Overview
- Headquarters
- Milwaukee, WI
- Average Client Assets
- $1.6 million
- Minimum Account Size
- $10,000,000
- SEC CRD Number
- 8158
Fee Structure
Primary Fee Schedule (THE DDK GROUP - WRAP)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $10,000,000 | Negotiable |
| $10,000,001 | $25,000,000 | 0.60% |
| $25,000,001 | $50,000,000 | 0.45% |
| $50,000,001 | $75,000,000 | 0.30% |
| $75,000,001 | $100,000,000 | 0.15% |
| $100,000,001 | and above | Negotiable |
Minimum Annual Fee: $60,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | Below minimum client size | |
| $5 million | Below minimum client size | |
| $10 million | Negotiable | Negotiable |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- HNW Share of Firm Assets
- 34.27%
- Total Client Accounts
- 367,123
- Discretionary Accounts
- 216,498
- Non-Discretionary Accounts
- 150,625
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Companies, Portfolio Management for Pooled Investment Vehicles, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection, Educational Seminars
Regulatory Filings
Additional Brochure: BAIRD ADVISORS (2026-03-27)
View Document Text
Baird Advisors
Brochure
March 27, 2026
Baird Advisors
777 East Wisconsin Avenue
Milwaukee, Wisconsin 53202
Toll Free: 800-792-2473
www.bairdadvisors.com
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue
Milwaukee, WI 53202
1-800-792-2473
rwbaird.com
Member FINRA & SIPC
SEC File No. 801-7571
This brochure (“Brochure”) provides information about the qualifications and business practices of
Robert W. Baird & Co. Incorporated (“Baird”) and Baird Advisors, an investment management
department operating within Baird. Clients should carefully consider this information before
becoming a client of Baird Advisors. If you have any questions about the contents of this Brochure,
please contact Baird Advisors at the toll-free phone number listed above. The information contained
in this Brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority. Additional information about Baird is available on
the SEC’s website at www.adviserinfo.sec.gov.
Material Changes
Baird Advisors, an investment management department operating within Robert W. Baird & Co.
Incorporated (“Baird”), updated its Form ADV Part 2A brochure (the “Brochure”) on March 27, 2026. The
following summary discusses the material changes that Baird Advisors has made to the Brochure since
March 21, 2025, the date of the last annual update to the Brochure.
• Baird Advisors updated information about Baird’s regulatory assets under management and certain of
Baird’s affiliates and related parties. See the Sections of the Brochure entitled “Advisory Business—Robert
W. Baird & Co. Incorporated” and “Other Financial Industry Activities and Affiliations” for more
information.
• Baird Advisors updated its disclosures about the research, information and tools used by Baird Advisors’
investment professionals when formulating investment advice, which may include the use of artificial
intelligence (“AI”) tools, and the related risks. See the Section of the Brochure entitled “Methods of
Analysis, Investment Strategies and Risk of Loss—Methods of Analysis” for more information.
• Baird Advisors updated investment risk information related to information security, cybersecurity, and
other technology‑related events, issuers’ use of AI, and those associated with recent events, such as those
associated with the U.S. administration’s policy initiatives, inflation, conflicts in Iran and the Middle East,
the war between Ukraine and Russia, and the strain in relationships between the U.S. and other countries.
See the Section of the Brochure entitled “Methods of Analysis, Investment Strategies and Risk of Loss—
Principal Risks” for more specific information.
A client should note that the foregoing summary only discusses material changes made to the Brochure
since March 21, 2025. The updated Brochure contains changes that are not listed above.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Table of Contents
Advisory Business ........................................................................................... 1
Baird Advisors .............................................................................................. 1
Robert W. Baird & Co. Incorporated ................................................................ 2
The Client-Baird Fiduciary Relationship ............................................................ 2
Fees and Compensation .................................................................................. 2
Separate Accounts ........................................................................................ 2
Mutual Funds ............................................................................................... 4
Other Compensation Received by Baird Advisors and Baird ................................ 4
Performance-Based Fees and Side-By-Side Management ................................ 5
Types of Clients............................................................................................... 5
Methods of Analysis, Investment Strategies and Risk of Loss ......................... 5
Methods of Analysis ...................................................................................... 5
Portfolio Investments .................................................................................... 7
Investment Strategies ................................................................................... 8
Principal Risks ............................................................................................ 10
Disciplinary Information ............................................................................... 15
Other Financial Industry Activities and Affiliations ....................................... 17
Baird’s Broker-Dealer Activities .................................................................... 17
Baird’s Other Investment-Related Activities ................................................... 17
Certain Affiliated Parties .............................................................................. 17
Other Financial Industry Activities ................................................................ 17
Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading ................................................................................ 18
Code of Ethics ............................................................................................ 18
Other Potential Conflicts .............................................................................. 18
Brokerage Practices ...................................................................................... 19
Broker-Dealer Selection .............................................................................. 19
Soft Dollar Benefits ..................................................................................... 20
Trade Aggregation, Allocation and Rotation Practices ...................................... 20
Directed Brokerage ..................................................................................... 21
Cross Trading Involving Advisory Accounts .................................................... 21
Trade Error Correction ................................................................................ 22
Review of Accounts ....................................................................................... 22
Client Referrals and Other Compensation ..................................................... 22
Custody ......................................................................................................... 23
Investment Discretion .................................................................................. 23
Voting Client Securities ................................................................................. 24
Financial Information.................................................................................... 25
Special Considerations for Retirement Accounts ........................................... 25
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
may negotiate with Baird Advisors to provide
other investment advisory services. However,
Baird Advisors generally limits its services to
providing investment advice relating to fixed
income investment strategies.
All of the investment strategies discussed in this
Brochure may not be appropriate for every client.
Baird Advisors will only select or recommend
those strategies believed to be suitable for a
particular client.
Advisory Business
This Brochure describes the investment advisory
services that Robert W. Baird & Co. Incorporated
(“Baird”) offers to its clients through Baird
Advisors, an investment management department
of Baird. Separate brochures describe other
investment advisory services that Baird offers to
its clients and discuss the agreements, fees and
potential conflicts of interest for each service. A
client or prospective client who wishes to obtain a
brochure for another investment advisory service
provided by Baird should call Baird toll-free at 1-
800-792-2473.
enter
into
an
A client that wishes to retain the services of Baird
Advisors will
investment
management agreement (“IMA”) with Baird
Advisors. The IMA will contain the specific terms
applicable to the client’s advisory relationship with
Baird Advisors.
The information contained in this Brochure is
current as of the date above and is subject to
change at Baird’s discretion. Please retain this
Brochure for your records.
information
in
fixed
Baird Advisors
Baird Advisors offers professional portfolio
management to separate account clients desiring
income markets. Baird
investments
Advisors also provides
investment advisory
services to certain mutual funds.
Separate Accounts
A client is responsible for providing to Baird
Advisors
that Baird Advisors
reasonably requires in order to provide the
services selected by the client. Baird Advisors will
rely on this information when providing its
advisory services. A client is also responsible for
informing Baird Advisors of any material changes
to that information or if there is any change to the
client’s investment objectives, risk tolerance,
financial circumstances, investment needs, or
other circumstances that may affect the manner
in which the client’s assets are invested or
services are provided to the client.
The investment advisory services offered by Baird
Advisors to separate account clients generally
include portfolio management, investment advice
and consulting services, performance reporting,
and related account services.
provides
Important Note for SMA Wrap Fee Program
Clients Baird Advisors
portfolio
fee
management services under SMA wrap
programs sponsored and administered by Baird.
As compensation for its services, Baird Advisors
receives a portion of the wrap fee the client pays
to Baird. If a client is participating in a wrap fee
program, the client should review the client’s
agreement with Baird and Baird’s Form ADV Part
2A Wrap Fee Program Brochure for a full
description of the services provided and fees
charged by Baird.
Mutual Funds and Investment Companies
Baird Advisors manages client portfolios with full
investment discretion and tailors its advisory
services to the individual needs of clients. Baird
Advisors analyzes a client’s specific needs,
investment time horizon, and risk tolerance to
help the client develop investment objectives and
guidelines for the client’s portfolio. As part of its
analysis, Baird Advisors works with a client to
select a benchmark index that characterizes the
risk tolerance and return expectations for the
client. Baird Advisors then uses an investment
strategy that is intended to generate an annual
rate of return that, before the deduction of fees,
is greater than the benchmark selected for the
client’s portfolio over full market cycles.
Baird Advisors provides investment management
and other services to certain mutual fund series of
Baird Funds, Inc. (“Baird Funds”)
investing
primarily in fixed income securities (the “Baird
Bond Funds”). Additional information about the
services Baird Advisors provides is available in the
additional
prospectus
and
statement
of
Subject to the agreement of Baird Advisors, a
client may impose reasonable restrictions on the
investments or types of investments to be held in
the client’s account. Please see “Investment
Discretion” below for more information. Clients
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
information for those Baird Funds, which are
available on
the Baird Funds’ website at
bairdassetmanagement.com/baird-funds.
under management,
As of December 31, 2025, Baird had
approximately $394.0688 billion in regulatory
assets
approximately
$289.4898 billion of which was managed on a
discretionary basis and approximately $104.5790
billion of which was managed on a non-
discretionary basis.
Baird Advisors also serves as investment sub-
adviser to a mutual fund series of the Bridge
Builder Trust. Additional information about the
services that Baird Advisors provides to that fund
is available in the prospectus and statement of
additional information for that fund.
is deemed
to have a
Robert W. Baird & Co. Incorporated
Baird is privately-held, employee-owned global
investment and wealth management firm formed
in the State of Wisconsin in 1919.
The Client-Baird Fiduciary Relationship
Baird
is registered with the Securities and
Exchange Commission (“SEC”) as an investment
adviser under the Investment Advisers Act of
1940, as amended (the “Advisers Act”). Baird
Advisors
fiduciary
relationship with a client when providing the
investment advisory services that are described in
this Brochure.
Baird is owned indirectly by its associates through
several holding companies. Baird
is owned
directly by Baird Financial Corporation (“BFC”).
BFC is, in turn, owned by Baird Financial Group,
Inc. (“BFG”), which
is the ultimate parent
company of Baird. Associates of Baird own
substantially all of the outstanding stock of BFG.
limitation,
that contain
through
that
require
them
transactions
and
From time to time Baird may engage in certain
business practices or may receive compensation
or other benefits that create a potential for
conflict between the interests of clients and the
interests of Baird Advisors and Baird. Baird
Advisors and Baird generally address potential
conflicts of interest by disclosing them to clients
through documents provided to clients, including,
this Brochure, Brochure
without
supplements
information about
individuals providing investment advice to clients,
and the agreements clients enter into with Baird
Advisors and Baird. In addition, Baird has adopted
internal policies and procedures for Baird Advisors
and Baird
to: provide
investment advice that is appropriate for advisory
clients (based upon the information provided by
such clients); make full disclosure of all potential,
material conflicts of interest; act with utmost care
and good faith in dealings with advisory clients;
and seek to obtain “best execution” of advisory
client transactions. The specific business practices
that create potential conflicts of interest with
clients and additional measures used by Baird
Advisors and Baird to address them are discussed
in other sections of this Brochure.
In addition to the investment advisory services
that Baird Advisors provides to clients, including
portfolio management, investment advice and
consulting, performance reporting and related
account services, Baird,
its other
departments, also offers various other investment
advisory services to clients not described in this
Brochure. These additional investment advisory
services Baird offers
include: analysis and
recommendations regarding asset allocation and
investment strategies; research, analysis and
recommendations regarding investment managers
and individual securities; investment consulting;
financial planning; and
investment policy
development. Baird also offers clients execution of
administrative
brokerage
services, including maintaining custody of account
assets. Clients may also negotiate other services
with Baird. Baird offers its services separately or
in combination with other services.
A client should note that registration as an
investment adviser does not imply a certain level
of skill or training.
by
clients
providing
Baird participates in wrap fee programs not
described in this Brochure and it provides portfolio
management services in connection with those
programs. Baird receives a portion of the wrap fee
paid
portfolio
for
management services under those wrap fee
programs.
Fees and Compensation
Separate Accounts
Advisory Fee
A client’s IMA will set forth the actual fee schedule
and calculation method for the advisory fee. Baird
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Advisors generally charges fees based on a
client’s assets under management, as shown in
the standard institutional fee schedule below.
Baird Advisors’ Standard Institutional Fee Schedule
Taxable Bond Strategies
Investment Minimum: $300 million
Market Value of Assets
Annual Fee Rate
custodian to pay the fee from their account. The
client is generally required to pay the fee within
thirty (30) days of the invoice date. If a client’s
IMA is in effect for only a portion of a quarter, the
fee is pro-rated for such portion based on the
number of days the funded account was managed
by Baird Advisors. In the event termination
occurs, the fee is based upon the Market Value or
average market value on the date of termination
or a date mutually agreed upon with the client.
On the first $100,000,000
0.30%
On the next $100,000,000
0.20%
On the remaining assets
0.15%
Baird may modify a client’s existing fees and
other charges or add additional fees or charges by
providing the client with ninety (90) days’ prior
written notice.
Baird Advisors’ Standard Institutional Fee Schedule
Municipal Bond Strategies
Investment Minimum: $50 million
Market Value of Assets
Annual Fee Rate
On the first $50,000,000
0.30%
The minimum asset value to open a separate
account with Baird Advisors for a taxable bond
strategy is typically $300 million. The minimum
asset value to open a separate account with Baird
Advisors for a municipal bond strategy is typically
$50 million.
On the next $50,000,000
0.20%
On the remaining assets
0.15%
The fees are calculated in arrears based on the
market value (“Market Value”) of the assets Baird
Advisors manages for the client. The Market Value
of assets is typically determined by the client’s
quarter-end custodial statement(s) and includes
accrued interest and cash or its equivalent held
for
investment. If Baird Advisors manages
multiple accounts on behalf of a client under an
IMA, Baird Advisors will generally aggregate client
assets for fee calculation purposes.
The advisory fee and minimum account value
applicable to a client are negotiable in certain
instances and may vary based upon a number of
factors, including but not limited to the size and
nature of the assets in the client’s account, the
client’s particular investment style or objective,
and any particular services requested by the
client. The fees paid by a client may differ from
the fees paid by other clients based on a number
of factors, including but not limited to, the factors
identified above. As new standard fee schedules
are put into effect, fee schedules applicable to
existing clients are not affected.
into other
Baird Advisors may enter
fee
arrangements, including performance-based fee
arrangements, with eligible clients. Performance-
based fee arrangements are further described in
the section entitled “Performance-Based Fees and
Side-By-Side Management” below.
If an account has cumulative net cash flows
during the calendar quarter totaling 10% or more
of the account’s beginning Market Value, Baird
Advisors will generally use a simple average
market value, adjusted for all cash flows during
the quarter, in lieu of a quarter-end Market Value.
The 10% or greater cash flow calculation applies
to each account individually.
Other Fees and Expenses
If client assets under an IMA are invested in the
Baird Bond Funds, the fees set forth above do not
apply to those assets and the client will bear the
cost of fund expenses as described in each fund’s
prospectus on those assets.
in addition
In addition to Baird Advisors’ fee described above,
a client of Baird Advisors may incur other fees
and expenses. The asset-based fee only covers
portfolio management and investment advice
provided by Baird Advisors, and a client may pay
for other services, such as custody and trade
execution, separately
to Baird
Advisors’ fee. Please see the section entitled
Fee invoices are generally sent quarterly to the
client and they can pay directly or instruct their
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
“Brokerage Practices” below for more information
about Baird Advisors’ trading practices.
redemption fees or similar fees that the fund or
its sponsor may impose on the client. A client
should review the prospectus or other applicable
offering documents for each investment fund in
which the client invests for further information.
