It is a dark moment for a bank with HSBC's pedigree to have to own up to mis-selling investments to elderly people with only 2 or 3 years to live.
HSBC has tried to distance itself from the poor advice given by its subsidiary, NHFA, saying that the advisers involved were not its employees.
Against that many will point to the fact that NHFA was in HSBC's clutches for nearly five years before the wrongdoing was exposed.
And how painful will this record punishment really be?
One leading financial adviser, Roddy Kohn of Kohn Cougar, has pointed out that the commission earned from selling the investments could exceed the value of the £10.5m fine.
Customers typically paid a 5% up front charge for the investments, followed by 1% a year. Apply that to the £285m worth of care plans NHFA sold and you end up with a tidy sum.