facilitate the future orderly resolution of large financial institutions ; changes in central banks ' policies with respect to the provision or removal of liquidity support to financial markets ; the ability of hsbc holdings plc ( `` hsbc `` and , together with its subsidiaries , `` hsbc group `` ) and hsbc bank usa , national association ( together with its subsidiaries , `` hsbc bank usa `` ) to fulfill the requirements imposed by applicable consent orders or guidance from regulators generally ; the use of us as a conduit for illegal activities without our knowledge by third parties ; the ability to successfully manage our risks ; the possibility of the inadequacy of our data management and policies and processes ; 36 hsbc usa inc. the financial condition of our clients and counterparties and our ability to manage counterparty risk ; concentrations of credit and market risk ; increases in our allowance for credit losses and changes in our assessment of our loan portfolios ; the ability to successfully implement changes to our operational practices as needed and or required from time to time ; damage to our reputation ; the ability to attract or retain key employees , including foreign workers , and customers ; the effects of competition in the markets where we operate including increased competition from non-bank financial services companies , including securities firms ; the effects of operational risks that are inherent in banking operations , including fraudulent and other criminal activities , breakdowns in processes or procedures and systems failure or non-availability ; disruption in our operations from the external environment arising from events such as natural disasters , climate change , outbreaks of contagious disease , acts of war , terrorist attacks , or essential utility outages ; a failure in or a breach of our operation or security systems or infrastructure , or those of third party servicers or vendors , including as a result of cyberattacks ; the ability of third party suppliers , outsourcing vendors , off-shored functions and our affiliates to provide adequate services ; losses suffered due to the negligence , fraud or misconduct of our employees or the negligence , fraud or misconduct on the part of third parties ; a failure in our internal controls ; our ability to meet our funding requirements ; adverse changes to our credit ratings ; financial difficulties or credit downgrades of mortgage bond insurers ; changes in financial accounting standards board ( `` fasb `` ) and international accounting standards board ( `` iasb `` ) accounting standards and their interpretation ; heightened regulatory and government enforcement scrutiny of financial institutions , including in connection with product governance and sales practices , account opening and closing procedures , customer and employee complaints and sales compensation structures related to such practices ; possible negative impact of regulatory investigations and legal proceedings related to alleged foreign exchange manipulation ; changes in the methodology for determining benchmark rates and the implementation of alternative benchmark rates , such as the secured overnight financing rate ( `` sofr `` ) ; heightened regulatory and government enforcement scrutiny of financial markets , with a particular focus on traded asset classes , including foreign exchange ; the possibility of incorrect assumptions or estimates in our financial statements , including reserves related to litigation , deferred tax assets and the fair value of certain assets and liabilities ; model limitations or failure ; the possibility of incorrect interpretations , application of or changes in tax laws to which we and our clients are subject ; the potential for additional financial contribution requirements to the hsbc north america holdings inc. ( `` hsbc north america `` ) pension plan ; unexpected and or increased expenses relating to , among other things , litigation and regulatory matters , remediation efforts , penalties and fines ; and the other risk factors and uncertainties described under item 1a , `` risk factors , `` in this annual report on form 10-k. forward-looking statements are based on our current views and assumptions and speak only as of the date they are made . we undertake no obligation to update any forward-looking statement to reflect subsequent circumstances or events . for more information about factors that could cause actual results to differ materially from those in the forward-looking statements , see item 1a , `` risk factors , `` in this annual report on form 10-k. 37 hsbc usa inc. executive overview hsbc usa is a wholly-owned subsidiary of hsbc north america , which is an indirect wholly-owned subsidiary of hsbc . husi may also be referred to in management 's discussion and analysis of financial condition and results of operations ( `` md & a `` ) as `` we , `` `` us `` or `` our . `` 2020 economic environment the u.s. economy partially rebounded during the second half of 2020 after deteriorating rapidly into recession earlier in the year driven by the covid-19 pandemic which resulted in disruption to business and economic activity as well as to