the fees charged by other advisers for similar advisory services. Material Relationships with Related Persons HSBC Securities and/or our management persons have a material relationship with the following related person(s) as follows. HSBC Global Asset Management (USA) Inc. (“AMUS”) is wholly owned by HSBC USA, Inc. (“HSBC USA”), and is indirectly owned by HSBC Holdings plc (“HSBC Group”). HSBC Group is a publicly owned corporation based in London, England and trades on various stock exchanges around the world. AMUS is registered with the SEC as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended (the “Advisers Act”). AMUS is an entity within HSBC Asset Management (“AM”). HSBC Asset Management (AM) is made up of 32  HSBC Securities (USA) Inc. - Form ADV Part 2A a group of companies in countries and territories throughout the world that are engaged in investment advisory and portfolio management activities. AMUS has been in business since January 29, 1986. AMUS provides advisory and administrative, support services to HSBC Securities for certain Managed Account Programs including advice as to proposed asset allocations, due diligence, advice as to Funds and portfolio managers and various operational services. HSBC Securities compensates AMUS for advisory and administrative services. In addition, AMUS and its affiliates act as the investment adviser and/or administrator to the proprietary funds included as investments in the Spectrum Programs. Certain HSBC Funds also have sub advisers, not always affiliated with AMUS that receive fees for providing various services to the funds. Funds outside of the HSBC Fund family are also offered as options in the HSBC Programs and may be advised by investment managers affiliated or unaffiliated with HSBC Securities, who also receive a fee for their investment services. AMUS or affiliates thereof receive compensation (such as mutual fund advisory fees, and other compensation), in addition to a portion of the fee for the Programs. Program fees for retirement accounts are reduced by the amount of AMUS’s advisory fee for proprietary funds. To the extent HSBC Securities includes an AMUS advised funds as the option into which an Account could be invested, the receipt of such additional compensation creates a conflict of interest. HSBC Securities clients will pay these fees as well as their Program fee as permissible by law. Additionally, clients can only elect to have their idle cash balances swept into money market funds currently all of which are managed by AMUS or its affiliates who provide investment advisory services, and for which AMUS or affiliates receives advisory fees. Clients will pay these fees as well as their Program fee as permissible by law. AMUS’s role is referenced in the investment advisory agreement for the Program. HSBC Securities selects the Funds in which an account will be invested. HSBC Securities as the distributor will receive compensation from the Funds. This creates a conflict of interest for HSBC Securities, which HSBC Securities seeks to mitigate through disclosure in this Brochure. HSBC Securities is a member of the New York Stock Exchange, Financial Industry Regulatory Authority, Securities Investor Protection Corporation. HSBC Securities is a sub-distributor of the HSBC Funds. AMUS uses the services of HSBC Securities (USA) Inc. to facilitate the distribution of HSBC Funds. Affiliates of AMUS receive fees for providing various services to the Funds. Certain employees of AMUS are registered representatives of HSBC Securities and may hold FINRA and state securities registration. HSBC Securities supervises such persons. In addition, Representatives of the Firm may be located in the Wealth Centers of HSBC Bank, and clients of HSBC Bank may be investment advisory clients. Clients are informed both verbally and in writing that investments are offered by HSBC Securities, member NYSE/FINRA/SIPC. HSBC Securities is an affiliate of HSBC Bank USA, N.A. Investment Products: Are not a deposit or other obligation of the bank or any of its affiliates; Not FDIC insured or insured by any federal government agency of the United States; Not guaranteed by the bank or any of its affiliates; and are subject to investment risk, including possible loss of principal invested. 33  HSBC Securities (USA) Inc. - Form ADV Part 2A HSBC Bank is a national bank organized and existing under the laws of the United States and a member of the Federal Reserve. HSBC Bank, with which we have entered into agreements, provides certain office space and certain administrative service such as payroll and benefits processing to HSBC Securities. Certain employees and officers of HSBC Securities are officers of HSBC Bank and report into the HSBC North America Holdings Company Committee. HSBC Securities and representatives are also licensed insurance agents with HSBC Insurance Agency USA, Inc. and HSBC Securities. In California, HSBC Securities conducts insurance business as HSBC Securities Insurance Services. In this capacity, we can offer advisory clients of our Firm insurance products for which we receive compensation. HSBC Securities has policies and procedures that are reasonably designed to mitigate conflicts of interests and comply with the regulatory requirements in selling insurance products. Representatives of HSBC Securities are also securities-licensed Registered Representatives of HSBC Securities, and in their capacity as Registered Representatives engage in the sale of securities-related products and services outside of the Spectrum Program. Clients are under no obligation to purchase or sell securities products and services through HSBC Securities or to participate in the Spectrum Program; however, if they choose to do so, clients should be aware that the Registered Representative at times will receive additional compensation which creates a conflict of interest. Please see Item 14 “Client Referrals and Other Compensation” section for additional information. Representatives of the Firm are employees of HSBC Bank. Certain IARs also serve as bank officers of HSBC Bank, engaging in the sale of bank related products and services. This position is in conjunction with their roles as IARs and Registered Representatives with HSBC Securities. Specific roles are noted in each IAR’s ADV Part 2B Brochure. Representatives of the firm are also licensed Insurance Agents with HSBC Securities and HSBC Insurance Agency (USA) Inc. Clients are under no obligation to purchase or sell securities and insurance products through HSBC Securities or HSBC Insurance Agency (USA) Inc.; however, if they choose to do so, the IAR at times will receive additional compensation as described in Item 14 “Client Referrals and Other Compensation” section. HSBC Securities provides investment advisory and brokerage advice outside of the Spectrum Program. As a registered broker-dealer with the Financial Industry Regulatory Authority (“FINRA”), HSBC Securities sells securities for a commission as a broker, outside of the Spectrum Program (and other Managed Account Programs) and is permitted to receive 12b-1 (distribution) and/or shareholder servicing fees from the sale of mutual funds. All fund sales charge information is disclosed in the mutual fund prospectus or offering document that is provided to the customer. HSBC Securities' practice, as a broker-dealer, of accepting such fees creates a conflict of interest. Representatives are paid a salary with the opportunity to receive a discretionary variable pay, which creates conflicts between you, us and your professional. Please see Item 14 “Client Referrals and Other Compensation” section for additional information. 34  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading HSBC Securities has adopted a Code of Ethics and Staff Dealing Policies and Procedures that governs employee personal securities transactions ("Code of Ethics"), designates access persons, protects material nonpublic information, and requires employees to comply with all relevant securities laws. The Code of Ethics reflects our belief in the absolute necessity to conduct business at the highest ethical and professional levels. The Code of Ethics is based on the principle that its officers, directors, and employees have a fiduciary duty to place the interests of clients first, and to conduct all personal securities transactions in accordance with the requirements of the Code of Ethics, in compliance with federal securities laws, and in a manner that avoids actual or potential conflicts of interest and does not otherwise take inappropriate advantage of a client relationship or abuse a position of trust and responsibility in respect of a client. In addition, the Code of Ethics includes provisions relating to outside business activities, the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. HSBC Securities requires all personnel to report their personal securities accounts to the Compliance Department and requires pre-approval of personal trades in accordance with the HSBC Securities’ policies and procedures. Firm personnel are required to submit an annual acknowledgement and certification attesting to their compliance and reporting requirements as well as compliance with all other aspects of our Code of Ethics. The Code of Ethics encourages internal reporting and protects employees who report violations from retaliation. Any violations of the Code of Ethics must be reported to the Chief Compliance Officer or other designated personnel. A copy of our HSBC Securities’ Code of Ethics will be furnished upon request. HSBC Securities and its employees at times will buy or sell securities for its or their own account, including the same securities that it recommends to clients, and at the same or different times as client trades on those securities, in accordance with the Code of Ethics. Employees of HSBC Securities, or its advisory affiliates, at times will hold the same or similar securities in their personal accounts, as clients may hold in their own portfolios, and from time to time will recommend such securities for purchase or sale in clients’ portfolios in the normal course of business. HSBC Securities has established informational barriers and has adopted various policies and safeguards in order to address conflicts of interest that may arise from such activities. 35  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 12: Brokerage Practices HSBC Securities is a member NYSE/FINRA/SIPC, a registered Futures Commission Merchant, a wholly- owned subsidiary of HSBC Markets (USA) Inc. and an indirect wholly-owned subsidiary of HSBC Holdings plc. HSBC Securities acts as introducing broker in the Spectrum Program, using the clearing and execution facilities of its third-party clearing broker, BNY Pershing, for all securities transactions executed within an Account, subject in all cases to best execution obligations and applicable law. HSBC Securities or another financial intermediary will serve as custodian for Accounts. HSBC Securities has entered into an agreement with BNY Pershing to act as the custodian under the Spectrum Program. The Firm generally does not select other broker-dealers to execute trades in the Programs, as the Program fees that clients pay cover only those trades executed by BNY Pershing. HSBC Securities does not participate in soft dollar business arrangements and receives no products, research, or services that the Firm would consider a factor in selecting or recommending a particular broker-dealer. The Firm does not use client brokerage to compensate or otherwise reward brokers for client referrals. The Firm does not engage in directed brokerage transactions. Trading Authorization Clients authorize HSBC Securities to cause the purchase and sale of securities and other assets for the Account and to act for the client in all matters necessary or incidental to those purchases or sales. HSBC Securities delegates trading authority to BNY Pershing. BNY Pershing is responsible for rebalancing Accounts based on the parameters set by HSBC Securities, through trade execution of the securities to be bought and sold, timing of the trades, subject to its duty to seek best execution as described below. Best Execution and Brokerage Services Through BNY Pershing, HSBC Securities effects all execution services in connection with the purchase or sale of securities and other investments for the Program Accounts. HSBC Securities can aggregate transactions in securities in or for the Program Accounts, other than shares of open-end investment companies, for execution with transactions of its other clients and HSBC Securities will allocate trades among all clients in a manner that HSBC Securities believes to be fair and equitable. HSBC Securities will act as introducing broker in the Programs, generally using the executing and clearing facilities of its third party clearing broker, BNY Pershing for all securities transactions executed within an Account. HSBC Securities or one of its affiliates or BNY Pershing may act as agent for both the buyer and seller in securities and other investment transactions when appropriate and permitted by law. HSBC Securities will not execute a trade when it believes such execution would be inconsistent with the principles of best execution or would violate applicable State or Federal law or regulations, or regulations of any self-regulatory body of which HSBC Securities or one of its affiliates is a member, as the case may be. Brokerage commissions and related transaction fees (other than brokerage commissions and fees paid by a fund in which the Account is invested) are included in the Program Fee, although it is expected that no commissions will be charged on purchases for an Account of open-end funds managed or advised by an affiliate of HSBC Securities or third parties. HSBC Securities can purchase or sell the same security for a number of clients, who are in different programs at the same time. Because of market fluctuations, the prices obtained on such transactions within a single day can vary substantially. In such a case, to more fairly allocate those market fluctuations among clients, transactions in the same security for a number of clients can be "batched". In these circumstances, the confirmations and statements for each client's transaction will show that the transaction was effected at a 36  HSBC Securities (USA) Inc. - Form ADV Part 2A price equal to the average execution price for all transactions in that security on that day. Since there are no separate transaction costs (no commissions) for trades executed by HSBC Securities in the Spectrum Program there is no transaction cost benefit. Principal, Agency and Cross Transactions HSBC Securities typically will not affect principal or cross trade transactions in the Spectrum Program. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser acts as broker for both the advisory client and for another person on the other side of the transaction. In some cases, when a client is funding their Account they can own an HSBC issued Structured Certificate of Deposit or Note (collectively “Structured Products”). When selling HSBC issued Structured Products, HSBC Securities will engage in a principal or cross trade to unwind the constituent parts of the Structured Products. HSBC Securities as a broker/dealer at times will receive incidental compensation for liquidating Structured Products; however, the International Wealth and Premier Banking division of HSBC Securities does not receive any compensation on the sale or early redemption of Structured Products. HSBC Securities as an investment advisor does not receive any compensation when a client sells a Structured Product to fund a managed account product. 37  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 13: Review of Accounts or Financial Plans A client’s Representative conducts annual Account reviews with the client to determine if the client’s profile remains current in addition to other factors. The Representative also reviews the Account’s proposal and Fund selections. The client’s Account activity is reviewed to determine if the asset allocation continues to be suitable, that any client mandates and restrictions continue to be met, and if the client’s financial situation and investment objectives must be updated or re-confirmed. Other matters that can be discussed should be negotiated fees (if any), program minimums and performance. This review is done with the client in person if possible, or by other means such as a phone call or video call (or will otherwise meet the regulatory requirements for an annual meeting) and based on the documented investment objectives and strategy of the Account. A Representative can review client Accounts more frequently than described above. Among the factors that can trigger an off-cycle review is a change in the client’s investment profile, a change in major market or economic events, the client’s life events, requests by the client, etc. We do not provide written reports to clients, unless requested. Representatives provide updates to clients at least annually. Our clearing agent, BNY Pershing, generates and provides at a minimum, a quarterly report to our clients. 38  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 14: Client Referrals and Other Compensation HSBC Securities does not pay referral fees to non-HSBC Securities employees for the referral of their clients to our Firm. Representative’s Compensation Your Representative (Wealth Relationship Manager) is paid a salary with the opportunity to receive discretionary variable pay, which creates conflicts between you, us and your Representative. We base discretionary variable pay (or individual variable pay decisions) on the Representative’s personal performance measured against established key performance indicators and objectives. When measuring your Representative’s overall performance and ability to meet objectives, we consider factors like gathering assets (including market fluctuation) and income for HSBC Securities, so your Representative has incentives to recommend that you invest assets with us and purchase investments. This also includes deposits and lending products (such as checking, savings, CDs, credit cards and mortgages). Please refer to the Compensation from Other Affiliates for Services Offering Securities and Other Products section below for additional information on Bank related activities. We earn more income from some investment recommendations (such as variable annuities) than others (such as mutual funds), for example, which gives your Representative an incentive to recommend products that will pay us more. When providing brokerage account recommendations, your representatives provide information about the income generated by recommendations of different products and services generally, and point to other materials, like prospectuses for example, that will describe the income we receive more specifically for the products you purchase. Should you also have a brokerage account, please consider that information in connection with your Representative’s compensation and conflicts. The differences in the amount of income and the frequency of the income generated to HSBC Securities has an impact on your Representative’s opportunity to receive discretionary variable pay, and an impact on the amount of any potential award. This impact and the conflict exists because income is among the factors considered by us in judging your Representative’s overall performance and ability to meet objectives. Another of the financial factors impacting measurement of performance is the amount of assets gathered, including assets that are brought to us for the first time through your Representative’s recommendations. This impact and the conflict exists because the amount of money brought into and maintained in accounts serviced by that Representative and the growth of the assets in accounts such as yours are also among the factors considered when judging your Representative’s overall performance and ability to meet objectives. Additional factors beyond asset gathering and income are also part of measuring your Representative’s overall performance. We consider factors such as compliance with rules, policies, procedures, code of ethics, industry regulations and standards of conduct. We consider your Representative’s activities in meeting with you and serving your financial needs. We will also assess the quality of your Representative’s sales presentations to you, which assessment can involve contacting you and asking for your feedback. The various factors of our discretionary variable pay decisions create conflicts, as your Representative has an interest in establishing a relationship with you, and for recommending our products and services. Certain supervisors in the Wealth Centers, are also eligible for discretionary variable pay affected by your Representative’s recommendations. To the extent that supervisors are reviewing transactions that generate income and assets for the accounts serviced by Representatives, they also have a conflict of interest. We 39  HSBC Securities (USA) Inc. - Form ADV Part 2A mitigate that conflict through policies and procedures and by measuring the overall performance of those supervisors when considering whether and how much of a potential discretionary variable pay they may receive. Internal Recognition Programs. Your Representative at times will be eligible to participate in HSBC internal recognition programs, consistent with industry practice and regulatory requirements, based upon overall personal performance. That personal performance is based on the factors noted above, including the gathering of assets and income to HSBC Securities, creating further incentives to recommend that you invest with us. We also consider factors, such as compliance with rules, their activities in meeting with customers and fulfilling customers’ financial needs. Title Designations. Along with years of experience, factors such as the income generated by your Representative’s recommendations of products and services, as well as the assets that they gather and maintain for us are considerations when determining if a Representative will be rewarded with honorary titles distinct to their seniority and/or promotions to such distinct titles partially based on their ability to meet internal goals. The opportunity to obtain such an honor further incentivizes your Representative to generate income and gather assets for us through the recommendation of our products and services to you. Other Benefits. Your Representative is eligible to receive other benefits based on the amount of their compensation. Non-Qualified Deferred Compensation Plan (NQDCP)  Elective plan for those who are eligible based on their total compensation at or above $250,000  Eligible participants have the option to elect to defer a portion of their fixed pay or variable pay on a pre-tax basis in the form of an investment account Deferral on Variable Pay  All HSBC employees are subject to a deferral on a portion of their annual total variable pay that is awarded at or above $100,000  The standard deferral is granted in the form of Restricted Share Units. The deferrals are under guidelines established by our parent corporations’ deferral plan, which allows them to defer the receipt of compensation. This does not represent additional compensation, and there is no benefit beyond the deferral of income taxes at the employee’s election. This ability to defer income however further incentivizes your Representative to generate income and gather assets and otherwise impact the factors considered in determining his or her discretionary variable pay. While HSBC Group maintains global sustainability goals, and a portion of certain variable pay have considerations based on these goals, Investment Adviser Representatives and their Supervisors are not provided with additional incentives to sell Spectrum II ESG. Compensation from Other Affiliates for Services Offering Securities and Other Products Your Representative is also authorized to act on behalf of HSBC Bank USA, N.A., in some cases directly providing deposit accounts and lending products or introducing you to colleagues for additional bank services. For Representatives serving Private Banking customers, these products offered through HSBC Bank may also include certain securities products and services that US national banks may offer directly. 