A. GENERAL DESCRIPTION OF ADVISORY FIRM
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 (“HSBC AM”), which 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.
B. TYPES OF ADVISORY SERVICES
AMUS provides discretionary and non-discretionary advisory services to clients in several major
markets and is a multi-product provider of investment and fund management services. For
institutions, AMUS provides active and tailored portfolio management on a global, regional, asset-
class and country specific basis. AMUS also serves as investment adviser to U.S. registered
investment companies.
C. INVESTMENT STRATEGIES INCLUDE:
Equity: US Equity
Fixed Income: U.S. Fixed Income-Investment Grade and High Yield, Global Credit-Investment
Grade and High Yield and Emerging Markets Fixed Income
Liquidity Cash Management: US Government, US Treasury, USD and Canadian US Dollar Prime
D. AFFILIATE AND SUB-ADVISORY RELATIONSHIPS
AMUS manages international and domestic accounts pursuant to sub-advisory agreements with
affiliated entities. In these relationships, AMUS provides investment advisory services to clients
who have signed an investment advisory agreement with another HSBC Group Company.
Conversely, AMUS can delegate investment management responsibilities, through sub-advisory
agreements, to affiliated companies. AMUS may also delegate investment management
responsibilities, through sub-advisory agreements, to third-party asset managers. The primary
client service relationship is generally maintained in the country where the client is located.
AMUS serves as an investment adviser or sub-adviser for several offshore funds. These offshore
funds 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.
AMUS acts as investment sub-adviser to affiliated investment advisers, which provide
discretionary investment advisory services to certain of its clients as previously noted. AMUS
renders continuous investment advice for the portions of the portfolios for which it is selected as
sub-adviser, and has investment discretion with respect thereto, subject to review and supervision
by the affiliated advisers.
Pursuant to a service level agreement with HSBC Alternative Investments Limited, AMUS
conducts due diligence processes on single manager hedge funds, as well as on funds of hedge
funds.
E. FUNDS
AMUS also serves as investment adviser to a family of SEC registered investment companies (i.e.,
Mutual Funds): the HSBC Funds. Certain of these registered investment companies use a master-
feeder structure. AMUS receives a fee for such services it provides, and all sub-advisers receive
fees for their services, as specified in the Funds’
prospectus.
F. WEALTH PORTFOLIO MANAGEMENT
AMUS oversees the asset allocation models used in the HSBC Spectrum Program (“Spectrum”),
HSBC Spectrum II Program (“Spectrum II”), HSBC Offshore Spectrum Program (“Offshore
Spectrum”), Managed Portfolio Account Program (“MPA”), and WealthTrack, each of which is
described below. AMUS collaborates with various HSBC AM teams to develop Strategic Asset
Allocations (“SAA”) subject to local constraints (e.g., asset classes and risk tolerance bands).
AMUS may also implement Tactical Asset Allocation (“TAA”) views based on both global and
local inputs.
AMUS also conducts research and due diligence on unaffiliated managers based upon both
quantitative and qualitative factors. As part of the qualitative review, AMUS may utilize firm and
strategy pitch books, and conduct portfolio manager and research analyst interviews to assess the
firm, investment staff, investment strategy and process, and portfolio construction. Style analytics,
attribution analysis, risk and performance comparisons against representative benchmarks and
peers may be used as part of the quantitative process. Strategies are reviewed on a periodic basis
with similar criteria described above. AMUS uses other HSBC Group entities to support its
research and due diligence process of thirdparty investment managers.
G. WRAP FEE PROGRAM ADMINISTRATIVE SUPPORT SERVICES
AMUS provides wealth portfolio management support services (“WPM Services”) to HSBC
Securities (USA) Inc. (“HSI”) for Spectrum, Spectrum II, Offshore Spectrum, MPA and
WealthTrack programs. WPM Services include, but are not limited, to developing asset allocation
models, model implementation, fund selection, product, marketing, sales support, finance, and
operational and administrative services.
HSI acts as sponsor and provides portfolio management services for Spectrum, Spectrum II,
Offshore Spectrum, MPA, and WealthTrack. HSI is a member of NYSE/FINRA/SIPC, a
Registered Investment Adviser, a registered Futures Commission Merchant (“FCM”), a wholly-
owned subsidiary of HSBC Markets (USA) Inc., and an indirect wholly-owned subsidiary of
HSBC Group.
H. INVESTMENT RESTRICTIONS
AMUS provides investment advisory services in accordance with the client’s investment
objectives, guidelines and restrictions. Where AMUS is a sub-adviser to a mandate, or an affiliate
is a sub-adviser to an AMUS mandate, the responsibility of the investment manager is generally
limited to the portion of the assets of the account under its management through the sub-advised
agreement. From time to time, investment objectives and guidelines will be amended as agreed by
the client and AMUS.
I. SEED CAPITAL
HSBC Global Asset Management Limited (“AMGB”), an affiliate of AMUS, may from time to
time invest capital in order for HSBC AM affiliates to launch new funds, thereby reducing the
initial costs borne by investors when the funds are small as well as reducing the impact of
transaction and other trading costs, while still providing access to the intended asset class with full
diversification.
J. REGULATORY ASSETS UNDER MANAGEMENT
For the period ending December 31, 2023 AMUS’s regulatory assets under management was
$150,497,338,051of which $142,343,120,709 was managed on a discretionary basis and
$8,154,217,342 was managed on a non-discretionary basis.