the capital markets . covid-19 's effects in the u.s. and globally have been extreme , and the duration of the pandemic and its ultimate repercussions continue to remain unclear as recently introduced vaccines may not be widely available to the general public for some time and the take-up rate , once available , is uncertain . unprecedented government economic intervention has likely dampened the pandemic 's effects , but at uncertain long-term cost , and additional government support beyond what was enacted in 2020 is currently being considered . story_separator_special_tag in addition , the international swaps and derivatives association updated its benchmark fallback language for new libor-based derivative contracts and established its industry protocol to facilitate the incorporation of the new fallback language into legacy non-cleared derivative contracts . we are adhering to the protocol , which became effective in january 2021. separately , central clearing counterparties are expected to amend their rules no later than the first half of 2021 to incorporate the new fallback language and adhere to the protocol for cleared derivative contracts . our businesses continue to actively develop their capabilities to offer alternative rate products and the supporting processes and systems . during 2020 , we implemented the capabilities to offer sofr-based arm loans in our wealth and personal banking business , sofr-based syndicated loans and real estate bilateral loans in our commercial banking business and sofr-based syndicated loans , bilateral loans and derivatives in our global banking and markets business . additional sofr-based derivative and bilateral loan capabilities are scheduled for implementation in 2021. however , the covid-19 pandemic has impacted the speed at which we are able to develop these capabilities and the readiness of our customers to use alternative rate products . consequently , the sale of libor-based products will continue for longer than initially anticipated . in addition , the covid-19 pandemic has likely affected the pace at which many of our customers will have been preparing to use alternative rate products and , therefore , also to transition their legacy contracts onto replacement rates . the ability of husi and its clients to transition legacy contracts onto replacement rates is dependent on the availability of products that reference replacement rates , including sofr , and on our customers being ready and able to adapt their own processes and systems to accommodate the replacement products . we have finalized pricing and data/workflow requirements related to transitioning legacy contracts onto replacement rates and , during the first quarter of 2021 , will begin to engage our clients to increase awareness , provide alternative products and determine their ability and readiness to transition . we also continue to formulate plans to enable us to transition our libor-based debt and other libor-based debt where we are the payment agent , though execution of these transition plans will , to a certain extent , also depend on the engagement of third party market participants in the transition process . the iba proposal to extend the publication of certain usd libor term rates to june 2023 discussed above will significantly aid in reducing the risks associated with transitioning legacy contracts onto replacement rates . the anticipated longer timeframe for transition may , however , increase potential timing differences between usd libor-based assets and liabilities moving to sofr prior to june 2023. in addition , the exit or transfer of certain derivative contracts as part of our restructuring plan and the sale of substantially all of our libor-linked variable rate debt securities maturing beyond 2021 have led to a reduction in our libor exposures during 2020. we continue to engage with industry participants , the official sector and our clients to support an orderly transition and the mitigation of the risks resulting from the transition . other covid-19 related developments the covid-19 pandemic has significantly disrupted economic activity in many countries , including the united states , and the u.s. government has taken multiple actions to mitigate the magnitude and persistence of the effects of the covid-19 pandemic . the united states has been operating under a presidentially declared national emergency since march 2020. in march 2020 , the coronavirus aid , relief and economic security act ( `` cares act `` ) , which provides financial assistance for businesses and individuals and targeted regulatory relief for financial institutions , was signed into law . in december 2020 , additional covid-19 relief legislation was enacted that extends many of the cares act programs and provides additional financial assistance for businesses and individuals . loan forbearance initiatives the cares act created a forbearance program for federally-backed mortgage loans and provided financial institutions with the option to temporarily suspend certain requirements under u.s. gaap related to troubled debt restructurings ( `` tdr loans `` ) beginning march 1 , 2020. this tdr loan guidance has been extended and