Robert W. Baird & Co.. Incorporated

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 

If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/27/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2014040147502
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM AND A
FIRM SUPERVISOR DID NOT REASONABLY SUPERVISE A FORMER REGISTERED REPRESENTATIVE'S MISUSE OF CUSTOMER FUNDS. THE FINDINGS STATED
THAT THE SUPERVISOR, WHO WAS THE REGISTERED REPRESENTATIVE'S DIRECT SUPERVISOR, DID NOT REASONABLY FOLLOW-UP ON RED FLAGS
ASSOCIATED WITH A TRADE CORRECTION REQUEST SUBMITTED BY THE REGISTERED REPRESENTATIVE THAT SHOULD HAVE ALERTED HIM TO THE
REGISTERED REPRESENTATIVE'S MISUSE OF CUSTOMER FUNDS. THE SUPERVISOR ALSO DID NOT FOLLOW CERTAIN OF THE FIRM'S WRITTEN
SUPERVISORY PROCEDURES (WSPS) RELATING TO TRADE CORRECTIONS WHICH, IF FOLLOWED, WOULD HAVE PREVENTED THE REGISTERED
REPRESENTATIVE'S MISUSE OF CUSTOMER FUNDS. THE FINDINGS ALSO STATED THAT IN REVIEWING AND APPROVING THE TRADE CORRECTION
REQUEST, THE SUPERVISOR DID NOT FOLLOW SOME OF THE FIRM'S WSPS. THE FIRM'S WSPS STATED THAT CUSTOMER LOSSES CAUSED BY A
REGISTERED REPRESENTATIVE'S ERROR WOULD BE BORNE BY THE FIRM OR THE REGISTERED REPRESENTATIVE. THE WSPS FURTHER STATED THAT
SUPERVISORS WERE REQUIRED TO OBTAIN AND MAINTAIN DOCUMENTATION AND VERIFICATION OF THE REASONS FOR, AND DETAILS SURROUNDING,
THE TRADE ERRORS AND CORRECTION. CONTRARY TO THESE PROCEDURES, THE SUPERVISOR APPROVED THE TRADE CORRECTION REQUEST WHEN THE
RESULTING CORRECTION ALLOCATED THE TRADE LOSS TO THE CUSTOMER RATHER THAN THE FIRM OR THE REGISTERED REPRESENTATIVE, AND HE DID
NOT REASONABLY DOCUMENT THE REASONS FOR, OR DETAILS SURROUNDING, THE TRADE CORRECTION. AFTER IT BECAME CLEAR THAT THE CUSTOMER
OF THE REGISTERED REPRESENTATIVE DID NOT, IN FACT, AGREE TO PURCHASE THE STOCK AT ABOVE-MARKET VALUE, THE FIRM REIMBURSED THE
CUSTOMER FOR THE LOSS. THE FINDINGS ALSO INCLUDED THAT THE FIRM DID NOT ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING
WSPS, FOR CORRECTING TRADE ERRORS THAT WAS REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,
REGULATIONS AND RULES. IN PARTICULAR, THE FIRM DID NOT IMPLEMENT REASONABLE WSPS, GUIDANCE, OR TRAINING TO ADEQUATELY DESCRIBE
THE SUPERVISORY STEPS ASSOCIATED WITH REVIEWING, APPROVING, AND PROCESSING TRADE CORRECTIONS. THE FIRM'S WSPS FOR HANDLING
TRADE CORRECTIONS WERE VAGUE AND AMBIGUOUS AND FIRM SUPERVISORS DID NOT UNDERSTAND HOW TO INTERPRET OR APPLY THE
PROCEDURES. FINRA FOUND THAT THE FIRM RECOGNIZED, THAT ITS WSPS FOR CORRECTING TRADE ERRORS NEEDED TO BE UPDATED BECAUSE THEY

WERE VAGUE AND AMBIGUOUS. NONETHELESS, THE FIRM DID NOT TAKE ANY STEPS TO ENHANCE THE WSPS OR PROVIDE SUPERVISORS WITH
TRAINING OR GUIDANCE ON THE RELEVANT WSPS UNTIL A YEAR LATER. THE FIRM DID NOT COMPLETE ITS ENHANCEMENT OF ITS WSPS FOR TRADE
CORRECTIONS UNTIL EARLY 2016.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
07/27/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 200,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM WAS CENSURED, FINED $200,000, AND UNDERTAKES TO, WITHIN 30 DAYS OF APPROVAL OF THIS AWC, PROVIDE A WRITTEN
CERTIFICATION TO FINRA THAT THE FIRM'S SYSTEMS, POLICIES AND PROCEDURES FOR CORRECTING TRADE ERRORS ARE REASONABLY
DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND RULES.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/17/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2015047484601
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
TRACE-ELIGIBLE SECURITIZED PRODUCTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTION AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
REPORT THE CORRECT TRADE EXECUTION TIME FOR TRANSACTIONS IN TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)-ELIGIBLE SECURITIZED
PRODUCTS TO TRACE AND FAILED TO SHOW THE CORRECT EXECUTION TIME ON BROKERAGE ORDER MEMORANDA.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
08/17/2016
 Exact
 Explanation

If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 6,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM WAS FINED $6,500.00
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to

the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/26/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2014040421301
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRADED AHEAD
OF CUSTOMER ORDERS AND ALSO EXECUTED CUSTOMER ORDERS OUTSIDE NORMAL MARKET HOURS, CONTRARY TO THE CUSTOMERS' INSTRUCTIONS.
THE FINDINGS STATED THAT THE FIRM ALSO FAILED TO HAVE ADEQUATE SUPERVISION CONCERNING THE TRADING AHEAD RULE, IN THAT ITS WRITTEN
SUPERVISORY PROCEDURES FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORY PROCEDURES
CONCERNING ORDER PROTECTION REQUIREMENTS APPLICABLE TO CUSTOMER ORDERS IN OTC SECURITIES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
09/26/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 12,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM WAS CENSURED, FINED $12,500, PAY RESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $125.54, PLUS INTEREST, AND
UNDERTAKES TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION.
2.
Principal Sanction:
Other Sanctions: 
N/A