40  HSBC Securities (USA) Inc. - Form ADV Part 2A In most cases, your Representative will also be authorized to offer additional insurance products through HSBC Insurance Agency (USA) Inc., including traditional life insurance products and certain property and casualty insurance (all for third party insurance carriers). These products and services compete with certain products and services offered through HSBC Securities, and can earn more income for our affiliates. Acting for multiple affiliates and being compensated by them presents conflicts because these factors are considered in your Representative’s objectives and measures of overall performance, which in turn impacts his or her opportunity for variable compensation through discretionary variable pay. HSBC Securities reserves the right, at its discretion and without prior notice to change the methods by which it compensates its sales professionals. Representative’s Outside Business Activities. In addition to approved roles acting on behalf of our affiliates, your Representative is permitted, subject to our review and approval, to engage in certain other business activities, other than the provision of brokerage and advisory services through us. Your Representative could also engage in another business including a family owned business, or serving as an officer, director, partner or employee of or consultant to another business organization. These outside business activities can cause conflicts with the brokerage or advisory services your Representative provides to your brokerage account. Because your Representative could receive fees from the outside business, he or she could have an incentive for you to engage or transact through the outside business to earn additional compensation. HSBC Securities has policies and procedures as well as our Code of Conduct to mitigate these conflicts. Gifts, Gratuities, Entertainment and Non-Monetary Compensation From time to time, HSBC or its employees will, as is generally consistent with customary industry practice and in accordance with HSBC’s policies and procedures, receive nonmonetary compensation (other than cash or cash equivalents), such as promotional items (e.g., coffee mugs, calendars or gift baskets), meals, entertainment (e.g., tickets to sporting events) and access to certain industry related conferences, from individuals or institutions (including investment sponsors) with whom they transact business or with whom they can engage in business dealings on behalf of clients. In addition to the receipt of gifts by HSBC or its employees, HSBC or its employees may also engage in providing such gifts, meals and entertainment which may also generate a conflict of interest to the extent they create an incentive for the recipient or beneficiary to use, recommend, offer or include products or services of HSBC Securities. The giving and receipt of gifts and other benefits are subject to limitations under internal HSBC Securities policies and procedures. Product Provider Payments and Conferences From time to time, HSBC Securities (and its affiliates) will receive marketing and training support payments, conference subsidies, and other types of financial compensation and incentives from mutual fund companies and other product providers, broker-dealers and other vendors to support the sale of their products and services to our clients, including our ERISA plan clients. Note that the level of vendor support or other payments is not dependent on or related to the level of assets invested in or with the products or services of the particular vendor, but the receipt of these payments presents HSBC Securities with a conflict of interest in recommending these parties’ services and products to clients. HSBC Securities deals with that conflict through disclosure in this Brochure. 41  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 15: Custody HSBC Securities or another financial intermediary will serve as custodian for accounts. Currently, BNY Pershing acts as the custodian for the Spectrum Programs. BNY Pershing is located at One Pershing Plaza, Jersey City, New Jersey 07399. BNY Pershing will generally furnish monthly, but no less frequently than quarterly, account statements summarizing account activity during the period. HSBC Securities from time to time comes into possession of client assets. As such, on an annual basis, HSBC Securities must ensure that the requirements of the Custody Rule are met. Confirmation Suppression Option: Clients can elect not to receive separate trade confirmations for an Account by completing a confirmation suppression request. Information from the confirmations will be reported at least quarterly to the client, in lieu of separate trade confirmations. Electronic Delivery Considerations for Offshore Spectrum: The use of electronic delivery is dependent upon each offshore jurisdiction’s procedures/regulation. 42  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 16: Investment Discretion Spectrum Program: HSBC Securities has limited discretion as the sponsor of the Program and provides a menu of Funds based on the selected model. Additionally, HSBC Securities has ongoing responsibility as the program sponsor and provides regular and continuous monitoring of the Account. If a client accepts HSBC Securities’ recommendations, HSBC Securities is responsible for arranging or effecting purchases or sales. Spectrum II and Offshore Spectrum Program(s): HSBC Securities has discretion to buy and sell Funds without advance notice to the client. Additionally, HSBC Securities has ongoing responsibility as the program sponsor and provides regular and continuous monitoring of the Account. HSBC Securities is responsible for arranging or effecting purchases or sales. Discretion Common to the Programs: In the Programs, to fulfill its responsibilities for regular and continuous monitoring of the Account, HSBC Securities has discretion to reallocate assets at any time (including an allocation into a new asset class), without consulting clients, for any reason it deems appropriate, including, without limitation, to respond to general market or macroeconomic circumstances, or to rebalance the investments periodically to restore the original allocation percentages or target weights. HSBC Securities can change the Funds or their weightings in a model to reflect changes such as the introduction of new asset classes or new model options, or to remove asset classes or models. Periodic rebalancing of Accounts to the target portfolio, as well as the allocation of subsequent investments and partial withdrawals, is subject to minimum trade size requirements and minimum asset class thresholds. Any such reallocation may trigger tax consequences as well as redemption fees in certain Funds. To make these periodic changes or reallocations, HSBC Securities can institute a mandatory blackout period, during which trading in the Account may be limited. The client can impose reasonable restrictions on its Account. Restrictions must be requested by clients in writing and are subject to review and acceptance by HSBC Securities. HSBC Securities cannot restrict specific securities that are held within any Funds. 43  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 17: Voting Client Securities Clients in the Programs retain the right to vote proxies solicited by or with respect to the Funds or any other securities held in the Account, and HSBC Securities will not accept proxy voting authority in the Programs. HSBC Securities is not liable or responsible for the timely delivery of proxies. 44  HSBC Securities (USA) Inc. - Form ADV Part 2A Item 18: Financial Information HSBC Securities does not require nor do we solicit prepayment of more than $1,200 in fees per client, six (6) months or more in advance. Therefore, we have not included a balance sheet for our most recent fiscal year. There are no financial commitments to likely impair our ability to meet contractual obligations to our clients, and we have not been the subject of a bankruptcy petition at any time during the last ten years. 45 

HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 Form ADV Part 2A – Appendix 1 MANAGED PORTFOLIO ACCOUNT WRAP FEE PROGRAM BROCHURE HSBC Securities (USA) Inc. 66 Hudson Boulevard East, New York, NY 10001 Tel: 212-525-5000 Website: WWW.US.HSBC.COM January 2026 This managed account or wrap fee program brochure for the Managed Portfolio Account (“MPA”) program provides information about the qualifications and business practices of HSBC Securities (USA) Inc. (“HSBC Securities”, “We”, or the “Firm”) and it should be considered before investing in MPA. If you have any questions about the contents of this brochure, please direct your written inquiry to the address listed above, or call (800) 662-3343. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about HSBC Securities (USA) Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. HSBC Securities is a federally registered investment adviser with the SEC. Registration with the SEC or with any state securities authority, the use of the term “registered investment adviser”, and descriptions of HSBC Securities and some of our associates as “registered” does not imply a certain level of skill or training. Investment Products: ARE NOT FDIC INSURED MAY LOSE VALUE ARE NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY ARE NOT GUARANTEED BY THE BANK OR ANY OF ITS AFFILIATES ARE NOT A DEPOSIT OR OTHER OBLIGATION OF THE BANK OR ANY OF ITS AFFILIATES All decisions regarding the tax implications of your investment(s) should be made in consultation with your independent tax advisor. 1 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 Item 2: Material Changes to Our Part 2A-Appendix 1 of Form ADV Firm Brochure There is one material change made to the HSBC Securities Form ADV Part 2A-Appendix 1 (commonly referred to as the “Brochure”) since the update of the Brochure in June 2025. Item 4: Services, Fees and Compensation Effective April 1, 2026, HSBC Securities will be implementing changes to all program accounts regarding how fees are billed and how they are structured.  The Managed Portfolio (MPA) Account Program will be implementing a new fee schedule beginning April 1, 2026.  Managed Portfolio Account Program (“MPA” “MPA Program” or the “Program”) Manager Fee(s) Separately Billed and Applied to MPA accounts: The Program fee is being reduced but will no longer include Separately Managed Accounts (“SMA”) or Unified Managed Accounts (“UMA") manager (i.e., portfolio manager or model manager, which include HSBC Securities affiliates) fees that will be separately billed and applied to program accounts. As these fees will be assessed separately (and based on how account assets are actually allocated, total program fees (i.e., the aggregate of both program and manager fees) could be higher or lower than before this change.  MPA Fees Will Be Billed in Arrears: MPA Program fees will transition from advance billing (i.e., where you pay your advisory fees in advance) to billing in arrears (i.e., you will be charged after the services have been provided). As a result, the billing for the second quarter of 2026 will not occur until July 2026. This change is designed to provide greater transparency and align your payments with the services you have received. 2 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 Item 3: Table of Contents Item 2: Material Changes .................................................................................................................2 Item 3: Table of Contents ................................................................................................................3 Item 4: Services, Fees and Compensation .......................................................................................4 Item 5: Account Requirements and Types of Clients ....................................................................20 Item 6: Investment Strategy and Asset Allocation Evaluation ......................................................20 Item 7: Client Information Provided to Investment Managers ......................................................33 Item 8: Client Contact with Investment Managers ........................................................................34 Item 9: Additional Information ......................................................................................................34 3 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 Item 4: Services, Fees and Compensation HSBC Securities has been in business as an investment adviser registered with the SEC since 2005. HSBC Securities is also a broker-dealer, which was originally formed in December 1969 under a predecessor name. HSBC Securities is a Delaware corporation headquartered in New York City. HSBC Securities is also a wholly-owned subsidiary of HSBC Markets (USA) Inc. and an indirect wholly-owned subsidiary of HSBC Holdings plc (“HSBC Group”). HSBC Securities is the sponsor of an advisory account program referred to as the MPA which is a multi- product, fee-based separately managed account program. MPA offers two investment account options: SMA and UMA. The MPA Program is designed to assist clients, including individuals, trusts, estates or charitable organizations; retirement accounts; and corporations, limited liability companies and/or other business entities with their investment needs based on financial objectives, time horizon and risk tolerance. Through the MPA Program, HSBC Securities will, for a fee, facilitate access to professional asset management and other services through the use of third party and affiliated investment managers and model providers. As selected by you, fees for your account’s use of these third party and affiliated investment managers and model providers are assessed and applied separately and in addition to HSBC Securities’ MPA Program fee. Special rules apply to certain types of retirement accounts, such as individual retirement accounts (“IRA”) and Employee Retirement Income Security Act of 1974, as amended (“ERISA”) plan accounts. HSBC Global Asset Management (USA) Inc. (“AMUS”), a U.S. registered investment adviser, acts as investment manager and model provider under the MPA Program (depending on capacity, “Affiliated Manager” or “Affiliated Model Manager”). Inclusion of an Affiliated Manager/Affiliated Model Provider in MPA creates a conflict of interest because HSBC Securities and its affiliates receive additional compensation when we recommend, and you select that your account assets be invested with the Affiliated Manager or pursuant to a model provided by the Affiliated Model Manager. The amount of this compensation may be more than what HSBC Securities and its affiliates would receive if we recommended, and you select that your account assets be invested with a third-party investment manager or pursuant to a model provided by a third-party investment manager. Therefore, HSBC Securities and its affiliates have a financial incentive to recommend that your account assets be invested with an Affiliated Manager/Affiliated Model Manager. Special rules apply to certain types of retirement accounts. See the Fees and Other charges section below for details on changes effective April 1, 2026. UMA will also provide, at the client’s election, tax optimization services at no additional cost to U.S. persons, for U.S. taxes only. HSBC Securities has entered into an agreement with AMUS to perform certain services, for compensation from HSBC Securities, in the MPA Program. Additionally, HSBC Securities has entered into an agreement with HSBC Bank (USA) N.A., to perform certain services, for compensation from HSBC Securities, in the MPA Program. In both cases, these service arrangements are provided for the benefit of HBSC Securities in providing its services under MPA, as discussed more fully below. 4 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 In this Brochure we use the following terms:  Model Manager (UMA Program only) – an investment manager who provides model portfolios consisting of individual securities to HSBC Securities. Model Managers do not have discretion over a client’s account.  SMA Manager (SMA Program only) – an investment manager who invests client accounts in individual securities. SMA Managers have discretion over a client’s account.   Overlay Manager (UMA Program only) – Overlay Manager implements a Model Manager’s recommendations in client accounts. HSBC Securities currently acts as Overlay Manager and has delegated certain of its activities to an affiliate and a third party. HSBC Securities can at its discretion engage an unaffiliated Overlay Manager upon thirty (30) days written notice to the client. Investment Strategy – refers to the client selected target asset allocation specified in the Proposal, which will be implemented through mutual funds, ETFs, models and separately managed accounts. Oversight HSBC Securities, through the Managed Account Oversight Committee (“Committee”), oversees the operation of MPA as well as the services provided by AMUS and any other material vendor. The Committee is chaired by HSBC Securities and consists of members and invitees who are employees of HSBC Securities and AMUS. Employees of AMUS have no authority to make decisions or otherwise influence approvals of the Committee. Services HSBC Securities offers the MPA Program to its clients, and aside from sponsorship, is responsible for client contact, communications, suitability, account opening services (such as Know Your Client and Anti- Money Laundering reviews), and relationship management. The Firm is also responsible for Account Type and Investment Strategy recommendations, trading, trade servicing, account maintenance, client service, custody of client assets and overall operational support for the Firm’s investment advisory products. For additional information on custody, please see Item 9. HSBC Securities also provides ongoing client services that include the following: 1. Periodic portfolio review and consultation with clients through our Investment Adviser Representatives (“Representative”). 2. Handling subsequent transactions (additional investments and redemptions). 3. Responding to client inquiries about their accounts. 4. Requests for an annual in-person or telephonic/video call meeting with clients to discuss the account and any changes to the client’s investment objectives or reasonable investment restrictions. 5. Periodic Account Rebalancing. 