can now be applied until the earlier of january 1 , 2022 or 60 days following the termination of the presidentially declared national emergency . during the third quarter of 2020 , we elected to adopt the tdr loan guidance in the cares act and are not applying tdr loan classification to covid-19 related loan modifications in the form of a long-term payment deferral ( for commercial loans all payment modifications , including all payment deferrals ) granted to borrowers that were current ( less than 30 days past due ) as of december 31 , 2019 which otherwise may have been reported as tdr loans . the cares act also prohibits servicers of federally-backed mortgage loans from initiating any foreclosure action on any residential property that is not vacant or abandoned for a period of 60 days . this moratorium has been extended until june 30 , 2021. in addition to these federal measures , some state governments have taken action to require forbearance with respect to certain loans and fees . we 41 hsbc usa inc. are continuing to monitor federal , state and international regulatory developments in relation to covid-19 and their potential impact on our operations . in april 2020 , federal banking regulators issued a revised interagency statement on loan modifications and the reporting for financial institutions working with customers affected by the covid-19 pandemic ( `` interagency statement `` ) . the interagency statement confirmed that covid-19 related short-term loan modifications ( e.g . , payment deferrals of six months or less ) provided to borrowers that were current ( less than 30 days past due ) at the time the relief was granted are

liquidity and capital resources effective liquidity management is defined as ensuring we can meet customer loan requests , customer deposit maturities/withdrawals and other cash commitments efficiently under both normal operating conditions and under unpredictable circumstances of industry or market stress . to achieve this objective , we have guidelines that require sufficient liquidity to cover potential funding requirements and to avoid over-dependence on volatile , less reliable funding markets . guidelines are set for the consolidated balance sheet of hsbc usa to ensure that it is a source of strength for our regulated , deposit-taking banking subsidiary , as well as to address the more limited sources of liquidity available to it as a holding company . similar guidelines are set for hsbc bank usa to ensure that it can meet its liquidity needs in various stress scenarios . cash flow analysis , including stress testing scenarios , forms the basis for liquidity management and contingency funding plans . see `` risk management '' in this md & a for further discussion of our approach towards liquidity and funding risk management , including information regarding the key measures employed to define , monitor and control our liquidity and funding risk . during 2020 , the covid-19 pandemic caused disruption to the financial markets as well as business and economic activity . we continue to actively monitor and control our liquidity and funding risk in accordance with hsbc policy . to date , we have not experienced any significant impact to our liquidity or funding capabilities as a result of this disruption .


 Write a concise suspicious activity report of the following text delimited by triple backquotes. Return your response as a formal report which covers the key points highlighting the location,dates,entity names and account holder information in chronological order of the text.
     ```liquidity and capital resources effective liquidity management is defined as ensuring we can meet customer loan requests , customer deposit maturities/withdrawals and other cash commitments efficiently under both normal operating conditions and under unpredictable circumstances of industry or market stress . to achieve this objective , we have guidelines that require sufficient liquidity to cover potential funding requirements and to avoid over-dependence on volatile , less reliable funding markets . guidelines are set for the consolidated balance sheet of hsbc usa to ensure that it is a source of strength for our regulated , deposit-taking banking subsidiary , as well as to address the more limited sources of liquidity available to it as a holding company . similar guidelines are set for hsbc bank usa to ensure that it can meet its liquidity needs in various stress scenarios . cash flow analysis , including stress testing scenarios , forms the basis for liquidity management and contingency funding plans . see `` risk management '' in this md & a for further discussion of our approach towards liquidity and funding risk management , including information regarding the key measures employed to define , monitor and control our liquidity and funding risk . during 2020 , the covid-19 pandemic caused disruption to the financial markets as well as business and economic activity . we continue to actively monitor and control our liquidity and funding risk in accordance with hsbc policy . to date , we have not experienced any significant impact to our liquidity or funding capabilities as a result of this disruption .
