December 20, 2018

BY EDGAR

Ms. Cecilia Blye, Chief

Office of Global Security Risk

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

United States

Re: HSBC Holdings plc (“HSBC”)
Form 20-F for Fiscal Year Ended December 31, 2017
Filed February 20, 2018
File No. 001-14930

Dear Ms. Blye:

On behalf of our client HSBC, I write to request an extension of time to respond to your comment letter (the “Comment Letter”) dated December 18, 2018, relating to the above- referenced filing. The staff requested a response within 10 business days of the date of the Comment Letter. Due to the timing of the Comment Letter and the nature and extent of the information you have requested, HSBC respectfully requests an additional 10 business days in which to respond to the Comment Letter.

Please do not hesitate to contact me if you have any questions or if I can be of assistance at this time. You can reach me in London at +44 20 7614 2230.

Yours sincerely,

/s/ David I. Gottlieb

David I. Gottlieb

cc:	Mr. Pradip Bhaumik, Securities and Exchange Commission
	Mr. Ewen Stevenson, HSBC Holdings plc Mr. Gavin Francis, HSBC Holdings plc