5 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 Pursuant to intercompany agreements, HSBC Bank USA, N.A. (“HBUS”) and AMUS provide the following services to HSBC Securities: (i) advice as to proposed asset allocations, (ii) advice on Investment Strategies in the MPA Program and (iii) various operational services. HSBC Securities compensates HBUS and AMUS for these services. In addition, HBUS makes certain strategies available, including management services, in the MPA Program under an intercompany agreement with HBUS. HSBC Securities contracts with HSBC’s Global Manager Selection – Funds & ETFs team (referred to as “GMS”) and HSBC Alternative Investments Limited (HAIL), to conduct due diligence and to provide a basis for HSBC Securities to review and approve third party provided/sponsored Investment Strategies that are aligned with the asset allocations offered within the MPA Program. GMS also reviews proprietary HSBC strategies and models for HSBC Securities. The due diligence process employed by GMS for assessment of proprietary Investment Strategies (i.e., managers, models and funds) is less rigorous from the approach GMS typically applies to third party managed investments funds, strategies and models. Several aspects typically covered in third party reviews are not included in the proprietary due diligence and GMS’ conclusions around some of these areas may, at times, come from internal HSBC certifications provided by affiliates and oversight functions including (where necessary & appropriate) confirmations from investments, risk, and regulatory functions. HSBC Securities makes the final selection of Investment Strategies available under the MPA Program. HSBC Securities does not offer managed account or wrap fee programs other than HSBC Spectrum, Spectrum II and Offshore Spectrum Account Programs (“Spectrum, Spectrum II and Offshore Spectrum”, HSBC Prism Advisory (only available to HSBC Private Bank clients) and MPA Programs -its proprietary investment advisory offerings. Accordingly, HSBC Securities offers a limited range of investment advisory solutions available to meet certain client’s particular circumstances. All of HSBC Securities’ managed account programs make available access to the services of a Representative who is available to discuss updates in the client’s financial situation and handle account updates and changes. General and specific disclosures for all of HSBC Securities’ managed account program offerings are covered in separate Form ADV Part 2A and Appendixes 1, applicable to each program. The documents for Spectrum, Spectrum II and Offshore Spectrum can be found in the following website: https://www.us.hsbc.com/investments/products/asset-allocation/.  The Spectrum program offers actively managed mutual funds and passively managed exchange-traded funds (“ETFs”) (collectively “Funds”). Spectrum also has the option to offer actively managed ETFs and passively managed index funds.  The Spectrum II program offers actively managed mutual funds. Spectrum II also has the option to offer actively and passively managed ETFs and passively managed index funds.  The Offshore Spectrum Program is a discretionary offshore fund asset allocation program open to qualified non-resident aliens who reside in certain foreign jurisdictions, as approved by the Firm and in accordance with the local laws of those jurisdictions. The Offshore Spectrum 6 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 Program offers Funds.  The Spectrum programs are described in a separate brochure. As of May 2025, HSBC Securities is offering to clients of the HSBC Private Bank the HSBC Prism Advisory Program. HSBC Private Bank is the marketing name for the private banking business. In the United States, HSBC Private Bank offers banking products and services through HBUS. HSBC Bank provides banking products and services. Investment, annuities, and variable life insurance products are offered by HSBC Securities. HSBC Securities is an affiliate of HBUS. The HSBC Prism Advisory Program (“Prism Advisory”) offers discretionary and advisory services, which provides HSBC Private Bank clients with asset allocation models utilizing separately managed accounts, model managers and Funds for a fee. Details of the Prism Program are described in a separate brochure. A link to these documents is below. https://www.us.hsbc.com/content/dam/hsbc/us/en_us/investments/products/asset-allocation/hsbc-prism- adv.pdf Reinvestment/Distribution Models under MPA Clients can choose to receive dividends, interest, distributions and other income paid on securities held in the MPA account (collectively “Distributions”) directly or reinvest the Distributions in accordance with the selected Investment Strategy used for their account. Clients should reach out to their Representative for more information. Clients that wish to reinvest Distributions in their account should choose portfolios that only allow reinvestment. Model Managers that provide reinvestment-only model portfolios do not select securities with particular dividend targets and payment of the income stream can be inconsistent month over month. In the event you wish to have your Distributions reinvested, for ETFs and individual securities, any dividends and interest will be invested into the account’s sweep money market funds until the next regularly scheduled rebalance takes place. When applicable, the dividends and capital gains paid on mutual funds will be reinvested according to the Investment Strategy selected. For standalone SMAs, dividends are reinvested unless the client selects the income distribution version. Capital gains distributions are not paid out for SMAs. Clients should consider legal and/or tax implications when considering their options regarding Distributions and consult with their attorney or tax advisor. Please note, the withdrawal and payment of Distributions to the client can affect the performance of the account and will reduce account assets. HSBC also offers certain Investment Strategies in the MPA Program that are available to qualified Non- Resident Aliens who reside in approved jurisdictions. Comparison of SMA Program to UMA Program SMA Program In the SMA Option, account assets are managed in a single Investment Strategy or “sleeve.” An SMA Manager, which could be an HSBC Securities affiliate, will invest a client’s account in individual 7 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 securities. The SMA Manager has discretion over the client’s account. Investment Strategies under the SMA Options do not include ETFs or mutual funds. UMA Program In the UMA Program, a client’s assets are managed pursuant to a targeted asset allocation using several Investment Strategies, or sleeves. Each sleeve will be invested in mutual funds, ETFs, or individual securities recommended by a Model Manager, which could be an HSBC Securities affiliate. Model Managers do not have discretion over a client’s account. HSBC Securities, as the Overlay Manager in the UMA Program, has discretion over a client’s account and implements the recommendations provided by the Model Managers. Subject to the client approved asset allocation under the Proposal, the Overlay Manager is authorized to make changes to the assets in client accounts and/or to reallocate assets at any time (including an allocation into a new asset class), without consulting clients including, without limitation, to respond to general market or macroeconomic circumstances, or to rebalance the account periodically to restore the target asset allocation selected by the client. The Overlay Manager can reallocate assets to reflect changes such as the introduction of new asset classes or new model portfolios, as well as the removal of asset classes or model portfolios. Periodic rebalancing of accounts, as well as the allocation of subsequent investments and partial withdrawals, is subject to minimum trade size requirements and minimum asset class thresholds. Any reallocation may trigger tax consequences as well as redemption fees for certain mutual funds. In order to facilitate these reallocations, HSBC Securities is authorized to institute a mandatory blackout period, during which trading in the account can be limited or suspended. UMA client accounts are periodically rebalanced to restore to their selected targeted asset allocation. Rebalancing typically occurs on a quarterly basis, on a date determined by HSBC Securities and Pershing ® LLC (“BNY Pershing” or “Pershing”) (see below for services provided by Pershing). The investments in an account’s selected Investment Strategy, such as a mutual fund, ETF or model portfolio, are evaluated to determine how far they have drifted from its targeted allocation. For all asset classes except cash, the relative drift threshold is 15% while the drift threshold is 25% for cash. If an Investment Strategy has drifted beyond the drift threshold, the account will be rebalanced back towards its targeted asset allocation subject to minimum trading amounts. As a service provider to HSBC Securities, AMUS oversees the asset allocation models available in MPA and provides the subject matter expertise and administrative resources to support the MPA Program. AMUS collaborates with various AMUS teams to develop Strategic Asset Allocations (“SAA”) subject to limits (e.g., asset classes and risk tolerance bands) and Tactical Asset Allocation (“TAA”) views based on both global and local inputs. AMUS considers a number of factors when determining whether to recommend to HSBC Securities a change in the TAA, including macroeconomic analyses, market trends, valuation of asset classes and outlook for asset classes. This means that HSBC Securities, at its discretion, can periodically adopt changes to MPA’s asset allocation models based upon AMUS’s advice. The TAA serves as an indication of asset class preferences by AMUS. HSBC Securities chooses SMA Managers, Model Managers and Funds available in the MPA Program, using a process involving quantitative and qualitative factors provided by GMS and HAIL, as applicable, 8 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 to determine how well a particular Investment Strategy represents its intended asset class. An Investment Strategy can include U.S. and foreign equity securities (including emerging market securities), and investment grade, lower quality corporate and governmental fixed income securities. Funds also can invest in financial instruments such as swaps and other derivatives to gain exposure to a particular group of securities, an index or an asset class (such as commodities), or to hedge a position. Environmental Social Governance (ESG) Funds Effective on or about November 20, 2023, HSBC Securities will no longer offer ESG Funds in the UMA Program. Clients who have ESG funds in their existing UMA portfolios can maintain existing positions and continue to fund additional shares. However, clients will not be able purchase new ESG funds in their UMA account(s). ESG funds are only available in the Spectrum II Program. General and specific disclosures for the Spectrum II program offerings are covered in separate Form ADV Part 2A. Please see additional disclosures further in Item 6 and Item 9. Client Profile The Representative will assist clients in completing information requests designed to elicit personal, financial and investment information concerning the client’s financial circumstances, risk preference and tolerance, liquidity requirements, and investment objectives. The client, in consultation with their Representative will use the U.S. Risk Profile Questionnaire and Scoring to evaluate the level of risk and investment preference desired for the client’s MPA recommended asset allocation. As a result of this consultative process, the Representative prepares a Proposal for the client’s MPA Program account. The Proposal will contain a recommended asset allocation that takes into account the client’s investment objectives, risk tolerance and the investment products available through MPA. For the UMA Program the client can make adjustments within certain parameters to the asset allocation targets. For the UMA Program, client assets will be invested in accordance with the selected asset allocation through multiple Investment Strategies using a mix of Model Managers and Funds. For the SMA Program, client assets will be invested in a single Investment Strategy as reflected in the Proposal represented by a single SMA Manager. Clients can choose multiple SMA’s using multiple accounts. In either case, an Affiliated Manager or product may be used. The client’s Representative will consult with the client periodically, but not less than annually, by requesting an in-person or telephonic/video call meeting (or will otherwise meet the regulatory requirements for an annual meeting) to determine whether to update the client’s financial information and determine whether any changes should be made to the client's Proposal, asset allocation, risk tolerance, or other factors that would affect the management of the client’s account. Clients are also encouraged to contact their Representative promptly in the event of any material changes to the information they have provided, or any other changes in their financial circumstances or investment goals that would affect the management of their account. Portfolio Management UMA Program HSBC Securities will, as part of the Proposal, recommend an asset allocation and a menu of recommended Investment Strategies for each applicable asset class. The client can also indicate their own personal preference for an asset allocation based on their unique financial circumstances and subject to certain 9 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 guidelines for each asset class. The client, in consultation with the Representative, will select one or more of the Investment Strategies to fulfill each asset class. HSBC Securities acts as Overlay Manager to provide portfolio implementation and coordination services for the client’s account. HSBC Securities has delegated certain activities to an affiliate and a third party. Client adjustments to recommended asset allocation, selected Investment Strategies, investment restrictions and preferences can materially affect the composition and performance of investment portfolios. In addition, each client’s account begins investing at different times in different market conditions, which can also have an effect on the account’s investment return. The timing of the client’s contributions to or withdrawals from the account also can affect account performance. For these reasons, the performance and investment returns of MPA client accounts with the same or similar investment objectives will differ. The optional tax optimization service in the UMA Program uses a client’s portfolio information to evaluate the tax implications of portfolio trades prior to execution. Within an MPA UMA client’s account portfolio, where possible, gains and losses across multiple investment styles will be selected to minimize the overall tax impact. The tax impact of portfolio rebalancing will also be evaluated. Specific information as to client's tax status and other financial information (including holdings in non-MPA accounts) will not be considered in this service. There can be no assurances that the service will result in the optimal tax consequences for clients. In addition, the tax optimization service can have a negative impact on the investment performance of a UMA account and any such negative impact may not be fully offset by tax benefits, if any. The tax optimization services should not be considered tax advice. Potential clients should consult with their independent tax advisors to assess the tax implications of the optimization service. The service is offered to U.S. persons, for U.S. taxes only. Periodic rebalancing and liquidations may cause certain securities in an account to be restricted from purchases for a period of (30) days due to wash sale rules. HSBC Securities will not invest contributions that are deposited into accounts with wash sale restricted securities until the (30) day wash sale restriction has expired. As a result, an account may have a higher than normal cash position for a period of time, which will generally be held in an HSBC affiliate money market fund or other product. This situation may adversely affect account performance. SMA Program Under the SMA Program, the client account is managed, on a discretionary basis, by the selected SMA Manager. For more information about a particular SMA Manager’s portfolio management, see the SMA Manager’s Form ADV brochure. Client adjustments to selected Investment Strategy, investment restrictions and preferences can materially affect the composition and performance of investment portfolios. In addition, each client’s account begins investing at different times in different market conditions, which can also have an effect on the account’s investment return. The timing of the client’s contributions to or withdrawals from the account also can affect account performance. For these reasons, the performance and investment returns of MPA client accounts with the same or similar investment objectives will differ. 10 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 Services Provided by Pershing® LLC (BNY Pershing) In support of the MPA Program, BNY Pershing provides HSBC Securities with a technology solution for providing client proposals, submitting and tracking service orders and maintenance requests, and creating performance and other reports. BNY Pershing also provides operational services, including new client account set up; maintenance; order processing; billing (including implementation of fee schedules, inception billing, quarterly billing and contribution and withdrawal billing); mailed and/or electronic performance reporting, quarterly reports and daily on-demand summaries. BNY Pershing’s affiliate, Pershing Advisor Solutions (“PAS”), formerly, Lockwood Advisors, Inc. enters into agreements with the SMA Managers in the MPA Program. BNY Pershing effects the purchase and/or sale of securities in a Client UMA sleeve after the Overlay Manager updates a model. BNY Pershing also invests new sleeves or rebalances existing sleeves in accordance with the selected Investment Strategy as provided for in the Proposal. Proxy Voting HSBC Securities is authorized to vote proxies for the securities held in MPA Program accounts.  For the single Investment Strategy SMA Program accounts, HSBC Securities has delegated this authority to the MPA SMA Managers.  For the multi-Investment Strategy UMA Program accounts, a third-party voting service, Institutional Shareholder Services (“ISS”), acts as an independent voting agent on behalf of HSBC Securities. ISS provides proxy analysis and voting recommendations, manages the operational process, and votes proxies based on HSBC’s Proxy Voting Guidelines. AMUS as part of the services provided to the MPA Program oversees the voting of proxies for UMA Program accounts. A copy of AMUS's Proxy Voting Policy and information about how proxies were voted is available upon client request. A client can vote proxies for their account by notifying HSBC Securities in writing. HSBC Securities is not liable or responsible for the timely delivery of proxies. Custody and Reporting HSBC Securities or another financial intermediary serves as custodian for accounts. Currently, HSBC Securities has entered into an agreement with BNY Pershing to act as the custodian for the MPA Program. BNY Pershing is located at One Pershing Plaza, Jersey City, New Jersey 07399. BNY Pershing will generally furnish monthly, but no less frequently than quarterly, account statements summarizing account activity during the period. Clients can suppress receipt of separate trade confirmations for an account by completing a confirmation suppression request. Information from the confirmations will be reported at least quarterly to the client, in lieu of separate trade confirmations. BNY Pershing facilitates the production and mailing of quarterly performance statements to clients in the MPA Program. The performance statements are intended to inform clients as to how their accounts within the MPA Program have performed during the period and are not intended to replace the statements of the custodian. 