| The Securities and Exchange Surveillance Commission (SESC) conducted 
                the inspection of HSBC Securities Japan limited Tokyo branch (HSBC) 
                based on the provisions of the Securities and Exchange Law (SEL) 
                and found legal violations described below.
 The SESC sent recommendation to the Minister of Finance to take 
                disciplinary action against HSBC pursuant to Article 19 1) of Ministry of Finance Establishment 
                Law on May 26, 1998. I. Bucketing and Counter Bucketing 1) On August 5, 1997, HSBC received buy order of 77 issues (a customer had requested the director of Japanese Equities Trading 
                  Department who was in charge of placing orders to place market 
                  orders at closing and get them executed at closing price, and 
                  if it seemed difficult, try to get it executed at the price 
                  as close to the final execution price as possible) and placed 
                  them but 9 issues out of them was not executed. However, to 
                  meet the customer's request, the director of equities department 
                  of HSBC informed the customer that all the orders had been traded 
                  at the final execution price of that day, and on the next day 
                  he bought the shares on the company's account for the delivery 
                  to the customer. (Violation of SEL Article 47 applied in Law on Foreign Securities 
                  Firms (LFSF) Article 171) and SEL Article 129 1)) OnAugust7, 1997 HSBC received buy orders of over the counter 
                  stock from a customer. The director who had placed the order 
                  informed the customer by mistake that 7,000 shares was traded 
                  although in fact only 6,000 had been executed. On the following 
                  day, he found that mistake. However, instead of receiving another 
                  order from the customer and placing it, he bought 1,000 shares 
                  on the company's account for the delivery to the cumtomer on 
                  August 11, 1997. (Violation of SEL Article 47 applied in LFSF 
                  Article 171))ailing to submit reports or submitting reports containing false statements 
                  In are sult of execution of buy order of 77 issues mentioned inh1), 
                  the director of Japanese Equities Trading Department who was 
                  in charge of placing the orders found that the execution price 
                  of 7 issues of them was not the same as the final execution price. Therefore, to meet the customer's request, the director 
                  informed the customer that the 7 issues had been also executed 
                  at the final execution price respectively and delivered them 
                  to the customer.
 2) As for 12 discretionary orders received from corporate customers 
                  from January 1997 to February 1998, in order to make the average 
                  of execution price of them close to the average of all transactions 
                  on the stock exchange on that day or by other reasons, the director 
                  informed on his own decision the customer of the price which 
                  was different from the real execution price and delivered them. 3) On September 24, 1997, though there was no untrue statement 
                  in an original report which an employee submitted to the customer 
                  , after submitting the report, he found that he informed the 
                  customer of wrong contents of transaction by phone. He did not 
                  want the customer to know his mistake. In this reason, after 
                  getting understanding of head of equities sales, he exchanged 
                  the original report with false one. 4) As for 40 orders received from customers from January 1997 
                  to February 1998, employees informed the customers of wrong 
                  contents of transaction and put the wrong data into the in-house 
                  computer system. Though they had found the mistakes the following 
                  day, they did not dare to correct the errors on the director 
                  's decision and delivered them to customers with the price different 
                  from the execution price. As mentioned above, as for 1), 2), 3) HSBC with involvement of 
                the director of Japanese Equities Trading Department or other 
                employees put the price which was different from the real execution 
                price into the in-house cumputer deliberately. As a result of 
                this, the company submitted reports containing false statements 
                based on these wrong data. As for 4), even after noticing these mistakes, HSBC did not dare 
                to resubmit true reports to customers for correcting the errors. (Violation of LFSF Article 37 3) and SEL Article 48 applied in 
                LFSF Article 171)) |