HSI has been in business as an investment adviser registered with the SEC since 2005. HSI is also a broker- dealer, which was originally formed in December 1969 under a predecessor name. HSI is a Delaware corporation headquartered in New York City. HSI is also a wholly-owned subsidiary of HSBC Markets (USA) Inc. and an indirect wholly-owned subsidiary of HSBC Holdings plc. HSI 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”). HSI 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”). The Firm also offers the Wealth Track Program, which is a web-based (digital investment management) program whereby individuals receive online advisory services for which the technology interface (and not advisory services) is provided by a third party, Marstone Inc. Collectively all programs offered by HSI are referred to as “Managed Account Programs.” Clients in the Spectrum, Spectrum II, Offshore Spectrum and MPA programs have an Investment Adviser Representative (“Representative”) who is available to discuss updates in the client’s financial situation and handle account updates and changes. The Wealth Track Program does not make available the services of a Representative; however, client support is available by telephone through the Wealth Services Desk which can be contacted at 800-662- 3343. General and specific disclosures for the MPA and Wealth Track program offerings are covered in separate Brochures. The documents for MPA can be found in the following website: https://www.us.hsbc.com/investments/products/asset-allocation/. Information on Wealth Track can be found in the following website: https://www.us.hsbc.com/investments/online-investing/wealth-track/. HSI does not offer any non-proprietary or third party advisory programs. 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. HSI 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. 2929 Walden Ave Depew, NY 14043 ATTN: Wealth Services 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, HSI 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. 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 HSI or its delegate recommends a Fund for removal from the Spectrum Program, clients will be notified of the recommendation in their statement or via a mailing and indicating that another fund will be purchased as the replacement fund if the client does not select an alternative by the deadline indicated. Clients are instructed to discuss their options with their Representative upon receipt of the notice. 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. 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 payment of the Distributions directly to the client may affect the performance of the Account. 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 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. HSI 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 HSI 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. Corporate Partner Models HSI also offers models specifically designed for corporate partner firms, and the asset allocation and fulfillment options for these programs are customized to meet the requirements of the respective firms. Only principals, partners and directors of the corporate partner firms may invest in these models. If additional information is needed, please consult your Representative. Environmental Social Governance (ESG) Funds HSBC Securities (USA) Inc. makes available Environmental Social Governance (ESG) funds for selection within the Programs. Each third party 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. HSI through Global Manager Selection – Funds & ETFs (“GMS”) undertakes due diligence when selecting third-party managers. However, HSI relies on the ESG measurement criteria reported by third party fund managers, and HSI does not conduct its own due diligence on a manager’s ESG measurement 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. Please see additional disclosure below for ESG Funds in Item 8 and Item10. Spectrum II and Spectrum II Environmental Social Governance (ESG) Models Both referred to as the Spectrum II Program(s) 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), HSI 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. HSBC Securities (USA) Inc. makes available Environmental Social Governance (ESG) funds for selection within the Programs. Each third party 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. HSI through Global Manager Selection – Funds & ETFs (“GMS”) undertakes due diligence when selecting third-party managers. However, HSI relies on the ESG measurement criteria reported by third party fund managers, and HSI does not conduct its own due diligence on a manager’s ESG measurement 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. The Representative will provide the client with a Proposal containing a list of Funds selected by HSI 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, HSI as the investment adviser will have investment discretion, in accordance with the selected asset allocation model. When HSI or its delegate recommend a Fund for removal from the Spectrum II Program, HSI 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. 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. 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. HSI 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. HSI 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”) and its affiliates (proprietary Funds). The Offshore Spectrum models are made up of Funds that offer investors the ability to align their financial goals with their values. The Representative will provide the client with a Proposal containing a list of Funds selected by HSI and a recommended allocation of assets across various asset classes. 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, HSI as the investment adviser will have investment discretion, in accordance with the selected asset allocation model. When HSI or its delegate recommend a Fund for removal from the Offshore Spectrum Program, HSI 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 only to U.S. citizens and U.S. residents. The firm also offers the Offshore Spectrum Program to Non-Resident Aliens. The key difference between the Programs is that clients choose their Funds in the Spectrum Program and HSI 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”) and its affiliates (proprietary Funds). The only AMUS proprietary Funds in the Programs are money market funds. The balance of the Funds in the Programs are third party Funds. The only money market funds available in the Programs are the AMUS money market funds. Third party Funds used within the Programs are those that have been researched and approved for use by GMS and are aligned with the asset classes offered within the Programs’ models. GMS evaluates third party Funds included in the Programs on a continuous basis. If GMS no longer has conviction in the management of the Fund, GMS can recommend them for removal from 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 HSI’s 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. HSI compensates AMUS for these services. Pursuant to an intercompany agreement, GMS provides HSI with, among other services, approved third party Funds for use in the Programs. HSI compensates GMS for these services. HSI, 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 HSI and consists of members and invitees who are employees of HSI and AMUS. Employees of AMUS will have no authority to make decisions or otherwise influence approvals of the Committee. HSI Client Services HSI 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, HSI provides certain ongoing client services that include the following: 1. Periodic portfolio review and consultation with clients through our Representatives. 2. Handling subsequent transactions (additional investments and redemptions). 3. Responding to client inquiries about their Accounts and issues pertaining to their Accounts. 4. HSI or a Representative will annually request an in-person or telephonic 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. Investment Management HSI 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. HSI 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 advised by third party managers and investments that HSI 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 HSI. Clients can fund their account with cash equivalents or shares of Funds acceptable to HSI 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. HSBC cannot control the timing of the liquidation. For the Offshore Spectrum Program, currency deposits will only be accepted in U.S Dollar Currency. HSI does not take taxes into account in making investment decisions for client Accounts. HSI 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 HSI 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. HSI does not credit its representatives any 12b-1 fees that are earned in the Programs. HSI 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 or target weights. HSI 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. HSI 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. HSI 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. (“HSI”). 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. 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 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. HSBC Bank 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 Programs. The account could revert to an unmanaged brokerage account and fail to reach its investment goals. Any securities based lending fees and interest are separate and in addition to Program fees. Neither HSI, 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 Pershing® LLC (“Pershing”) In support of the Spectrum Program, Pershing provides HSI with a technology solution for providing client proposals, submitting and tracking service orders and maintenance requests, and creating performance and other reports. 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, 2022 the assets under management in the Programs are as follows: The Spectrum Program has approximately $2.16 billion in non-discretionary assets under management, although HSI serves as the sponsor and the advisor of the program’s management. There was approximately $208 million in discretionary assets under management under the Spectrum II program. For the newly launched Offshore Spectrum program there was approximately $1.35 million in discretionary assets. As of December 31, 2022 the assets under management in the other advisory programs are as follows: The MPA SMA Program has approximately $186 million in non-discretionary assets under management, although HSI has discretion over the program management. The MPA UMA Account Program has approximately $167 million in non-discretionary assets under management. The Wealth Track Program has approximately $544 thousand in discretionary assets under management.