HSBC Bank USA, National Association

FFIEC UBPR User's Guide §IV — Earnings Analysis; OCC Comptroller's Handbook, "Interest Rate Risk"

Year-to-date net interest margin is 1.50%. Compressed margin can reduce core earnings capacity and may indicate asset-yield pressure, funding-cost pressure, interest-rate-risk exposure, or adverse balance-sheet mix.

Provide management's margin analysis, including earning-asset yields, funding costs, repricing gaps, deposit betas, and modeled sensitivity to parallel and nonparallel rate shocks. Document board-approved actions to restore sustainable margin without assuming excessive credit, liquidity, or interest-rate risk.

FASB ASC Topic 326, Financial Instruments - Credit Losses; Interagency Policy Statement on Allowances for Credit Losses (June 2020; revised April 2023) - https://www.federalreserve.gov/frrs/guidance/interagency-policy-statement-on-allowances-for-credit-losses.htm

Allowance for credit losses $489M is measured against nonaccrual loans $718M while nonaccrual loans are measured against total loans and leases $57,114M.

Provide the current CECL methodology, qualitative factor support, loss-rate support, individually evaluated loan analysis, charge-off timing review, and board approval materials showing why the allowance remains appropriate despite low nonaccrual coverage.

12 CFR § 337.6 — Brokered deposits; FDIC Brokered Deposit Rule

Brokered deposits $26,298M against total deposits $137,635M. Elevated brokered-deposit reliance can increase liquidity sensitivity, funding-cost volatility, and supervisory restrictions if capital condition weakens.

Provide a brokered-deposit funding plan with board-approved concentration limits, maturity distribution, rate-sensitivity analysis, and contingency actions if brokered channels become unavailable or restricted. Demonstrate compliance monitoring for 12 CFR § 337.6.

Federal Reserve, Review of the Federal Reserve's Supervision and Regulation of Silicon Valley Bank (April 28, 2023); Joint Agency Statement on Liquidity Risk Management (July 28, 2023); FDIC FIL-84-2008, Liquidity Risk Management

Total deposits $137,635M and insured deposits $46,569M indicate material uninsured-deposit exposure. Uninsured deposits are calculated as total deposits less insured deposits and can be more prone to rapid runoff under stress. Threshold calibration: post-SVB community-bank median uninsured share is 40-55%; this rule fires above 55% because that level requires explicit liquidity contingency planning.

Provide deposit segmentation by customer type, size, relationship tenure, and operational dependency. Update liquidity stress assumptions for uninsured runoff, identify high-confidence contingent funding sources (FHLB, discount window, BTFP collateral pre-positioning), and document board-approved concentration limits and trigger-based escalation.