A client is responsible for bearing or paying, in
addition to Baird Advisors’ fee, all other costs and
expenses, including, but not limited to:
• commissions, markups, markdowns,
Clients who have accounts managed by Baird
Advisors may also have other accounts with Baird
that are not managed by Baird Advisors. Those
accounts may be subject to fees, commissions or
other expenses that are entirely separate from
the payment of fees and expenses for the services
provided by Baird Advisors.
and
spreads charged by broker-dealers that buy
debt obligations from, or sell debt obligations
to, the client’s account (such costs may be
inherently reflected in the price the client pays
or receives for such debt obligations);
• underwriting discounts or similar fees related to
the public offering of investment products;
• custody fees;
• extra or special fees or expenses that may
result from the execution of odd lot trade orders
(i.e., “odd-lot differential”);
Mutual Funds
As compensation for its services, Baird Advisors
receives fees from each mutual fund it advises,
which fees are disclosed in each fund’s prospectus
and statement of additional information. Other
fees that are payable as an investor in a mutual
fund are described in the fund’s prospectus and
statement of additional information.
• electronic fund fees, wire transfer fees, and
similar fees or expenses related to account
transfers;
• currency conversions and transactions;
related
to
the
• fees
establishment,
administration or termination of retirement
accounts, retirement or profit sharing plans,
trusts or any other legal entity;
Other Compensation Received by Baird Advisors
and Baird
Baird Advisors. Baird Advisors and its associates
do not receive compensation based upon the sale
of securities or other investment products. Baird
Advisors will purchase for client accounts, or will
recommend the purchase of, various investment
products, including “no load” mutual funds.
• fees imposed by the SEC or securities markets,
including transaction fees imposed by electronic
trading platforms, which fees may be imbedded
in the price the client receives for the debt
obligation; and
imposed upon or
resulting
• taxes
from
transactions effected for a client’s account, such
as income, transfer or transaction taxes, foreign
stamp duties, or any other costs or fees
mandated by law or regulation.
their own
internal
Baird. Baird is registered as a broker-dealer under
the Securities Exchange Act of 1934, as amended
(the “Exchange Act”), and in such capacity, Baird
provides brokerage and related services to clients,
including the purchase and sale of individual
stocks, bonds, mutual funds, private investment
funds, and other securities, and sales of life
insurance policies and annuities. Baird receives
compensation based upon the sale of such
securities and other
investment products,
including asset-based sales charges and service
fees on the sale of mutual funds. This practice
presents a conflict of interest because it gives
Baird (but not Baird Advisors or its associates) an
incentive to recommend investment products
based upon the compensation received rather
than on a client’s needs. A client has the option to
purchase
investment products through other
brokers or agents that are not affiliated with
Baird. For more specific information about Baird’s
compensation and other benefit arrangements
and how Baird addresses the potential conflicts of
Certain investment products, such as mutual
funds, exchange traded funds (“ETFs”), and other
similar investment pools (collectively, “investment
funds”), have
fees and
expenses that are borne either directly or
indirectly by their holders, including a client.
These fees are separate from, and in addition to,
Baird Advisors’ fee. As a result of making
investments in these types of products, a client
should be aware that the client is paying multiple
layers of fees and expenses on the amount of the
client’s assets so invested—those fees and Baird
Advisors’ fee. A client is also responsible for any
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Interest
interest, please see the sections “Other Financial
Industry Activities and Affiliations” and “Code of
Ethics, Participation or
in Client
Transactions and Personal Trading” below.
that all such clients receive fair and equitable
treatment over time. Baird has also adopted
policies and procedures reasonably designed to
ensure that client assets are valued by client’s
custodian.
to performance-based
into performance-based
endowments
and
fee arrangements are made
institutions;
and
registered
individuals.
Types of Clients
Baird Advisors offers its services to all types of
current and prospective clients, including, but not
limited to: pension and profit sharing plans;
trusts; estates; charitable organizations; colleges;
hospitals;
foundations;
corporations or other business entities; banks or
investment
thrift
companies;
Applicable
requirements for opening or maintaining an
account with Baird Advisors, such as minimum
account size, are discussed in the section entitled
“Fees and Compensation—Advisory Fee” above.
Performance-based
fixed
Methods of Analysis, Investment Strategies
and Risk of Loss
Methods of Analysis
Baird Advisors specializes in structured, risk-
controlled
income management. Our
approach is to define the appropriate level of risk
or volatility compatible with our client’s objective
and to deliver superior returns commensurate
with this risk.
Performance-Based Fees and Side-By-Side
Management
Baird Advisors and Baird advise client accounts
that are subject
fee
arrangements. However, Baird Advisors does not
typically enter
fee
arrangements and it will do so only in limited
circumstances if specifically requested by a client.
Any such
in
compliance with applicable provisions of Rule 205-
3 under the Advisers Act. A client’s agreement to
a performance-based fee arrangement may create
an incentive for Baird Advisors to recommend or
invest a client’s account in riskier or more
speculative products than would be the case in
fee
the absence of a performance-based
fee
arrangement.
arrangements also present a potential conflict of
interest for Baird Advisors and Baird with respect
to client accounts they also manage that are not
subject to performance-based fee arrangements
because such arrangements give Baird Advisors
and Baird an incentive to favor client accounts
subject to performance-based fees over client
accounts that are not subject to performance-
based fees.
is why our disciplined,
We believe that the bond capital market is very
efficient in discounting risk and return potential
over time for taking interest rate risk along the
duration curve. This efficiency has made interest
rate timing strategies very difficult for active bond
managers to consistently get right and add value.
This
risk-controlled
investment approach starts with a duration
neutral position versus the market benchmark it
is expected to outperform and seeks to add
incremental value through more bottom-up yield
curve positioning, sector allocation, security
selection and competitive execution of trades.
to detect any possible
to make securities allocations
In addition to complying with its fiduciary duties
by disclosing this conflict of interest to clients
through this Brochure, Baird Advisors generally
addresses potential conflicts of interest posed by
performance-based fee arrangements by capping
the amount of performance-based fees that may
be earned with respect to a client’s account. By
capping performance-based fees, Baird Advisors
attempts to reduce the incentive to invest a
client’s account in riskier or more speculative
products. Baird Advisors also periodically monitors
the holdings and performance of performance-
based fee accounts and compares them to
accounts not subject to a performance fee that
are also managed using a similar strategy in an
attempt
inequitable
treatment. Baird Advisors and Baird also attempt
to minimize potential conflicts of interest posed by
performance-based fee arrangements through
internal trade allocation procedures that are
designed
to
discretionary client accounts in a manner such
Yield Curve Positioning. The yield curve is a
graphic representation of yields offered by fixed
income debt obligations in relation to their
maturities and durations. Baird Advisors selects
debt obligations with maturities and yields that it
believes have the greatest potential for achieving
a
to
client’s objective, while attempting
substantially match the average duration of the
client’s portfolio with the average duration of the
client’s benchmark index.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
fiduciary duties with its investment objective of
strong risk-adjusted performance.
to ESG
integration
Environmental, social, and governance related
risk factors are integrated into Baird Advisors’
investment process and serve as important inputs
to the investment team’s decision-making and
research efforts as it assesses the long-term
sustainability of a bond issuer. Baird Advisors’
approach
focuses on
identifying material risk factors that can impact
an issuer’s ultimate creditworthiness and the
valuation of securities it issues.
invests
Sector Allocation. Baird Advisors also evaluates
the return potential of each sector. These sectors
include: U.S., government and other public sector
entities, asset-backed and mortgage-backed
obligations of U.S. and foreign issuers and
corporate debt of U.S. and foreign issuers for
clients pursuing the Ultra Short Bond, Short-Term
Bond, Intermediate Bond, Aggregate Bond, Core
Plus Bond and Liability-Driven Investing Portfolio
Strategies; and tax-exempt general obligation
bonds, revenue bonds, pre-refunded bonds, and
insured bonds for clients pursuing the Quality
Intermediate Municipal Bond Portfolio Strategy,
Core
Intermediate Municipal Bond Portfolio
Strategy, Short/Intermediate Municipal Bond
Portfolio Strategy, Short-Term Municipal Bond
Portfolio Strategy, 1-3 Year Municipal Bond
Portfolio Strategy, Municipal Bond Portfolio
Strategy, and Strategic Municipal Bond Portfolio
Strategy. Baird Advisors
in debt
obligations in those sectors which it believes
represent the greatest potential for achieving a
client’s objectives.
Selection.
Long-term
in
Competitive Execution of Trades. Competitive
execution of each trade represents the final step
in adding value to a portfolio. When we buy and
sell securities, we seek to ensure best execution
of each trade, taking into account price, security
and counterparty risks, the terms and conditions
imposed by the dealer in connection with the
factors we deem
trade, and certain other
appropriate. We have long-standing relationships
with the leading broker/dealer firms and are
continually
them, actively
touch with
monitoring yield spreads and bonds’ actual
trading levels as reported by dealers in FINRA’s
Trade Reporting and Compliance Engine system
(“TRACE”) and dealer posts.
to
process, we
focus
on
Security
strategic
investment decisions serve as the basis for
incorporating specific securities into portfolios.
Baird Advisors starts with the strategy benchmark
and focuses on the individual securities that can
best accomplish its goal. Every characteristic of a
security is carefully analyzed. Baird Advisors first
determines which issuers appear to offer the best
relative value within each sector. Available issues
are selected based on credit quality, duration
characteristics, embedded options, and liquidity.
Given the opportunity to add value to a portfolio
while maintaining strict adherence
the
guidelines and controlling risk, Baird Advisors
may purchase securities of comparable or similar
quality which are not part of the benchmark.
experienced
portfolio
As a fixed income investment manager, Baird
Advisors has a fiduciary responsibility to act in the
best long-term interest of its clients with the goal
of generating consistent and competitive long-
term investment results over time. The team
believes material environmental, social, and
governance (“ESG”) risk factors can have an
impact on long-term sustainability and need to be
considered in the overall risk assessment of
issuing entities. Baird Advisors believes
its
approach to integrating environmental, social,
and governance risk factors as considerations
across the investment process helps to align its
to active bond management
Our approach
emphasizes
the value added of bottom-up
security selection. We begin with the client’s
investment objectives and guidelines to determine
the permissible universe of bonds we can invest in
and to define the overall risk tolerance. In the
construction
the
contribution-to-duration and percentage exposure
of each security and sector when analyzing any
allocation to the portfolio and our goal is to
effectively measure and control the duration or
price risk of each portfolio versus the benchmark.
Each permissible security is evaluated based on
the credit fundamentals of the issuer or the
underlying asset collateral, the structural risks of
the security itself and market liquidity risk. This
risk identification process is facilitated with the
use of multiple quantitative models coupled with
managers
highly
interpreting the output from these models and
providing an additional qualitative assessment of
the risk inherent in each security. After the risks
of the security are quantified, the valuation is
expressed in terms of expected excess return
over a comparable US Treasury (or other
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Baird Advisors Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
portfolio management process. Baird has
established policies and procedures designed to
address the risks posed by AI Tools, which include
requirements that AI Tools pass a Baird-level due
diligence process and that Baird associates obtain
training and independently verify AI Tool outputs.
However, such measures cannot completely
eliminate the risks posed by AI Tools.
appropriate reference instrument such as AAA-
rated Municipal) and the security is compared to
securities with similar risk profiles within and
across various sectors. This relative value analysis
helps us select the securities we believe are
undervalued and have the best risk-adjusted
expected return potential within the permissible
universe of bonds. Our portfolio construction
process assembles these securities with above-
average risk-adjusted expected returns focusing
on risk control relative to the benchmark and the
discipline of diversification.
government
entities,
and, when
On an ongoing basis, Baird Advisors’ portfolio
managers monitor client portfolios to evaluate the
impact of changing economic and market
conditions. In addition, the appropriateness of the
client’s portfolio holdings are also assessed in
terms of the client’s overall objectives, such as
return expectations, risk tolerance, and liquidity
trading opportunities are
needs. Ongoing
deemed
reviewed
analyzed,
appropriate, executed.
Portfolio Investments
Baird Advisors may invest a client’s account from
time to time in any combination of U.S. dollar-
denominated debt obligations that are fixed,
variable or floating rate instruments, including but
not limited to, obligations of government and
other public sector entities (including, but are not
limited to, U.S., state and local (municipal)
governments and their agencies and authorities,
foreign
and
non‑governmental organizations), asset-backed
and mortgage-backed obligations of U.S. and
foreign issuers, corporate debt of U.S. and foreign
issuers, mutual funds, ETFs, other registered
investment companies, and other investment
pools (including such funds affiliated with Baird)
and money market instruments.
loans, utilities,
summarization,
analysis
of
Baird
Advisors’
Baird Advisors may use artificial intelligence
(“AI”) tools, such as machine learning, predictive
analytics and probabilistic modeling tools, data
processing and automation tools, generative AI
tools, visual, speech and audio tools, specialized
domain tools, and other similar technologies and
tools (collectively, “AI Tools”), in formulating
investment decisions. Generally, the use of AI
Tools is limited to certain aspects of Baird
Advisors’ investment process, such as assisting
with drafting of materials, automation of workflow
processes, and the compilation, reproduction,
organization,
and
interpretation of information. The use of AI Tools
is only supportive of Baird Advisors’ investment
process and does not replace the professional
judgment
investment
professionals. All AI Tool-assisted outputs used in
the portfolio management process are subject to
human
inform
review before such outputs
recommendations or investment decisions.
government
obligations,
Asset‑backed obligations in which a client account
may invest are backed with underlying assets
such as credit card receivables, auto receivables,
reimbursement/rate
student
increase allowances and certain residential home
loans. The types of municipal obligations used by
Baird Advisors include, but are not limited to,
taxable and tax‑exempt general obligation and
revenue bonds, as well as advance refunded and
escrowed‑to‑maturity bonds. For clients pursuing
municipal bond strategies, Baird Advisors may
also use other municipal obligations, including
pre‑refunded bonds, general obligation bonds,
revenue bonds and municipal lease participations,
zero coupon bonds, and municipal housing bonds.
Money market instruments in which a client
account may invest include, among other things,
repurchase
U.S.
agreements, cash, bank obligations, commercial
paper, variable amount master demand notes,
corporate bonds, certificates of deposit and
money market funds.
Certain strategies may invest in non-investment
grade or unrated instruments. To the extent a
client is eligible, Baird Advisors may invest a
client account in Rule 144A securities, which are
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations,
deceptive behaviors and other flaws due to the
construction of their underlying models and the
composition of their training data, which can
result in outputs that seem plausible but are in
fact inaccurate, incomplete, or misleading. The
use of AI Tools creates a risk that erroneous
the
information
could negatively
influence
7
Baird Advisors Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
regulations
(known
as
not registered under the federal securities laws
and cannot be sold to the U.S. public because of
SEC
“restricted
securities”).
under
investment
Intermediate Bond Portfolio Strategy. The
investment objective of the Intermediate Bond
Portfolio Strategy is to seek an annual rate of
total return, before expenses, greater than the
annual rate of total return of the Bloomberg
Intermediate U.S. Government/Credit Bond
Index. The Bloomberg
Intermediate U.S.
Government/Credit Bond Index is an unmanaged,
market value weighted index of investment grade,
fixed-rate debt
including government and
corporate securities with maturities between one
and ten years.
Baird Advisors may use futures contracts for
certain of its bond fund strategies and may also
use U.S. Treasury Futures for client accounts if
approved
policy
their
statement. From time to time, Baird Advisors may
also use bank loans, common or preferred stocks,
warrants, rights, publicly-traded master limited
partnerships (“MLPs”), and protective long put
options strategies.
the Bloomberg Quality
investment
returns
Investment Strategies
Baird Advisors uses investment strategies that are
intended to generate an annual rate of return
that, before the deduction of fees, is greater than
the benchmark selected for the client’s portfolio
over full market cycles. Baird Advisors also
manages portfolios in a manner designed to limit
the dispersion of
in
comparison to the client’s benchmark index.
consisting of
tax-exempt,
Baird Advisors offers the following investment
strategies to clients:
Quality Intermediate Municipal Bond Portfolio
Strategy. The primary investment objective of the
Quality Intermediate Municipal Bond Portfolio
Strategy is to seek current income that is
substantially exempt from federal income tax. A
secondary objective is to seek total return with
relatively low volatility of principal. The Quality
Intermediate Municipal Bond Portfolio Strategy
Intermediate
uses
Municipal Bond Index as its benchmark. The
Bloomberg Quality Intermediate Municipal Bond
Index is an unmanaged, market value weighted
index
fixed-rate
securities that are rated A3 or better, with
maturities between two and twelve years.
