Final Approval to Establish HSBC Bank plc US Branch in New York

Chartering, Organization and Structure
Corporate Decision #1379
June 2026
June 18, 2026
Sent by electronic mail only
Michael Roberts
Chief Executive Officer
HSBC Bank plc
8 Canada Square
London E14 5HQ
United Kingdom
Re: Final Conditional Approval for HSBC Bank plc, London, United Kingdom to establish a Federal Branch in New York, New York OCC Control Number: 2025-FBA_InitialEst-341934 Dear Chief Executive Officer Roberts:
This letter constitutes the final approval of the Office of the Comptroller of the Currency (OCC) for HSBC Bank plc (HSBC Bank plc) to establish a federal branch to be located at 66 Hudson Boulevard, New York, New York, with the name “HSBC Bank plc US Branch” (Branch) and to commence operations effective July 1, 2026. HSBC Bank plc represented to the OCC that HSBC Bank plc performed all the necessary steps to commence business as a federal branch. As a federal branch, the Branch generally has the same rights and responsibilities as national banks operating at the same location and is subject to the same laws, regulations, policies, and procedures that apply to national banks. The Branch’s license certificate will be forwarded to you under separate cover. Retain the license certificate as part of your official records as it must be surrendered to the OCC in the event of the liquidation or conversion of the Branch. Capital Equivalency Deposit The Branch’s capital equivalency deposit shall be maintained in an unaffiliated U.S. member bank, consistent with section 4(g) of the International Banking Act of 1978, 12 USC 3102(g), and the OCC’s regulation at 12 CFR 28.15, and pursuant to an agreement in such form and containing such limitations and conditions as prescribed by 12 CFR 28.15. Conditions of Approval This final conditional approval is subject to the following conditions.

1. In addition to compliance with other applicable requirements under United States law,
   HSBC Bank plc and the Branch will make available to the OCC such information on the

2 operations and activities of HSBC Bank plc, the Branch, and any of its affiliates that the OCC deems necessary to determine and enforce compliance by HSBC Bank plc and the Branch with applicable Federal laws, irrespective of whether activities are performed by the Branch in the U.S. or on behalf of the Branch in the United Kingdom or elsewhere. If the disclosure of any required information is prohibited by law or otherwise, HSBC Bank plc and the Branch will cooperate with the OCC including seeking timely waivers of or exemptions from any applicable confidentiality or secrecy restrictions or requirements in order to enable HSBC Bank plc, the Branch, and its affiliates to make such information available to the OCC.
2. HSBC Bank plc and the Branch shall consent to the jurisdiction of the Federal courts of
the U.S. and of all U.S. government agencies, departments, and divisions for the purposes of any and all claims made by, proceedings initiated by, or obligations to, the U.S., the OCC and any other U.S. government agency, department or division, in any matter arising under the National Bank Act, the International Banking Act of 1978, and other applicable Federal banking laws.
3. During its first three (3) years of operations, the Branch (i) shall give the OCC’s Large
and Global Financial Institutions Supervisory Office at least sixty (60) days prior written notice of its intent to significantly deviate or change from its business plan or operations and (ii) shall obtain the OCC’s prior written determination of no objection for any such significant deviation or change from its business plan or operations. The OCC may impose additional conditions it deems appropriate in a written determination of no objection to the Branch’s notice.
4. HSBC Bank plc and the Branch must comply with all understandings and commitments
contained in any approval order issued by the Federal Reserve Board in connection with the proposed Federal Branch. The conditions of this approval are conditions “imposed in writing by a Federal banking agency in connection with any action on any application, notice, or other request” within the meaning of 12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. Procedural Requirements to Establish a Branch HSBC Bank plc and the Branch are reminded that the procedural requirements enclosed as part of the preliminary conditional approval letter dated November 26, 2025, apply once the Branch opens. By opening, HSBC Bank plc agrees to subject the Branch to these requirements of operation. The requirements bear reiteration here.  The Branch must have adequate fidelity insurance coverage.  The Branch must open within eighteen (18) months of the date of this preliminary conditional approval; otherwise, the approval is withdrawn.  The Branch will maintain its accounts, books, and records as prescribed by 12 CFR Part 28 and in such manner as to facilitate the complete and accurate presentation of financial statements and other reports in form and content as required by the OCC.  Management must ensure applicable policies and procedures are established and approved by the board of directors before the Branch commences business.

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 The final, comprehensive implementation plan, including project plans, and continuous quarterly updates must be provided to the Supervisory Office. You are reminded that for a period of two (2) years after the Branch is opened for business, the OCC must review and have no objection to any new executive officers prior to that individual assuming such position. This approval and the activities and communications by OCC employees in connection with the filing, do not constitute a contract, express or implied, or any other obligation binding upon the OCC, the United States, any agency or entity of the United States, or any officer or employee of the United States, and do not affect the ability of the OCC to exercise its supervisory, regulatory, and examination authorities under applicable law and regulations. The OCC’s decision is based on the HSBC Bank plc’s representations, submissions, and information available to the OCC as of this date. The OCC may modify, suspend or rescind this decision if a material change in information on which the OCC relied occurs prior to the date of the transaction to which this decision pertains. The foregoing may not be waived or modified by any employee or agent of the OCC or the United States. The supervisory office for the Branch is the HSBC Supervisory Office of the Large and Global Financial Institutions department. If you have any questions about the supervision of the Branch, contact Examiner-in-Charge Richard Gilbert. For any questions regarding this letter or other chartering, organization and structure matters, please contact the Chartering, Organization, and Structure department. Sincerely, //signed// Jason J. Almonte Deputy Comptroller Chartering, Organization and Structure cc: Andrew Fullum, HSBC Bryan Rowe, HSBC Curtis Tao, HSBC Richard Gilbert, OCC