HSBC Securities (USA) Inc. (“HSI”, or the “Firm” or “We”) has been in business as an investment adviser registered with the U.S. Securities and Exchange Commission since 2005. HSI is also a broker-dealer which was originally formed in December 1969 under a predecessor name. The Firm 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 is the sponsor of 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”). MPA is designed to assist clients, including individuals, retirement accounts, and institutions, with their investment needs based on financial objectives, time horizon and risk tolerance. Through the MPA Program, HSI will facilitate access to professional asset management and other services and third party investment managers for a single “wrap” fee. 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. HSI has entered into an agreement with HSBC Global Asset Management (USA) Inc. (“AMUS”) to perform certain services, for compensation, in the MPA Program. Additionally, HSI has entered into an agreement with HSBC Bank (USA) N.A., to perform certain services, for compensation, in the MPA Program. In this Brochure we use the following terms to refer to the investment managers in the MPA Program:  Model Manager (UMA option only) – an investment manager who provides model portfolios consisting of individual securities to HSI. Model Managers do not have discretion over a client’s account.  SMA Manager (SMA option only) – an investment manager who invests client accounts in individual securities. SMA Managers have discretion over a client’s account.  Overlay Manager (UMA option only) – HSI as the Overlay Manager implements a Model Manager’s recommendations in client accounts. HSI has delegated certain activities to an affiliate and a third party.  Investment Strategy – refers to all investment vehicles used including mutual funds, ETFs, Models and SMAs. Oversight HSI, 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 HSI and consists of members and invitees who are employees of HSI and AMUS. Employees of AMUS have no authority to make decisions or otherwise influence approvals of the Committee. Services HSI 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 investment advice, 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. HSI 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 meeting with clients to discuss the account and any changes to the client’s investment objectives or reasonable investment restrictions. Pursuant to an intercompany agreement, AMUS provides (i) advice as to proposed asset allocations, (ii) advice on investment strategies in the MPA Program and (iii) various operational services. HSI compensates AMUS for these services. In addition, some strategies available in the programs are managed under an intercompany agreement with HSBC Bank USA, N.A. (HBUS). Please note that financial planning tools may 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 HSI. Please note that you are under no obligation to use any HSI product or service to execute the financial plan generated by the financial planning tool. The financial plan generated does not constitute a solicitation, offer or recommendation to enter into any investment strategy or transaction, 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”). HSI does not intend to act in a fiduciary capacity or provide fiduciary investment advice. 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 about whether or not to roll over a plan. HSI 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. HSI 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. If a financial plan is generated to a customer, who has decided to make a rollover, the financial plan is not and is not intended to be fiduciary investment advice under ERISA or the Code. If you choose to roll over from 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. HSI contracts with HSBC’s Global Manager Selection – Funds & ETFs team (referred to as “GMS”) and HSBC Alternative Investments Limited (HAIL), to research and approve investment strategies that are aligned with the asset classes offered within the MPA Program. HSI makes the final selection of investment strategies to be used. HSBC Alternative Investments Limited (HAIL) provides certain services for the Programs related to alternative funds effective on or about April 3, 2023. HSI 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”) and MPA, its proprietary investment advisory offerings. Accordingly, HSI offers a limited range of investment advisory solutions available to meet certain client’s particular circumstances. Spectrum, Spectrum II and Offshore Spectrum make available access to the services of an Investment Adviser Representative (“Representative”) who is available to discuss updates in the client’s financial situation and handle account updates and changes. General and specific disclosures for the Spectrum and Spectrum II program offerings are covered in separate Form ADV Part 2A and Appendixes 1. 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 Program offers managed funds and Exchange Traded Funds (ETFs) (collectively “Funds”).  The Spectrum programs are described in a separate brochure. Reinvestment/Distribution Models 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 used for their account. Clients should reach out their Representative for more information. Please note, the payment of Distributions to the client can affect the performance of the account. 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 exchange traded funds and individual securities, any dividends and interest 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. Clients should consider legal and/or tax implications when considering their options regarding Distributions and consult with their attorney or tax advisor. Comparison of SMA Option to UMA Option SMA Option In the SMA Option, a client’s assets are managed in a single strategy or “sleeve.” An SMA Manager will invest a client’s account in individual securities. The SMA Manager has discretion over the client’s account. UMA Option In the UMA Program, a client’s assets are managed using several strategies, or sleeves. Each sleeve will be invested in mutual funds, ETFs, or individual securities recommended by a Model Manager. Model Managers do not have discretion over a client’s account. HSI, as the Overlay Manager in the UMA Program, has discretion over a client’s account and implements the recommendations from Model Managers. 