Ultra Short Bond Portfolio Strategy. The
investment objective of the Ultra Short Bond
Portfolio Strategy is to seek current income
consistent with preservation of capital. The
Strategy’s benchmark is the Bloomberg U.S.
Short-Term Government/Corporate Index. The
Short-Term
U.S.
Bloomberg
Government/Corporate Index is an unmanaged,
market value weighted index that tracks the
performance of U.S. government and corporate
bonds rated investment grade or better, with
maturities of less than one year.
Portfolio Strategy.
Short-Term Municipal Bond Portfolio Strategy. The
investment objective of the Baird Short-Term
Municipal Bond Portfolio Strategy is to seek
current income that is exempt from federal
income tax and is consistent with the preservation
of capital. The Short-Term Municipal Bond
Portfolio Strategy uses the Bloomberg Short (1-5
Year) Municipal Index as its benchmark. The
Bloomberg Short (1-5 Year) Municipal Bond Index
is an unmanaged, market value weighted index
that measures the performance of investment-
grade, tax-exempt, and fixed-rated municipal
securities with time to maturity of more than one
year and less than five years.
including government and
Short-Term Bond
The
investment objective of the Short-Term Bond
Portfolio Strategy is to seek an annual rate of
total return, before expenses, greater than the
annual rate of total return of the Bloomberg 1-3
Year U.S. Government/Credit Bond Index. The
Bloomberg 1-3 Year U.S. Government/Credit
Bond Index is an unmanaged, market value
weighted index of investment grade, fixed-rate
debt
corporate
securities with maturities between one and three
years.
(1-10 Year)
Index
Short/Intermediate Municipal Bond Portfolio
Strategy. The investment objective of the Baird
Short/Intermediate Municipal Bond Portfolio
Strategy is to seek a high level of current income
that is exempt from federal income tax and is
consistent with preservation of capital. The
Short/Intermediate Municipal Bond Portfolio
Strategy uses the Bloomberg 1-10 Year Municipal
Bond Index as its benchmark. The Bloomberg
is an
Municipal Bond
unmanaged, market value weighted index of
8
Baird Advisors Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment-grade, tax-exempt, and
fixed-rate
securities with maturities between one and ten
years.
debt
issues,
including
total return, before fund expenses, greater than
the annual rate of total return of the Bloomberg
U.S. Aggregate Bond Index. The Bloomberg U.S.
Aggregate Bond Index is an unmanaged, market
value weighted index of investment grade, fixed-
rate
government,
corporate, asset-backed, and mortgage-backed
securities, with maturities of at least one year.
Core
Intermediate Municipal Bond Portfolio
Strategy. The investment objective of the Baird
Core
Intermediate Municipal Bond Portfolio
Strategy is to seek a high level of current income
that is exempt from federal income tax and is
consistent with preservation of capital. The Core
Intermediate Municipal Bond Portfolio Strategy
uses the Bloomberg Municipal Bond (1-15) Year
Index as its benchmark. The Bloomberg Municipal
Bond (1-15 Year) Index is an unmanaged, market
value weighted index of investment-grade, tax-
exempt, and fixed-rate securities with maturities
between one and 17 years.
Core Plus Bond Portfolio Strategy. The investment
objective of the Core Plus Bond Portfolio Strategy
is to seek an annual rate of total return, before
fund expenses, greater than the annual rate of
total return of the Bloomberg U.S. Universal Bond
Index. The Bloomberg U.S. Universal Bond Index
is an unmanaged, market value weighted index of
fixed income securities issued in U.S. dollars,
including U.S. government and investment grade
debt, non-investment grade debt, asset-backed
and mortgage-backed securities, Eurobonds,
144A securities and emerging market debt with
maturities of at least one year.
1-3 Year Municipal Bond Portfolio Strategy. The
investment objective of the Baird 1-3 Year
Municipal Bond Portfolio Strategy is to seek
current income that is exempt from federal
income tax and is consistent with the preservation
of capital. The 1-3 Year Municipal Bond Portfolio
Strategy uses the Bloomberg 1-3 Year Composite
Municipal Bond Index, which is an equal-weighted
blended Index of both the Bloomberg 1 Year
Index and the Bloomberg 3 Year Index.
Liability-Driven Investing (LDI) Portfolio Strategy.
The investment objective of the Liability-Driven
Investing Portfolio Strategy is to seek an annual
rate of total return, before expenses, greater than
the annual rate of total return of a benchmark
selected for the client’s portfolio. The particular
benchmark is selected based on the specific client
portfolio’s investment objectives and may be
either a published benchmark or a custom
benchmark.
Municipal Bond Strategy. The
investment
objective of the Baird Municipal Bond Portfolio
Strategy is to seek a current income that is
exempt from federal income tax and is consistent
with preservation of capital. The Municipal Bond
Portfolio Strategy uses the Bloomberg Municipal
Bond Index as its benchmark.
Other Strategies. Baird Advisors also manages
client assets in accordance with other investment
strategies specifically designed for a client in light
of a client’s particular needs.
Temporary Strategies. Baird Advisors may invest
all of a client’s assets in cash or short-term,
investment grade debt obligations as a temporary
defensive position during adverse market,
economic or political conditions and in other
limited circumstances.
(1-10 Year)
Index
Strategic Municipal Bond Portfolio Strategy. The
investment objective of the Baird Strategic
Municipal Bond Portfolio Strategy is to seek
current income that is exempt from federal
income tax and is consistent with preservation of
capital. The Strategic Municipal Bond Portfolio
Strategy uses the Bloomberg 1-10 Year Municipal
Bond Index as its benchmark. The Bloomberg
Municipal Bond
is an
unmanaged, market value weighted index of
investment-grade, tax-exempt, and
fixed-rate
securities with maturities between one and ten
years.
Bond
Portfolio
Strategy.
Aggregate
The
investment objective of the Aggregate Bond
Portfolio Strategy is to seek an annual rate of
Although each portfolio strategy targets the
annual rate of return of a specific benchmark
index, the investments selected by Baird Advisors
generally will not mirror the assets in their
respective benchmark indices. There can be no
assurance that any particular portfolio strategy
will be successful
in achieving the client’s
investment goals and objectives.
9
Baird Advisors Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
benchmark index, so material events affecting a
client’s portfolio (for example, an issuer’s decline
in credit quality) may influence the performance
to a greater degree than such events will
influence the client’s benchmark index.
in
Bond Market Risks. The major risks of each
strategy are those of investing in the bond
market. A bond’s market value
is affected
significantly by changes
interest rates—
generally, when interest rates rise, the bond’s
market value declines and when interest rates
decline, its market value rises (“interest rate
risk”). Generally, the longer a bond’s maturity,
the greater the interest rate risk and the higher
its yield. Conversely, the shorter a bond’s
maturity, the lower the interest rate risk, and the
lower its yield (“maturity risk”). Because bond
values may fluctuate, a client’s portfolio value
may fluctuate.
in
Call Risks. If the securities in which the client
invests are redeemed by the issuer before
maturity (or “called”), the client may have to
reinvest the proceeds in securities that pay a
lower interest rate, which may decrease the yield
for the client’s portfolio. This will most likely
happen when interest rates are declining.
Baird Advisors seeks to control credit quality risk
by purchasing only investment grade, U.S. dollar-
denominated debt obligations for client accounts
pursuing the Short-Term Bond, Intermediate
Bond, Quality Intermediate Municipal Bond or
Aggregate Bond Portfolio Strategies. Client
accounts pursuing the Ultra Short Bond, Core Plus
Bond, Core
Intermediate Municipal Bond,
Short/Intermediate Municipal Bond, Short-Term
Municipal Bond, 1-3 Year Municipal Bond ,
Municipal Bond and Strategic Municipal Bond
Portfolio Strategies will be invested primarily in
investment grade debt obligations, but Baird
Advisors may also invest up to 10%, 20%, 10%,
10%, 10%, 5%, 15% and 30%, respectively, of a
client’s net assets in debt obligations that are
non-investment grade at time of purchase. Client
accounts pursuing the Liability-Driven Investing
Portfolio Strategy will primarily be invested in
investment grade debt obligations, but Baird
Advisors may also invest in non-investment grade
debt obligations and in U.S. Treasury Futures if
authorized by the client. For client accounts
pursuing the 1-3 Year Municipal Bond Portfolio,
Municipal Bond Portfolio or Strategic Municipal
Bond Portfolio Strategies, Baird Advisors may
futures contracts. Baird Advisors
invest
attempts to diversify each client’s portfolio by
holding debt obligations of many different issuers
and choosing issuers in a variety of sectors.
receiving
the
interest payments due
conditions
or
to changes
other
they will
contain
Principal Risks
Risk is inherent in any investment in debt
obligations and Baird Advisors does not guarantee
any level of return on a client’s investments.
There is no assurance that a client’s investment
objectives will be achieved. A Baird Advisors client
may be subject to certain risks, including, but not
limited to, the risks described below. The risks
discussed below vary by investment style or
strategy, and the specific investments in the
client’s portfolio, and each risk may or may not
apply to a client. A client should also review the
prospectuses or other disclosure documents for
the debt obligations purchased for the client’s
account, as
important
information about the risks associated with
investing in such debt obligations.
Management Risks. Baird Advisors may err in its
choices of debt obligations or portfolio allocations,
including the integration of ESG factors. Such
errors could result in a negative return and a loss
to clients. Each client’s portfolio may hold fewer
or different debt obligations than the client’s
Credit Quality Risks. Individual issues of fixed
income debt obligations may be subject to the
credit risk of the issuer. Therefore, the underlying
issuer may experience unanticipated financial
problems and may be unable to meet its payment
obligations. Municipal obligations in particular
may be adversely affected by political and
economic conditions and developments (for
example, legislation reducing state aid to local
governments.) Bonds
lowest
investment grade rating or a non-investment
grade rating may have speculative characteristics
and, compared to higher grade debt obligations,
may have a weakened capacity to make principal
and
in
adverse
economic
circumstances. Ratings agencies such as Moody’s,
Fitch and S&P provide ratings on bonds based on
their analyses of information they deem relevant.
Ratings are essentially opinions or judgments of
the credit quality of an issuer and may prove to
be inaccurate. In addition, there may be a delay
between events or circumstances adversely
affecting the ability of an issuer to pay interest
and/or repay principal and an agency’s decision to
downgrade a security.
10
Baird Advisors Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the value of mortgage-backed
decline
in
obligations.
Non-investment
grade
in
it
invests experiences
Municipal Obligations Risks. Clients pursuing the
Quality Intermediate Municipal Bond Portfolio
Strategy, Core Intermediate Municipal Bond
Portfolio Strategy, Short-Term Municipal Bond
Portfolio Strategy and the Short/Intermediate
Municipal Bond Portfolio Strategy may have more
than 25% of their portfolios invested in municipal
obligations issued by entities located in the same
state or the interest on which is paid solely from
revenues of similar projects. As a result, changes
in economic, business or political conditions
relating to a particular state or types of projects
may have a disproportionate impact on client’s
portfolio value. The repayment of principal and
interest on some of the municipal debt obligations
in which clients may invest may be guaranteed or
insured by a monoline insurance company. The
monoline guarantee or insurance will generally
enhance the credit rating and lower the interest
rate payable by the issuer on the debt obligation.
Certain monoline insurers have suffered losses
from insuring structured products and other debt
obligations backed by residential mortgages. If a
company insuring municipal debt obligations in
which a client
financial
difficulties, the credit rating and price of the debt
obligation may deteriorate.
Non-Investment Grade Bond Risks. Non-
investment grade debt obligations, while generally
offering higher yields than investment grade debt
obligations with similar maturities, involve greater
including the possibility of default or
risk,
bankruptcy.
debt
obligations tend to be more sensitive to economic
conditions than higher-rated debt obligations. As
a result, they generally are more sensitive to
credit risk and are considered more speculative
than debt obligations
the higher-rated
categories. During an economic downturn or a
sustained period of rising interest rates, highly
leveraged issuers of non-investment grade debt
obligations may experience financial stress and
may not have sufficient cash flow to meet their
payment obligations. The risk of loss due to
default by an issuer of these obligations is
significantly greater than issuers of higher-rated
obligations because such obligations are generally
unsecured and are often subordinated to other
creditors. Baird Advisors may have difficulty
disposing of certain non-investment grade debt
obligations because there may be a thin trading
market for such obligations. To the extent a
secondary trading market does exist,
is
generally not as liquid as the secondary market
for higher-rated debt obligations. Periods of
economic uncertainty generally result in increased
volatility in the market prices of these debt
obligations and will also increase the volatility of
the client’s portfolio value.
interest rates
Municipal Housing Bonds Risks. Municipal housing
bonds are bonds issued by state and municipal
authorities established to purchase single family
and other residential mortgages from commercial
banks and other lending institutions within the
applicable state or municipality. Certain factors,
including changes in national and state policies
relating to payments such as unemployment
insurance and welfare, and adverse economic
developments, particularly those affecting less
skilled and low-income workers, may affect the
mortgagor’s ability to maintain payments under
the underlying mortgages. Mortgages may also be
partially or completely prepaid prior to their final
stated maturities.
investing the proceeds
to extension
lease,
interests
Mortgage- and Asset-Backed Debt Obligations
Risks. Mortgage- and asset-backed obligations
can be more sensitive to interest rate risk than
other types of fixed income debt obligations.
Modest movements
interest rates (both
in
increases and decreases) may quickly and
significantly reduce the value of certain types of
these obligations. When
fall,
mortgage- and asset-backed obligations may be
subject to prepayment risk. Prepayment risk is
the risk that the borrower will prepay some or the
entire principal owed to the investor. If that
happens, Baird Advisors may have to replace the
obligation by
in an
obligation with a lower yield. When interest rates
rise, certain types of mortgage- and asset-backed
risk.
obligations are subject
Mortgage- and asset-backed obligations can also
be subject to the risk of default on the underlying
residential or commercial mortgages or other
assets. Weakening real estate markets may cause
default rates to rise, which would result in a
Municipal Lease Obligations Risks. Some client
portfolios may purchase participation interests in
municipal leases. These are undivided interests in
a
installment purchase contract, or
conditional sale contract entered into by a state or
local government unit to acquire equipment or
in municipal
facilities. Participation
leases pose special risks because many leases
11
Baird Advisors Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
liquidate securities at an inopportune time in
order to distribute cash, as required by tax laws.
facilities
in
and contracts contain “non-appropriation” clauses
that provide that the governmental issuer has no
obligation to make future payments under the
lease or contract unless money is appropriated for
this purpose by the appropriate legislative body.
Although these kinds of obligations are secured by
the leased equipment or facilities, it might be
difficult and time consuming to dispose of the
the event of
equipment or
nonappropriation, and
the client might not
recover the full principal amount of the obligation.
When-Issued, Delayed Delivery and Forward
Commitments Risks. When-issued, delayed
delivery and forward commitment transactions
involve the risk that the price or yield obtained in
a transaction (and therefore the value of a debt
obligation) may be less favorable than the price
or yield (and therefore the value of a debt
obligation) available in the market when the debt
obligations delivery takes place. Failure of the
other party to consummate the trade may result
in the client incurring a loss or missing an
opportunity to obtain a price considered to be
advantageous.
slower
payments
Extension Risks. Extension risk is the risk that
debt obligations, including mortgage- and asset-
backed obligations, will be paid off more slowly
than originally anticipated, increasing the average
life of such debt obligations and the sensitivity of
the prices of such debt obligations to future
interest rate changes. For example, rising interest
rates could cause property owners to pay their
mortgages more slowly than expected, resulting
of mortgage-backed
in
obligations. This could lengthen the duration of
the obligation, making its price more sensitive to
interest rate changes.
Futures Contracts Risks. Futures contracts are
subject to the same risks as the underlying
investments that they represent, but also may
involve risks different from, and possibly greater
than, the risks associated with investing directly
in the underlying investments. Investments in
futures contracts may result in a substantial loss
in a short period. The loss may be potentially
unlimited and may be more than the original
investment. Investments in futures contracts
involve additional costs, may be more volatile
than other investments and may involve a small
initial investment relative to the risk assumed. If
Baird Advisors incorrectly forecasts the value of
investments in using a futures contract, a client
might have been in a better position than if the
client had not entered into the contract. In the
futures markets, it may not always be possible to
execute a buy or sell order at the desired price, or
to close out an open position due to market
conditions, limits on open positions and/or daily
price fluctuations. Changes in the value of a
client’s investment may differ substantially from
the changes anticipated by the client when it
established the positions, and unanticipated price
movements in a futures contract may result in a
loss substantially greater than the client’s initial
investment in such a contract.
