HSBC USA Inc 06 10-K Pt 4/10

HSBC Holdings PLC
05 March 2007


                                                                      Exhibit 14

                  Code of Ethics for Senior Financial Officers
             (As required by Section 406 of the Sarbanes-Oxley Act)

As (Chief Executive Officer) (Chief Financial Officer) (Controller) of HSBC USA
Inc. (the "Company"), I certify that I will adhere to the following principles
and responsibilities, as well as the Company's Statement of Policy and Code of
Ethics:

o     Act with honesty and integrity, and comply with the Company's policies and
      procedures relating to any actual or apparent conflict of interest
      involving personal and professional relationships;

o     Provide other officials and constituents of the Company information that
      is full, fair, accurate, complete, objective, timely and understandable;

o     Comply with rules and regulations of all U.S. and non-U.S. governmental
      entities, as well as other private and public regulatory agencies to which
      the Company is subject;

o     Act at all times in good faith, responsibly, with due care, competence and
      diligence, and without any misrepresentation of material facts;

o     Act objectively, without allowing my independent judgment to be
      subordinated;

o     Respect the confidentiality of Company information, except when authorized
      or otherwise required to make any disclosure, and avoid the use of any
      Company information for personal advantage;

o     Share my knowledge and skills with others to improve the Company's
      communications to its constituents;

o     Promote ethical behavior among employees under my supervision at the
      Company;

o     Promote responsible use of and control over all assets and resources of
      the Company entrusted to me; and

o     Promptly report any violations of the Code of Ethics to the Company's
      General Counsel or Secretary.

Failure to comply with the Code of Ethics may lead to termination of employment.

Date: _________________                 ________________________________________
                                        Signature

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