3.
Date Initiated (MM/DD/YYYY): 
09/08/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-17532
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
UNSPECIFIED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
SEC IA RELEASE 4526/SEPTEMBER 8, 2016: THE SECURITIES AND EXCHANGE COMMISSION (COMMISSION) DEEMS IT APPROPRIATE THAT CEASE-AND-
DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT),
AGAINST ROBERT W. BAIRD & CO. INCORPORATED. THIS MATTER ARISES FROM THE FIRM'S FAILURE TO ADOPT AND IMPLEMENT ADEQUATE POLICIES
AND PROCEDURES TO TRACK AND DISCLOSE TRADING AWAY PRACTICES BY CERTAIN OF THE SUBADVISORS PARTICIPATING IN THE FIRM'S WRAP FEE
PROGRAMS. THE FIRM, IN ITS ADVISORY CAPACITY, OFFERS ITS ADVISORY CLIENTS THE OPPORTUNITY TO INVEST IN SEPARATELY MANAGED WRAP FEE
PROGRAMS. THROUGH THESE PROGRAMS, THE FIRM'S ADVISORY CLIENTS PAY AN ANNUAL FEE IN EXCHANGE FOR RECEIVING ACCESS TO SELECT
SUBADVISORS AND TRADING STRATEGIES, ADVICE FROM THE FIRM'S FINANCIAL ADVISORS, AND TRADE EXECUTION SERVICES THROUGH THE FIRM AT
NO ADDITIONAL COST. HOWEVER, IF A SUBADVISOR CHOOSES NOT TO DIRECT THE EXECUTION OF PARTICULAR EQUITY TRADES THROUGH THE FIRM
AND THE EXECUTING BROKER CHARGES A COMMISSION OR FEE, THE FIRM'S ADVISORY CLIENTS OFTEN ARE CHARGED ADDITIONAL COMMISSIONS OR
FEES FOR THOSE TRANSACTIONS. THIS PRACTICE IS REFERRED TO AS "TRADING AWAY" AND THESE TYPES OF TRADES ARE FREQUENTLY CALLED
"TRADE AWAYS." HISTORICALLY, THE FIRM DID NOT TRACK OR MONITOR WHICH SUBADVISORS WERE TRADING AWAY FROM THE FIRM, HOW OFTEN
THOSE SUBADVISORS WERE TRADING AWAY, OR THE SPECIFIC COSTS ASSOCIATED WITH THOSE TRADE AWAYS. THE FIRM BEGAN COLLECTING COST
INFORMATION FROM SUBADVISORS WHO WERE TRADING AWAY BUT FAILED TO ADOPT OR IMPLEMENT ANY POLICIES AND PROCEDURES DESIGNED TO
PROVIDE INFORMATION TO THE FIRM'S CLIENTS AND FINANCIAL ADVISORS ABOUT THE AMOUNT OF THE ADDITIONAL COSTS OF TRADING AWAY.
WITHOUT THE AVAILABILITY OF SUCH INFORMATION, THE FIRM'S FINANCIAL ADVISORS COULD NOT SEPARATELY CONSIDER THE COSTS ASSOCIATED
WITH TRADING AWAY PRACTICES IN CONDUCTING THEIR INITIAL AND PERIODIC SUITABILITY ANALYSES FOR ADVISORY CLIENTS IN WRAP FEE
PROGRAMS WHOSE FUNDS WERE MANAGED BY CERTAIN SUBADVISORS. BY FAILING TO ADOPT AND IMPLEMENT SUCH POLICIES AND PROCEDURES,
THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/08/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 250,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM WAS ORDERED TO CEASE AND DESIST, FINED $250,000 AND ORDERED TO COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE
ORDER.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

BAIRD, WITHOUT ADMITTING OR DENYING THE FINDINGS, CONSENTED TO THE SANCTIONS AND FINDINGS OF THE SEC THAT IT VIOLATED SECTION
206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER BY FAILING TO ADOPT AND IMPLEMENT ADEQUATE POLICIES AND PROCEDURES TO
TRACK AND DISCLOSE TRADING AWAY PRACTICES BY CERTAIN OF THE SUBADVISORS PARTICIPATING IN BAIRD'S WRAP FEE PROGRAMS OFFERED
THROUGH ITS PRIVATE WEALTH MANAGEMENT DEPARTMENT. THROUGH THESE PROGRAMS, BAIRD'S ADVISORY CLIENTS PAY AN ANNUAL FEE IN
EXCHANGE FOR RECEIVING ACCESS TO SELECT SUBADVISORS AND TRADING STRATEGIES, ADVICE FROM BAIRD'S FINANCIAL ADVISORS, AND TRADE
EXECUTION SERVICES THROUGH BAIRD AT NO ADDITIONAL COST. HOWEVER, IF A SUBADVISOR CHOOSES NOT TO DIRECT THE EXECUTION OF
PARTICULAR EQUITY TRADES THROUGH BAIRD IN ORDER TO FULFILL ITS BEST EXECUTION OBLIGATION AND THE EXECUTING BROKER CHARGES A
COMMISSION OR FEE, BAIRD'S ADVISORY CLIENTS OFTEN ARE CHARGED ADDITIONAL COMMISSIONS OR FEES FOR THOSE TRANSACTIONS, WHICH IS
OFTEN EMBEDDED IN THE PRICE PAID OR RECEIVED FOR THE SECURITY. THIS PRACTICE IS REFERRED TO AS "TRADING AWAY" AND THESE TYPES OF
TRADES ARE FREQUENTLY CALLED "TRADE AWAYS." BAIRD WAS FOUND TO HAVE FAILED TO ADOPT OR IMPLEMENT POLICIES AND PROCEDURES
DESIGNED TO PROVIDE SPECIFIC INFORMATION TO BAIRD'S CLIENTS AND FINANCIAL ADVISORS ABOUT THE COSTS OF TRADING AWAY. BAIRD AGREED
TO PROVIDE ADDITIONAL DISCLOSURE TO CLIENTS AND REVIEW AND, AS NECESSARY, UPDATE ITS POLICIES AND PROCEDURES.IN RESOLVING THIS
MATTER, THE SEC RECOGNIZED BOTH THE VOLUNTARY REMEDIAL ACTS PROMPTLY UNDERTAKEN BY BAIRD AND ITS COOPERATION WITH THE SEC
STAFF.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:

