SETTLEMENT AGREEMENTSettlement Agreement • September 11th, 2014 • New York
Contract Type FiledSeptember 11th, 2014 JurisdictionThis SETTLEMENT AGREEMENT (the “Agreement”) is entered into as of September 12, 2014, by and between (i) the Federal Housing Finance Agency (“FHFA” or “Plaintiff”), as Conservator of the Federal Home Loan Mortgage Corporation (“Freddie Mac”) and the Federal National Mortgage Association (“Fannie Mae,” and, together with Freddie Mac, “the GSEs”), Freddie Mac, and Fannie Mae, on the one hand, and (ii) HSBC North America Holdings Inc., HSBC USA Inc., HSBC Markets (USA) Inc., HSBC Bank USA, N.A., HSI Asset Securitization Corporation, HSBC Securities (USA) Inc. (“HSBC Securities”), Neal Leonard, Gerard Mattia, Todd White, and Jon Voigtman (collectively, the “HSBC Defendants”), on the other. The HSBC Defendants, together with FHFA and the GSEs, are referred to herein as the “Settling Parties,” with each a “Settling Party.”1