```    
 Suspicious Activity Report : facilitate the future orderly resolution of large financial institutions ; changes in central banks ' policies with respect to the provision or removal of liquidity support to financial markets ; the ability of hsbc holdings plc ( `` hsbc `` and , together with its subsidiaries , `` hsbc group `` ) and hsbc bank usa , national association ( together with its subsidiaries , `` hsbc bank usa `` ) to fulfill the requirements imposed by applicable consent orders or guidance from regulators generally ; the use of us as a conduit for illegal activities without our knowledge by third parties ; the ability to successfully manage our risks ; the possibility of the inadequacy of our data management and policies and processes ; 36 hsbc usa inc. the financial condition of our clients and counterparties and our ability to manage counterparty risk ; concentrations of credit and market risk ; increases in our allowance for credit losses and changes in our assessment of our loan portfolios ; the ability to successfully implement changes to our operational practices as needed and or required from time to time ; damage to our reputation ; the ability to attract or retain key employees , including foreign workers , and customers ; the effects of competition in the markets where we operate including increased competition from non-bank financial services companies , including securities firms ; the effects of operational risks that are inherent in banking operations , including fraudulent and other criminal activities , breakdowns in processes or procedures and systems failure or non-availability ; disruption in our operations from the external environment arising from events such as natural disasters , climate change , outbreaks of contagious disease , acts of war , terrorist attacks , or essential utility outages ; a failure in or a breach of our operation or security systems or infrastructure , or those of third party servicers or vendors , including as a result of cyberattacks ; the ability of third party suppliers , outsourcing vendors , off-shored functions and our affiliates to provide adequate services ; losses suffered due to the negligence , fraud or misconduct of our employees or the negligence , fraud or misconduct on the part of third parties ; a failure in our internal controls ; our ability to meet our funding requirements ; adverse changes to our credit ratings ; financial difficulties or credit downgrades of mortgage bond insurers ; changes in financial accounting standards board ( `` fasb `` ) and international accounting standards board ( `` iasb `` ) accounting standards and their interpretation ; heightened regulatory and government enforcement scrutiny of financial institutions , including in connection with product governance and sales practices , account opening and closing procedures , customer and employee complaints and sales compensation structures related to such practices ; possible negative impact of regulatory investigations and legal proceedings related to alleged foreign exchange manipulation ; changes in the methodology for determining benchmark rates and the implementation of alternative benchmark rates , such as the secured overnight financing rate ( `` sofr `` ) ; heightened regulatory and government enforcement scrutiny of financial markets , with a particular focus on traded asset classes , including foreign exchange ; the possibility of incorrect assumptions or estimates in our financial statements , including reserves related to litigation , deferred tax assets and the fair value of certain assets and liabilities ; model limitations or failure ; the possibility of incorrect interpretations , application of or changes in tax laws to which we and our clients are subject ; the potential for additional financial contribution requirements to the hsbc north america holdings inc. ( `` hsbc north america `` ) pension plan ; unexpected and or increased expenses relating to , among other things , litigation and regulatory matters , remediation efforts , penalties and fines ; and the other risk factors and uncertainties described under item 1a , `` risk factors , `` in this annual report on form 10-k. forward-looking statements are based on our current views and assumptions and speak only as of the date they are made . we undertake no obligation to update any forward-looking statement to reflect subsequent circumstances or events . for more information about factors that could cause actual results to differ materially from those in the forward-looking statements , see item 1a , `` risk factors , `` in this annual report on form 10-k. 37 hsbc usa inc. executive overview hsbc usa is a wholly-owned subsidiary of hsbc north america , which is an indirect wholly-owned subsidiary of hsbc . husi may also be referred to in management 's discussion and analysis of financial condition and results of operations ( `` md & a `` ) as `` we , `` `` us `` or `` our . `` 2020 economic environment the u.s. economy partially rebounded during the second half of 2020 after deteriorating rapidly into recession earlier in the year driven by the covid-19 pandemic which resulted in disruption to business and economic activity as well as to the capital markets . covid-19 's effects in the u.s. and globally have been extreme , and the duration of the pandemic and its ultimate repercussions continue to remain unclear as recently introduced vaccines may not be widely available to the general public for some time and the take-up rate , once available , is uncertain . unprecedented government economic intervention has likely dampened the pandemic 's effects , but at uncertain long-term cost , and additional government support beyond what was enacted in 2020 is currently being considered . story_separator_special_tag in addition , the international swaps and derivatives association updated its benchmark fallback language for new libor-based derivative contracts and established its industry protocol to facilitate the incorporation of the new fallback