g
y
y
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
03/11/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19051
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IA RELEASE 40-5148, MARCH 11, 2019: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT
PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED AGAINST ROBERT W. BAIRD & CO. INCORPORATED ("RESPONDENT").
ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF BREACHES OF
FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY THE RESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES
AND THE FEES IT RECEIVED. AT TIMES DURING THE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS
MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS
WERE ELIGIBLE. RESPONDENT RECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS. RESPONDENT FAILED TO DISCLOSE IN ITS FORM
ADV OR OTHERWISE THE CONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE
CLASSES THAT PAY SUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD
SUCH MUTUAL FUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE
ADVISERS ACT.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
03/11/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS AND PREJUDGMENT INTEREST
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS
206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $3,946,606.10 AND PREJUDGMENT INTEREST
OF $212,561.34, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ROBERT W. BAIRD & CO. INCORPORATED (BAIRD), ALONG WITH MANY OTHER INVESTMENT ADVISORY FIRMS, VOLUNTARILY PARTICIPATED IN THE SEC'S
SHARE CLASS SELECTION DISCLOSURE (OR SCSD) INITIATIVE. UNDER THE SCSD INITIATIVE, INVESTMENT ADVISORY FIRMS WERE OFFERED THE
OPPORTUNITY TO VOLUNTARILY SELF-REPORT VIOLATIONS OF THE FEDERAL SECURITIES LAWS RELATING TO MUTUAL FUND SHARE CLASS SELECTION
AND RELATED DISCLOSURE ISSUES AND AGREE TO STANDARDIZED SETTLEMENT TERMS IMPOSED BY THE SEC, INCLUDING RETURNING MONEY TO
AFFECTED INVESTORS. THE CENTRAL ISSUE IDENTIFIED BY THE SEC IN ESTABLISHING THE SCSD INITIATIVE WAS THAT, IN MANY CASES, INVESTMENT
ADVISORY FIRMS BOUGHT FOR OR RECOMMENDED TO THEIR CLIENTS MUTUAL FUND SHARE CLASSES THAT HAD DISTRIBUTION OR SERVICE FEES
(COMMONLY KNOWN AS 12B-1 FEES) PAID OUT OF FUND ASSETS TO THE FIRMS WHEN LOWER-COST SHARE CLASSES WERE AVAILABLE TO THOSE
CLIENTS, AND THE INVESTMENT ADVISORY FIRMS DID NOT ADEQUATELY DISCLOSE THE CONFLICT OF INTEREST ASSOCIATED WITH THOSE SHARE
CLASSES. ON MARCH 11, 2019, THE SEC ISSUED ORDERS UNDER THE SCSD INITIATIVE TO A TOTAL OF 79 INVESTMENT ADVISERS (INCLUDING BAIRD)
REFLECTING THE STANDARDIZED SETTLEMENT TERMS. ADDITIONAL ORDERS ARE EXPECTED TO BE ISSUED TO MORE FIRMS. THE ORDER PERTAINS TO
BAIRD'S PRIVATE WEALTH MANAGEMENT (PWM) INVESTMENT ADVISORY BUSINESS. BAIRD'S ASSET MANAGEMENT BUSINESS AND THE BAIRD FUNDS
WERE NOT SUBJECT TO THE ORDER. IN RESPONSE TO THE SEC'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE, BAIRD HAS MADE CHANGES TO ITS
PWM INVESTMENT ADVISORY PROGRAMS IN WHICH MUTUAL FUNDS AVAILABLE IN THOSE PROGRAMS DO NOT INCLUDE SHARE CLASSES THAT PAY 12B-
1 FEES. THE MUTUAL FUND SHARE CLASSES AVAILABLE TO CLIENTS IN BAIRD'S INVESTMENT ADVISORY PROGRAMS ARE GENERALLY THOSE THAT ARE
LOWEST COST SHARE CLASSES MOST WIDELY OFFERED BY EACH MUTUAL FUND FAMILY ACROSS ITS VARIOUS FUNDS TO MOST TYPES OF ELIGIBLE
INVESTORS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
06/07/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2017052842901
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT PUBLISHED
SEVEN RESEARCH REPORTS ABOUT AN ISSUER WITHOUT DISCLOSING THAT THE RESEARCH ANALYST WHO AUTHORED THE REPORTS WAS ENGAGED IN
EMPLOYMENT DISCUSSIONS WITH THE ISSUER THAT CONSTITUTED AN ACTUAL, MATERIAL CONFLICT OF INTEREST. THE FINDINGS STATED THAT THE
RESEARCH ANALYST'S CANDIDACY FOR EMPLOYMENT AT THE ISSUER WAS CLEARLY VIABLE, AND THE ISSUER AND THE RESEARCH ANALYST HAD
EXPRESSED MUTUAL INTEREST AND TAKEN CONCRETE STEPS IN FURTHERANCE OF THEIR EMPLOYMENT DISCUSSIONS. DURING THESE EMPLOYMENT
DISCUSSIONS, THE RESEARCH ANALYST AUTHORED AND THE FIRM PUBLISHED THE SEVEN RESEARCH REPORTS ON THE ISSUER WITHOUT DISCLOSING
THAT THE RESEARCH ANALYST WAS ENGAGED IN THE EMPLOYMENT DISCUSSIONS WITH IT. THE FIRM'S FAILURE TO DISCLOSE THE ACTUAL, MATERIAL
CONFLICT OF INTEREST ARISING FROM THE RESEARCH ANALYST'S EMPLOYMENT DISCUSSIONS WITH THE ISSUER IN THE RESEARCH REPORTS
AUTHORED BY HIM AND PUBLISHED BY THE FIRM MADE THOSE REPORTS MISLEADING.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/07/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 150,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 