11 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 HSBC Securities from time to time comes into possession of the client assets. As such, on an annual basis, HSBC Securities must ensure that the requirements of the Custody Rule are met (e.g., the performance of a surprise examination by an independent public accountant). Reasonable Restrictions A client can request reasonable restrictions on the investments in the account. For example, a client may request that the SMA Manager or Overlay Manager not buy a particular stock or stocks from a particular industry. If a restriction request is so overly broad as to make it not possible to manage the account according to the Investment Strategy, HSBC Securities will work with the client’s Representative to determine a potential alternative. Reasonable restrictions are subject to approval by the SMA Manager or Overlay Manager, as applicable. The implementation of a restriction on a security otherwise included in a MPA UMA Program model will result in a prorated increase of the other non-restricted securities in that model, which could adversely affect the account performance. Discretionary Authority: SMA HSBC Securities’ discretionary authority is limited to evaluating and monitoring the SMA Managers responsible for managing the assets in a client’s account. Neither HSBC Securities nor AMUS has responsibility or liability for the individual investment decisions of any SMA Manager or rebalancing by any SMA Manager. However, some strategies available in the SMA program are managed by the Affiliated SMA Manager, HBUS. The client will designate an SMA Manager, which can include an affiliate of HSBC Securities, who will have investment discretion over the account. The SMA Manager will determine the securities to be purchased, held or sold for an account and the weightings thereof, subject to any reasonable investment restrictions or limitations imposed by client, properly communicated in writing to HSBC Securities and accepted by the SMA Manager. Discretionary Authority: UMA HSBC Securities acts as Overlay Manager to provide portfolio implementation and coordination services for the UMA Program account. HSBC Securities has delegated certain activities to an affiliate and a third party. In addition, HSBC Securities can at its discretion, engage an unaffiliated Overlay Manager upon thirty (30) days written notice to the client. In the UMA Program, HSBC Securities’ discretionary authority is limited to implementing and rebalancing the account to the client’s selected asset allocation, as provided for in the Proposal and updated from time to time; evaluating, selecting and monitoring the investment strategies made available under MPA, and coordinating investment restrictions, as applicable; and, if selected, performing tax optimization in each UMA account. HSBC Securities has no responsibility or liability for the individual recommendations of any Model Manager or the investment manager of any Fund. However, some models available in the UMA Program are maintained under an intercompany agreement with HBUS wherein HBUS serves as the Affiliated Model Manager. Best Execution and Brokerage Services Each SMA Manager has the discretion to select broker-dealers to execute trades and is responsible for selecting broker-dealers in a manner consistent with its obligation to seek best execution. Clients are encouraged to review the SMA Manager’s Form ADV brochure regarding its brokerage practices. SMA 12 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 Managers will generate trade recommendations and orders through a variety of methods and transmit those orders to HSBC Securities’ designated trading entity at BNY Pershing. SMA Managers will seek to execute securities purchases and sales with or through BNY Pershing and can also execute fixed income trades with or through BNY Pershing but rarely do. Clients authorize and direct all transactions in their account, except as provided below, to be affected by or through BNY Pershing. See the Trading Away section below for additional information. HSBC Securities generally provides securities execution and related brokerage services using BNY Pershing’s clearing and execution facilities. If the SMA Manager believes using another broker-dealer is consistent with its obligation to seek best execution on a particular transaction, the SMA Manager can use a broker-dealer other than BNY Pershing. Please refer to an SMA Manager’s Form ADV brochure for information about its selection of broker- dealers. When the SMA Manager directs transactions for execution with or through broker-dealers other than BNY Pershing, the client will incur additional transaction costs not included in the MPA investment advisory fee. These transaction costs will not be shown on the brokerage statements or trade confirmations and are embedded in the price of the security. Clients sometimes pay exchange or similar fees to third parties, including but not limited to fees to convert foreign shares to American Depository Receipts as well as foreign taxes. All of these charges are in addition to the MPA Program, SMA Manager and Model Manager fees. See the Fees and Other charges section below for details on changes effective April 1, 2026. Trading Away for SMA Managers Clients should be aware that some SMA Managers, particularly those specializing in fixed income, have placed all or substantially all of their client trades with another broker-dealer for execution, also known as “trading away”. Some SMA Managers also trade away in foreign ADRs or U.S. equity securities; however, the level of this trading away varies by manager. SMA Managers trade away for various reasons, including because it can be more efficient to place a single trade for all clients rather than a series of trades for their clients in different wrap programs. Please refer to a SMA Manager’s Firm Brochure for information about its selection of broker-dealers. If the SMA Manager executes trade orders with another broker-dealer, you likely will incur trading costs in addition to the MPA asset based fees. The trading costs can include commissions, markups, mark downs or “spreads” paid to market makers. They will be embedded in the price of the security and not shown on a confirmation or statement. See the Fees and Other charges section below for details on changes effective April 1, 2026. Special Disclosures for Fixed Income Manager Neuberger Berman Neuberger Berman Tax-Exempt Intermediate Maturity Fixed Income Strategy (Neuberger Berman) The Neuberger Berman SMA Manager, buys and sells municipal securities for clients on various electronic trading platforms; these platforms typically charge between $0.10 to $10 per bond. The higher fee rate will be usually charged when very small lot sizes are being traded. These transaction costs will 13 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 not be shown on the brokerage statements or trade confirmations and are embedded in the price of the security. Principal, Agency and Cross Transactions SMA Manager places trades in the MPA Program, and BNY Pershing places trades in the UMA Program. Please refer to the SMA Manager’s Form ADV brochure for its trading practices. HSBC Securities acts as an introducing broker for the MPA Program (and other clients and programs), using the clearing and execution facilities of our third-party clearing agent, BNY Pershing, for all securities transactions executed within a client’s account, subject in all cases to best execution obligations and applicable law. It is HSBC Securities’ policy that it will not affect principal or cross trade transactions in the MPA Program. In a principal transaction, an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. In an agency cross transaction, a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser acts as broker for both the advisory client and for another person on the other side of the transaction. In some cases, when a client is funding their account, they may own an HSBC issued Structured Certificate of Deposit or Note (collectively “Structured Products”). When selling or making an early redemption of Structured Products, HSBC Securities will engage in a principal or cross trade to unwind the constituent parts of the Structured Products. HSBC Securities as a broker-dealer at times will receive incidental compensation for liquidating Structured Products, however, the International Wealth and Premier Banking division of HSBC Securities does not receive any compensation on the early redemption of Structured Products. HSBC Securities as an investment adviser does not receive any compensation when a client sells a Structured Product to fund its managed account. Termination The MPA client agreement can be terminated by either party by written notice to the other party. The notice period is found in the MPA account agreement. Account termination will not affect: (i) the validity of any action taken previously by HSBC Securities under the client agreement; (ii) liabilities or obligations of the parties from transactions initiated before termination; or (iii) the client’s obligation to pay advisory fees pro-rated through the date of termination. Please see the MPA Client Agreement for full details. Fees and Other Charges Through March 31st 2026, fees are charged quarterly in advance. Beginning April 1, 2026, MPA Program fees will transition from advance billing (i.e., where you pay your advisory fees in advance) to billing in arrears (i.e., you will be charged after the services have been provided, not before). As a result, the billing for the second quarter of 2026 will not occur until July 2026. This change is designed to provide greater transparency and align your payments with the services you receive. Also, currently, your total fee is a bundled amount that includes both the Program Fee and SMA Manager fees for SMA Program and applicable Model Manager fees for UMA Program. Effective April 1, 2026, the Program fee is being reduced but will no longer include the SMA/UMA and Model Mangers fees, which include HSBC Securities affiliates. SMA and Model Manager fees will now be separately billed 14 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 and applied to program accounts (see below). As these fees will be assessed separately (and based on how account assets are actually allocated), total program fees (i.e., the aggregate of both program and manager fees) could be higher or lower than before this change. Fees are calculated as a percentage of assets in the account as of the last business day of the previous calendar quarter. The client authorizes the Custodian (as defined below) to deduct HSBC Securities’ and AMUS’s or HBUS’s fees directly from the client’s account. HSBC Securities’ fee covers advisory, administrative, custodial and brokerage services, under the Program except that fees do not include:    brokerage transaction fees or commissions associated with Trading Away; dealer markups or markdowns that are embedded in the price of certain securities, executed on a “net” basis, (e.g. fixed income securities); any fees imposed by regulatory or governmental authorities (including those imposed by the Securities and Exchange Commission);    wire transfer and other miscellaneous fees incurred in the underlying HSBC Securities brokerage account (See HSBC Securities brokerage fee schedule, available from HSBC Securities or your representative); costs associated with special requests by a client; or any management, administrative, distribution or other operating fees or expenses of a mutual fund (including a money market fund) or ETF held in the account. These separate operating fees and expenses are disclosed in the fund’s or ETF’s prospectus.  Beginning April 1, 2026, SMA Manager or Model Manger fees, which may be an HSBC Securities affiliate. No fee adjustment will be made for appreciation or depreciation in the asset value of the account during any quarterly period. If during a billing period, a client makes a contribution or withdrawal equal to $25,000 or more of cash or securities or other assets (other than dividends, interest or capital gains distributions on securities held in the account), the client’s next quarterly advisory fee will be credited or debited (on a pro rata basis) accordingly through a separate billing made in arrears. This amount is based upon the market value of the additional assets, prorated for the number of days remaining in the billing period and based on HSBC Securities’ then-current fee schedule applicable to the account. A pro rata portion of any prepaid fees will be returned, in the event of termination of the account agreement. The Funds made available through the MPA Program include both mutual funds and ETFs advised by non-HSBC investment companies (third party funds) and funds advised by AMUS or its affiliates who provide investment advisory services (proprietary funds). The only money market funds available in the MPA Programs are money market mutual funds that are advised by an HSBC affiliate. HSBC Securities pays a portion of the MPA Program fees to the Program’s service providers, including its affiliates. In addition to Program fees, clients pay their share of a mutual fund’s, ETF’s and other investment fund’s fees and expenses, which include 12b-1 (distribution) fees, management fees, administrative fees, operating costs, and all other asset-based costs. 15 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 In connection with investments in an HSBC affiliated Fund by a retirement account-an IRA or an employee benefit plan subject to the ERISA, HSBC Securities will offset any additional compensation it (or an affiliate) receives in connection with such investments by crediting against the account fee an amount that is equal to such additional fees and compensation HSBC Securities (and its affiliates) receive for the applicable billing period with respect to such investment. For information regarding the structure, fees, and risks associated with investing in Funds, see applicable SEC’s Investor Bulletins under Investor Alerts and Bulletins on https://www.investor.gov/. In the MPA Program, HSBC Securities does not credit its Representatives with any 12b-1 fees HSBC Securities receives. However, when HSBC receives 12b-1 fees, the Firm’s policy is to credit the client’s account in an amount equal to the amount of the client’s share of any Rule 12b-1 fees the Firm received. Representatives’ compensation may create certain conflicts of interest between you, HSBC Securities and your Representative. Please see Item 9B “Material Relationships or Arrangements with Related Persons” and “Other Compensation” sections for additional information. 1. Current Standard Fee Schedule for SMA Program through March 31, 2026: Model: All Fixed Income All Equity Total Portfolio Assets Under Management: Fee rate per (annum) on assets First $500,000 1.50% 2.50% Next $500,000 1.20% 2.00% Over $1,000,000 0.95% 1.50% 2. HSBC U.S. Treasury Strategy Total Portfolio Assets Under Management: Fee rate per (annum) on assets First $5,000,000 0.50% Next $5,000,000 0.375% Over $10,000,000 0.25% Current Standard Fee Schedule for UMA Program through March 31, 2026: 16 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 Model: Conservative Moderately Moderate Aggressive Conservative Moderately Aggressive Fee rate (per annum) on assets Total Portfolio Assets Under Management: First $500,000 Next $500,000 Over $1,000,000 1.55% 1.25% 0.90% 1.60% 1.30% 0.95% 1.70% 1.35% 1.00% 2.15% 1.70% 1.30% 2.50% 2.00% 1.50% The above referenced fee schedule applies to clients in the MPA Program(s) through March 31, 2026. Accounts opened in the past were opened under a different fee schedule. The MPA Fee Schedule will change Effective April 1, 2026. The revised fee schedules are outlined below and will automatically apply to your account beginning on the effective date April 1, 2026. Effective April 1, 2026, the fees payable for any calendar quarter will be charged in arrears, based on the average daily account asset value during the prior calendar quarter and the annual fee rate(s) set forth in the following schedule. *HSBC will be implementing new fee schedules for the Managed Portfolio Accounts (MPA) effective April 1, 2026. The Program Fees will no longer include the Separately Managed Account (SMA/UMA) manager (i.e., portfolio manager or model manager, which include HSBC Securities affiliates) fees now will be separately billed and applied to program accounts (below). As these fees will be assessed separately (and based on how account assets are actually allocated), total program fees, (i.e., the aggregate of both program fees and manager fees) could be higher or lower than before the change. The fees payable for any calendar quarter will be charged in arrears, based on the average daily account asset value during the prior calendar quarter and the annual fee rate(s) set forth in the following schedule. 17 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 The following fee ranges apply and are subject to change: SMA Manager Fee Ranges: The SMA Manager Fee will vary based on the asset class and manager selected by the client as part of the Proposal, subject to market movements, contributions, withdrawals and periodic rebalancing between investment strategies. Fixed Income Only Strategies: 0.15% -0.29% Equity Strategies: 0.24% -0.50% *Model manager fees are generally lower than separately managed account fees. UMA Model Manager Fee Ranges: The Model Manager Fee will vary based on the assets class and model manager selected by the client as part of the Proposal, subject to market movements, contributions, withdrawals and periodic rebalancing between investment strategies. Equity Strategies: 0.30% -0.40% *Model manager fees are generally lower than separately managed account fees. A schedule of the individual manager fees is available for reference. Actual SMA/Model Manager fee(s) applied will depend on the specific manager(s)/Investment Strategies utilized for your account. See your account statement(s) for more information about manager allocations. Please reach out to your IAR for additional information. HSBC Securities in its sole discretion can discount the MPA Program Fee. Discounted fees are subject to review and adjustment. Effective April 1, 2026, SMA Manager Fees and Model Manager fees will not be subject to any negotiated discount. HSBC Securities, in its sole discretion, can discount the MPA Program Fee for any client or group of clients at the Firm’s discretion based on a number of factors. Any discounts are subject to review and adjustment. SMA Manager Fees and Model Manager Fees are not subject to discounts. HSBC Securities believes its fees are reasonable in relation to the scope of services provided, but such fees are not always the lowest available. For ERISA plans, IRAs and other tax-qualified savings accounts, Affiliated Model Manager Fees and Affiliated SMA Manager Fees, where such managers are available, will either be waived or credited. HSBC Securities reserves the right to restrict the availability of Affiliated Model Manager models for any reason. HSBC Securities has a conflict of interest in offering these models to these accounts for no additional compensation. Restricting these models may affect the recommended Investment Strategy the client receives and affect account performance. Please reach out to your IAR for additional information. 