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, for any reason it deems appropriate, including, without limitation, to respond to general market or macroeconomic circumstances, or to rebalance the assets periodically to restore the original allocation percentages or target weights. 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, HSI is authorized to institute a mandatory blackout period, during which trading in the account can be limited or suspended. As a service provider to HSI, AMUS oversees the asset allocations used in MPA and provides the subject matter expertise and administrative resources to support the MPA Program. AMUS collaborates with various HSBC Global Asset Management 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 HSI a change in the tactical asset allocation, including macroeconomic analyses, market trends, valuation of asset classes and outlook for asset classes. This means that HSBC Securities, at its discretion, can change the target asset allocation periodically based upon AMUS’s advice. HSI chooses mutual funds, SMA Managers, Model Managers and ETFs available in the MPA Program, using a process involving quantitative and qualitative factors provided by GMS to determine how well the investment strategy represents its asset class. The 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. Mutual 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 (USA) Inc. 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 investment portfolio. 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 Option the client can make adjustments within certain parameters to the asset allocation targets. Client assets will be invested in accordance with a mix of investment strategies using multiple Model Managers (in the UMA Option) or in a single investment strategy (in the SMA Option). The client’s Representative will consult with the client periodically, but not less than annually, by requesting an in-person or telephonic 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 Options HSI will recommend an asset allocation and a menu of recommended investment strategies in each 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 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. HSI acts as Overlay Manager to provide portfolio implementation and coordination services for the client’s account. HSI has delegated certain activities to an affiliate and a third party. In addition, HSI may at its discretion engage an unaffiliated Overlay Manager upon thirty (30) days written notice to the client. Client adjustments to recommended asset allocation, investment strategies, investment restrictions and preferences may 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 UMA 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. 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. Services Provided by Pershing® LLC (“Pershing”) In support of the MPA 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. Pershing’s affiliate, Lockwood Advisors, Inc. (“Lockwood”) enters into agreements with the SMA Managers in the MPA Program. Pershing effects the purchase and/or sale of securities in a Client UMA sleeve after the Overlay Manager updates a model. Pershing also invests new sleeves or rebalances existing sleeves in accordance with the selected Model Portfolio. Proxy Voting HSI is authorized to vote proxies for the securities held in MPA Program accounts. For the single-sleeve SMA accounts, HSI has delegated this authority to the MPA SMA Managers. For the multi-sleeve UMA accounts, a third party voting service, Institutional Shareholder Services (“ISS”), acts as an independent voting agent on behalf of HSI. ISS provides proxy analysis and voting recommendations, manages the operational process, and votes proxies based on HSBC’s guidelines. If there is a conflict or need for clarification ISS refers the proxy to AMUS, which will review it as part of the services that AMUS provides to the MPA program. AMUS will use any research provided by ISS in rendering its decision and submitting the proxy vote. 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 HSI in writing. HSI is not liable if the client does not receive proxies in sufficient time to vote them. Custody and Reporting HSI or another financial intermediary serves as custodian for accounts. Currently, HSI has entered into an agreement with Pershing® LLC (“Pershing”) to act as the custodian for the MPA Program. Pershing is located at One Pershing Plaza, Jersey City, New Jersey 07399. 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. 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. HSI from time to time comes into possession of the client assets. As such, on an annual basis, HSI 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 strategy, HSI 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. The allocation to restricted securities in MPA UMA separately managed account models will be prorated across the other non-restricted securities in a model. Discretionary Authority: SMA HSI's discretionary authority is limited to evaluating and monitoring the SMA Managers responsible for managing the assets in a client’s account. Neither HSI nor AMUS has responsibility or liability for the individual investment decisions of any SMA Manager. The client will designate SMA Managers who will have investment discretion over their 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 HSI and accepted by the SMA Manager(s). Discretionary Authority: UMA HSI acts as Overlay Manager to provide portfolio implementation and coordination services for the Account. HSI has delegated certain activities to an affiliate and a third party. In addition, HSI may at its discretion, engage an unaffiliated Overlay Manager upon thirty (30) days written notice to the client. HSI’s discretionary authority is limited to establishing and rebalancing the asset allocation; evaluating, selecting and monitoring the Model Managers, investment strategies and coordinating investment restrictions; and, if selected, performing tax optimization in each UMA account. HSI has no responsibility or liability for the individual recommendations of any Model Manager or the investment manager of any mutual fund or ETF. 