THE FIRM WAS CENSURED AND FINED $150,000.00
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN RESPONSE TO THIS MATTER, BAIRD TOOK PROACTIVE MEASURES TO REITERATE COMPLIANCE POLICIES PERTAINING TO RESEARCH DISCLOSURES
ON MATERIAL CONFLICTS. THIS INVOLVED THE PUBLICATION OF POLICY REMINDERS, DISCUSSIONS AT MONTHLY RESEARCH DEPARTMENT MEETINGS,
ENHANCEMENT OF RESEARCH ANALYST NEW HIRE ORIENTATION, AMENDMENTS TO THE RESEARCH ASSOCIATE AND RESEARCH SUPERVISORY
COMPLIANCE MANUALS AND EDITS TO PROCEDURES REGARDING REVIEW OF RESEARCH. THE FIRM ALSO ENHANCED ITS RESEARCH DEPARTMENT FIRM
ELEMENT TRAINING AND HELD DISCUSSIONS ON RELEVANT POLICY AND PRACTICE AT PERIODIC RESEARCH ANALYST MEETINGS. GOING FORWARD,
BAIRD WILL CONTINUE TO MONITOR ADHERENCE TO RELEVANT POLICIES AND WILL CONTINUE TO APPROPRIATELY EDUCATE AND REMIND RESEARCH
ANALYSTS OF THEIR RESPONSIBILITIES. ANY POTENTIAL FOR DISCLOSURE DUE TO SIMILAR CIRCUMSTANCES WILL BE REVIEWED BY THE FIRM'S
MANAGEMENT AS WELL AS THE LEGAL AND COMPLIANCE DEPARTMENT.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:

SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NEW YORK STOCK EXCHANGE
2.
Principal Sanction:
Censure
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/15/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NYSE PROCEEDING NO. 2020-12-15- 00012
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JUNE 11, 2018, BAIRD RECEIVED ORDERS FROM A CUSTOMER TO BUY SECURITY 1. AFTER RECEIVING THE ORDERS, BAIRD ROUTED THEM, AS TWO
SEPARATE PARENT ORDERS TO TWO DIFFERENT NYSE FLOOR BROKER FIRMS. BOTH RECIPIENT FLOOR BROKER FIRMS, AS EXECUTING BROKERS, BROKE
UP THE PARENT ORDERS INTO CHILD ORDERS AND ROUTED THEM TO THE MARKET FOR EXECUTION. BAIRD'S SENDING OF THESE ORDERS TO TWO
DIFFERENT FLOOR BROKER FIRMS INADVERTENTLY LED TO COMPETING CHILD ORDERS ON BEHALF OF THE CUSTOMER IN SECURITY 1 THAT COULD
EXECUTE AT THE SAME TIME AND PRICE OVER A SIX-HOUR PERIOD. NEITHER FLOOR BROKER FIRM WAS AWARE THE OTHER FIRM WAS HANDLING THE
COMPETING ORDERS. ONE PURPOSE OF NYSE RULE 122 IS TO PREVENT CIRCUMVENTION OF THE NYSE PARITY ALLOCATION RULES SO THAT A MEMBER
ORGANIZATION OR ITS CUSTOMER CANNOT OBTAIN PREFERENTIAL EXECUTION BY SENDING COMPETING ORDERS TO MULTIPLE FLOOR BROKERS AT
THE SAME TIME. BECAUSE BAIRD ROUTED ORDERS TO NYSE FLOOR BROKER FIRMS FOR EXECUTION, THE FIRM HAD OBLIGATIONS TO IMPLEMENT
REASONABLY DESIGNED SUPERVISORY SYSTEMS, INCLUDING WSPS, TO DETECT AND PREVENT ROUTING OF POTENTIALLY COMPETING ORDERS TO TWO
DIFFERENT FLOOR BROKERS. SPECIFICALLY, BAIRD SHOULD HAVE HAD SUPERVISORY PROCEDURES IN PLACE TO CONDUCT REASONABLE DUE
DILIGENCE TO ASSURE THAT ORDERS IT WAS ROUTING TO DIFFERENT FLOOR BROKER FIRMS IN THE SAME SECURITY THAT COULD HAVE EXECUTED AT
THE SAME TIME AND PRICE WERE NOT FOR THE ACCOUNT OF THE SAME PRINCIPAL. PRIOR TO OCTOBER 2020, THE FIRM HAD NO PROCEDURES IN
PLACE ADDRESSING NYSE RULE 122.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
12/13/2021
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 12,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
BAIRD PAID THE $12,500.00 FINE ON 12/29/2021