18 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 For purposes of determining the Fee Rate from such schedule, we will consider the Account assets held by you and/or others in your designated relationship as determined by us. Comparison Cost of Service The MPA Program can cost clients more or less than purchasing such services separately (or investing in such Investment Strategies and Funds directly, where available) depending on the frequency of trading in the client’s account, commissions charged at other broker-dealers or investment firms for similar products, advisory fees charged by other investment firms, and other factors. Please consult the advisory agreement, accompanying schedule of fees, and fund prospectuses for other terms, conditions, representations and disclosures relating to the MPA program. HSBC Securities encourages clients to review each recommended SMA Manager’s Firm Brochure for their respective conflicts of interest, trading, privacy policies, codes of ethics, etc. Account Funding If a prospective client intends to fund an MPA account with assets from the redemption of securities, mutual funds, the surrender of an insurance product, early withdrawal from a certificate of deposit, or the sale of any other financial instruments, the client should consider the cost of any possible sales charges, fees or commissions previously paid or to be paid upon such redemption or sale, or any penalties that the client will incur in order to surrender or withdraw from, certain instruments. It can be costly or inappropriate to fund an MPA account in this manner. The client understands that the client may incur a capital gain, loss or a tax liability on any sale, which may reduce client’s invested capital. An ACH (automated clearing house) transaction is a bank transfer that occurs between banks at your direction and authorization. Please note there can be limits to the amount of money that you can transfer in from your account. As these limits are subject to change, please contact your Representative for additional information. Affiliated Managers and Model Providers HSBC Securities may invest your account assets, as selected by you and reflected in the Proposal, in managed account strategies that are managed by an affiliated investment manager, such as HBUS. By participating in the MPA Program, you acknowledge and agree that your account may be invested in strategies managed by an Affiliated Manager and that you will pay the applicable manager fee to the Affiliated Manager, in addition to any program fees. You further acknowledge that this arrangement creates a conflict of interest and financial incentive because HSBC Securities and its affiliates receive additional compensation when your assets are invested with an Affiliated Manager. The aggregate amount of this compensation may be more than what HSBC Securities and its affiliates would receive when your assets are invested with a third-party investment manager or pursuant to a model provided by a third-party investment manager. HSBC Securities seeks to address this conflict through disclosure. Third Party SMA Managers and Model Providers Independence All SMA Managers and Model Managers participating in the MPA managed account programs, other than Affiliated Managers and Model Providers as disclosed above, are independent of HSBC Securities. HSBC 19 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 Securities does not control or direct the investment decisions of these independent managers including if such managers invest in funds managed or advised by an HSBC Securities affiliate. Item 5: Account Requirements and Types of Clients HSBC Securities has established a minimum account size of $250,000 for MPA accounts and can waive this minimum account size at its discretion. Each SMA Manager also has a minimum account size for both SMA and UMA accounts. Smaller Program accounts can have different performance than larger accounts. If the account is small (less than $250,000) it may not be able to be invested in all securities and could have higher cash which will lead to a different performance experience. A client’s account can include a mutual fund that has higher fees and expenses than a similar Model Manager or SMA Manager. HSBC Securities will not necessarily exchange a mutual fund for a similar Model Manager or SMA Manager with a higher investment minimum if a client’s assets increase to above the investment minimum. Clients should discuss all investment options with their HSBC Securities Representative. HSBC Securities will terminate accounts that fall below these minimums in HSBC Securities’ sole discretion. Some SMAs and UMA models within the MPA programs can be offered to eligible non-resident aliens who reside in certain foreign jurisdictions, as approved by the Firm and in accordance with the local laws of those jurisdictions. It should be noted that if a client moves to another jurisdiction that is not approved for investments it may cause the account to be terminated. If the account is terminated it will be removed from management and the client will only be able to place sell orders. In addition, if a client moves to a jurisdiction that is not approved by a specific fund company, HSBC Securities will be required to redeem that holding(s) and in the case of certain fund companies, HSBC Securities may cause your account to be terminated with all account holdings required to be redeemed. Clients should consider legal and/or tax implications when considering their options. Clients should consult with their attorney or tax advisor. Item 6: Investment Strategy and Asset Allocation Evaluation HSBC Securities has entered into agreements with AMUS, GMS and HAIL to provide certain services for the Programs. The methods of analysis and investment strategies AMUS, GMS and HAIL use in the MPA Programs are outlined below. GMS Strategy Evaluation HSBC Securities makes decisions regarding investment strategies leveraging the funds researched by GMS. GMS researches and approves third party investment strategies (mutual funds, ETFs and separately managed accounts). GMS conducts due diligence based upon both quantitative (e.g., investment performance returns, peer rankings, tracking error, expense ratio, etc.) and qualitative (e.g., firm, people, 20 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 investment strategy and process, portfolio construction, etc.) factors to approve the investment strategies available through the MPA Program. As part of the qualitative review, GMS will review performance attribution, analyze portfolio holdings and assess liquidity and capital erosion. Risk metrics and periodic performance comparisons against representative benchmarks and peers are used as part of the quantitative process. GMS also conducts ongoing monitoring of the investment strategies using similar criteria as the initial review process. GMS also reviews proprietary strategies using a similar approach focused primarily on the investment team, the strategy and its historical track record. The due diligence process employed by GMS for this assessment of proprietary strategies is different from the approach GMS typically applies to third party mutual funds and strategies. Several aspects typically covered in third party reviews are not included in the proprietary due diligence - and GMS’ conclusions around some of these areas may, at times, come from internal HSBC certifications from various business and oversight functions including (where necessary & appropriate) confirmations from investments, risk, and regulatory functions. Some of the proprietary funds are managed by AMUS or its affiliates. AMUS receives investment advisory fees from the proprietary Funds used in the Programs. HSBC Securities makes the final selection of investment strategies to be used. Based upon its findings during the ongoing monitoring, GMS may change the status of an investment strategy to “Hold.” If the factors that led to a Hold status remain unresolved, GMS will change the status of the investment strategy to “Not Approved/Not Recommended.” A Fund’s status may change directly to “Not Approved/Not Recommended” in case the concerns are material requiring immediate action. In certain cases, where there is a significant change affecting the investment strategy, HSBC Securities can recommend the immediate removal without a hold period. MPA clients are notified via their client statement or mailing provided with information on the selected replacement Investment Strategy. Depending on the circumstances, HSBC Securities reserves the right to freeze the client’s portfolio until the replacement investment strategy is established within the MPA program. The transition process from one investment strategy to another may result in transactions that will generate realized gains or losses. To the extent the SMA Manager of a replacement strategy accepts responsibility for the management of specific security positions from the strategy being replaced, the transfer of positions to the new strategy will not incur a transaction cost. Alternative Funds used within the MPA Programs Similar to GMS, HAIL researches and approves alternative Funds using a variety of qualitative and quantitative criteria. HAIL conducts due diligence based upon both quantitative (e.g., investment performance returns, peer rankings, etc.) and qualitative (e.g., firm, people, investment strategy and process, portfolio construction, etc.) factors to approve the investment strategies available through the MPA program. Performance comparisons against representative benchmarks and peers are used as part of the quantitative process. HAIL also conducts ongoing monitoring of the Funds using similar criteria as the initial review process and may place a fund on Hold or move a fund to Not Approved similar to the GMS process described above. Certain funds available within the MPA UMA Program that are not labeled as sustainable investment funds may include sustainability considerations in their investment processes, but any such funds (are not included for their sustainability considerations but instead for other qualities of their investment focus or 21 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 strategies. The UMA advisory program allows clients the option to customize their fund selections using the fund menu. Please also refer to the SMA Manager’s Firm Brochure in addition to the prospectuses for funds offered in the programs for descriptions of investment strategy risks. Asset Allocation Evaluation AMUS oversees the asset allocation used in the MPA program and provides administrative resources to support the program. In providing this service, AMUS collaborates with AMUS to develop the asset allocation models, considering both its long-term and its short-term tactical views. Over the long-term, SAA take into account expected long-term asset class returns, volatilities and correlations in determining recommended allocations, subject to restrictions such as appropriate asset classes and risk tolerance bands. As such, SAAs reflect our long-term expectations for capital markets balancing expected returns with a reasonable level of volatility for the models in the Program. Ranges / guidelines are provided for each asset class to allow for client flexibility. SAAs and asset class ranges are reviewed periodically. In the short-term, capital markets will often deviate from our expectations and present the opportunity to adjust our recommended allocations. In periodically reviewing the models, AMUS will make refinements to the asset allocation models using TAA which adjusts allocations considering short-term trends and relative valuations in capital markets. As such, TAA seeks to take advantage of relative valuation opportunities that arise in the short-term and are expected to enhance portfolio performance over the long-term. In making recommendations to HSBC Securities, AMUS will source the information and tools used in its analysis from both global and local teams balancing our long-term strategic expectations with short-term tactical opportunities. This means that HSBC Securities, at its discretion, can periodically adopt changes to MPA’s asset allocation models based on advice provided by AMUS. The client can also change an asset allocation based on their unique financial circumstances and subject to certain guidelines for each asset class. Review process for Environment, Social Governance (ESG) Funds:  GMS conducts due diligence on ESG/sustainable funds to assess their ESG characteristics, evaluating their ESG intentionality and ensuring this is reflected in their resultant portfolio.  On a fund-specific level, GMS applies HSBC Group’s Sustainable Investment (SI) definitions to determine if a fund is an ESG fund. In addition to the alignment to SI definitions, GMS undertakes a qualitative evaluation of ESG considerations, with a deep dive into the sustainable investment philosophy, style, proprietary ESG frameworks and voting policy; and an-evidence-based assessment that ensures the approach consistently reflects in the portfolio holdings.  The ESG assessment is documented, discussed and approved through various committees. The committees will review new ESG fund additions as well as fund downgrades / upgrades and will take note of completed fund reviews where the status remains unchanged. Each fund manager may use different metrics such as ESG rating and carbon intensity to measure the environmental or social impact of their strategies. The criteria used can be highly subjective and may vary significantly across and within sectors. HSBC Securities through Global Manager Selection – Funds & ETFs (“GMS”) undertakes its own due diligence when selecting managers for ESG consideration. While GMS conducts its own due diligence, GMS is still reliant on the underlying proprietary ESG measurement criteria used by fund managers and does not conduct its own due diligence into a manager’s 22 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 proprietary ESG measurement scoring or criteria. There is no guarantee that the nature of the ESG characteristics of an investment will be aligned with any particular investor’s ESG objectives or that the stated level or target level of ESG goals will be achieved. Share Class Evaluation In the UMA Program where mutual funds can be held, some mutual fund share classes charge distribution fees (12b-1 fees), shareholder servicing fees, and/or sub-transfer agency fees. Some mutual fund sponsors or distributors also pay a portion of their fees to offer their shares in other UMA programs, a practice called “revenue sharing.” HSBC Securities credits 12b-1 fees received back to client’s account and does not accept revenue sharing payments from any of the mutual funds in the UMA Program. While we seek to provide you with the lowest cost share class of a Fund, whether we offer the lowest cost share class to clients depends on several factors. First, a fund may not make its lowest cost share class available in the Programs. Second, some institutional share classes are not available to retail investors, in or outside of the Programs. Third, if BNY Pershing charges us a fee to trade lowest-cost share classes for your account, we will not use that share class for your account. When we offer a higher- cost share class because BNY Pershing charges us a fee to trade the lowest-cost class, we have a conflict of interest, because we are avoiding paying a fee while causing your account to pay higher Fund fees and expenses. When we offer a share class in the Programs that is not the lowest cost class, you will pay higher Fund fees and expenses, which will reduce your returns and lower the performance of your account. Some lower cost share classes are available outside the Programs, but you will not receive the Programs’ services and benefits. There will be no cost to you if HSBC Securities initiates a share class conversion; however, you may have tax consequences. Any share class conversions will be reflected on your account statements. Risks: Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase in value and your account(s) could enjoy a gain, it is also possible that the stock market may decrease in value and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the stock market, are appropriately diversified in your investments, and ask us any questions you may have. Investments in a client’s MPA account and shares of funds, including money market funds, are: not a deposit or other obligation of HSBC Bank or any of its affiliates; not FDIC insured or insured by any federal government agency of the United States; not guaranteed by HSBC Bank or any of its affiliates; and are subject to investment risk, including possible loss of the principal amount invested. Set forth below are certain material risk factors that are often associated with the investment strategies and types of investments relevant to most of HSBC Securities’ clients. The information included in this brochure does not include every potential risk associated with each investment strategy or applicable to a particular client account. Not all risks are applicable to all products. Clients are urged to ask questions regarding risk factors applicable to a particular strategy or investment product, read all product-specific risk disclosures and determine whether a particular investment strategy or type of security is suitable for their account in light of their circumstances, investment objectives and financial situation. 23 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 • Allocation Risk: The risk that target asset and sector allocations and changes in target asset and sector allocations cause the portfolio to underperform other similar funds or cause you to lose money, and that the portfolio may not achieve its target asset and sector allocations. • Asset-Backed Security Risk: Asset-backed securities are debt instruments that are secured by interests in pools of financial assets, such as credit card or automobile receivables. The value of these securities will be influenced by the factors affecting the assets underlying such securities, changes in interest rates, changes in default rates of borrowers and private insurers or deteriorating economic conditions. During periods of declining asset values, asset-backed securities may be difficult to value or become more volatile and/or illiquid. Asset-backed securities may not have the benefit of a security interest in collateral comparable to that of mortgage assets, resulting in additional credit risk. • Banking Risk: Investments in securities issued by U.S. and foreign banks can be sensitive to changes in government regulation and interest rates and to economic downturns in the United States and abroad, and susceptible to risks associated with the financial services sector. • Concentration Risk: When a model or client account invests in a concentrated number of asset classes or sectors, a decline in the value of these asset classes or sectors may cause your overall account value to decline to a greater degree than that of a less concentrated model. Models that invest a large percentage of assets in only one asset class or sector (or in only a few) are more vulnerable to price fluctuation than models that diversify among a broad range of asset classes or sectors. Some mutual funds and ETFs focus investments on a small number of stocks, bonds, industries, foreign currencies or particular countries which increases risk. These funds are more susceptible to risks associated with a single economic, political or regulatory occurrence than a more diversified fund might be. • Convertible Bond Risk. Convertible bonds are subject to the risks of equity securities when the underlying stock price is high relative to the conversion price (because more of the security’s value resides in the conversion feature) and debt instruments when the underlying stock price is low relative to the conversion price (because the conversion feature is less valuable). A convertible bond is not as sensitive to interest rate changes as a similar non-convertible debt instrument and generally has less potential for gain or loss than the underlying equity security. • Counterparty Risk: The risk that the other party to an investment contract, such as a derivative (e.g., ISDA Master Agreement) or a repurchase or reverse repurchase agreement, will not fulfill its contractual obligations or will not be capable of fulfilling its contractual obligations due to circumstances such as bankruptcy or an event of default. Such risks include the other party's inability to return or default on its obligations to return collateral or other assets as well as failure to post or inability to post margin as required applicable credit support agreement. • Commodity Related Investments Risk: The risks of investing in commodities, including investments in companies in commodity-related industries may subject a portfolio to greater volatility than investments in traditional securities. The potential for losses may result from changes in overall market movements or demand for the commodity, domestic and foreign political and economic events, adverse weather, discoveries of additional reserves of the commodity, embargoes and changes in interest rates or expectations regarding changes in interest rates. 24 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 • Currency Risk: Fluctuations in exchange rates between the U.S. dollar and foreign currencies, or between various foreign currencies, may negatively affect a portfolio’s investment performance. • Custody Risk: The Funds invest in securities markets that are less developed than those in the U.S., which may expose a portfolio to risks in the process of clearing and settling trades and the holding of securities by foreign banks, agents and depositories. The laws of certain countries may place limitations on the ability to recover assets if a foreign bank, agent or depository enters bankruptcy. In addition, low trading volumes and volatile prices in less developed markets may make trades more difficult to complete and settle, and governments or trade groups may compel local agents to hold securities with designated foreign banks, agents and depositories that may be subject to little or no regulatory oversight or independent evaluation. Local agents are held only to the standards of care of their local markets. • Cyber Security Risk: With the increased use of technology such as the Internet to conduct business, HSBC Securities, as with all businesses and digital platforms that store, process, transmit or transact information via networked technology, is susceptible to a breach of confidentiality, loss of data integrity or disruption in availability of its networked systems. Cyber vulnerability continues to be leveraged by criminals to perpetrate crimes at an increasing rate, often exceeding traditional offenses, and poses a significant threat to economic, social and geopolitical stability for private firms and countries. HSBC Securities faces sophisticated cyber threats from state-sponsored attackers, hackers for hire, organized cyber syndicates, and other threat actors seeking our critical corporate and customer information. Cyber incidents can result from deliberate internal or external attacks. Cyber-attacks can include, but are not limited to, gaining unauthorized access to computer systems (e.g., through “hacking” or malicious software (aka Malware) denial-of-service attacks on websites (i.e., efforts to make network services unavailable to intended users). Unintentional cyber incidents can occur, such as the inadvertent release of confidential information that could result in the violation of applicable privacy laws. A failure in or a breach of our operational or security systems or infrastructure, or those of our third-party vendors and other service providers, including as a result of cyber-attacks, could disrupt our businesses, result in the disclosure or misuse of confidential or proprietary information, and may adversely impact our businesses. Data quality and integrity are critical for decision making, enterprise risk management and operational processes, as well as for complying with applicable regulation. Our businesses depend on our ability to process a large number of complex transactions, most of which involve, in some fashion, networked computing devices. If any of our financial, accounting, data processing or other recordkeeping systems and management controls fail, or are subject to cyber-attack that could compromise integrity, availability or confidentiality of our systems or data, we could be materially adversely affected. Cyber security failures or breaches at HSBC Securities or at service providers (including, but not limited to, sub-advisers, accountants, custodians, transfer agents and administrators), and the issuers of securities in which HSBC Securities invests on behalf of its clients, could result in the loss or theft of client data or 25 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 funds, the inability to access electronic systems, loss or theft of proprietary information or corporate data, physical damage to a computer or network system, or costs associated with system repairs. Cyber security failures or breaches can result in financial losses, interfere with our ability to calculate a fund’s net asset value, impede our trading, and prevent clients and shareholders from transacting business. These failures or breaches can cause violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. In addition, we could incur substantial costs to prevent any cyber incidents in the future. HSBC Securities relies on cybersecurity risk controls that are managed enterprise wide for HSBC Group in order to ensure that threats are identified and mitigated properly. While HSBC Group (a corporate parent company of HSBC Securities) has preventative, detective and mitigation technologies in place as well as mature business continuity and resiliency plans in the event of cyber-attacks, it is not possible to identify and create mitigation measures for every type of event that might result in a service disruption. • Debt Instruments Risk: The risks of investing in debt instruments include:  High-Yield Securities (“Junk Bond”) Risk: Investments in high-yield securities (commonly referred to as “junk bonds”) are often considered speculative investments and have significantly higher credit risk than investment-grade securities and tend to be less marketable (i.e., less liquid) than higher rated securities. The prices of high-yield securities, which may be more volatile and less liquid than higher rated securities of similar maturity, may be more vulnerable to adverse market, economic or political conditions.  