Government Obligation Risks. Baird Advisors may
invest client assets in debt obligations issued,
sponsored or guaranteed by the U.S. government,
its agencies and instrumentalities. However, no
assurance can be given that the U.S. government
will provide financial support to U.S. government-
sponsored agencies or instrumentalities where it
is not obligated to do so by law. For instance,
debt obligations
issued by the Government
National Mortgage Association (“Ginnie Mae”) are
supported by the full faith and credit of the United
States. Debt obligations issued by the Federal
National Mortgage Association (“Fannie Mae”) and
the Federal Home Loan Mortgage Corporation
(“Freddie Mac”) have historically been supported
only by the discretionary authority of the U.S.
government. While the U.S. government provides
financial support to various U.S. government-
sponsored agencies and instrumentalities, such as
those listed above, no assurance can be given
that it will always do so.
Treasury Futures Risks. Risks associated with the
use of futures contracts include risks outlined
elsewhere, such as interest rate risks, liquidity
risks, credit risks, and management risks, as well
as risks associated with the use of derivatives.
Derivatives are financial contracts whose value
are derived from the value of an underlying asset,
reference rate, or index.
Zero Coupon Bonds Risks. Zero coupon bonds do
not pay interest on a current basis and may be
highly volatile as interest rates rise or fall. In
addition, while such bonds generate income for
purposes of generally accepted accounting
standards, they do not generate cash flow and
thus could cause the client to be forced to
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
lead to decreased liquidity and increased volatility
in the fixed income markets.
interest
in
relation
respect
to certain
taxation,
or
Foreign Securities Risks. Foreign investments,
even those that are U.S. dollar-denominated, may
involve additional risk, including political and
economic instability and differences in financial
reporting standards, in addition to less regulated
securities markets. Such securities may also be
subject to greater fluctuations in price than
securities of domestic corporations. In addition,
there may be less publicly available information
about a foreign company than about a domestic
company. With
foreign
countries, there is a possibility of expropriation or
confiscatory
diplomatic
developments, which could affect investments in
those countries.
Tax Risks. Municipal debt obligations may
decrease in value during times when tax rates are
falling. Since
income on municipal
obligations is normally not subject to regular
federal income taxation, the attractiveness of
municipal obligations
to other
investment alternatives is affected by changes in
federal income tax rates applicable to, or the
continuing federal tax-exempt status of, such
interest income. Any proposed or actual changes
in such rates or exempt status, therefore, can
significantly affect the liquidity, marketability and
supply and demand for municipal obligations,
which would in turn affect Baird Advisors’ ability
to acquire and dispose of municipal obligations at
desirable yield and price levels. Investment in
tax-exempt debt obligations poses additional
risks. In many cases, the Internal Revenue
Service (“IRS”) has not ruled on whether the
interest received on a tax-exempt obligation is
tax-exempt, and accordingly, purchases of these
debt obligations are based on the opinion of bond
counsel to the issuers at the time of issuance.
Baird Advisors relies on these opinions and will
not review the basis for them.
Sector Risks. From time to time, based on market
or economic conditions, a client account may have
significant positions in specific sectors of the
market. Potential negative market or economic
developments affecting one or more of these
sectors could have a greater impact on the client’s
account than on an account with fewer holdings in
that sector.
Security,
Cybersecurity
the
that
could
compromise
technology
Such
incidents may
it
less desirable
for
those
Liquidity Risks. Liquidity risk is the risk that
certain debt obligations may be difficult or
impossible to sell at the time and price that Baird
Advisors would like to sell. Baird Advisors may
have to lower the price, sell other debt obligations
or forego an investment opportunity, any of which
may have a negative effect on the management
or performance of client portfolios. The liquidity of
a particular debt obligation depends on the
strength of demand for the debt obligation, which
is generally related to the willingness of broker-
dealers to make a market for the debt obligation
as well as the interest of other investors to buy
the debt obligation. During periods of economic
uncertainty, significant economic and market
downturns and periods in which financial services
firms are unable to commit capital to make a
market
in, or otherwise buy, certain debt
obligations, Baird Advisors may experience
challenges in selling such obligations at optimal
prices. In addition, recent regulatory changes
applicable to financial intermediaries that make
markets in debt securities have restricted or
financial
made
intermediaries to hold large inventories of debt
securities. Because market makers provide
stability to a market through their intermediary
services, a reduction in dealer inventories may
Information
and
Technology-Related Risks. As issuers and their
service providers increasingly rely on digital
technologies, such as
Internet, cloud
computing, and AI‑enabled systems, they face
heightened information security, cybersecurity,
and other technology‑related risks,
including
the
incidents
confidentiality, integrity, or availability of their
systems, data, or
infrastructure.
Technology-related incidents may result from
deliberate adversarial actions (such as cyber
attacks) or unintentional events (such as systems
or human error) and could have a materially
adverse impact on the issuer’s performance and
operations.
involve
unauthorized access, disclosure, use, corruption,
degradation, or destruction of systems or data
(such as
through hacking, malware, social
engineering or theft of digital devices); or the
disruption of systems access to authorized users
(such as through denial of service attacks). Such
events can impede critical functions, compromise
sensitive business and protected customer
information, and may result in financial losses,
business interruptions, impediments to the ability
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
or
penalties,
reputational
involve
investigate,
or
remediate
in
the
section
titled
their
own
information
related
incidents
use
protected
incidents,
to process transactions, breaches of applicable
privacy, data protection, or other laws, regulatory
fines
harm,
reimbursement or other remediation costs, and
increased compliance or operational expenses.
Substantial costs may be incurred to prevent,
detect,
future
technology related incidents. Issuers’ increasing
use of AI systems introduces additional risks
discussed
“Artificial
Intelligence Risks” below. Issuers may also rely
on third party or cloud based platforms that
security,
present
cybersecurity, and other technology‑related risks.
Similar adverse consequences may arise from
technology
affecting
governmental authorities,
regulatory bodies,
financial market systems, exchanges, brokers-
dealers, banks, insurance companies, custodians,
or other market participants. Although issuers and
their service providers may adopt business
continuity plans, information security controls,
and risk management programs designed to
prevent or mitigate such
these
measures are subject to inherent limitations,
including the possibility that certain risks may not
be identified or fully addressed. As a result, client
Accounts and investments may be negatively
affected.
systems, infrastructure, and data, which can
create vendor dependency, limit visibility into and
validation of AI model performance, and increase
the risk of disruption in data availability. The
regulatory environment for AI is rapidly evolving
inconsistent or conflicting
and may
requirements across
jurisdictions. Compliance
may require significant investment, changes to AI
the discontinuation of certain
systems, or
AI‑enabled features. Non‑compliance may lead to
fines, enforcement actions, or operational
constraints. AI systems are vulnerable
to
cyberattacks or other adversarial actions that can
impair system performance and integrity and
compromise sensitive business and protected
customer information. The impairment of AI
systems or
the unauthorized disclosure of
sensitive business or protected information can
result in material disruption and damage to
legal and
significant
business operations,
regulatory
remediation
liabilities, substantial
expenses, and reputational harm. AI systems may
inadvertently
information,
potentially giving rise to intellectual property
infringement claims and substantial damages.
Public concerns regarding fairness, transparency,
and responsible use of AI may reduce demand for
an issuer’s products or services. Failure to use AI
responsibly may harm an issuer’s reputation and
competitive position.
tools
timely access
Money Market Fund Risks. An investment in a
money market fund is not insured or guaranteed
by the FDIC or any other government agency.
Although money market funds typically seek to
preserve the value of an investment at $1.00 per
share, there can be no assurance that will occur,
and it is possible to lose money should the fund
value per share fall. In some circumstances,
money market funds may be forced to cease
operations when the value of a fund drops. In
that event, the fund's holdings may be liquidated
and distributed to the fund's shareholders. This
liquidation process could take time to complete.
During that time, the amounts a client has
invested in the money market fund would not be
available for purchases or withdrawals. Certain
types of money market funds are required to
calculate their NAV in a manner such that the NAV
will vary based upon the market value of assets
and liabilities of the fund (also known as a
“floating NAV”). In addition, certain money
market funds are required to impose redemption
fees (also known as liquidity fees) and suspend
redemptions (also known as redemption gates) in
Artificial Intelligence Risks. Issuers of investments
increasingly use AI systems in various aspects of
their business operations, creating competitive
market pressures to increase the development
and use of AI systems. Failure to effectively
develop or use AI systems may place an issuer at
a competitive disadvantage. At the same time, AI
systems present significant risks that could
materially affect an issuer’s business and financial
performance. AI Tools rely on complex models,
large datasets, and evolving algorithms. AI Tools
are highly-useful but complex and fallible systems
that can exhibit bias, hallucinations, deceptive
behaviors and other flaws due to the construction
of their underlying models and the composition of
their training data, which can result in outputs
that seem plausible but are in fact inaccurate,
incomplete, or misleading. The use of erroneous
outputs can undermine customer trust and
expose issuers to litigation, regulatory scrutiny,
substantial remediation costs, and reputational
harm. AI
to
require
high‑quality, compliant data, and any disruption in
data availability can impair or disable AI Tool
functionality. Issuers often rely on third-party AI
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Federal Reserve and political divisions and discord
add further uncertainty to the economic outlook.
certain circumstances. More specific information
about how a money market fund calculates its
NAV and the circumstances under which it will
impose a redemption fee or suspend redemptions
is set forth in the prospectus for that money
market fund.
Internationally, geopolitical risks have increased
as the U.S. and Israel are engaged in a military
conflict with Iran. The conflict has disrupted
global trade and caused an increase in the price
of oil. The continuation or escalation of military
strikes could lead to a lengthy period of military
conflict, and Iran’s military attacks and other
hostile actions against other countries present a
risk of widening the conflict. In addition, the war
between Ukraine and Russia is now passing its
fourth anniversary, instability in parts of the
Middle East persist, and relations between the
U.S. and other countries are strained.
Protective Long Put Options. Options trading is a
highly specialized activity that entails greater than
ordinary investment risks, including the complete
loss of the amount paid as premiums to the writer
of the option. Regardless of how much the market
price of the underlying debt obligation or index
increases or decreases, the option buyer’s risk is
limited to the amount of the original investment
for the purchase of the option. Options may be
more volatile than the underlying debt obligations
or indices, and therefore, on a percentage basis,
an investment in options may be subject to
greater fluctuation than an investment in the
underlying debt obligations. There is no assurance
that a liquid secondary trading market exists for
closing out an unlisted option position.
Furthermore, unlisted options are not subject to
the protections afforded purchasers of listed
options by CME Clearing, which performs the
obligations of its members who fail to perform in
connection with the purchase or sale of options.
Rapid advancements in artificial intelligence (AI)
and automation are increasingly influencing global
economic trends, corporate decision making, and
financial market dynamics. Expanding investment
in these technologies is contributing to shifts in
how industries operate, compete, and allocate
resources. The fast pace of technological change,
potential disruptions to existing business models,
and evolving regulatory responses
introduce
additional uncertainty and may contribute to
market volatility.
and
Taken together, these developments may have a
significant negative impact upon global economic
conditions and contribute to a heightened risk
environment. As a result, fluctuations in asset
prices may increase, and such volatility could
adversely affect the value of a client’s portfolio.
Recent Events. Global financial markets have
continued to experience periods of elevated
volatility, driven by a combination of economic,
macroeconomic
broader
political,
developments.
across major
Conditions
economies have been influenced by shifting policy
priorities, changes in geopolitical relationships,
and evolving investor expectations.
Within the United States, the current U.S.
intent on
administration has demonstrated
implementing policy changes through executive
orders and legislation, contributing to a less
certain policy environment. Potential adjustments
to federal programs, regulatory initiatives, and
legislative priorities create additional factors for
markets to assess, which may cause meaningful
inflation reduction
market uncertainty. While
remains a central
for policymakers,
focus
achieving the U.S. Federal Reserve Board’s long
term inflation target of 2% continues to prove
challenging. Although annual price increases have
generally moderated, the price of many goods
and services remains elevated compared to levels
from a few years ago. Leadership changes at the
Disciplinary Information
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
15
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
supervisor within
system,
including WSPs,
training,
In July 2016, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that the firm and a
its Private Wealth
firm
Management business did not
reasonably
supervise a former Financial Advisor who misused
a customer’s funds. After the supervisor realized
the misuse by the Financial Advisor, Baird
reimbursed the customer for the loss. The
findings stated that the supervisor did not
reasonably follow-up on red flags associated with
a trade correction request submitted by the
Financial Advisor, that the supervisor did not
follow certain of Baird’s written supervisory
procedures (“WSPs”) relating to trade corrections
and that Baird did not establish and maintain a
supervisory
for
correcting trade errors that was reasonably
designed to ensure compliance with applicable
securities laws, regulations and rules. Baird was
censured and fined $200,000.
received on employees’ personal devices.
Following
the SEC’s
the commencement of
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,
surveillance program,
technology solutions and similar matters related
to off-channel communications.
The following information pertains to Baird’s
Private Wealth Management business, a separate
and distinct division of Baird.
certain of
the
its
to adopt or
to
provide
designed
to Baird’s clients and
In April 2016, Baird, without admitting or denying
the findings, consented to the sanctions and
findings of FINRA that it violated NASD Conduct
Rule 3010, FINRA Rule 3110, and FINRA Rule
2010, by failing to establish and maintain a
supervisory system and procedures reasonably
designed to ensure that customers who purchased
mutual fund shares received the benefit of
applicable sales charge waivers. In May 2015,
Baird began a review to determine whether Baird
had provided available sales charge waivers to
eligible customers. Based on this review, in May
2015, Baird self-reported to FINRA that various
eligible customers had not received available
sales charge waivers. Baird was found to have
retirement plan and
disadvantaged certain
charitable organization customers
that were
eligible to purchase Class A shares in certain
mutual funds without a front-end sales charge.
The findings also stated that these customers
were instead sold Class A shares with a front-end
sales charge or Class B or C shares with higher
ongoing fees and the potential application of a
contingent deferred sales charge. Baird was
censured and required to pay restitution to
affected customers estimated to be approximately
$2.1 million including interest.
In September 2016, the SEC announced that
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
subadvisors
participating in Baird’s wrap fee programs offered
through
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
implement policies and
failed
specific
procedures
information
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. Baird also was ordered to cease
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and desist committing or causing any violations
and any future violations of Section 206(4) of the
Advisers Act and Rule 206(4)-7 thereunder and
pay a civil money penalty in the amount of
$250,000.
products and services provided by PWM, and
private equity funds offered by Baird Capital.
Baird Advisors does not use those investment
products and services when managing client
accounts.
Certain Affiliated Parties
Affiliated Mutual Funds
Additional information about Baird’s disciplinary
history is available on the SEC’s website at
www.adviserinfo.sec.gov.
Other Financial Industry Activities and
Affiliations
Baird is registered with the SEC as a broker-
dealer under the Exchange Act and as an
investment adviser under the Advisers Act. Baird
is also affiliated with or related to certain broker-
financial
investment advisors, other
dealers,
services firms and investment products that are
identified below. Certain Baird associates and
certain management persons of Baird may invest
in those investment products.
through
(“PWM”),
and
statement
of
Baird’s Broker-Dealer Activities
Baird is engaged in a broad range of broker-
dealer activities
its Private Wealth
Investment Banking,
Management
Public Finance and Institutional Equities Services
Businesses.
Baird is the investment adviser and principal
underwriter for the Baird Funds. Baird Advisors
provides investment management, administrative,
and other services to the Baird Bond Funds. The
Baird Bond Funds have investment objectives and
strategies substantially similar to the portfolio
strategies discussed above. Baird Equity Asset
Management provides investment management
to certain Baird Funds
and other services
investing primarily in equity securities (the “Baird
Equity Funds”), and Greenhouse Funds LLLP
(“Greenhouse”) is the investment subadvisor to
one of those Funds, the Baird Equity Opportunity
Fund. CCM provides investment management and
other services to certain Baird Funds pursuing
global or international investment strategies (the
“Chautauqua Funds”). As compensation for its
services, Baird receives fees from each Baird
Fund, which fees are disclosed in each Fund’s
prospectus
additional
information available on Baird’s website at
bairdassetmanagement.com/baird-funds.