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE FIRM ACCEPTED AND CONSENTED WITHOUT ADMITTING OR DENYING THE FINDINGS AND THE IMPOSITION OF A $12,500 FINE. UPON
IDENTIFICATION OF THE ORDER ROUTING INCIDENT BY THE NYSE, BAIRD PROMPTLY RE-EDUCATED TRADING STAFF ON THE REQUIREMENTS OF NYSE
RULE 122 AND WILL CONTINUE TO APPROPRIATELY EDUCATE AND REMIND TRADING STAFF OF THEIR RESPONSIBILITIES. BAIRD ALSO TOOK STEPS TO
UPDATE ITS SUPERVISORY SYSTEM BY IMPLEMENTING A SUPERVISORY REVIEW PROCEDURE SPECIFIC TO THE REQUIREMENTS OF NYSE RULE 122.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Other Sanctions: 

3.
Date Initiated (MM/DD/YYYY): 
08/31/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2020065107401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT USED A
PUBLISHED COMMISSION SCHEDULE PURSUANT TO WHICH IT CHARGED COMMISSIONS ON LOW-PRINCIPAL TRANSACTIONS THAT WERE NOT FAIR AND
REASONABLE. THE FINDINGS STATED THAT FOR ALL EQUITY TRANSACTIONS, THE FIRM IMPOSED A MINIMUM COMMISSION OF $100, IN ADDITION TO A
HANDLING FEE. AS A RESULT OF THE MINIMUM COMMISSION, THE FIRM CHARGED A TOTAL OF AT LEAST $266,481 IN UNFAIR COMMISSIONS OF
TRANSACTIONS ON BEHALF OF CUSTOMERS. THE COMMISSIONS CHARGED RANGED FROM OVER FIVE PERCENT TO 93 PERCENT OF THE TRANSACTIONS'
PRINCIPAL VALUE. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM WAS UNREASONABLE BECAUSE IN ESTABLISHING ITS
COMMISSION SCHEDULE AND IN SETTING COMMISSIONS ON TRANSACTIONS, THE FIRM DID NOT APPROPRIATELY CONSIDER THE FACTORS SET FORTH
IN FINRA RULE 2121.01 FOR TRANSACTIONS WHEN THE MINIMUM $100 COMMISSION WAS IMPOSED. SPECIFICALLY, WHILE THE FIRM GENERALLY
FLAGGED TRANSACTIONS WHERE CUSTOMERS WERE CHARGED OVER FIVE PERCENT OF PRINCIPAL AND REVIEWED THOSE TRANSACTIONS FOR
EXCESSIVE COMMISSIONS, THE FIRM'S SUPERVISORY SYSTEM DID NOT FLAG FOR REVIEW TRANSACTIONS WHEN THE FIRM CHARGED THE MINIMUM
$100 COMMISSION.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
08/31/2022
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 150,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PLUS INTEREST
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM WAS CENSURED, FINED $150,000.00 AND ORDERED TO PAY $266,481, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE FIRM ACCEPTED AND CONSENTED WITHOUT ADMITTING OR DENYING THE FINDINGS AND THE IMPOSITION OF A $150,000 FINE. AFTER FINRA
DISCUSSED THE $100 MINIMUM EQUITY COMMISSION WITH ROBERT W. BAIRD & CO., INCORPORATED ("BAIRD") DURING THE 2020 ROUTINE
EXAMINATION, BAIRD PROMPTLY MODIFIED ITS PUBLISHED COMMISSION SCHEDULE TO ELIMINATE THE MINIMUM COMMISSION AMOUNT AND UPDATED
ITS WRITTEN SUPERVISORY PROCEDURES TO ALIGN WITH THE NEW PUBLISHED SCHEDULE. BAIRD ALSO TOOK STEPS TO MAKE PAYMENTS TO THE
AFFECTED CUSTOMERS, WHICH ON AVERAGE AMOUNT TO $36.62 PER TRADE AND $57.64 PER CUSTOMER. BAIRD WILL CONTINUE TO MAKE EFFORTS
TO ENSURE THAT IT CHARGES FAIR PRICES AND COMMISSIONS ON ALL SECURITIES TRANSACTIONS WITH ITS CUSTOMERS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/29/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:

3-21768
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE
AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST ROBERT W. BAIRD & CO. INCORPORATED ("RESPONDENT" OR
"BAIRD"). RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT ("OFFER") THAT THE COMMISSION HAS DETERMINED TO ACCEPT. THE COMMISSION
FINDS THAT THE FEDERAL SECURITIES LAWS IMPOSE RECORDKEEPING REQUIREMENTS ON BROKER-DEALERS AND REGISTERED INVESTMENT. THESE
PROCEEDINGS ARISE OUT OF THE FAILURE OF BAIRD EMPLOYEES THROUGHOUT THE FIRM, INCLUDING AT SENIOR LEVELS, TO ADHERE TO CERTAIN OF
THESE REQUIREMENTS AND BAIRD'S OWN POLICIES. USING THEIR PERSONAL DEVICES, THESE EMPLOYEES COMMUNICATED BOTH INTERNALLY AND
EXTERNALLY BY PERSONAL TEXT MESSAGES ("OFF-CHANNEL COMMUNICATIONS"). FROM AT LEAST JANUARY 2019, BAIRD EMPLOYEES SENT AND
RECEIVED OFF-CHANNEL COMMUNICATIONS THAT RELATED TO THE BUSINESS OF THE BROKER-DEALER AND REGISTERED INVESTMENT ADVISER
OPERATED BY BAIRD. RESPONDENT DID NOT MAINTAIN OR PRESERVE THE SUBSTANTIAL MAJORITY OF THESE WRITTEN COMMUNICATIONS.
RESPONDENT'S FAILURE WAS FIRM-WIDE AND INVOLVED EMPLOYEES AT VARIOUS LEVELS OF AUTHORITY. AS A RESULT, BAIRD VIOLATED SECTION
17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER AND SECTION 204 OF THE ADVISERS ACT AND RULE 204-2(A)(7) THEREUNDER.
BAIRD'S SUPERVISORS, WHO WERE RESPONSIBLE FOR SUPERVISING JUNIOR EMPLOYEES, COMMUNICATED OFF-CHANNEL USING THEIR PERSONAL
DEVICES. BAIRD'S FAILURE TO IMPLEMENT ITS POLICIES AND PROCEDURES THAT PROHIBIT SUCH COMMUNICATIONS LED TO ITS FAILURE TO
REASONABLY SUPERVISE ITS EMPLOYEES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT AND SECTION 203(E)(6) OF THE
ADVISERS ACT. DURING THE TIME PERIOD, BAIRD RECEIVED AND RESPONDED TO COMMISSION SUBPOENAS FOR DOCUMENTS AND/OR RECORDS
REQUESTS IN NUMEROUS COMMISSION INVESTIGATIONS. AS A RESULT, BAIRD'S RECORDKEEPING FAILURES LIKELY IMPACTED THE COMMISSION'S
ABILITY TO CARRY OUT ITS REGULATORY FUNCTIONS AND INVESTIGATE VIOLATIONS OF THE FEDERAL SECURITIES LAWS ACROSS THESE
INVESTIGATIONS. COMMISSION STAFF UNCOVERED BAIRD'S MISCONDUCT AFTER COMMENCING A RISK-BASED INITIATIVE TO INVESTIGATE THE USE OF
OFF-CHANNEL AND UNPRESERVED COMMUNICATIONS AT BROKER DEALERS. BAIRD HAS INITIATED A REVIEW OF ITS RECORDKEEPING FAILURES AND
BEGUN A PROGRAM OF REMEDIATION. AS A RESULT OF ITS CONDUCT, FROM AT LEAST JANUARY 2019 THROUGH THE DATE OF THIS ORDER,
RESPONDENT WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER AND SECTION 204 OF THE ADVISERS
ACT AND RULE 204-2(A)(7) THEREUNDER. FURTHERMORE, BAIRD FAILED TO REASONABLY TO SUPERVISE ITS EMPLOYEES WITH A VIEW TO PREVENTING
OR DETECTING CERTAIN OF ITS EMPLOYEES' AIDING AND ABETTING VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4)
THEREUNDER, WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT; AND SECTION 204 OF THE ADVISERS ACT AND RULE 204-2(A)(7)
THEREUNDER, WITHIN THE MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/29/2023
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 15,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM WAS ORDERED TO CEASE AND DESIST, IS CENSURED, SHALL PAY A CIVIL MONEY PENALTY OF $15,000,000, AND SHALL COMPLY WITH
CERTAIN UNDERTAKINGS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

IN SEPTEMBER 2023, BAIRD ENTERED INTO AN OFFER OF SETTLEMENT WITH THE SEC (THE "SETTLEMENT"), IN WHICH IT ADMITTED THAT IT VIOLATED
SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER AND SECTION 204 OF THE ADVISERS ACT AND RULE 204-2(A)(7)
THEREUNDER FOR FAILING TO MAINTAIN RECORDS OF CERTAIN BUSINESS-RELATED COMMUNICATIONS MADE BY BAIRD ASSOCIATES WHEN THEY USED
THEIR PERSONAL DEVICES ("OFF-CHANNEL COMMUNICATIONS") AND FOR FAILING TO SUPERVISE ITS ASSOCIATES' BUSINESS-RELATED
COMMUNICATIONS. THE SETTLEMENT WAS RELATED TO AN SEC RISK-BASED INITIATIVE, WHEREBY THE SEC INVESTIGATED A LARGE NUMBER OF
FINANCIAL SERVICES FIRMS TO DETERMINE WHETHER THOSE FIRMS WERE PROPERLY RETAINING BUSINESS-RELATED TEXT AND INSTANT MESSAGES
AND OTHER OFF-CHANNEL COMMUNICATIONS SENT AND RECEIVED ON EMPLOYEES' PERSONAL DEVICES. FOLLOWING THE COMMENCEMENT OF THE
SEC'S INITIATIVE, BAIRD COOPERATED WITH THE SEC AND CONDUCTED VOLUNTARY INTERVIEWS OF A SAMPLING OF BAIRD SUPERVISORS TO GATHER
AND REVIEW MESSAGES FOUND ON THEIR PERSONAL DEVICES. IT WAS DISCOVERED THAT CERTAIN BAIRD SUPERVISORS COMMUNICATED OFF-
CHANNEL USING NON-BAIRD APPROVED METHODS ON THEIR PERSONAL DEVICES ABOUT BAIRD'S BROKER-DEALER AND INVESTMENT ADVISER
BUSINESSES. AS PART OF THE SETTLEMENT, BAIRD WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF SECTION
17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER AND SECTION 204 OF THE ADVISERS ACT AND RULE 204-2(A)(7) THEREUNDER AND
TO PAY A CIVIL MONETARY PENALTY OF $15 MILLION. IN ADDITION, BAIRD AGREED TO CERTAIN UNDERTAKINGS, INCLUDING RETAINING AN
INDEPENDENT COMPLIANCE CONSULTANT TO CONDUCT A REVIEW OF BAIRD'S POLICIES AND PROCEDURES, TRAINING, SURVEILLANCE PROGRAM,
TECHNOLOGY SOLUTIONS AND SIMILAR MATTERS RELATED TO OFF-CHANNEL COMMUNICATIONS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II