language into legacy non-cleared derivative contracts . we are adhering to the protocol , which became effective in january 2021. separately , central clearing counterparties are expected to amend their rules no later than the first half of 2021 to incorporate the new fallback language and adhere to the protocol for cleared derivative contracts . our businesses continue to actively develop their capabilities to offer alternative rate products and the supporting processes and systems . during 2020 , we implemented the capabilities to offer sofr-based arm loans in our wealth and personal banking business , sofr-based syndicated loans and real estate bilateral loans in our commercial banking business and sofr-based syndicated loans , bilateral loans and derivatives in our global banking and markets business . additional sofr-based derivative and bilateral loan capabilities are scheduled for implementation in 2021. however , the covid-19 pandemic has impacted the speed at which we are able to develop these capabilities and the readiness of our customers to use alternative rate products . consequently , the sale of libor-based products will continue for longer than initially anticipated . in addition , the covid-19 pandemic has likely affected the pace at which many of our customers will have been preparing to use alternative rate products and , therefore , also to transition their legacy contracts onto replacement rates . the ability of husi and its clients to transition legacy contracts onto replacement rates is dependent on the availability of products that reference replacement rates , including sofr , and on our customers being ready and able to adapt their own processes and systems to accommodate the replacement products . we have finalized pricing and data/workflow requirements related to transitioning legacy contracts onto replacement rates and , during the first quarter of 2021 , will begin to engage our clients to increase awareness , provide alternative products and determine their ability and readiness to transition . we also continue to formulate plans to enable us to transition our libor-based debt and other libor-based debt where we are the payment agent , though execution of these transition plans will , to a certain extent , also depend on the engagement of third party market participants in the transition process . the iba proposal to extend the publication of certain usd libor term rates to june 2023 discussed above will significantly aid in reducing the risks associated with transitioning legacy contracts onto replacement rates . the anticipated longer timeframe for transition may , however , increase potential timing differences between usd libor-based assets and liabilities moving to sofr prior to june 2023. in addition , the exit or transfer of certain derivative contracts as part of our restructuring plan and the sale of substantially all of our libor-linked variable rate debt securities maturing beyond 2021 have led to a reduction in our libor exposures during 2020. we continue to engage with industry participants , the official sector and our clients to support an orderly transition and the mitigation of the risks resulting from the transition . other covid-19 related developments the covid-19 pandemic has significantly disrupted economic activity in many countries , including the united states , and the u.s. government has taken multiple actions to mitigate the magnitude and persistence of the effects of the covid-19 pandemic . the united states has been operating under a presidentially declared national emergency since march 2020. in march 2020 , the coronavirus aid , relief and economic security act ( `` cares act `` ) , which provides financial assistance for businesses and individuals and targeted regulatory relief for financial institutions , was signed into law . in december 2020 , additional covid-19 relief legislation was enacted that extends many of the cares act programs and provides additional financial assistance for businesses and individuals . loan forbearance initiatives the cares act created a forbearance program for federally-backed mortgage loans and provided financial institutions with the option to temporarily suspend certain requirements under u.s. gaap related to troubled debt restructurings ( `` tdr loans `` ) beginning march 1 , 2020. this tdr loan guidance has been extended and can now be applied until the earlier of january 1 , 2022 or 60 days following the termination of the presidentially declared national emergency . during the third quarter of 2020 , we elected to adopt the tdr loan guidance in the cares act and are not applying tdr loan classification to covid-19 related loan modifications in the form of a long-term payment deferral ( for commercial loans all payment modifications , including all payment deferrals ) granted to borrowers that were current ( less than 30 days past due ) as of december 31 , 2019 which otherwise may have been reported as tdr loans . the cares act also prohibits servicers of federally-backed mortgage loans from initiating any foreclosure action on any residential property that is not vacant or abandoned for a period of 60 days . this moratorium has been extended until june 30 , 2021. in addition to these federal measures , some state governments have taken action to require forbearance with respect to certain loans and fees . we 41 hsbc usa inc. are continuing to monitor federal , state and international regulatory developments in relation to covid-19 and their potential impact on our operations . in april 2020 , federal banking regulators issued a revised interagency statement on loan modifications and the reporting for financial institutions working with customers affected by the covid-19 pandemic ( `` interagency statement `` ) . the interagency statement confirmed that covid-19 related short-term loan modifications ( e.g . , payment deferrals of six months or less ) provided to borrowers that were current ( less than 30 days past due ) at the time the relief was granted are