Certain Baird and Baird Advisors associates and
certain management persons of Baird and Baird
Advisors are registered, or have an application
pending to register, as registered representatives
and associated persons of Baird to the extent
necessary or appropriate to perform their job
responsibilities.
Baird Advisors serves as investment sub-adviser
to two mutual fund series of the Bridge Builder
Trust and Baird receives compensation for those
services. Additional information about that mutual
fund, including information relating to the fees
paid by that fund for investment management
services, is available in the fund’s prospectus and
statement of additional information.
Other Affiliated Financial Services Firms
for
Baird’s Other Investment-Related Activities
Baird PWM and its Financial Advisors may, from
time to time refer clients to Baird Advisors or to
Baird Equity Asset Management,
another
investment management department of Baird or
Chautauqua Capital Management (“CCM”), a part
of Baird Equity Asset Management. Baird PWM
Financial Advisors are eligible
referral
compensation to be paid by Baird that is based
upon, among other factors, the compensation
received by Baird.
Baird is affiliated with other investment advisors,
broker-dealers, a trust company and other
financial services firms that offer their own
investment products and services. A list of Baird’s
affiliates is available in Baird’s Form ADV Part 1A
available at https://adviserinfo.sec.gov. Baird
Advisors does not use those investment products
and services when managing client accounts.
Baird offers other
investment products and
services through its other business units, such as
equity-based investment products and services
provided by Baird Equity Asset Management and
investments
CCM,
retail-investor-oriented
Other Financial Industry Activities
Baird has business relationships with investment
from Baird
managers separate and apart
Advisors. Other investment management firms
17
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
including
for
investment
may select Baird, in its capacity as a broker-
dealer, to execute portfolio trades for their
clients,
funds they
advise. Investment management firms may also
select Baird to provide custody, research or other
services. Baird receives compensation for those
services. That compensation is not paid to Baird
Advisors or its associates.
Baird has also implemented certain policies and
procedures relating to Baird’s and its associates’
trading activities that are designed to prevent
them from improperly benefiting from the trading
activities of Baird’s advisory clients. For example,
Baird Advisors conducts trading activity
for
advisory clients through trading personnel that
are different from the trading personnel executing
trades for Baird’s own accounts. In addition,
Baird’s Compliance Department monitors the
personal trading activities of all of Baird’s
associates providing advisory-related services to
clients.
Other Potential Conflicts
Baird’s Investment Banking and Fixed Income
Capital Markets Activities
municipal
advisory,
Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
Code of Ethics
Subject to the restrictions described below, Baird
and its affiliates and associates may engage in
securities transactions for their own accounts,
including the same or related securities that are
recommended to or owned by Baird clients. These
transactions may include trading in securities in a
manner that differs from, or is inconsistent with,
the advice given to Baird clients, and the
transactions may occur at or about the same time
that such securities are recommended to or are
purchased or sold for client accounts. This creates
a potential for a conflict between the interest of
clients and the interests of Baird and its affiliates
and associates.
from
participating
in
or
by
Baird’s
Through
its Investment Banking and Public
Finance Departments, Baird provides investment
banking,
securities
underwriting and related services to various
issuers of
corporate, municipal, and other
securities. Baird receives compensation and fees
from such entities in connection with the services
it provides. Baird may, therefore, have an
incentive to favor the securities of issuers for
which Baird provides such services over the
securities of issuers for which Baird does not
provide such services. From time to time, to the
extent permitted by applicable law, rules and
regulations, Baird Advisors may purchase
securities for client accounts in offerings in which
Baird acts as manager, co-manager, underwriter
or placement agent. Applicable law and rules may
prohibit certain types of accounts, such as
accounts subject to the Employee Retirement
Income Security Act of 1974, as amended
(“ERISA”),
certain
transactions or may limit overall participation by
Baird Advisors' clients. Such purchases are not
made from Baird but from other participants in
the offering. Generally, Baird will not receive
direct compensation for the portion of securities
allocated to Baird Advisors clients, although Baird
may receive indirect compensation and other
benefits by virtue of Baird Advisors’ clients’
participation on such offerings, such as ensuring
the offering is fully-subscribed and successful.
Baird Advisors will only purchase such securities
in an offering for a client when it believes it is in a
client’s best interest to do so.
To address the potential for conflicts of interest,
Baird has adopted a Code of Ethics (the “Code”)
that applies to
its associates that provide
investment advisory services to clients, including
Baird Advisors associates, and certain associates
who have access to non-public
information
relating to advisory client accounts (“Access
Persons”). The Code prohibits Access Persons
from using knowledge about advisory client
account transactions to profit personally, directly,
or indirectly, by trading in his or her personal
accounts. In addition, an Access Person must
generally pre-clear his or her trades or obtain
prior authorization
from Baird’s Compliance
Department before executing a trade. The Code
also generally prohibits Access Persons from
executing a security transaction for their personal
accounts during a blackout period that starts
seven days before and ends seven days after the
date that a client transaction in that same
security is executed. The Code provides for
certain exceptions deemed appropriate by Baird
management
Compliance
Department. A copy of the Code is available to
clients or prospective clients upon request.
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Other Client Relationships
Addressing Conflicts
Certain client accounts managed by Baird
Advisors and Baird have similar
investment
objectives and strategies but may be subject to
different fee schedules. Thus, Baird Advisors and
Baird have an incentive to favor client accounts
that generate a higher level of compensation.
Baird’s Broker-Dealer and Related Activities
related services
transactions; and
to make securities allocations
bonds, mutual
funds,
In its broker-dealer capacity, Baird provides
brokerage and
to clients,
including the purchase and sale of individual
stocks,
alternative
investment products and other securities. Baird
receives compensation based upon the sale of
such investment products.
to prevent
them
from
The foregoing activities could create a conflict of
interest with clients. Baird addresses these
potential conflicts through disclosure in this
Brochure and by adopting internal policies and
procedures for Baird and its associates that
require them to provide investment advice that is
appropriate for advisory clients (based upon the
information provided by such clients); that
require them to seek to obtain “best execution” of
that are
advisory client
designed
to
discretionary client accounts in a manner such
that all such clients receive fair and equitable
treatment over time. In addition, Baird has
adopted a Code of Ethics and other internal
trading policies and procedures relating to Baird’s
and its associates’ trading activities that are
designed
improperly
benefiting from the trading activities of Baird’s
advisory clients. See “Code of Ethics, Participation
or Interest in Client Transactions and Personal
Trading—Code of Ethics” above.
time
that
investments
Baird and its affiliates and associates may buy or
sell investments that are recommended to or
owned by a client for their own accounts, or they
may act as broker or agent for other clients
buying or selling those
investments. Those
transactions may
include buying or selling
investments in a manner that differs from, or is
inconsistent with, the advice given to a client, and
those transactions may occur at or about the
same
are
such
recommended to or are purchased or sold for a
client’s account.
from
time
Baird and its associates, by reason of Baird’s
investment banking or other
broker-dealer,
activities, may
time acquire
to
information deemed confidential, material and
non-public, about corporations or other entities
and their securities. Baird and its associates are
prohibited by applicable law or agreements from
disclosing such information to clients or acting
upon such information with respect to any client
account.
Other Interests
Other sections of this Brochure also describe
instances when Baird Advisors or Baird may
recommend to clients, and may buy and sell for
client’s accounts, securities in which Baird and its
affiliates and associates have a material financial
interest. For more information, please see “Other
Financial Industry Activities and Affiliations”
above and “Brokerage Practices” and “Client
Referrals and Other Compensation” below.
Brokerage Practices
Broker-Dealer Selection
Baird Advisors will select the broker-dealers that
will execute trade orders for a client’s accounts,
unless the client has provided instructions to
Baird Advisors to the contrary. As an investment
adviser, Baird Advisors has an obligation to seek
“best execution” of client trade orders. “Best
execution” means that Baird Advisors must place
client trade orders with those broker-dealers that
Baird Advisors believes are capable of providing
the best qualitative execution of client trade
orders under the circumstances, taking into
account the full range and quality of the services
offered by the broker-dealer. When selecting a
broker or dealer, Baird Advisors may consider the
following factors: financial standing of executing
firm and counterparty risk, execution capability
and past execution performance; the terms and
conditions imposed by the broker or dealer in
connection with the trade; timeliness in rendering
services; and continuity and quality of the overall
provision of services. It is important to note that
Baird Advisors’ best execution obligation does not
require Baird Advisors to solicit competitive bids
for each transaction or to seek the lowest
available cost of trade orders, so long as Baird
Advisors reasonably believes that the broker-
dealer selected can be reasonably expected to
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
provide clients with the best qualitative execution
under the circumstances.
assist Baird Advisors in potentially avoiding an
adverse effect on the price of a debt obligation
that could result from simultaneously placing a
number of separate, successive or competing,
client orders.
To avoid potential conflicts of interest, Baird
Advisors has adopted an internal policy that it will
not typically use Baird’s institutional equity or
fixed income trading departments to provide
execution services, unless specifically requested
or directed to do so by a client.
trading platforms
Baird Advisors generally aggregates buy and sell
orders when executing trades for client accounts
under its discretionary management when it has
the opportunity to do so. However, Baird Advisors
determines whether or not to utilize block
transactions for a client in its sole discretion and
Baird Advisors’ decision is subject to its duty to
seek best execution. Baird Advisors will aggregate
a client’s trade orders only when Baird Advisors
deems it to be appropriate and in the best
interests of the client, consistent with a client’s
investment objectives and risk tolerance, and
permitted by regulatory requirements.
Baird Advisors may also purchase or sell debt
obligations through electronic trading platforms.
typically
These electronic
provide access to bids and offers from a greater
number of dealers on a timely basis; however,
these electronic platforms may
impose an
execution or transaction fee imbedded in the price
paid or received for the debt obligation (i.e., a
markup or markdown).
for
the
Soft Dollar Benefits
Baird Advisors does not receive research in
addition to execution services from a broker-
dealer in connection with its clients’ securities
transactions. These
research benefits are
commonly referred to as “soft dollar benefits”.
Baird Advisors may from time to time receive
generic market commentaries or market research
from broker-dealer firms. However, the receipt of
those materials is not tied to the execution of
client transactions.
All advisory clients participating
in a block
transaction will receive for the debt obligation
bought or sold the same execution price or spread
to an applicable reference base rate or yield
curve. As a result, the price or spread received by
a client may be higher or lower than the price or
spread the client may have received had the
transaction been effected
client
independently from the block transaction. In
addition, a client’s transaction costs may vary
depending upon, among other things, the type of
debt obligations bought or sold, and
the
securities’ sector, rating and index eligibility.
Baird Advisors seeks to select broker-dealers
based upon the broker’s or dealer’s ability to
provide best execution, and Baird Advisors will
not cause clients to pay commissions (or markups
or markdowns) higher than those charged by
other broker-dealers for the purpose of obtaining
soft dollar benefits. Furthermore, Baird Advisors
to execute
does not select broker-dealers
transactions for client accounts based upon client
referrals received from broker-dealers.
Trade Aggregation, Allocation and Rotation
Practices
Baird Advisors may aggregate contemporaneous
buy and sell orders for the accounts over which it
has discretionary authority (a practice also known
as bunching trades or block transactions). This
practice may enable Baird Advisors to obtain
more favorable execution, including better pricing
and enhanced investment opportunities, than
would otherwise be available if orders were not
aggregated. Using block transactions may also
The amount of debt obligations available in the
marketplace, at a particular price or spread at a
particular time, may not satisfy the needs of all
clients participating in a block transaction and
may be insufficient to provide full allocation
across all client accounts. To address this
possibility, Baird Advisors has adopted trade
allocation policies and procedures
that are
designed to make debt obligation allocations to
discretionary client accounts in a manner such
that all such clients receive fair and equitable
treatment over time. If a block transaction cannot
be executed in full at the same price or time, the
debt obligations actually purchased or sold will
generally be allocated based on the needs of the
clients participating in the block transaction.
When making an allocation, Baird Advisors, in its
discretion, takes into consideration a client’s
investment objectives, risk tolerance, strategies
and investment guidelines and restrictions; the
client’s cash needs and expected cash flows; and
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
including
issuer and
in
a
directed
investment
the client’s
the composition of
portfolio,
sector
its
representation and its average maturities and
duration, and the liquidity of the position size.
Baird Advisors may conduct a series of
transactions in debt obligations with similar
characteristics to meet the needs of clients not
receiving an allocation in a block transaction.
Baird Advisors’ clients, Baird Advisors may
employ the use of “step-outs” to satisfy the
client’s directed brokerage arrangement. A “step-
out” occurs when an executing broker executes
the trade and then “steps out” the trade to a
clearing broker (which would be the directed
broker-dealer
brokerage
arrangement) that confirms and settles the trade.
In such a case, a client will bear the costs of any
commissions, markups or markdowns imposed by
the executing broker-dealer in addition to the
costs of any commissions, markups or markdowns
imposed by the directed broker-dealer. As a
result, a directed brokerage arrangement may be
more costly to a client, as it may result in the
client paying higher commissions, markups,
markdowns and greater bid/offer spreads, or
receiving a less favorable net price.
Directed Brokerage
Baird Advisors will comply with any guidelines
and/or limitations reasonably requested by a
client relating to brokerage for the client’s
account. Specific guidelines and/or limitations
requested by clients vary from client to client
based upon a client’s particular objectives and
other factors. When possible, Baird Advisors will
also observe any non-binding statement of client
preferences with respect to brokerage direction.
If a client directs Baird Advisors to use a
particular broker-dealer, and if the particular
broker-dealer referred the client to Baird Advisors
or if the particular broker-dealer refers other
clients to Baird Advisors or Baird in the future,
Baird Advisors or Baird may benefit from the
client’s directed brokerage arrangement. Because
of these potential benefits, Baird Advisors and
Baird may have an economic interest in having
the client continue
the directed brokerage
arrangement. The benefits that Baird Advisors
and Baird receive conflict with the client’s interest
in having Baird Advisors recommend that the
client utilize another broker-dealer to execute
some or all transactions for the client’s account.
Before directing Baird Advisors to use a particular
broker-dealer, a client should carefully consider
the possible costs or disadvantages of directed
brokerage arrangements.
If a client directs Baird Advisors to use a
particular broker-dealer for execution of the
client’s trade orders (a “directed brokerage
arrangement”), and Baird Advisors agrees to the
arrangement, a client should understand that
Baird Advisors may be unable to achieve best
execution for the client’s transactions. A client
should note that any costs related to the directed
brokerage arrangement are not included in Baird
Advisors’ fee and that the client will be solely
for monitoring, evaluating and
responsible
reviewing the arrangement with the directed
broker-dealer and paying any commissions or
markups or markdowns or other costs imposed by
the directed broker-dealer. A client should also
note that Baird Advisors generally will not
aggregate the client’s directed brokerage trade
orders with orders for other Baird Advisors’
clients. As a result, a client’s transaction costs
may be higher because the client will not benefit
from any volume discounts or other reduced
transaction costs that Baird Advisors may obtain
for its other clients. A client should further note
that Baird Advisors will generally place the client’s
trade orders with the directed broker-dealer after
Baird Advisors completes its trading for other
Baird Advisors’ client accounts. The client’s trade
orders will significantly bear the market price
impact, if any, of those trades executed earlier by
Baird Advisors. As a result, the client may receive
a less favorable net price for the trade.
If Baird Advisors aggregates a client’s directed
brokerage trade orders with trade orders for other
Cross Trading Involving Advisory Accounts
Baird Advisors generally does not engage in cross
transactions for client accounts. However, in the
limited instance of when one or more clients need
to buy and one or more clients need to sell put
bonds, Baird Advisors may engage in cross
transactions to the extent Baird Advisors believes
it is in all applicable clients’ best interest to do so.