1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/07/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2020068655201
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITS SUPERVISORY
SYSTEM DID NOT PROVIDE CERTAIN CUSTOMERS WITH MUTUAL FUND SALES CHARGE WAIVERS AND FEE REBATES TO WHICH THEY WERE ENTITLED
THROUGH RIGHTS OF REINSTATEMENT OFFERED BY MUTUAL FUND COMPANIES. THE FINDINGS STATED THAT THE FIRM'S SYSTEM THAT PROVIDED
CUSTOMERS WITH RIGHTS OF REINSTATEMENT BENEFITS ON ELIGIBLE TRANSACTIONS WAS NOT REASONABLY DESIGNED IN TWO BASIC RESPECTS.
FIRST, THE FIRM'S OVERSIGHT OF DISCOUNTS AVAILABLE THROUGH RIGHTS OF REINSTATEMENT RELIED ON AN AUTOMATED ALERT THAT WAS
DESIGNED PRIMARILY TO MONITOR FOR MUTUAL FUND SWITCHES THAT OCCURRED WITHIN 90 DAYS OF A PRIOR SALE. THUS, THE ALERT WAS NOT
DESIGNED TO, AND DID NOT, CAPTURE ALL TRANSACTIONS ELIGIBLE FOR REINSTATEMENT PRIVILEGES BECAUSE MANY FUNDS' REINSTATEMENT
PERIODS EXCEEDED 90 DAYS. SECOND, THE FIRM RELIED ON AN INEFFECTIVE REVIEW OF THESE ALERTS-BASED ON A MANUAL REVIEW OF RANDOM
SAMPLES-TO SUPERVISE AND CONFIRM WHETHER THE FIRM CREDITED ELIGIBLE CUSTOMERS WITH REINSTATEMENT PRIVILEGES. AS A RESULT OF ITS
SUPERVISORY DEFICIENCIES, BAIRD DID NOT PROVIDE ACCOUNTS WITH RIGHTS OF REINSTATEMENT BENEFITS TO WHICH THEY WERE ENTITLED, AND
CUSTOMERS PAID $519,646.23 IN EXCESS SALES CHARGES AND FEES. THE FIRM HAS SINCE ENHANCED ITS SUPERVISORY SYSTEM.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
11/07/2023
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 519,646.23
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
NONE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM PAID $519,646.23 IN RESTITUTION TO CUSTOMERS PRIOR TO THE EFFECTIVE DATE OF THIS AWC.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response

must fit within the space provided).
UPON RECEIPT OF FINRA'S SWEEP INQUIRY IN 2021, BAIRD CONDUCTED AN INTERNAL REVIEW TO IDENTIFY POTENTIALLY DISADVANTAGED
CUSTOMERS AND CALCULATED A REMEDIATION AMOUNT, VOLUNTARILY EXTENDING THE REVIEW PERIOD BEYOND FINRA'S REQUESTED DATE. PRIOR TO
RESOLVING THE MATTER WITH FINRA, BAIRD PROACTIVELY REMEDIATED 2,300 CUSTOMERS A TOTAL OF $519,646.23, PLUS INTEREST, FOR AN
AVERAGE AMOUNT OF IMPACT PER CUSTOMER OF APPROXIMATELY $225.00. BAIRD ALSO ENHANCED ITS SUPERVISORY SYSTEM, INCLUDING BY
CREATING AND IMPLEMENTING NEW EXCEPTION REPORTS DESIGNED SPECIFICALLY TO IDENTIFY MISSED RIGHTS OF REINSTATEMENT. THESE
ENHANCEMENTS ALSO AUTOMATED THE PREVIOUSLY MANUAL REVIEW.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:

Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/06/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2022075391301
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
UNSPECIFIED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, AS
SUCCESSOR-IN-INTEREST TO HEFREN-TILLOTSON, VIOLATED REG BI'S COMPLIANCE OBLIGATION. THE FINDINGS STATED THAT HEFREN-TILLOTSON'S
REGISTERED REPRESENTATIVES RECOMMENDED THAT CUSTOMERS OPEN PORTFOLIO REVIEW PROGRAM ACCOUNTS, WHICH ENROLLED THE
CUSTOMERS IN AN ADVISORY SERVICE, EVEN THOUGH THE CUSTOMERS WERE ALREADY RECEIVING THOSE SERVICES THROUGH THEIR EXISTING OR
SIMULTANEOUSLY OPENED PORTFOLIO REVIEW OR INVESTMENT ADVISORY ACCOUNTS. THESE CUSTOMERS DID NOT RECEIVE ANY ADDITIONAL
SERVICES BY OPENING THESE ACCOUNTS. AS A RESULT, THESE CUSTOMERS PAID $557,830.64 IN UNNECESSARY ACCOUNT FEES. SUBSEQUENTLY,
BAIRD VOLUNTARILY DISCONTINUED CHARGING PORTFOLIO REVIEW FEES AND RECOMMENDING PORTFOLIO REVIEW ACCOUNTS AFTER ITS
ACQUISITION OF HEFREN-TILLOTSON'S BROKERAGE BUSINESS. THE FINDINGS ALSO STATED THAT HEFREN-TILLOTSON'S WRITTEN PROCEDURES, AND
SUPERVISORY SYSTEM, WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REG BI'S REQUIREMENT THAT ACCOUNT-TYPE
RECOMMENDATIONS ARE IN THE CUSTOMER'S BEST INTEREST. THE FIRM'S WSPS DID NOT PROVIDE ANY PROCEDURES OR GUIDANCE REGARDING THE
FACTORS TO CONSIDER WHEN RECOMMENDING PORTFOLIO REVIEW PROGRAM ACCOUNTS. MOREOVER, THE FIRM'S WSPS DID NOT REQUIRE
REPRESENTATIVES TO CONSIDER WHETHER CUSTOMERS WOULD BENEFIT FROM A RECOMMENDATION TO OPEN A NEW PORTFOLIO REVIEW ACCOUNT
WHEN THE CUSTOMER WAS ALREADY RECEIVING THE SERVICES PROVIDED IN CONNECTION WITH THAT ACCOUNT TYPE. THE FIRM'S WSPS ALSO
FAILED TO DETAIL ANY STEPS THAT PRINCIPALS SHOULD TAKE TO DETERMINE WHETHER AN ACCOUNT-TYPE RECOMMENDATION WAS IN THE
CUSTOMER'S BEST INTEREST IN LIGHT OF THE CUSTOMER'S INVESTMENT PROFILE, THE COSTS OF SUCH AN ACCOUNT, AND THE SERVICES PROVIDED
IN CONNECTION WITH THAT ACCOUNT.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
03/06/2025
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 100,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
INTEREST
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM WAS CENSURED, FINED $100,000, AND ORDERED TO PAY $557,830.64, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

