Writer's Direct Dial: (212) 225-2376

E-Mail: hgrannis@cgsh.com

February 22, 2013

BY EDGAR

Ms. Stephanie J. Ciboroski

Senior Assistant Chief Accountant

Securities and Exchange Commission

100 F Street, NE

Washington, D.C.  20549

United States

Re: HSBC USA Inc. (“HUSI”)

Form 10-K for Fiscal Year Ended December 31, 2011

Form 10-Q for Fiscal Quarter Ended September 30, 2012

File No. 001-07436

Dear Ms. Ciboroski:

I understand from my colleague David Gottlieb that he had the opportunity to speak today with your colleague Rebekah Lindsey in connection with the comment letter that was received on December 31, 2012 relating to HUSI’s Annual Report on Form 10-K for the year ended December 31, 2011 and Quarterly Report on Form 10-Q for the quarter ended September 30, 2012.  As discussed, HUSI intends to respond to the comments by no later than March 15, 2013.

Ms. Stephanie J. Ciboroski, p. 2

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 at (212) 225-2376.

    Yours sincerely,

/s/ Helena K. Grannis

Helena K. Grannis

cc:           Ms. Rebekah Lindsey, Securities and Exchange Commission

Mr. Michael J. Forde, HSBC USA Inc.