Also, from time to time, Baird Advisors may
engage in in-kind transactions involving a client’s
purchase or sale of debt obligations from or to a
Baird Bond Fund in exchange for shares of such
Baird Bond Fund. Baird Advisors will only engage
in such a transaction when Baird Advisors
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
performance
compared
to
account’s
the
performance of a relevant benchmark index at
least monthly.
believes that the transaction is consistent with the
client’s best
interest. When effecting such
transactions, Baird Advisors seeks to comply with
the requirements of the Baird Bond Funds’ in-kind
transaction procedures, or other applicable SEC
guidance.
Baird Advisors generally provides written
performance reports to clients on a quarterly
basis. These quarterly performance
reports
contain the client account’s characteristics and
performance summary. Baird Advisors may
provide additional information in the performance
report to meet the specific reporting needs of a
client as the client and Baird Advisors may agree.
reallocating
the
transaction
in
performance
reports
are
Trade Error Correction
It is Baird’s policy that if there is a trade error for
which Baird is responsible, Baird will take actions,
based on the facts and circumstances surrounding
the error, to put the client’s account in the
position that it would have been in as if the error
had not occurred, including by adjusting or
reversing the transaction, entering an offsetting
transaction,
to
another account (subject to the review and
approval of the Compliance Department), or other
methods that may be deemed appropriate by
Baird. Errors caused by Baird Advisors or Baird
will be corrected at no cost to client’s account,
with the client’s account not recognizing any loss
from the error. Baird may net gains and losses
from a single error event involving more than one
transaction in a security or transactions in
multiple securities. The client’s account will be
fully compensated for any losses incurred as a
result of an error event. If the trade error results
in a gain, the gain may be retained by Baird.
However, it is Baird Advisors’ practice that the
client typically retains the gain. If the gain is
retained by Baird, such gain is not given to or
shared with Baird Advisors or any Baird associate.
A client’s account performance may be compared
to a benchmark index or indices. The benchmark
may be a blended benchmark that combines the
returns for two or more indices. Benchmarks
shown
for
informational purposes only. Baird Advisors’
selection and use of benchmarks is not a promise
or guarantee that the performance of a client’s
the stated
account will meet or exceed
benchmark. When the client compares account
performance to the performance of a market
index, the client should recognize that a market
index merely reflects the performance of a list of
unmanaged debt obligations included in the index
and the index performance does not take into
account management fees, execution costs, and
other expenses related to the operation of a
portfolio. The debt obligations included in a
client’s account generally do not exactly mirror
the debt obligations included in the index.
Baird Advisors and Baird offer many services and,
from time to time, may have other clients in other
programs trading in opposition to a client. To
avoid favoring one client over another client,
Baird attempts to use objective market data in
the correction of any trading errors.
When preparing performance
reports, Baird
Advisors will generally rely on the value of a
client’s assets provided by the client’s custodian.
Baird Advisors and Baird do not verify or
guarantee
the accuracy of such valuation
information.
to
individual
debt
the account’s
Review of Accounts
Baird Advisors’ portfolio management
team
provides ongoing review of all Baird Advisors’
client accounts. The Baird Advisors’ portfolio
management
team generally performs daily
reviews on each client account’s duration, yield
curve position, sector allocation, overall portfolio
obligations,
exposure
compliance with
investment
strategy and client-imposed guidelines, and
deviation from other accounts using the same
strategy. The portfolio management
team
generally reviews reports documenting each
Client Referrals and Other Compensation
Baird Advisors and its associates do not receive
compensation based upon the sale of securities or
other
investment products. Baird or Baird
Advisors may provide compensation to other
individuals who refer clients in some instances.
When applicable, the compensation paid is a
percentage of the client’s fee payments to Baird
or Baird Advisors. The amount of compensation
will vary, with the specific level determined based
upon consideration of various factors including,
but not limited to, the individual’s role in
developing the client relationship and the assets
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
under management. Baird may pay these fees to
registered representatives of Baird and
its
affiliates as well as to unaffiliated solicitors that
have entered into a written agreement with Baird.
client’s selected custodian. A client should
carefully review those account statements and
compare them with any account statements
provided by Baird Advisors or Baird.
and
Personal
Trading”
Baird and Baird’s affiliates and associates may
receive certain economic benefits in connection
with providing advisory services to clients, which
are described in the sections entitled “Other
Financial Industry Activities and Affiliations”,
“Code of Ethics, Participation or Interest in Client
Transactions
and
“Brokerage Practices” above.
complete
unlimited
Custody
Each client is responsible for appointing the
client’s custodian, which will have possession of
the assets of the client’s account and settle
transactions for the account. Clients receiving
advisory services from Baird Advisors generally
select a third party custodian unaffiliated with
Baird to have custody of the client’s securities and
other assets. A client who uses a third party
custodian authorizes Baird Advisors to give
instructions to the client’s custodian for all actions
necessary or incidental to the purchase, sale,
exchange, and delivery of debt obligations and
other investments held in the client’s account.
The client must also instruct the custodian: (a) to
accept instructions from Baird Advisors relating to
the purchase, sale, exchange, redemption or
delivery of debt obligations or other investments
in the account; (b) notify Baird Advisors promptly
of any additions to, or withdrawals from, the
account; and (c) to the extent applicable,
disburse fees due to Baird Advisors.
on
the
(e.g.,
required
to make
A client should understand that Baird Advisors
does not monitor, evaluate or review any third
party custodian. The client should also understand
that the client will pay a custody fee in addition to
the fee paid to Baird Advisors for separate
accounts.
statements,
electronic
Investment Discretion
Clients generally give Baird Advisors
the
discretionary investment authority to determine
independently
the specific debt obligations
purchased or sold and the amount of debt
obligations purchased or sold. By executing an
IMA with Baird Advisors, a client authorizes Baird
Advisors to make investment decisions for the
client’s account, with the authority to determine
the amount, type and timing with respect to
buying, holding, exchanging, converting and
selling debt obligations and other assets for the
client’s account, subject to the client’s portfolio
strategy. The client’s IMA also grants to Baird
Advisors
trading
and
authorization and appoints Baird Advisors as
agent and attorney-in-fact with respect to the
client’s accounts and all related trading and other
decisions. Pursuant to such authorization, Baird
Advisors may, in its sole discretion and at the
client’s risk, (a) purchase, sell, exchange, convert
and otherwise trade the securities and other
investments in the account; (b) arrange for
delivery and payment in connection with the
above,
including the deposit of margin or
collateral which shall include the transfer of
money or securities to the extent necessary to
meet the obligations of the account with respect
to any investments made pursuant to the IMA; (c)
on behalf of the account to (i) enter into
agreements and execute certain documents
binding
brokerage
client
agreements, clearing agreements, and the Master
Securities Forward Transaction Agreement, as
investments
applicable)
pursuant to the IMA, which shall include market
and/or industry standard documentation and the
standard representations contained therein; and
(ii) acknowledge the receipt of brokers’ risk
trading
disclosure
disclosure statements and similar documents; and
(d) act on the client’s behalf in all matters
necessary or incidental to the handling of the
account.
Baird Advisors generally accepts reasonable
limitations to its discretionary authority with
respect to brokerage direction and investment
selection, including the designation of particular
While Baird Advisors does not act as custodian
when the client selects a third party custodian,
Baird Advisors may be deemed under Rule
206(4)-2 of the Advisers Act to have custody of
client assets in certain circumstances, such as
when the client has authorized Baird Advisors to
deduct its advisory fees directly from a client's
custody account. All clients for whom Baird is
deemed to have custody will receive account
statements, at least quarterly, directly from the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
strategies offered by Baird Advisors. Baird
Advisors generally only invests client accounts in
unaffiliated open-end mutual funds when that
fund has an investment objective and strategy
not available through a Baird Bond Fund. A
client’s consent may be revoked at any time.
investments or types of investments that should
not be purchased for the client’s account. Any
such limitations agreed to by client and Baird
Advisors are generally included in the client’s
investment policy statement, as an addendum to
the client’s IMA or in a separate letter of
understanding. When possible, Baird Advisors will
also attempt
to observe any non-binding
statement of client preferences with respect to
factors such as brokerage direction, holding
periods, and securities selection.
Voting Client Securities
Baird Advisors does not typically recommend or
select for client accounts securities that have
voting rights. However, by signing an IMA, clients
authorize and delegate the right to Baird to vote
proxies with respect to the securities held in their
accounts.
investment
to clients upon
their
Baird Advisors has adopted written policies and
procedures that are reasonably designed to
ensure that Baird votes client securities in the
best
interests of clients. Those procedures
address material conflicts of interest that may
arise between Baird Advisors’ or Baird’s interests
and those of their clients. Although a description
of Baird Advisors’ proxy voting policies and
procedures is provided below, Baird Advisors will
furnish a copy of its proxy voting policies and
request.
procedures
Additionally, clients may obtain information on
how Baird actually voted proxies with respect to
the securities held in their accounts by contacting
Baird Advisors by calling (414) 765-3500.
In the event that a client’s account is restricted
from investing in certain investments, Baird
Advisors will select such other replacement
investments, if any, as it deems appropriate.
Accounts with
restrictions may
from accounts without
perform differently
restrictions and performance may be poorer. In
addition, in the event there is a change in the
classification or credit rating of an investment
held in the client’s account, a client’s investment
restrictions may force Baird Advisors to sell such
investment at an inopportune time, possibly
negatively impacting account performance and
causing the client’s account to realize taxable
gains or losses, which could be significant. A
client should also be aware that, if the client’s
account holds any investment vehicle (such as a
mutual fund or ETF), any investment restrictions
the client places on the client’s account generally
will not flow through to the investments owned by
that investment vehicle.
In situations in which a client has delegated to
Baird voting authority with respect to securities in
the client’s account, Baird will vote proxies in a
manner that Baird believes is consistent with the
client’s best interests.
Baird Advisors may use
the discretionary
authority granted to it by a client to invest the
client’s accounts in mutual funds that pay fees to
Baird or to any of its affiliates for investment
advisory or other services they provide to the
mutual funds (“affiliated investment products”).
governance
services,
voting
recommendations.
In the normal course of business Baird Advisors
does not typically invest in equity securities on
behalf of clients. In the event Baird Advisors
clients hold voting securities, Baird utilizes an
independent provider of proxy voting and
corporate
currently
Institutional Shareholder Services (“ISS”), to
analyze proxy materials and votes and make
independent
ISS
provides proxy voting guidelines regarding its
position on various matters presented by
companies to their shareholders for consideration.
Baird will typically vote shares in accordance with
the recommendations made by ISS. However,
ISS’s guidelines are not exhaustive, do not
address all potential voting issues, and do not
necessarily correspond with the opinions of the
By signing an IMA with Baird Advisors, a client
consents to Baird Advisors investing all or a
portion of the client’s account
in affiliated
investment products. The amount of fees received
by Baird and its affiliates is described in the
prospectus or other offering documents for the
investment product. Baird Advisors will use its
discretionary authority to invest the client’s
account in affiliated investment products when
Baird Advisors determines it to be in the client’s
best interest to do so. Baird Advisors generally
invests client accounts in individual securities and,
in certain instances and to the extent approved by
a client, Baird Bond Funds that mirror SMA
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
of
claims
against
companies
Baird Advisors portfolio managers. In the event
the portfolio manager for a client’s account
believes the ISS recommendation is not in the
best interest of the client, the portfolio manager
will bring the issue to Baird’s Proxy Voting Sub-
Committee through a proxy challenge process.
The Sub-Committee will then be responsible for
determining how the vote will be cast. For those
matters for which the independent proxy voting
service does not provide a specific voting
recommendation, each portfolio manager will cast
the vote in a manner he or she believes is in the
best interest of clients. The votes cast for a
client’s account may differ from those votes cast
for other Baird Advisors or Baird clients based on
differing views of portfolio managers.
take any action or submit any forms or other
applications for or on behalf of its separately
managed account clients regarding any class
action lawsuits or other legal claims (including
notices
in
bankruptcy) to which clients may be entitled to
participate. Rather, Baird Advisors, if they receive
any written materials related to the foregoing, will
forward to client’s custodian any written materials
they receive related to the foregoing. At a client’s
request, Baird Advisors will forward information
that Baird Advisors actually receives about such
claims to the client or may provide information
and assistance to the client in considering and
responding to the materials. Baird Advisors does
not, otherwise, offer legal or tax advice regarding
clients’ investments, and a proper assessment or
evaluation of the advantages and disadvantages
of participating in class action lawsuits or of
bringing other legal claims (and filing notices of
claims
legal
in bankruptcy) require capable
counsel.
interests of
Financial Information
Baird Advisors does not require or solicit
prepayment of fees and, thus, has not included a
balance sheet of Baird’s most recent fiscal year.
Neither Baird nor Baird Advisors is aware of any
financial condition that is reasonably likely to
impair their ability to meet their contractual
commitments to clients, nor has either been the
subject of a bankruptcy petition at any time
during the past ten years.
to
the
The proxy voting policies and procedures also
address instances in which Baird’s interests may
appear to conflict with client
interests. In
situations where there is a potential conflict of
interest, Baird’s Proxy Voting Sub-Committee will
determine the nature and materiality of the
conflict. If the conflict is determined to not be
material, the Sub-Committee will vote the proxy
in a manner the Sub-Committee believes is in the
the client and without
best
consideration of any benefit to Baird or its
affiliates. If the potential conflict is determined to
be material, Baird’s Proxy Voting Sub-Committee
will take one of the following steps to address the
potential conflict: (1) cast the vote in accordance
with the recommendations of ISS or other
independent third party; (2) refer the proxy to
the client or to a fiduciary of the client for voting
purposes; (3) suggest that the client engage
another party to determine how the proxy should
be voted; (4) if the matter is not addressed by
ISS, vote in accordance with management’s
recommendation; or (5) abstain from voting.
While Baird uses its best efforts to vote proxies,
there are instances when voting is not practical or
is not, in Baird’s or the portfolio managers’ view,
in the best interest of clients.
to
Baird Advisors generally does not permit clients to
direct particular votes once they have granted
Baird Advisors discretionary voting authority.
Clients wishing to vote securities may do so by
terminating the discretionary voting authority
granted to Baird Advisors.
In addition to the services described above, Baird
has engaged ISS for vote execution and record-
keeping services. Baird Advisors will generally not
Special Considerations for Retirement
Accounts
If a client’s account is a an account subject to
ERISA or an individual retirement account (“IRA”)
subject
Internal Revenue Code
(collectively, “Retirement Accounts”), each owner,
trustee, responsible plan
fiduciary, or other
fiduciary (“Retirement Account Fiduciary”) of the
client should understand that Baird Advisors or
Baird may invest for the client, recommend that
the client invest in, or make available for
investment
to plan participants, affiliated
investment products, that Baird and its affiliates
will receive fees or other compensation related to
such investments, and that they will retain such
compensation
the extent permitted by
applicable law, rule or regulation, including,
without limitation, Department of Labor (“DOL”)
Prohibited Transaction Exemption (“PTE”) 77-4,
DOL PTE 2020-02 or other advisory opinions
issued by the DOL.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and
the
fiduciary
Fiduciary
such Fiduciary
is
that
for complying with all
that: (i)
the
investment
transactions, and
the duty
broker-dealer,
and
terminating
monitoring
a
If the client’s account is a Retirement Account and
if Baird Advisors is directed to implement a
directed brokerage arrangement for the account,
each Retirement Account Fiduciary of the client
should understand that the directed brokerage
arrangement must be for the exclusive benefit of
participants and beneficiaries of the Retirement
Account
responsibilities
discussed in ERISA Technical Bulletin 86-1. Each
should also
Retirement Account
solely
understand
responsible
fiduciary
in ERISA Technical
responsibilities discussed
Bulletin 86-1, including, without limitation, the
duty to make an initial determination that the
directed broker-dealer is capable of providing best
execution for the client’s brokerage transactions,
the duty to monitor the services provided by the
directed broker-dealer so as to assure that the
client has received best execution of the client’s
brokerage
to
determine that the commissions paid by the client
and any other fees or costs incurred by the client
are reasonable in relation to the value of the
brokerage and other services received by the
client. The client and each Retirement Account
Fiduciary of the client should also understand that
the client and the client’s Retirement Account
Fiduciaries are solely responsible for engaging a
directed
its
directed
performance
brokerage arrangement, and that Baird Advisors
is not responsible for determining whether a
directed broker-dealer is capable of providing best
execution.
investment product
To the extent Baird Advisors, Baird or their
affiliates rely upon PTE 77-4, each Retirement
Account Fiduciary should understand that when
Baird Advisors or Baird invests the assets of a
Retirement Account in an affiliated investment
product that pays investment advisory fees to
Baird or any of its affiliates, Baird and its affiliates
may receive such investment advisory fees in
accordance with the terms of DOL PTE 77-4, and,
as required thereby, Baird Advisors will waive its
advisory fees on that portion of the assets
invested in the affiliated investment product for
such period of time so invested or Baird Advisors
will offset the investment advisory fees received
by Baird or any of its affiliates from the affiliated
investment product against the advisory fee that
Baird Advisors charges to the client. For the
purpose of complying with the terms of DOL PTE
77-4, the client and each Retirement Account
Fiduciary of the client acknowledge in the client’s
IMA
in affiliated
investment products for the client’s account is
appropriate because of, among other things, the
investment goals, redeemability, liquidity, and
diversification of those products; (ii) subject to
Baird Advisors’ investment strategies, all assets of
the client’s account may be invested in one or
more of the affiliated investment products; (iii)
the client and such Retirement Account Fiduciary
received prospectuses or other offering or
disclosure documents for the affiliated investment
products that may be used in connection with the
account, each of which include a summary of all
fees that may be paid by the affiliated investment
products to Baird or its affiliates; and (iv) the
client received information concerning the nature
and extent of any differential between the rate of
such affiliated investment product fees and the
advisory fees payable by the client to Baird
Advisors. The differential between the fees to be
charged by Baird Advisors for the investment
advisory services it provides to the client and, if
applicable, the investment advisory and other
similar fees paid by the affiliated investment
product to Baird or its affiliates with respect to
the services Baird or any of its affiliates provides
to the affiliated
is the
difference between Baird Advisors’ fee disclosed in
the client’s IMA and the applicable investment
management, investment advisory and other
similar fees detailed in the applicable prospectus
or other offering or disclosure documents for the
affiliated investment product.
