HSBC Holdings plc Information Request Form

Company: HSBC Holdings plc

Ticker: (NYSE) HSBC

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Certification of Plaintiff Pursuant to Federal Securities Laws

I, duly certify and say, as to the claims asserted under the federal securities laws, that:

1. I have reviewed a complaint filed in the action.

2. I did not purchase the security that is the subject of this action at the direction of plaintiff's counsel or in order to participate in this action.

3. I am willing to serve as a representative party on behalf of the class, including providing testimony at deposition and trial, if necessary.

4. My transaction(s) in HSBC Holdings plc which are the subject of this litigation during the class period set forth in the complaint are set forth in the chart attached hereto.

5. Within the last 3 years,

I have not sought to serve nor have I served as a class representative in any federal securities fraud case.
I have sought to serve as a class representative in

6. I will not accept any payment for serving as a representative party on behalf of the class beyond the Plaintiff's pro rata share of any recovery, except as ordered or approved by the court, including any award for reasonable costs and expenses (including lost wages) directly relating to the representation of the class.

Are you US Citizen?

Yes. I certify under penalty of perjury that the foregoing is true and correct. Executed this
No. I certify under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this

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Signed pursuant to California Civil Code Section 1633.1, et seq. - and the Uniform Electronic Transactions Act as adopted by the various states and territories of the United States.

By your signature above, you confirm that have retained Levi & Korsinsky, LLP to represent you and the shareholder class as a lead plaintiff in the pending class action against HSBC Holdings plc. This representation will be on a contingency basis, meaning that Levi & Korsinsky will advance all expenses in the litigation and will only seek compensation and/or reimbursement of expenses if the firm obtains a recovery. Regardless of the result, we will never ask you to directly pay for any attorneys’ fees, expenses, or costs. Should we obtain a favorable result, we may ask the court to award us compensation and reimbursement of expenses to be paid by the defendants or as a portion of any class recovery. In exchange for our representation, you agree to cooperate as our client by providing, for example, relevant documents and deposition testimony, if necessary. During the course of this litigation, we may employ and/or work with other law firms, experts, and third-parties to successfully prosecute this action. If you are not appointed as the lead plaintiff or Levi & Korsinsky is not appointed as lead counsel, we will notify you of such decision at which time this representation will end unless otherwise extended by you and the firm. We look forward to working with you towards a successful resolution of this action.

I have reviewed the complaint linked in paragraph 1

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Thank you for completing your submission. If our attorneys find you are a viable candidate for lead plaintiff they will reach out regarding the next steps.

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Investigation Details

On September 20, BuzzFeed News and the International Consortium of Investigative Journalists (ICIJ) published the FinCEN Files, a comprehensive investigation of global financial institutions involving “more than 400 reporters in 88 countries”. The FinCEN Files investigation purportedly “reveal[s] how some of the world’s biggest banks have facilitated the work of notorious terrorists, drug cartels, and despots” and centers around more than 2,100 suspicious activity reports (“SARs”) submitted to the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”). Banks and other financial institutions submit SARs when they observe transactions that suggest money laundering or other illegal activity, and while these reports can support investigations and intelligence gathering, they are not by themselves evidence of a crime. The FinCen Files included SARs filed by nearly 90 financial institutions.

According to the FinCEN Files investigation, “HSBC’s Hong Kong branch allowed WCM777, a Ponzi scheme, to move more than $15 million even as the business was being barred from operating in three states. Authorities say the scam stole at least $80 million from investors, mainly Latino and Asian immigrants, and the company’s owner used the looted funds to buy two golf courses, a 7,000-square-foot mansion, a 39.8-carat diamond, and mining rights in Sierra Leone.”

Following these allegations, on September 21, 2020, shares of HSBC fell by more than 6.5% in intraday trading, significantly damaging shareholders.