AS SET FORTH IN THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), ALL OF THE ACTIVITIES/VIOLATIONS/MATTERS DESCRIBED IN THE
AWC OCCURRED PRIOR TO THE TIME HEFREN-TILLOTSON MERGED INTO BAIRD. BAIRD, AS SUCCESSOR-IN-INTEREST TO HEFREN-TILLOTSON,
VOLUNTARILY DISCONTINUED THE PORTFOLIO REVIEW PROGRAM PRIOR TO THE TIME THESE ACCOUNTS WERE AT BAIRD. FINRA ALSO RECOGNIZED
THAT BAIRD PROVIDED SUBSTANTIAL ASSISTANCE IN CALCULATING APPROPRIATE RESTITUTION.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
MASSACHUSETTS SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
(1) CEASE AND DESIST FROM FURTHER ACTS AND PRACTICES IN VIOLATION OF THE ACT AND REGULATIONS; (2) CENSURE WITH RESPECT TO THE
CONDUCT DESCRIBED IN THE ORDER; (3) REVIEW OF WRITTEN SUPERVISORY POLICIES AND PROCEDURES WITH RESPECT TO M.G.L. C.110A, §§201(C)

AND 201(D); (4) REGISTER AND MAINTAIN REGISTRATION OF ITS IARS WHO PROVIDE INVESTMENT ADVISORY SERVICES AND HAVE A PLACE OF
BUSINESS IN MASSACHUSETTS; (5) ADMINISTRATIVE FINE IN THE AMOUNT OF $57,500.
3.
Date Initiated (MM/DD/YYYY): 
03/20/2026
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
R-2025-0421
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ROBERT W. BAIRD & CO. INCORPORATED ENGAGED IN ACTS AND PRACTICES IN VIOLATION OF THE ACT AND REGULATIONS BY NOT ENSURING THAT ITS
INVESTMENT ADVISER REPRESENTATIVES, WHO HAD A PLACE OF BUSINESS IN MASSACHUSETTS, WERE PROPERLY REGISTERED WITH MASSACHUSETTS
PRIOR TO PROVIDING INVESTMENT ADVISORY SERVICES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
03/23/2026
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 57,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
(1) CEASE AND DESIST FROM FURTHER ACTS AND PRACTICES IN VIOLATION OF THE ACT AND REGULATIONS; (2) CENSURE WITH RESPECT TO THE
CONDUCT DESCRIBED IN THE ORDER; (3) REVIEW OF WRITTEN SUPERVISORY POLICIES AND PROCEDURES WITH RESPECT TO M.G.L. C.110A,
§§201(C) AND 201(D); (4) REGISTER AND MAINTAIN REGISTRATION OF ITS IARS WHO PROVIDE INVESTMENT ADVISORY SERVICES AND HAVE A
PLACE OF BUSINESS IN MASSACHUSETTS; (5) ADMINISTRATIVE FINE IN THE AMOUNT OF $57,500
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
ADMINISTRATIVE FINE IN THE AMOUNT OF $57,500 PAID IN FULL ON 3/24/2026.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE MASSACHUSETTS SECURITIES DIVISION ALLEGED THAT THE FIRM FAILED TO ENSURE THAT TWO INVESTMENT ADVISER REPRESENTATIVES WITH A
PLACE OF BUSINESS IN MASSACHUSETTS WERE PROPERLY REGISTERED AS INVESTMENT ADVISER REPRESENTATIVES IN THE STATE PRIOR TO
PROVIDING INVESTMENT ADVISORY SERVICES. SPECIFICALLY, THE DIVISION ALLEGED THAT THE REPRESENTATIVES BEGAN PROVIDING ADVISORY
SERVICES WHILE THEIR MASSACHUSETTS INVESTMENT ADVISER REPRESENTATIVE REGISTRATIONS WERE INCOMPLETE DUE TO THE ABSENCE OF
REQUIRED CRIMINAL OFFENDER RECORD INFORMATION (CORI) ACKNOWLEDGEMENT FORMS. AS A RESULT, THE REPRESENTATIVES PROVIDED
INVESTMENT ADVISORY SERVICES TO MASSACHUSETTS CLIENTS WHILE UNREGISTERED. NO CLIENT HARM WAS ALLEGED. BAIRD COOPERATED FULLY
AND CORRECTED THE ISSUE. AS PART OF THE SETTLEMENT, BAIRD AGREED TO: A CENSURE, CEASE AND DESIST FROM FURTHER VIOLATIONS, REVIEW
ITS APPLICABLE WRITTEN SUPERVISORY POLICIES AND PROCEDURES, AND PAY A $57,500 ADMINISTRATIVE FINE. AFTER THE DIVISION MADE BAIRD
AWARE OF THEIR UNIQUE FORM REQUIREMENTS, THE FIRM PROMPTLY OBTAINED THE NECESSARY DOCUMENTS TO COMPLETE THE APPLICATION
PROCESS, BAIRD ALSO TOOK STEPS TO MODIFY ITS WRITTEN SUPERVISORY PROCEDURES TO ALIGN WITH THE DIVISION'S REQUIREMENTS TO AVOID

RECURRENCE OF THIS ISSUE.