26
Baird Advisors Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Additional Brochure: BAIRD EQUITY ASSET MANAGEMENT - CHAUTAUQUA CAPITAL MANAGEMENT (2026-03-27)
View Document Text
Baird Equity Asset Management
Brochure
March 27, 2026
Baird Equity Asset Management
777 East Wisconsin Avenue
Milwaukee, Wisconsin 53202
Toll Free: 800-792-2473
www.bairdequityassetmanagement.com
Chautauqua Capital Management
921 Walnut Street, Suite 250
Boulder, Colorado 80302
Toll Free: 800-792-2473
www.chautauquacapital.com
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue
Milwaukee, WI 53202
1-800-792-2473
rwbaird.com
Member FINRA & SIPC
SEC File No. 801-7571
This brochure (“Brochure”) provides information about the qualifications and business practices of
Robert W. Baird & Co. Incorporated (“Baird”), Baird Equity Asset Management, an investment
management department operating within Baird, and Chautauqua Capital Management (“CCM”), a
division of Baird Equity Asset Management. Clients should carefully consider this information before
becoming a client of Baird Equity Asset Management. If you have any questions about the contents of
this Brochure, please contact Baird Equity Asset Management at the toll-free phone number listed
above. The information contained in this Brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities authority. Additional
information about Baird is available on the SEC’s website at www.adviserinfo.sec.gov.
Material Changes
Baird Equity Asset Management, an investment management department operating within Robert W. Baird
& Co. Incorporated (“Baird”), and Chautauqua Capital Management (“CCM”), a division of Baird Equity Asset
Management, updated their Form ADV Part 2A brochure (the “Brochure”) on March 27, 2026. The following
summary discusses the material changes that Baird Equity Asset Management has made to the Brochure
since March 21, 2025, the date of the last annual update to the Brochure.
• Baird Equity Asset Management updated information about Baird’s regulatory assets under management.
See the Section of the Brochure entitled “Advisory Business” for more information.
• Baird Equity Asset Management added information about collective investment trusts for which it acts as
investment advisor. See the Sections of the Brochure entitled “Advisory Business”, “Fees and
Compensation” and “Other Financial Industry Activities and Affiliations” for more information.
• Baird Equity Asset Management updated its fee schedule for the CCM International Growth Equity
Portfolio, the CCM Global Growth Equity Portfolio, the Chautauqua International Growth Equity QP Fund,
LP and the Chautauqua Global Growth Equity QP Fund, LP as shown below.
CCM International Growth Equity Portfolio
CCM Global Growth Equity Portfolio
Chautauqua International Growth Equity QP Fund, LP
Chautauqua Global Growth Equity QP Fund, LP
Value of Assets
Annual Fee Rate
On the first $100,000,000
0.70%
On the next $200,000,000
0.50%
On the remaining assets
0.30%
• Baird Equity Asset Management updated the descriptions of the Large Cap Balanced Portfolio, the
International Growth Equity Portfolio, and the Global Growth Equity Portfolio. See the Section of the
Brochure entitled “Methods of Analysis, Investment Strategies and Risk of Loss—Investment Strategies”
for more information
• Baird Equity Asset Management updated its disclosures about the research, information and tools used by
Baird Equity Asset Management investment professionals when formulating investment advice, which may
include the use of artificial intelligence (“AI”) tools, and the related risks. See the Section of the Brochure
entitled “Methods of Analysis, Investment Strategies and Risk of Loss—Methods of Analysis” for more
information.
• Baird Equity Asset Management updated investment risk information related to information security,
cybersecurity, and other technology‑related events, issuers’ use of AI, and those associated with recent
events, such as those associated with the U.S. administration’s policy initiatives, inflation, conflicts in Iran
and the Middle East, the war between Ukraine and Russia, and the strain in relationships between the U.S.
and other countries. See the Section of the Brochure entitled “Methods of Analysis, Investment Strategies
and Risk of Loss—Principal Risks” for more specific information.
• Baird Equity Asset Management updated information about Baird’s affiliates and related parties. See the
Section of the Brochure entitled “Other Financial Industry Activities and Affiliations” for more information.
A client should note that the foregoing summary only discusses material changes made to the Brochure
since March 21, 2025. The updated Brochure contains changes that are not listed above.
ii
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Table of Contents
Advisory Business ........................................................................................... 1
Robert W. Baird & Co. Incorporated ................................................................ 1
The Client-Baird Fiduciary Relationship ............................................................ 1
Baird Equity Asset Management ..................................................................... 2
Fees and Compensation .................................................................................. 5
Separate Accounts ........................................................................................ 5
Mutual Funds ............................................................................................... 9
Private Funds ............................................................................................... 9
Collective Investment Trusts .......................................................................... 9
Other Compensation Received by Baird Equity Asset Management
and Baird .............................................................................................. 10
Performance-Based Fees and Side-By-Side Management .............................. 10
Types of Clients............................................................................................. 11
Methods of Analysis, Investment Strategies and Risk of Loss ....................... 11
Investment Strategies ................................................................................. 11
Methods of Analysis .................................................................................... 16
Portfolio Investments .................................................................................. 19
Principal Risks ............................................................................................ 21
Disciplinary Information ............................................................................... 29
Other Financial Industry Activities and Affiliations ....................................... 31
Baird’s Broker-Dealer Activities .................................................................... 31
Baird’s Other Investment-Related Activities ................................................... 32
Certain Affiliated and Related Parties ............................................................ 32
Other Financial Industry Activities ................................................................ 33
Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading ................................................................................ 33
Code of Ethics ............................................................................................ 33
Other Potential Conflicts .............................................................................. 34
Brokerage Practices ...................................................................................... 36
Baird Equity Asset Management’s Trading Practices ........................................ 36
Other Managers’ Trading Practices ................................................................ 41
Trade Execution Services Performed by Baird ................................................. 41
Review of Accounts ....................................................................................... 42
Portfolios Managed by Baird Equity Asset Management ................................... 42
Accounts Managed by Other Managers .......................................................... 43
Other Information ...................................................................................... 43
Client Referrals and Other Compensation ..................................................... 44
Custody ......................................................................................................... 44
Separate Accounts ...................................................................................... 44
Private Funds ............................................................................................. 45
Investment Discretion .................................................................................. 45
Voting Client Securities ................................................................................. 46
Baird Equity Asset Management and CCM ...................................................... 46
Other Manager Strategies ............................................................................ 48
Financial Information.................................................................................... 48
Special Considerations for Retirement Accounts ........................................... 48
iii
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
analysis
and
research,
analysis
planning;
investment
and
account
transactions
and
Baird offers various investment advisory services
to clients, including services not described in this
Brochure. The investment advisory services Baird
include: portfolio management and
offers
recommendations
analysis;
investment
regarding asset allocation and
strategies;
and
recommendations regarding investment managers
and individual securities; investment consulting;
policy
financial
development;
performance
monitoring. Baird also offers clients execution of
administrative
brokerage
services, including maintaining custody of account
assets. Clients may also negotiate other services
with Baird. Baird offers its services separately or
in combination with other services.
to
clients,
including
the
by
clients
providing
Baird participates in wrap fee programs not
described in this Brochure and it provides portfolio
management services in connection with those
programs. Baird receives a portion of the wrap fee
paid
portfolio
for
management services under those wrap fee
programs.
Baird’s
website
under management,
to obtain a brochure
As of December 31, 2025, Baird had
approximately $394.0688 billion in regulatory
assets
approximately
$289.4898 billion of which was managed on a
discretionary basis and approximately $104.5790
billion of which was managed on a non-
discretionary basis.
Advisory Business
This Brochure describes the investment advisory
services that Robert W. Baird & Co. Incorporated
(“Baird”) offers to its clients through Baird Equity
Asset Management, an investment management
department of Baird, and Chautauqua Capital
Management (“CCM”), a group or division within
Baird Equity Asset Management. For purposes of
this Brochure, the term Baird Equity Asset
Management shall include CCM unless otherwise
noted. Separate brochures describe other
investment advisory services that Baird offers to
its clients and discuss the agreements, fees and
potential conflicts of interest associated with each
service. This Brochure also references other
documents that contain additional
important
information about Baird. Those documents
describe the types of services that Baird offers to
clients and certain types of investments it makes
available
terms,
conditions, fees and costs applicable to those
services and investments and certain risks and
conflicts of interest associated with those services
and investments. Those documents are available
on
at
bairdwealth.com/retailinvestor. Included on that
website is Baird’s Form CRS Client Relationship
Summary. A client of Baird who is a retail investor
should have already received a copy of that
document. A client or prospective client who
for another
wishes
investment advisory service provided by Baird, or
a paper copy of any of the other documents
referenced in this Brochure, including the Client
Relationship Summary, should call Baird toll-free
at 1-800-792-2473.
The information contained in this Brochure is
current as of the date above and is subject to
change at Baird’s discretion. Please retain this
Brochure for your records.
investment advisory services
The Client-Baird Fiduciary Relationship
Baird
is registered with the Securities and
Exchange Commission (“SEC”) as an investment
adviser under the Investment Advisers Act of
1940, as amended (the “Advisers Act”). Baird
Equity Asset Management is deemed to have a
fiduciary relationship with a client when providing
the
that are
described in this Brochure.
Robert W. Baird & Co. Incorporated
Baird is privately-held, employee-owned global
investment and wealth management firm formed
in the State of Wisconsin in 1919.
From time to time Baird may engage in certain
business practices or may receive compensation
or other benefits that create a potential for
conflict between the interests of clients and the
interests of Baird Equity Asset Management and
Baird. Baird Equity Asset Management and Baird
generally address potential conflicts of interest by
disclosing them to clients through documents
provided to clients, including, without limitation,
this Brochure, Brochure supplements that contain
Baird is owned indirectly by its associates through
is owned
several holding companies. Baird
directly by Baird Financial Corporation (“BFC”).
BFC is, in turn, owned by Baird Financial Group,
Inc. (“BFG”), which
is the ultimate parent
company of Baird. Associates of Baird own
substantially all of the outstanding stock of BFG.
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
about
individuals
(the
SAM Custom Portfolio strategies. CCM offers two
(2) primary equity investment strategies: the
International Growth Equity Portfolio; and the
“CCM
Global Growth Equity Portfolio
Strategies”).
Baird Equity Asset Management also manages
client portfolios according to other strategies
selected by clients (“Other Baird Equity Asset
Management Strategies”, and with the Baird
Equity Asset Management Growth Strategies, the
SAM Strategies, and the CCM Strategies, the
“Baird Equity Asset Management Strategies”).
information
providing
investment advice to clients, and the agreements
clients enter
into with Baird Equity Asset
Management and Baird. In addition, Baird has
adopted internal policies and procedures for Baird
Equity Asset Management and Baird that require
them to: provide investment advice that is
appropriate for advisory clients (based upon the
information provided by such clients); make full
disclosure of all potential, material conflicts of
interest; act with utmost care and good faith in
dealings with advisory clients; and seek to obtain
“best execution” of advisory client transactions.
The specific business practices
that create
potential conflicts of interest with clients and
additional measures used by Baird Equity Asset
Management and Baird to address them are
discussed in other sections of this Brochure.
Baird Equity Asset Management also makes
available to clients certain investment strategies
that are offered by other managers (“Other
Managers”), which may include affiliates of Baird
(the “Other Manager Strategies”).
A client should note that registration as an
investment adviser does not imply a certain level
of skill or training.
below
Equity
Asset Management
Subject to the agreement of Baird Equity Asset
Management, a client may impose reasonable
restrictions on the securities or types of securities
to be held in the client’s account. Please see
“Investment Discretion”
for more
information. Clients may negotiate with Baird
Equity Asset Management to provide other
investment advisory services.
offered
by Baird
generally
include
All of the investment strategies discussed in this
Brochure may not be appropriate for every client.
Baird Equity Asset Management will only select or
recommend those strategies believed to be
suitable for a particular client.
Baird Equity Asset Management
Baird
offers
professional portfolio management to separate
account clients desiring investments in equity and
investment advisory
balanced portfolios. The
Equity Asset
services
Management
portfolio
management, asset allocation, investment advice
and consulting services, performance reporting,
and related account services. Baird Equity Asset
Management also provides investment advisory
services to certain mutual funds and private
limited partnerships.
Separate Accounts
to
the
A client that wishes to retain the services of Baird
Equity Asset Management will enter into an
investment management agreement with Baird
Equity Asset Management. The
investment
management agreement will contain the specific
terms applicable
client’s advisory
relationship with Baird Equity Asset Management.
to select an
A client is responsible for providing to Baird
Equity Asset Management and any Other Manager
managing the client’s portfolio information that
Baird Equity Asset Management or the Other
Manager reasonably requires in order to provide
the services selected by the client including, but
not limited to, any investment policy statement
and anticipated liquidity needs. Baird Equity Asset
Management and the Other Manager will rely on
this information when providing its advisory
services. A client is also responsible for informing
Baird Equity Asset Management manages client
portfolios with full investment discretion and
tailors its advisory services to the individual needs
of clients. Baird Equity Asset Management
analyzes a client’s specific needs and risk
investment strategy
tolerance
appropriate for the client. Baird Equity Asset
Management offers two (2) primary growth
investment strategies: a Mid Cap Growth
Portfolio; and a Small/Mid Cap Growth Portfolio
(the “Baird Equity Asset Management Growth
Strategies”). Baird Equity Asset Management also
offers Specialized Asset Management (“SAM”)
portfolio strategies
“SAM Strategies”),
(the
consisting of SAM Large Cap Core Portfolio
strategies; SAM Strategic Portfolio strategies and
2
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Management an advisory fee in addition to the
wrap fee they pay to the Program Sponsor.
Baird Equity Asset Management and the Other
Manager in writing of any material change in
circumstances that might materially affect the
manner in which the client’s assets should be
invested.
fee programs, Program
Under such wrap
Sponsors generally assist a client with the
selection of Baird Equity Asset Management (or
may have the discretion to select Baird Equity
Asset Management) to manage the assets in the
client’s account maintained at the Program
Sponsor. They generally also provide trade
execution services and custodial services for the
client’s account as part of the wrap fee paid by
the client.
Important Note for Wrap Fee Program Clients.