Interest Rate Risk: Fluctuations in interest rates may affect the yield and value of investments in income producing or debt instruments.  Credit Risk: A portfolio could lose money if an issuer or guarantor of a debt instrument fails to make timely payments of interest or principal or enters bankruptcy. This risk is greater for lower-quality bonds than for bonds that are investment grade.  Inventory Risk: The market-making capacity in some debt markets has declined as a result of reduced broker-dealer inventories relative to portfolio assets, reduced broker-dealer proprietary trading activity and increased regulatory capital requirements for financial institutions such as banks. Because market makers provide stability to a market through their intermediary services, a significant reduction in dealer market-making capacity has the potential to decrease liquidity and increase volatility in the debt markets.  Prepayment Risk: During periods of falling interest rates, borrowers may pay off their debt sooner than expected, forcing an underlying portfolio to reinvest the principal proceeds at lower interest rates, resulting in less income.  Extension Risk: The risk that during periods of rising interest rates, borrowers pay off their debt later than expected, preventing a portfolio from reinvesting principal proceeds at higher interest rates, increasing the sensitivity to changes in interest rates and resulting in less income than potentially available. 26 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 • Depositary Receipts Risk: Investments in depositary receipts, such as ADRs and GDRs, may entail the special risks of international investing, including currency exchange fluctuations, government regulations, and the potential for political and economic instability. • Derivatives Risk: Use of derivative instruments involves risks different from, or possibly greater than, the risks associated with investing directly in securities and other traditional investments and could increase the volatility of a portfolio’s asset value and cause losses. Risks associated with derivatives include the risk that the derivative is not well correlated with the security, index or currency to which it relates; the risk that derivatives may result in losses or missed opportunities; the risk that the portfolio will be unable to sell the derivative because of an illiquid secondary market; the risk that a counterparty is unwilling or unable to meet its obligation; and the risk that the derivative transaction could expose the portfolio to the effects of leverage, which could increase the portfolio’s exposure to the market and magnify potential losses, particularly when derivatives are used to enhance return rather than offset risk. There is no guarantee that derivatives, to the extent employed, will have the intended effect, and their use could cause lower returns or even losses to the portfolio. The use of derivatives by the portfolio to hedge risk may reduce the opportunity for gain by offsetting the positive effect of favorable price movements. • Diversification Risk: Diversification is a risk management strategy that mixes a wide of investments within a portfolio. A diversified portfolio contains a mix of distinct asset types and investment vehicles in an attempt at limiting exposure to any single asset or risk. It does not guarantee a profit or protect against a loss in a declining market. It also cannot eliminate the risk of fluctuating prices and uncertain returns. • Emerging Markets Risk: Investments in emerging market countries are subject to all of the risks of foreign investing generally, and have additional heightened risks due to a lack of established legal, political, business and social frameworks to support securities markets, including: greater market volatility and illiquidity, lower trading volume, delays in trading or settling portfolio securities transactions; currency and capital controls or other government restrictions or intervention, such as expropriation and nationalization; greater sensitivity to interest rate changes; pervasiveness of corruption and crime; currency exchange rate volatility; and higher levels of inflation, deflation or currency devaluation. The prices of securities in emerging markets can fluctuate more significantly than the prices of securities in more developed countries. The less developed the country, the greater effect such risks may have on an investment. • Environmental Social Governance (ESG) Investments: HSBC Securities makes available Environmental Social Governance (ESG) funds with certain limitations by the program and model type. Effective on or about November 20, 2023, HSBC Securities will offer the following in respect to ESG funds and investments:  MPA (SMA) Programs/models: o The MPA (SMA) program does not offer ESG Investment options in the MPA (SMA) Program.  MPA (UMA) Programs/models: o The MPA (UMA) programs will no longer offer ESG Investment options in the MPA (UMA) Program for new investors. Existing clients holding ESG exposed positions 27 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 and investments have the option to continue investing in them.  Spectrum Programs/models: o The Spectrum program and models will no longer offer ESG Investment options in the Spectrum Program for new investors (please note that Spectrum II is considered a separate program). Existing clients holding ESG exposed positions and investments have the option to continue investing in them.  Spectrum II Programs/models: o The Spectrum II program and models will continue to be open to new investors who desire ESG Investment options with the choice of the ESG related models. Sustainable Investments is a broad term that refers to any form of financial services integrating Environmental, Social and Governance (ESG) criteria that aims to generate long-term financial returns while advancing sustainable solutions and outcomes. As a result of the ESG screening criteria utilized by these funds, the investment opportunities may be more limited than that of other funds, and as a result using an ESG investment approach may produce more modest gains than using another investment approach. There is no guarantee that an investment approach that considers environmental, social and governance (ESG) factors will produce returns similar to those that do not consider these factors. Investment approaches that consider ESG factors may diverge from traditional market benchmarks. Also, some asset classes might not be available in the Spectrum II ESG Program. There is currently no generally adopted industry criteria/standards for what qualifies as an ESG investment, how to measure performance of ESG investments, and the impact of ESG investments on performance. This can result in discrepancies in results and approach in the calculation of ESG data. An ESG portfolio is not guaranteed to outperform (financially) similar investments that do not meet ESG criteria. There is no guarantee that the ESG characteristics a manager or HSBC Securities uses will be aligned with those of the client’s or that these characteristics will match the client’s expectation of ESG investing. Also, each fund manager can have different ESG assessment criteria and exclusion criteria. ESG investment is an evolving area, and an investment that is considered ESG today may not meet those standards at some point in the future. Therefore, the range of ESG investment strategies that any underlying fund in the Program employs may change in the future. • Equity Securities Risk: The prices of equity securities fluctuate from time to time based on changes in a company’s financial condition or overall market and economic conditions. As a result, the value of equity securities may fluctuate drastically from day to day. The risks of investing in equity securities also include:  Style Risk: The risk that use of a growth or value investing style may fall out of favor in the marketplace for various periods of time. Growth stock prices reflect projections of future earnings or revenues and may decline dramatically if the company fails to meet those projections. A value 28 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 stock may not increase in price as anticipated if other investors fail to recognize the company’s value.  Capitalization Risk: Stocks of large capitalization companies may be volatile in the event of earnings disappointments or other financial developments. Medium and smaller capitalization companies may involve greater risks due to limited product lines and market and financial or managerial resources. Stocks of these companies may also be more volatile, less liquid and subject to the potential for greater declines in stock prices in response to selling pressure. Stocks of smaller capitalization companies generally have more risk than medium capitalization companies.  Issuer Risk: An issuer’s earnings prospects and overall financial position may deteriorate, causing a decline in a portfolio’s asset value. • Exchange Traded Fund Risk: An investment in ETFs involves risk, including the loss of principal. ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the Fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any Fund-level capital gains, as ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent net asset value (‘NAV”), which is generally calculated at least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. • Financial Services Risk: Investments in the financial services group of industries may be particularly affected by economic cycles, interest rate changes, and business developments and regulatory changes applicable to the financial services group of industries. For example, declining economic and business conditions can disproportionately impact companies in the financial services group of industries due to increased defaults on payments by borrowers. Interest rate increases can also adversely affect financial services companies by increasing their cost of capital. In addition, financial services companies are heavily regulated and, as a result, political and regulatory changes can affect the operations and financial results of such companies, potentially imposing additional costs and possibly restricting the businesses in which such companies may engage. • Foreign Securities Risk: Investments in foreign securities are generally considered riskier than investments in U.S. securities, and are subject to additional risks, including international trade, political, economic and regulatory risks; fluctuating currency exchange rates; less liquid, developed or efficient trading markets; the imposition of exchange controls, confiscations and other government restrictions; and different corporate disclosure and governance standards. • Frontier Market Countries Risk: Frontier market countries generally have smaller economies and even less developed capital markets or legal, regulatory and political systems than traditional emerging markets. As a result, the risks of investing in emerging market countries are magnified in frontier market 29 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 countries. Frontier market economies are less correlated to global economic fluctuations than developed economies and have low trading volumes and the potential for extreme price volatility and illiquidity. The government of a frontier market country may exercise substantial influence over many aspects of the private sector, including by restricting foreign investment, which could have a significant effect on economic conditions in the country and the prices and yields of securities in a Fund’s portfolio. Economies in frontier market countries generally are heavily dependent upon international trade and, accordingly, have been and may continue to be adversely affected by trade barriers, exchange controls, managed adjustments in relative currency values and other protectionist measures imposed or negotiated by the countries with which they trade. These economies also have been and may continue to be affected adversely by economic conditions in the countries with which they trade. Brokerage commissions, custodial services and other costs relating to investment in frontier market countries generally are more expensive than those relating to investment in more developed markets. The risk also exists that an emergency situation may arise in one or more frontier market countries as a result of which trading of securities may cease or may be substantially curtailed and prices for investments in such markets may not be readily available. • Government Securities Risk: There are different types of U.S. government securities with different levels of credit risk. U.S. government securities issued or guaranteed by the U.S. Treasury and/or supported by the full faith and credit of the United States have the lowest credit risk. A U.S. government sponsored entity, although chartered or sponsored by an Act of Congress, may issue securities that are neither insured nor guaranteed by the U.S. Treasury and are riskier than those that are. • Index Fund Risk: The risk that the underlying funds’ performance will not correspond to its benchmark index for any period of time and may underperform the overall stock market. • Initial Public Offering Risk: Investments in securities purchased at an initial public offering ("IPO") or secondary public offering are often subject to a broader set of market impacts such as investor perception and market opinions of companies that were previously privately held. As such, prices of securities purchased at an IPO or secondary public offering may be more volatile or fluctuate more rapidly than other types of securities. Additionally, to the extent an account is smaller in size, investments in securities purchased at an IPO or secondary public offering may have a more significant impact on the account's performance or value than the securities would on an account larger in size as those securities may represent a larger proportion of the overall securities held by a smaller account. • Issuer Risk: The risk that the issuer’s earnings prospects and overall financial position will deteriorate, causing a decline in the value of the portfolio. • Leverage Risk: Leverage created by borrowing or investments, such as derivatives, can diminish the portfolio’s performance and increase the volatility of the portfolio’s asset value. • Liquidity Risk/Illiquid Securities Risk: The risk that the portfolio could lose money if it is unable to dispose of an investment at a time that is most beneficial or be unable to meet redemption demand. • Market Risk: Issuer, political, or economic developments can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. In the short term, equity prices can fluctuate dramatically in response to these developments. Different parts of the market and 30 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 different types of equity securities can react differently to these developments. For example, large-cap stocks can react differently from small-cap or mid-cap stocks, and “growth” stocks can react differently from “value” stocks. • Model Risk: A model is defined as a quantitative method, system, or approach that applies statistical, economic, financial or mathematical theories, techniques, and assumptions to process input data into quantitative estimates. Quantitative methodologies or systems whose inputs are (partially or wholly) qualitative or based on expert judgment may be classified as a model providing that the outputs produced by the model are quantitative in nature. HSBC Securities, in conjunction with AMUS, use models to assist in the investment decision making process, to analyze the investment risks borne by a fund or client account, to measure the liquidity in a fund or client account, to conduct stress tests and for other reasons. Model risk is defined as the risk of funds or HSBC Securities and/or affiliates experiencing an actual or potential financial loss, or the breach of a regulation or client restriction, owing to the misspecification or misapplication of a model in relation to its intended use, or the improper implementation or incorrect execution of a model. • Mortgage- and Asset-Backed Securities Risk: Mortgage- and asset-backed securities are debt instruments that are secured by interests in pools of mortgage loans or other financial assets. Mortgage- and asset- backed securities are subject to prepayment, extension, market, and credit risks (market and credit risk are described elsewhere in this section). Prepayment risk reflects the risk that borrowers may prepay their mortgages faster than expected, thereby affecting the investment’s average life and perhaps its yield. Conversely, an extension risk is present during periods of rising interest rates, when a reduction in the rate of prepayments may significantly lengthen the effective durations of such securities. • Participatory Note Risk: Even though a participatory note is intended to reflect the performance of the underlying securities on a one-to-one basis so that investors will not normally gain or lose more in absolute terms than they would have made or lost had they invested in the underlying securities directly, the performance results of participatory notes will not replicate exactly the performance of the issuers or markets that the notes seek to replicate due to transaction costs and other expenses. Investments in participatory notes involve risks normally associated with a direct investment in the underlying securities. In addition, participatory notes are subject to counterparty risk. Participatory notes constitute general unsecured, unsubordinated contractual obligations of the banks or broker-dealers that issue them, and an investment in these instruments is relying on the creditworthiness of such banks or broker- dealers and has no rights under the participatory notes against the issuers of the securities underlying such participatory notes. There can be no assurance that the trading price or value of participatory notes will equal the value of the underlying value of the securities they seek to replicate. • Political Risk: The risk that an investment’s return could suffer as a result of political changes or instability in a country. Instability affecting investment returns could stem from a change in government, legislative bodies, other foreign policy makers, or military control. Political risk is also known as “geopolitical risk” and becomes more of a factor as the time horizon of an investment gets longer. • Real Estate Risk: Real estate related investments will expose a portfolio to risks similar to those associated with direct ownership of real estate, including losses from casualty or condemnation, and changes in local and general economic conditions, supply and demand, interest rates, zoning laws, regulatory limitations on rents, property taxes and operating expenses. 