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 Firm Brochure regarding its brokerage practices. SMA Managers will generate trade recommendations and orders through a variety of methods and transmit those orders to HSI’s designated trading entity at Pershing. SMA Managers will seek to execute securities purchases and sales with or through Pershing, and can also execute fixed income trades with or through Pershing but rarely do. Clients authorize and direct all transactions in their account, except as provided below, to be effected by or through Pershing. See the Trading Away section below for additional information. HSI generally provides securities execution and related brokerage services using 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 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 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 fee. 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 however is generally minimal. 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 Program Fee. The trading costs may include commissions, markups, mark downs or “spreads” paid to market makers in addition to the Program Fee. They will be embedded in the price of the security and not shown on a confirmation or statement. 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 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 SMA Option, and Pershing places trades in the UMA Option. Please refer to the SMA Manager’s Firm Brochure for its trading practices. HSI 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, Pershing, for all securities transactions executed within a client’s account, subject in all cases to best execution obligations and applicable law. It is HSI’s policy that the Firm 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, HSI will engage in a principal or cross trade to unwind the constituent parts of the Structured Products. HSI as a broker-dealer at times will receive incidental compensation for liquidating Structured Products, however, the Wealth Management division of HSI does not receive any compensation on the early redemption of Structured Products. HSI as an investment adviser does not receive any compensation when a client sells a Structured Product to fund its managed account. Termination The client agreement can be terminated by either party by written notice to the other party. The notice period is found in the account agreement. Account termination will not affect: (i) the validity of any action taken previously by HSI 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 Fees are charged quarterly in advance. 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 to deduct HSI’s and AMUS’s or HBUS’s fees directly from the client’s account. HSI’s fee covers all advisory, administrative, custodial and brokerage services, under the Program except that HSI’s 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 HSI brokerage account (See HSI brokerage fee schedule, available from HSI 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. 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 HSI’s 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 mutual funds and ETFs made available through the MPA Program include both funds advised by non- HSBC investment companies (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 MPA Programs are the proprietary money market funds. HSI pays a portion of the MPA Program fees to the Program’s service providers. In addition to Program fees, clients pay their share of a mutual fund’s or ETF’s fees and expenses, which include 12b-1 (distribution) fees, management fees, administrative fees, operating costs, and all other asset-based costs. For information regarding the structure, fees, and risks associated with investing in ETFs, see the SEC’s Investor Bulletin on ETFs: https://www.sec.gov/servlet/sec/investor/alerts/etfs.pdf In the MPA Program, HSI does not credit its representatives with any 12b-1 fees HSI 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 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 9B “Material Relationships or Arrangements with Related Persons” and “Other Compensation” sections for additional information. The current MPA Program fee schedules for SMA and UMA are: SMA 1. Standard Fee Schedule Model: All Fixed Income All Equity Total Portfolio Assets Under Management: Fee rate per (annum) on assets1 L1 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 assetsL1 First $5,000,000 0.50% Next $5,000,000 0.375% Over $10,000,000 0.25% UMA Standard Fee Schedule for accounts opened on or after November 10, 2014: Model: Conservative Moderately Conservative Moderate Moderately Aggressive Aggressive 1 L1 - Fiduciaries of ERISA and Tax Qualified Plans should refer to Section 3 of the advisory agreement for a discussion of certain credits applicable in the event investments are made in affiliated mutual funds. Total Portfolio Assets Under Management: Fee rate (per annum) on assetsL1 First $500,000 1.55% 1.60% 1.70% 2.15% 2.50% Next $500,000 1.25% 1.30% 1.35% 1.70% 2.00% Over $1,000,000 0.90% 0.95% 1.00% 1.30% 1.50% The above referenced fee schedule applies to new clients in the MPA Program(s). Accounts opened in the past were opened under a different fee schedule. Fees are generally negotiable. HSI in its sole discretion can discount the MPA Program Fee. Negotiated fees are subject to review and adjustment. Certain qualifying related accounts participating in the managed account programs are entitled to discounted fees. To determine if a client's related account is eligible for a discount, clients should contact their Representative. Comparison Cost of Service The MPA Program 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 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. HSI 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 may be costly or inappropriate to fund an MPA account in this manner. An ACH (automated clearing house) transaction is a bank transfer that occurs between banks at your direction and authorization. ACH transfers to/from your MPA Account can only be made to/from your HSBC Bank account. Please note there are limits to the amount of money that you can transfer in from your HSBC Bank account. As these limits are subject to change, please contact your Representative for additional information.