HSBC Bank Australia Ltd is to "review and remediate" clients who received "potentially deficient" advice on retail structured products between January 2009 and March 2013. This is the main outcome of an enforceable undertaking the bank has entered into with the Australian Securities and Investments Commission.The agreement stems from what ASIC called a "proactive surveillance of HSBC's advice on retail structured products", which uncovered instances where advisers had not tried hard enough to gather information about their clients' personal circumstances.Their advice may not have been appropriate, leading ASIC to conclude HSBC "may have failed to comply with certain obligations" under the Corporations Act and the bank's own Australian financial services licence.HSBC has since reviewed its advice on structured products and lodged a breach notification with ASIC, reporting potential deficiencies in the advice provided to 464 of the 557 clients reviewed.According to an ASIC's statement, the bank is now required to: develop and implement a remediation plan to ensure affected clients are reviewed and remediated in an efficient, honest and fair manner; develop and implement an assessment plan to determine whether the problems identified in the advice on structured products extend to clients who were advised to invest in other types of products between January 2009 and March 2013 and, if so, ensure those other affected clients are also fairly remediated; and appoint an independent expert to report to ASIC on the adequacy of HSBC's review and remediation program.An HSBC spokesperson said the bank was still finalising the terms of the independent review, in line with the processes and timetable outlined in the EU. "The independent expert will be appointed in line with the requirements of the Enforceable Undertaking. We have 15 business days to ask ASIC to approve our choice of independent expert and once they have approved we have ten business days to appoint," he said.The spokesman said that in the intervening three years since the breach notification by HSBC, the bank had made improvements to the incentives, training, and quality control in its Wealth business. "The changes made to the advice processes and controls framework were assessed by an independent expert who identified no material exceptions or further recommendations," the spokesman said."The entire process will be agreed with ASIC and overseen by [the yet to be announced] independent expert. We are confident that the work already undertaken will enable us to fulfil our obligations and assess the clients in line with our undertaking."The bulk of the review was expected to focus on the files that ASIC have specified in their media release, the HSBC spokesman said.