31 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 • Redemption Risk: A fund or client portfolio may experience a redemption(s) resulting in large outflows of cash from time to time. This activity could have adverse effects on performance if the advisor were required to sell securities at times when it otherwise would not do so. This activity could also accelerate the realization of capital gains/losses and increase transaction costs. • Regulatory Risk: U.S. regulators and legislators have recently amended a wide range of rules and pending and ongoing regulatory reforms (e.g., the Dodd Frank Act) continue to have a material impact on the advisory business. These regulations and reforms may significantly change the operating environment and the ultimate effect cannot be adequately predicted. Any further changes by the SEC or additional legislative developments may affect a portfolio’s operations, investment strategies, performance and yield. • Regulatory Risk in Other Countries: Disclosure and regulatory standards in emerging market countries are in many respects less stringent than U.S. standards. Therefore, disclosure of certain material information may not be made, and less information may be available. Additionally, regulators in many countries continue to review the regulation of such portfolios. Any further changes by a regulatory authority or additional legislative developments may affect a portfolio’s operations, investment strategies, performance and yield. • Repurchase Agreement Risk: The use of repurchase agreements, which are agreements where a party buys a security from another party (“seller”) and the seller agrees to repurchase the security at an agreed- upon date and price (which reflects a market rate of interest), involves certain risks. For example, if the seller of the agreements defaults on its obligation to repurchase the underlying securities at a time when the value of these securities has declined, a portfolio may incur a loss upon disposition of the securities. There is also the risk that the seller of the agreement may become insolvent and subject to liquidation. • Short Sale Risk: The risk of entering into short sales, including the potential loss of more money than the actual cost of the investment, and the risk that the third party to the short sale may fail to honor its contract terms, causing a loss to the portfolio. • Sovereign Debt Risk: Sovereign debt instruments, which are instruments issued by foreign governmental entities, are subject to the risk that the governmental entity may be unable or unwilling to repay the principal or interest on its sovereign debt due to, among other reasons, cash flow problems, insufficient foreign currency reserves, political considerations, the relative size of the governmental entity’s debt or its failure to implement economic reforms required by the International Monetary Fund or other multilateral agencies. A governmental entity that defaults may ask for additional loans or for more time to pay its debt. There is no legal process for collecting sovereign debts that a government does not pay nor are there bankruptcy proceedings through which all or part of the sovereign debt that a governmental entity has not repaid may be collected. • Stable NAV Risk: The following applies to money market funds that maintain a stable price of $1.00 per share. The fund may not be able to maintain a Net Asset Value (“NAV”) per share of $1.00 (a “Stable NAV”) at all times. The failure of other money market funds to maintain a Stable NAV (or the perceived threat of such a failure) could adversely affect the fund’s NAV. Shareholders of a money market fund 32 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 should not rely on or expect HSBC Securities, the fund's adviser or an affiliate to help a fund maintain a Stable NAV. Pending money market fund reform changes may also impact Stable NAV policies of funds. • Stand-by Commitments Risk: Stand-by commitments are subject to certain risks, which include the ability of the issuer to pay when the commitment is exercised, the fact that the commitment is not marketable, and the fact that the maturity of the underlying obligation generally differs from that of the commitment. • Underlying Fund Selection Risk: The risk that a portfolio may invest in underlying funds that underperform other similar funds or the markets more generally, due to poor investment decisions by the investment adviser(s) for the underlying funds or otherwise underlying funds also have their own expenses, which the portfolio bears in addition to its own expenses. • Variable Rate Securities Risk: Variable (and floating) rate instruments have interest rates that are periodically adjusted either at set intervals or that float at a margin above a generally recognized rate. Variable (and floating) rate instruments are subject to the same risks as fixed income investments, particularly interest rate risk and credit risk. Due to a lack of secondary market activity for certain variable and floating rate instruments, these securities may be more difficult to sell if an issuer defaults on its financial obligation or when a portfolio is not entitled to exercise its demand rights. • When-Issued Securities: The price and yield of securities purchased on a “when-issued” basis is fixed on the date of the commitment, but payment and delivery are scheduled for a future date. Consequently, these securities present a risk of loss if the other party to a “when-issued” transaction fails to deliver or pay for the security. In addition, purchasing securities on a “when- issued” basis can involve a risk that the yields available in the market on the settlement date may actually be higher (or lower) than those obtained in the transaction itself and, as a result, the “when-issued” security may have a lesser (or greater) value at the time of settlement than a fund’s payment obligation with respect to that security. Item 7: Client Information Provided to Investment Managers HSBC Securities will share a client’s Proposal with its SMA Manager(s) and the Overlay Manager in addition to AMUS. HSBC Securities will not share a client’s Proposal with Model Managers. The Proposals are used to set up the manager/allocation for each account in Pershing's system. Item 8: Client Contact with Investment Managers Upon reasonable request, HSBC Securities will make available the appropriate service provider (AMUS or SMA Manager) personnel for consultation concerning the management of the client’s account in the MPA Program. Item 9: Additional Information 9A. DISCIPLINARY INFORMATION AND OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 33 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 DISCIPLINARY INFORMATION In the past, we have entered into certain settlements with our regulators and other third parties and have been the subject of adverse legal and disciplinary events. Below are summaries of certain events that may be material to your decision of whether to retain us for as an investment adviser. You can find other information on our Form ADV Part 1, available at www.adviserinfo.sec.gov.  On March 16, 2020, HSBC Securities entered into a settlement with the SEC concerning HSBC Securities’ 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 HSBC Securities’ 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 HSBC Securities disclosed to all brokerage customers in its Customer Agreement that conflicts of interest between customers and IARs may arise with respect to recurring income HSBC Securities receives. But in separate disclosures to advisory customers, HSBC Securities stated that IARs were compensated based solely on non-financial factors, and not on the fees paid to HSBC Securities. The SEC found that HSBC Securities did consider financial factors in setting IAR’s discretionary bonuses, including the amount of quarterly advisory fees Spectrum and MPA Program clients paid to HSBC Securities, which gave IARs an incentive to generate those fees. The SEC further determined that HSBC Securities 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, HSBC Securities agreed to a censure and to pay a fine of $725,000. HSBC Securities amended its disclosures in March 2018 and was not required to engage in any remediation. Disclosures are under Item 9B “Client Referrals” and “Other Compensation”.  On June 30, 2017, HSBC Securities agreed to a settlement with FINRA regarding allegations 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. HSBC Securities 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 HSBC Securities’ general ledger, certain internal audit records, risk management control records, unusual activity reports and certain policy manuals. The findings also stated that HSBC Securities failed to notify FINRA at least (90) days prior to retaining a vendor to provide electronic storage. HSBC Securities is also alleged to have failed to implement an audit system regarding the inputting of records in electronic storage media. HSBC Securities is alleged to have failed to obtain an attestation from their third-party vendor. Additionally, HSBC Securities failed to establish maintain and enforce written supervisory procedures reasonably designed to achieve compliance with applicable Securities Exchange Commission Rule for record retention requirements. HSBC Securities’ written supervisory procedures failed to specify how the Firm should supervise its compliance with record retention requirements under the rule. On June 30, 2017, without admitting or denying the findings, HSBC Securities agreed to a censure and fine, jointly and severally, of $1,500,000. The Firm also consented to a written plan of how it will undertake a comprehensive review of the adequacy of its policies and procedures. 34 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1  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 U.S. mortgage servicers and includes the following terms: $100 million to be allocated among participating federal and state parties, and $370 million in consumer relief. In addition, the settlement agreement sets forth national mortgage servicing standards to which HSBC U.S. affiliates will adhere. All except $32 million of the settlement is allocable to HSBC Finance Corporation. This matter was settled within the amount reserved. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Broker-Dealer Registration Status HSBC Securities is a full-service broker-dealer and investment adviser. We engage in a full range of primary and secondary securities activity in the U.S. and international markets, including acting as a primary dealer in corporate bonds, U.S. and international equities, and as a broker in futures and options. We are registered with the Securities and Exchange Commission, the Financial Industry Regulatory Authority, and various other regulatory bodies. HSBC Securities acts as an introducing broker for the MPA Program (and other clients and programs), using the clearing and execution facilities of our third- party clearing agent, BNY Pershing, for all securities transactions executed within a client’s account, as discussed above, subject in all cases to best execution obligations and applicable law. HSBC Securities is also registered as a futures commission merchant, and some of our management persons are associated persons of that entity. Material Relationships or Arrangements with Related Persons HSBC Securities has policies and procedures that are reasonably designed to mitigate conflicts of interests and comply with the regulatory requirements in selling securities including Funds. HSBC Securities and/or our management persons have a material relationship with the following related person(s) as follows: AMUS is wholly owned by HSBC USA, Inc. (“HSBC USA”) and is indirectly owned by HSBC Group. HSBC Group is a publicly owned corporation based in London, England and trades on various stock exchanges around the world. AMUS is registered with the SEC as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended (the “Advisers Act”). AMUS is an entity within HSBC Asset Management (“AM”). AM is made up of a group of companies in countries and territories throughout the world that are engaged in investment advisory and portfolio management activities. AMUS has been in business since January 29, 1986. 35 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 AMUS provides investment advice to registered investment companies and other institutions. AMUS is a service provider to the MPA Program and other HSBC Securities advisory programs and earns fees based on assets invested in the programs. In addition, AMUS and its affiliates act as the investment adviser and/or administrator to the proprietary funds included as investments in the MPA Program. Certain HSBC affiliated funds also have sub advisers, not always affiliated with AM that receive fees for providing various services to the funds. Funds outside of the HSBC Fund family are also offered as options in the HSBC Programs and can be advised by investment managers affiliated or unaffiliated with HSBC Securities, who also receive a fee for their investment services. AMUS or affiliates thereof receives compensation (such as mutual fund advisory fees, and other compensation), in addition to a portion of the fee for the MPA Program. In connection with investments in an HSBC affiliated Fund by a retirement account-an IRA or an employee benefit plan subject to ERISA, HSBC Securities will offset any additional compensation it (or an affiliate) receives in connection with such investments by crediting against the account fee an amount that is equal to such additional fees and compensation HSBC Securities (and its affiliates) receive for the applicable billing period with respect to such investment. To the extent HSBC Securities includes AMUS advised funds as the option into which a client’s account could be invested, the receipt of such additional compensation could create a conflict of interest. HSBC Securities’ clients will pay these fees as well as their Program fee as permissible by law. HSBC Securities compensates AMUS and other affiliates for services in the MPA Program. Fees paid by HSBC Securities to AMUS and other affiliates for services rendered are based on assets invested in the MPA Program. As Overlay Manager, HSBC Securities at its discretion as specified in the client agreement has delegated certain activities to an affiliate in exchange for compensation. In addition, HSBC Securities can at its discretion engage an unaffiliated Overlay Manager upon thirty (30) days written notice to the Client. Any unaffiliated third party who acts as Overlay Manager (a "Third Party Overlay Manager") is entitled to receive the benefits to which HSBC Securities, as Overlay Manager, is entitled. Conflicts of Interest HSBC Securities and/or our management persons have a material relationship with the following related person(s) as follows: The only money market fund(s) options available will be money market funds for which AMUS or another affiliate receives compensation related to investment advisory and other services. To the extent that HSBC Securities has discretion to invest the cash in the account (which can be 100% of the account for defensive or temporary purposes), the receipt of such additional compensation by HSBC Securities and its affiliates creates a conflict of interest for HSBC Securities. It should be also understood that the fee for the services provided with respect to the MPA Program, plus any such additional compensation received with respect to the MPA Program (or account investments) can be higher than the fees charged by other advisers for similar advisory services or arrangements. 36 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 The principal business of our Firm is that of a full service broker-dealer. Clients who have MPA Program accounts can also be clients of the broker-dealer. Therefore, clients can have similar securities in their commission-based brokerage accounts as they would have in their MPA account. HSBC Securities is also a registered broker-dealer and executes trades for clients in the MPA Program through BNY Pershing. HSBC Securities recommends to its clients shares in mutual funds to which AMUS serves as investment adviser. HSBC Securities has policies and procedures that are reasonably designed to mitigate conflicts of interests and comply with the regulatory requirements in selling securities including mutual funds. HSBC Securities provides investment advisory and brokerage advice outside of the MPA Program. As a registered broker-dealer with the Financial Industry Regulatory Authority (“FINRA”), HSBC Securities sells securities for a commission outside of the Program and is permitted to receive 12b-1 (distribution) and/or shareholder servicing fees from the sale of mutual funds. All sales charge information is disclosed in the mutual fund prospectus that is provided to the customer. HSBC Securities' practice, as a broker- dealer, of accepting such fees creates a conflict of interest. Representatives are paid a base salary and have an opportunity to receive a discretionary variable pay (as discussed more fully below), which creates conflicts between you, HSBC Securities and your representative. Please see the “Other Compensation” section below for additional information. While HSBC Group maintains global sustainability goals, and a portion of certain variable pay have considerations based on these goals, Investment Adviser Representatives and their Supervisors are not provided with additional incentives to sell ESG Spectrum II. HSBC Securities Representatives are also securities-licensed registered Representatives of HSBC Representative, and in their capacity as registered Representatives engage in the sale of securities-related products and services outside of the MPA Program. Clients are under no obligation to purchase or sell securities products and services through HSBC Securities or to participate in the MPA Program; however, if they choose to do so, clients should be aware that the registered Representative will receive additional compensation as described later in this section, that creates a conflict of interest. Please see the “Other Compensation” section below for additional information. In addition, Representatives at times will be located in Wealth Centers of HBUS (“Wealth Centers”), and clients of HBUS may be investment advisory clients. Clients are informed both verbally and in writing that securities products are not a deposit or other obligation of the bank or any of its affiliates; not FDIC insured or insured by any federal government agency of the United States; not guaranteed by the bank or any of its affiliates; and are subject to investment risk, including possible loss of principal invested. HBUS is a national bank organized and existing under the laws of the United States and a member of the Federal Reserve. HBUS, with which we have entered into agreements, provides certain office space and certain administrative service such as payroll and benefits processing to HSBC. Certain employees and officers of HSBC Securities are officers of HBUS and report into the HSBC North America Holdings Company Committee. 37 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 Conflicts of interest will arise whenever HSBC Securities has an economic or other incentive in its management of our clients’ accounts to act in a way that benefits HSBC Securities or an affiliate. Conflicts will result, for example, when HSBC Securities invests in an investment product, such as a separately managed account managed by a HSBC Securities affiliate. Certain strategies are managed by the HSBC Private Bank Discretionary Investment Management team, which is a division of HBUS. Through this agreement, HSBC Securities pays a portion of the MPA Program fees earned on this strategy to HSBC Bank for services provided. Fees paid by HSBC Securities to HBUS for services rendered are based on assets invested in the MPA Program. When HSBC Securities or an affiliate manages these investments, there is a benefit to HSBC Securities since it increases the overall revenue of HSBC Securities or an affiliate. Depending on the strategy, HBUS or HSBC Securities can recommend an affiliated Program Manager. HSBC Securities has an incentive to recommend, and has an incentive to include, a HBUS-managed strategy because an affiliate of HSBC Securities receives an increase in overall fees when these strategies are chosen by clients. Effective April 1, 2026, for ERISA plans, IRAs and other tax-qualified savings accounts, Affiliated Model Manager Fees, where such managers are available, will either be waived or credited. With respect to a strategy managed by HSBC Securities or an affiliate, the internal review process may not include an applicable universe of third party managed strategies. HSBC Securities manages this conflict through disclosure to clients and by subjecting affiliated Portfolio Managers to a review process as described in Item 6. Our Firm and most Representatives are also licensed insurance agents with HSBC Insurance Agency USA, Inc. and HSBC Securities. In California, HSBC Securities conducts insurance business as HSBC Securities Insurance Services. In this capacity, we can offer advisory clients of our Firm insurance products for which we receive compensation. HSBC Securities has policies and procedures that are reasonably designed to mitigate conflicts of interests and comply with the regulatory requirements in selling insurance products. See the “Other Compensation” section below for additional information. HSBC Securities is a member of the New York Stock Exchange, Financial Industry Regulatory Authority, Securities Investor Protection Corp. HSBC Securities is a sub-distributor of the HSBC Funds. AMUS uses the services of HSBC Securities to facilitate the distribution of HSBC Funds. Affiliates of AMUS receive fees for providing various services to the funds. HSBC Securities selects the Funds in which an account can be invested. HSBC Securities as the distributor will receive compensation from the Funds. This creates a conflict of interest for HSBC Securities, which HSBC Securities seeks to mitigate through disclosure in this Brochure. Certain employees of AMUS and HBUS are registered representatives of HSBC Securities and may hold FINRA and state securities registration. HSBC Securities maintains supervision of such persons. Financial Planning Tools Please note that financial planning tools can be made available to help clients from time to time. Such financial planning tools, and any financial plan generated, are offered at no additional cost. However, products or services selected as a result of an implemented plan will result in a cost to you and fees for HSBC Securities. Please note that you are under no obligation to use any HSBC Securities product or service to execute the financial plan generated by the financial planning tool. Unless we indicate otherwise 38 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 in writing, the financial plan generated does not constitute a solicitation, offer or recommendation to enter into any investment strategy or transaction, or fiduciary investment advice, nor is it intended to be investment advice under the ERISA or Section 4975 of the Internal Revenue Code of 1986, as amended (“the Code”). HSBC Securities does not intend to act in a fiduciary capacity or provide fiduciary investment advice with respect to financial planning tools. Rollovers We provide educational material regarding the options available to customers in qualified plans, but we do not provide any type of advice about a customer’s qualified plan, nor do we make any recommendations or provide advice about whether or not to roll assets out of a plan. HSBC Securities does not provide advice regarding rollover decisions and instead provides only educational material for customers to evaluate and independently consider, and should not be viewed, construed, or relied upon, as investment or fiduciary recommendations or advice under ERISA or the Code. HSBC Securities is not acting as a fiduciary under ERISA or the Code when you decide to engage us in a new service, including with respect to your decision, or the decision of a plan participant, to roll over assets into an IRA which includes traditional, inherited or ROTH IRAs. If a financial plan is generated to a customer with assets in an employer sponsored retirement plan, unless we indicate otherwise in writing, the financial plan is not and is not intended to be fiduciary investment advice under ERISA or the Code with respect to the assets in the employer sponsored retirement plan. about rollovers with us, please refer to our online page If you choose to roll assets out of a plan, we will then, at your request, make recommendations about our services and products for investments that the customer can choose to implement in an HSBC Securities IRA brokerage or advisory account or an IRA annuity. Because we will only be paid for our services if you choose to roll over your plan account to an account at HSBC, we have an incentive to encourage you to rollover to an account with us, which we mitigate through our policies and procedures. For more information at https://www.us.hsbc.com/investments/retirement/ira/ for educational material available. To request relevant acknowledgement forms, please contact your Representative, or call our Wealth Services Deck at 800.662.3343 M-F (8am-6pm) ET. Securities-Backed Line of Credit We do not use leverage as an investment strategy for managed accounts. However, where appropriate, an eligible client, as detailed in the Account Control Agreement and Risk Disclosure statement, may use a Securities-Backed Line of Credit (“SBLOC”), which is a bank line of credit collateralized by the assets of the managed account, as well as other collateral the client may hold at HBUS or HSBC Securities. SBLOC enables clients to take out a loan that is secured by that client’s brokerage and/or advisory portfolio. The maximum amount of the loan depends on the lending value of the client’s portfolio, as specified in the Credit Agreement entered into with by HBUS. Securities-Backed Lending creates additional risks for managed account clients including being subject to a collateral call due to a drop in the account’s value caused by downward market movement, market volatility, investment changes and credit exposure. All these can lead to collateral shortfalls and can cause HBUS, as the lender to ask the managed account client for additional collateral or to sell assets in the account to satisfy the collateral shortfall. HBUS will earn fees and interest on loans secured by managed account assets. A drop in a managed account’s value could cause the account to fall below the minimum required to participate in the managed account program. The account could revert to an unmanaged brokerage account and fail to reach 39 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 its investment goals. Any securities based lending fees and interest are separate and in addition to Program fees. Neither HSBC Securities, its representatives nor its affiliates will act as an investment adviser to a client as to the sale of securities subject to a collateral shortfall or credit line loan demand. We will make these sales in our capacity as a broker-dealer. In addition, as creditors, we and our affiliates can have interests that are averse to you. 9B. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING; REVIEW OF ACCOUNTS; CLIENT REFERRALS AND OTHER COMPENSATION’ AND OTHER FINANCIAL INFORMATION CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING HSBC Securities has adopted a Code of Ethics and Staff Dealing Policies and Procedures that governs employee personal securities transactions ("Code of Ethics"), designates access persons, protects material nonpublic information, and requires employees to comply with all relevant securities laws. The Code of Ethics reflects our belief in the absolute necessity to conduct business at the highest ethical and professional levels. HSBC Securities requires all personnel to report their personal securities accounts to the Compliance Department and requires pre-approval of personal trades in accordance with the Firm’s policies and procedures. Firm personnel are required to submit an annual acknowledgement and certification attesting to their compliance and reporting requirements as well as compliance with all other aspects of our Code of Ethics. The Code of Ethics encourages internal reporting and protects employees who report violations from retaliation. Any violations of the Code of Ethics must be reported to the Chief Compliance Officer or other designated personnel. A copy of our Firm’s Code of Ethics will be furnished upon request. HSBC Securities and its employees at times will buy or sell securities for its or their own account, including the same securities that it recommends to clients, and at the same or different times as client trades in those securities, in accordance with the Code of Ethics. Employees of HSBC Securities, or its advisory affiliates, at times will hold the same or similar securities in their personal accounts that clients may hold in their own portfolios, and from time to time will recommend such securities for purchase or sale in clients’ portfolios in the normal course of business. HSBC Securities has established informational barriers and has adopted various policies and safeguards in order to address conflicts of interest that can arise from such activities. REVIEW OF ACCOUNTS The custodian (or a designee) will provide each client with monthly, but in any event no less frequently than quarterly, account statements detailing the activity within the client's account. The statements will be based on activity provided by the custodian. 40 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 HSBC Securities through its agreement with AMUS or otherwise will monitor the account’s selected Investment Strategy on a periodic basis. The review will focus on several factors, including the following: i. whether the asset allocation models are being managed in accordance with their investment objectives and mandates; and ii. whether the performance of the Investment Strategies is managed according to stated investment objectives and performing in line with expectation. HSBC Securities or a Representative will annually request an in-person or telephonic or video call with a client (or will otherwise meet the regulatory requirements for an annual meeting) in order to determine if the client’s profile remains current and is consistent with the recommended asset allocation. An account review can also follow a change in client’s investment profile, a change in the securities market or a change in other economic conditions. The monthly or quarterly statements provided by the custodian (or a designee) detailing current holdings and account activity are in addition to the quarterly performance reports provided for the client’s account. CLIENT REFERRALS AND OTHER COMPENSATION HSBC Securities does not pay referral fees to non-HSBC Securities employees for the referral of their clients to our Firm. Representative’s Compensation Your Representative (Wealth Relationship Manager) is paid a base salary and has the opportunity to receive a discretionary variable pay generally influenced by demonstrating achievement of certain performance levels, which creates conflicts between you, us and your Representative. We base discretionary variable pay (or individual variable pay decisions) on the Representative’s personal performance measured against established key performance indicators and objectives. When measuring your Representative’s overall performance and ability to meet objectives, we consider factors like gathering assets and income and can include market fluctuation for HSBC Securities. so your Representative has incentives to recommend that you invest assets with us and purchase investments. This also includes deposits and lending products (such as checking, savings, CDs, credit cards and mortgages). Please refer to the Compensation from Other Affiliates for Services Offering Securities and Other Products section below for additional information on Bank related activities. We earn more income from some investment recommendations (such as variable annuities) than others (such as mutual funds), for example, which gives your Representative an incentive to recommend products that will pay us more. When providing brokerage account recommendations, your representatives provide information about the income generated by recommendations of different products and services generally, and point to other materials, like prospectuses for example, that will describe the income we receive more specifically for the products you purchase. Should you also have a brokerage account, please consider that information in connection with your Representative’s compensation and conflicts. The differences in the amount of income and the frequency of the income generated to HSBC Securities has an impact on your Representative’s opportunity to receive discretionary variable pay, and an impact on the amount of any 41 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 potential award. This impact and the conflict exists because income is among the factors considered by us in judging your Representative’s overall performance and ability to meet objectives. Another of the financial factors impacting measurement of performance is the amount of assets gathered, including assets that are brought to us for the first time through your Representative’s recommendations. This impact and the conflict exists because the amount of money brought into and maintained in accounts serviced by that Representative and the growth of the assets in accounts such as yours are also among the factors considered when judging your Representative’s overall performance and ability to meet objectives. Additional factors beyond asset gathering and income are also part of measuring your Representative’s overall performance. We consider factors such as compliance with rules, policies, procedures, code of ethics, industry regulations and standards of conduct. We consider your Representative’s activities in meeting with you and serving your financial needs. We will also assess the quality of your Representative’s sales presentations to you, which assessment can involve contacting you and asking for your feedback. The various factors of our variable pay decisions create conflicts, as your Representative has an interest in establishing a relationship with you, and for recommending our products and services. Certain supervisors in the Wealth Centers, are also eligible for discretionary variable pay affected by your Representative’s recommendations. To the extent that supervisors are reviewing transactions that generate income and assets for the accounts serviced by Representatives, they also have a conflict of interest. We mitigate that conflict through policies and procedures and by measuring the overall performance of those supervisors when considering whether and how much of a potential discretionary variable pay they may receive. Internal Recognition Programs. Your Representative at times will be eligible to participate in HSBC internal recognition programs, consistent with industry practice and regulatory requirements, based upon overall personal performance. That personal performance is based on the factors noted above, including the gathering of assets and income to HSBC Securities, creating further incentives to recommend that you invest with us. We also consider factors, such as compliance with rules, their activities in meeting with customers and fulfilling customers’ financial needs. Title Designations. Along with years of experience, factors such as the income generated by your Representative’s recommendations of products and services, as well as the assets that they gather and maintain for us are considerations when determining if a Representative will be rewarded with honorary titles distinct to their seniority and/or promotions to such distinct titles partially based on their ability to meet internal goals. The opportunity to obtain such an honor further incentivizes your Representative to generate income and gather assets for us through the recommendation of our products and services to you. Other Benefits. Your Representative is eligible to receive other benefits based on the amount of their compensation. Non-Qualified Deferred Compensation Plan (NQDCP) 42 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1  Elective plan for those who are eligible based on their total compensation at or above $250,000.  Eligible participants have the option to elect to defer a portion of their fixed pay or variable pay on a pre-tax basis in the form of an investment account. Deferral on Variable Pay  All HSBC employees are subject to a deferral on a portion of their annual total variable pay that is awarded at or above $100,000.  The standard deferral is granted in the form of Restricted Share Units. The deferrals are under guidelines established by our parent corporations’ deferral plan, which allows them to defer the receipt of compensation. This does not represent additional compensation, and there is no benefit beyond the deferral of income taxes at the employee’s election. This ability to defer income however further incentivizes your Representative to generate income and gather assets and otherwise impact the factors considered in determining his or her discretionary variable pay. Compensation from Other Affiliates for Services Offering Securities and Other Products. Your Representative will also be authorized to act on behalf of HBUS in some cases directly providing deposit accounts and lending products or introducing you to colleagues for additional bank services. For Representatives serving Private Banking customers, these products offered through HSBC Bank may also include certain securities products and services that U.S. national banks may offer directly. In most cases, your Representative will also be authorized to offer additional insurance products through HSBC Insurance Agency (USA) Inc., including traditional life insurance products and certain property and casualty insurance (all for third party insurance carriers). These products and services compete with certain products and services offered through HSBC Securities and can earn more income for our affiliates. Acting for multiple affiliates and being compensated by them presents conflicts because these factors are considered in your Representative’s objectives and measures of overall performance, which in turn impacts his or her opportunity for variable compensation through discretionary variable pay. HSBC Securities reserves the right, at its discretion and without prior notice to change the methods by which it compensates its sales professionals. Representative’s Outside Business Activities. In addition to approved roles acting on behalf of our affiliates, your Representative is permitted, subject to our review and approval, to engage in certain other business activities, other than the provision of brokerage and advisory services through us. Your Representative could also engage in another business including a family owned business, or serving as an officer, director, partner or employee of or consultant to another business organization. These outside business activities can cause conflicts with the brokerage or advisory services your Representative provides to your brokerage account. Because your Representative could receive fees from the outside business, he or she could have an incentive for you to engage or transact through the outside business to earn additional compensation. HSBC Securities has policies and procedures as well as our Code of Conduct to mitigate these conflicts. 43 DB1/ 165429923.6  HSBC Securities (USA) Inc. - Form ADV Part 2A-Appendix 1 Gifts, Gratuities, Entertainment and Non-Monetary Compensation: From time to time, HSBC or its employees will, as is generally consistent with customary industry practice and in accordance with HSBC’s policies and procedures, receive nonmonetary compensation (other than cash or cash equivalents), such as promotional items (e.g., coffee mugs, calendars or gift baskets), meals, entertainment (e.g., tickets to sporting events) and access to certain industry related conferences, from individuals or institutions (including investment sponsors) with whom they transact business or with whom they may engage in business dealings on behalf of clients. In addition to the receipt of gifts by HSBC or its employees, HSBC or its employees may also engage in providing such gifts, meals and entertainment which may also generate a conflict of interest to the extent they create an incentive for the recipient or beneficiary to use, recommend, offer or include products or services of HSBC Securities. The giving and receipt of gifts and other benefits are subject to limitations under internal HSBC Securities policies and procedures. Product Provider Payments and Conferences: From time to time, HSBC Securities (and its affiliates) will receive marketing and training support payments, conference subsidies, and other types of financial compensation and incentives from mutual fund companies and other product providers, broker-dealers and other vendors to support the sale of their products and services to our clients, including our ERISA plan clients. Note that the level of vendor support or other payments is not dependent on or related to the level of assets invested in or with the products or services of the particular vendor, but the receipt of these payments presents HSBC Securities with a conflict of interest in recommending these parties’ services and products to clients. HSBC Securities deals with that conflict through disclosure in this Brochure. HSBC Securities generally provides securities execution and related brokerage services using the clearing and execution facilities of BNY Pershing as detailed above. Each SMA Manager in the SMA Program has the discretion to select broker-dealers to execute trades for MPA and is responsible for executing MPA trades in a manner consistent with its obligation to obtain best execution, and clients are encouraged to review each SMA Manager’s Firm Brochure regarding its brokerage practices. FINANCIAL INFORMATION HSBC Securities does not require, nor do we solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we have not included a balance sheet for our most recent fiscal year. There are no financial commitments to likely impair our ability to meet contractual obligations to our clients, and we have not been the subject of a bankruptcy petition at any time during the past ten years. ADDITIONAL INFORMATION Assets Under Management As of December 31, 2024, the MPA Separately Managed Account Program has approximately $270 million dollars in non-discretionary assets under management. The MPA UMA Account Program has approximately $189 million dollars in non-discretionary assets under management. 44 DB1/ 165429923.6