Baird Equity Asset Management manages client
assets under wrap fee programs sponsored and
administered by Baird and unaffiliated parties (the
“Program Sponsors”). A list of Program Sponsors
is included on Schedule D to Baird’s Form ADV
Part 1A, which is available at the SEC’s website at
www.adviserinfo.sec.gov.
accounts,
including
Baird Equity Asset Management participates in
those wrap fee programs in one of two ways.
First, Baird Equity Asset Management may
manage client portfolios with full investment
discretion. Alternatively, Baird Equity Asset
Management may provide the Program Sponsor
with model portfolios, or other advice or
consulting services regarding the asset allocation
strategies, that the Program Sponsor provides to
clients.
Clients participating, or considering participating,
in a wrap fee program sponsored by Baird should
also review Baird’s Form ADV Part 2A Wrap Fee
Program Brochure in addition to this document.
Baird’s Wrap Fee Program Brochure contains
additional important information not contained in
this document that applies to Baird wrap fee
program
important
information about the services, fees, costs and
expenses and conflicts of interest that apply to
those accounts.
Clients who select Baird Equity Asset Management
to manage their assets within wrap fee programs
typically do so under either a “single contract” or
“dual contract” arrangement.
the
for executing
in wrap
fee programs
“Brokerage
Practices”
If Baird Equity Asset Management is selected to
manage the assets in a client account maintained
by the Program Sponsor, Baird Equity Asset
Management will manage the client’s account with
full investment discretion. Unless the client or
Program Sponsor directs Baird Equity Asset
Management to do otherwise, Baird Equity Asset
Management will select the broker-dealers that
will execute client trades. To the extent deemed
appropriate by Baird Equity Asset Management
pursuant to its duty to seek best execution, Baird
Equity Asset Management may place orders with
broker-dealers other than the Program Sponsor.
As a result, a client may incur costs in addition to
the wrap fee paid to the Program Sponsor if the
executing firm charges a commission, markup or
trade. Clients
markdown
participating
are
encouraged to read carefully the Section below
for more
entitled
information.
Under a single contract arrangement, a client
enters into an agreement with the Program
Sponsor and the Program Sponsor, in turn, enters
into a subadvisory or similar agreement with
Baird Equity Asset Management on the client’s
behalf. This type of arrangement is frequently
referred to as a single contract arrangement
because there is only one contract between the
client and the Program Sponsor; the client does
not have an agreement directly with Baird Equity
Asset Management. Clients with single contract
arrangements typically pay an asset-based wrap
fee to the Program Sponsor and, out of that wrap
fee, the Program Sponsor pays an advisory fee to
Baird Equity Asset Management.
services,
Baird
Equity
If Baird Equity Asset Management provides the
Program Sponsor with model portfolios, advice or
consulting
Asset
Management will not manage the client’s account
or select broker-dealers to execute client trades.
Under a dual contract arrangement, the client has
two contracts; one contract with the Program
Sponsor and another contract with Baird Equity
Asset Management. Clients with a dual contract
to Baird Equity Asset
arrangement pay
3
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Private Funds
sections
entitled
“Fees
If a client is participating in a wrap fee program,
the client should review the client’s agreement
with the Program Sponsor and the Program
Sponsor’s Form ADV Part 2A Brochure for a full
description of the services provided and fees
charged by the Sponsor. A client should also
review
and
the
Compensation” and
“Investment Discretion”
below for more information.
with
Baird
Equity
CCM provides
services on a
investment
discretionary basis to three private investment
funds, the Chautauqua International Growth
Equity QP Fund, LP, the Chautauqua Global
Growth Equity QP Fund, LP and the New World
Growth Equity Series, a series of the Chautauqua
Series Fund, LLC (the “Chautauqua Private
Funds”), which are private pooled investment
vehicles that are not required to be registered
with the SEC as investment companies. Baird
serves as the general partner or manager of the
Chautauqua Private Funds. Chautauqua Private
Fund interests are not publicly offered for sale
and are not registered with the applicable
securities regulators. Investors in the Chautauqua
Private Funds must be accredited investors and
qualified clients pursuant to federal and state
securities laws.
the
entitled
“Fees
Important Note about
the Other Manager
Strategies. The Other Manager Strategies are
made available to clients under a single contract
arrangement
Asset
Management, that is, a client enters into an
agreement with Baird Equity Asset Management
and Baird Equity Asset Management, in turn,
enters into a subadvisory agreement with the
Other Manager on the client’s behalf. If a client
selects an Other Manager Strategy, the client
authorizes and directs Baird Equity Asset
Management to appoint the Other Manager to
serve as sub-adviser to the client’s account. The
client also authorizes and directs the Other
Manager to manage the client’s portfolio with full
discretionary authority in accordance with the
Other Manager Strategy selected by the client.
See
and
sections
Compensation” and
“Investment Discretion”
below for more information.
Mutual Funds
Baird Equity Asset Management provides
investment management and other services to
certain mutual fund series of Baird Funds, Inc.
investing primarily in equity securities (the “Baird
Equity Funds”). Additional information about the
services Baird Equity Asset Management provides
is available in the prospectuses and statements of
additional information for those Baird Funds,
which are available on the Baird Funds’ website at
bairdassetmanagement.com/baird-funds.
is available
Baird Equity Asset Management serves as
investment sub-adviser to a mutual fund series of
the Principal Funds, Inc., and CCM serves as
investment sub-adviser to a mutual fund series of
the Pace® Select Advisors Trust. Additional
information about the services that Baird Equity
Asset Management and CCM provide to those
funds
in the prospectuses and
statements of additional information for those
funds.
CCM is responsible for managing the Chautauqua
Private Funds’ investment portfolios pursuant to
the investment objectives and investment policies
of the Chautauqua Private Funds that are stated
in each Chautauqua Private Fund’s private
offering memorandum. CCM determines what
investments will be purchased, held, sold, or
exchanged. Baird is responsible for all major
operational decisions of the Chautauqua Private
Funds and appoints service providers to perform
administrative, accounting, custody and investor
services for the Chautauqua Private Funds. These
services include, but are not be limited to,
processing subscriptions and redemptions of
interests
in the Chautauqua Private Funds,
calculation of the net asset value of each
Chautauqua Private Fund, preparation of the
financial statements, preparation of all reports to
limited partners of the Chautauqua Private Fund
including the IRS K‑1, administration of the
capital accounts of the Chautauqua Private Fund’s
limited partners or members, transfers of limited
partner interests and management of overhead
functions for the Chautauqua Private Funds. Baird
may amend the applicable Limited Partnership
Agreement or Operating Agreement without the
consent or approval of the limited partners or
members (as the case may be), so long as at
least sixty (60) days prior written notice of the
amendment is given in advance, to all limited
partners or members, as applicable. Such
amendments may be made at the absolute
discretion of Baird and may involve any or all
provisions of the applicable agreement or any
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
to
the structure or
other matters relating
operation of those Funds.
CCM International Growth Equity Portfolio
CCM Global Growth Equity Portfolio
Value of Assets
Annual Fee Rate
On the first $100,000,000
0.70%
On the next $200,000,000
0.50%
Additional information about the Chautauqua
Private Funds and the services that CCM provides
to them is available in the offering memoranda for
those funds.
On the remaining assets
0.30%
Collective Investment Trusts
its equivalent held
including
information relating
to
Baird Equity Asset Management, CCM and other
departments of Baird serve as investment adviser
to certain, different series of the Reliance Trust
Institutional Retirement Trust (“Reliance Trust”),
a collective investment trust (“CIT”). Additional
information about each series of the Reliance
Trust,
the
services provided to each series of the Reliance
Trust by Baird Equity Asset Management, CCM or
other departments of Baird, as the case may be,
is available in the offering documents for the
applicable series of the Reliance Trust.
Baird Equity Asset Management will calculate its
fee by applying the applicable fee rate to the
value of all of the assets in the client’s account,
including cash or
for
investment. Liabilities held in a client's accounts,
including the value of margin debit balances, open
short sale positions and open options positions
with a negative market value will be excluded
from the calculation of a client's advisory fee. The
value of cash balances held in a client’s account
will be excluded from the calculation of a client's
advisory fees in an amount equal to the value of
any open short sale positions and options
positions with a negative market value held in the
margin account.
Fees and Compensation
Separate Accounts
Advisory Fees
A client’s investment management agreement will
set forth the actual compensation a separate
account client will pay to Baird Equity Asset
Management. In most instances, a client pays
Baird Equity Asset Management an ongoing fee
based upon the value of assets in the client’s
account (an “asset-based fee”). The typical asset-
based fee varies depending upon the total value
of the client’s assets in the account, as shown in
the fee schedule below.
Fee Schedule
SAM Portfolios
Value of Assets
Annual Fee Rate
For purposes of calculating a client’s asset-based
fee, the value of assets in a client’s account is
generally determined by Baird. Baird generally
determines the value of the assets in the client’s
account using prices from third party pricing
services. However, if the client has its assets held
by a custodian other than Baird and if the third
party pricing service does not provide a price for
assets in the client’s account, Baird will rely upon
the price reported by the client’s third party
custodian. In some cases, Baird obtains prices
from the issuers or sponsors of investment
products in the client’s account when prices are
not otherwise readily available. This frequently
occurs with respect to the valuation of alternative
investment products in a client’s account.
On the first $10,000,000
0.75%
On the next $40,000,000
0.60%
in-depth
On the remaining assets
0.50%
Mid Cap Growth Portfolio
Small/Mid Cap Growth Portfolio
Value of Assets
Annual Fee Rate
On the first $50,000,000
0.70%
On the next $50,000,000
0.60%
On the remaining assets
0.55%
Baird Equity Asset Management and Baird do not
review of valuation
conduct an
information provided by
third party pricing
services, issuers, sponsors or custodians, and
they do not verify or guarantee the accuracy of
such information. Baird Equity Asset Management
for
and Baird do not accept responsibility
valuations provided by third parties that are
inaccurate unless they have a reason to believe
that the source of such valuations is unreliable.
The prices obtained by Baird from third party
pricing services, issuers, sponsors and custodians
5
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
for
agrees,
to
an
may differ from prices that could be obtained
from other sources. Values used
fee-
calculation purposes may vary
from prices
received in actual transactions and are not firm
bids, offers or guarantees of any type with
respect to the value of assets in an account, and
the fee for some securities may be calculated
based on values that are greater than the amount
a client would receive if the securities were
actually sold from the client’s account.
individual
If a client maintains a balance in the client’s
margin account with Baird, such balance has no
bearing on the asset-based advisory fees charged
on client’s account. In other words, the margin
balance (i.e., the outstanding amounts of the
margin loan a client owes to Baird) in client’s
account will not be applied to reduce the client’s
billable account value in calculating the advisory
fee.
The asset-based
fees and charges will be
automatically deducted from the client’s account,
unless the client requests, and Baird Equity Asset
alternate
Management
arrangement, such as having Baird Equity Asset
Management issue the client an invoice for the
fees (“direct billing”). Direct billing may not be
available for retirement plan accounts or other
accounts subject to the Employee Retirement
Income Security Act of 1974, as amended
(“ERISA”) or
retirement accounts
(“IRA”) subject to the Internal Revenue Code
(collectively, “Retirement Accounts”). If a client’s
account is subject to direct billing, the client is
required to pay each bill within thirty (30) days of
the date of the invoice. Baird Equity Asset
Management or Baird may automatically debit a
client’s account for the fees and other charges in
the event that Baird does not receive payment
from the client within thirty (30) days of the date
of the invoice. Baird Equity Asset Management or
Baird may rescind a direct billing arrangement
with a client at any time.
Baird Equity Asset Management or Baird may
modify a client’s existing fees and other charges
or add additional fees or charges by providing the
client with sixty (60) days’ prior written notice.
terminates
client’s
The account value used for the advisory fee
calculation may differ from that shown on a
client’s account statement or performance report
due to a variety of factors, including the client’s
use of margin, options, short sales, and other
considerations. If a client has assets held by a
third party custodian, the prices shown on a
client’s account statements provided by the
custodian may be different from the prices shown
on statements and reports provided by Baird due
to the use of different valuation sources by the
custodian and Baird.
If either Baird Equity Asset Management or the
investment
the
client
management agreement, a pro-rated refund from
the date of termination through the end of the
applicable billing period will generally be made to
the client in the client’s account. Generally, Baird
Equity Asset Management will not implement a
decrease in the client’s fee rate during a billing
period or otherwise reimburse or adjust advisory
fees during any such period for asset value
appreciation or depreciation in a client’s account
during such period. For example, if a client’s
account is subject to a tiered or breakpoint fee
schedule and the asset levels of the account move
into a new tier or cross a breakpoint during such
period, no rebate or fee adjustment will be made.
However, Baird Equity Asset Management, in its
sole discretion, may make fee adjustments in
response to asset fluctuations in a client’s account
occurring during a billing period that result from
contributions to, or withdrawals from, the client’s
account.
A client’s fees are payable in accordance with the
terms of the client’s investment management
agreement. Typically, fees are payable on a
calendar quarterly basis, in advance. The initial
billing period begins when the client’s investment
management agreement is signed by the client
and accepted by Baird and the account is opened
by Baird Equity Asset Management (the “Opening
Date”). The initial fee payment will be adjusted
for the number of days remaining in the then
current quarter. The initial advisory fee will be
based on the value of assets deposited in the
client’s account. The period which such payment
covers shall run from the Opening Date through
the last business day of the then current calendar
quarterly billing period. Thereafter, the quarterly
fees shall be calculated based upon the account’s
asset value on the last business day of the prior
calendar quarter and shall become payable on the
first business day of the then current calendar
quarter.
Some or all of the assets in a client’s account may
be invested in an institutional share class of one
or more mutual funds within Baird Funds, Inc.
6
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Other Manager Strategies Fees. The Other
Manager Strategies are provided under a single
contract arrangement. Under the single contract
arrangement, Baird Equity Asset Management is
responsible for paying the Other Manager its fee
out of the fee that the client pays to Baird Equity
Asset Management.
(the “Baird Funds”), for which Baird serves as
investment adviser. If any assets are held in any
of
the Baird Funds, Baird Equity Asset
Management generally will not charge the fees set
forth above on those assets, unless those assets
are held through a wrap fee program (including
wrap fee programs sponsored by Baird), in which
event Baird Equity Asset Management’s fee will
generally be assessed on those assets.
Wrap Fee Programs. As discussed above, clients
who select Baird Equity Asset Management to
manage their assets within wrap fee programs
typically do so under either a “single contract” or
“dual contract” arrangement.
The minimum asset value to open a Growth
Strategy account is $20,000,000, a SAM Custom
account is $1,000,000, a SAM Strategic/non-
Custom SAM account is $200,000, and a CCM
Strategy account is $100,000,000. For the Baird
Equity Asset Management Growth and SAM
Strategies, Baird Equity Asset Management
generally imposes a minimum annual fee of
$7,500. For the CCM Strategies, clients may be
subject to a minimum fee, which will be set forth
in the client’s agreement. Unless otherwise
agreed in writing, the minimum fee will apply if a
client’s portfolio asset value falls below the
minimum account value. A client should note that
this will cause the client to pay a fee at a higher
rate than shown in the table above.
Clients with single contract arrangements typically
pay an asset-based wrap fee to the Program
Sponsor and, out of that wrap fee, the Program
Sponsor pays an advisory fee to Baird Equity
Asset Management. The portion of the wrap fee
paid to Baird Equity Asset Management varies
from program to program based upon the rate
negotiated by the Program Sponsor, taking into
account the investment strategies being pursued,
the amount of client assets involved, and the level
of services to be provided. Specific information on
the advisory fee payable to Baird Equity Asset
Management will be provided by the applicable
Program Sponsor. For information on the amount,
calculation and billing of the wrap fee charged by
the Program Sponsor, clients should consult with
the Program Sponsor or refer to their wrap fee
program agreement or the Program Sponsor’s
Form ADV Part 2A Wrap Fee Program Brochure.
The advisory fee and minimum account value
applicable to a client are negotiable in certain
instances and may vary based upon a number of
factors, including but not limited to, whether a
client is participating in a wrap fee program, the
size and nature of the assets in the client’s
account, the client’s particular investment style or
objective, and any particular services requested
by the client. In some instances, clients may pay
a higher fee than indicated in the fee schedule
above. The fees paid by a client may differ from
the fees paid by other clients based on a number
of factors, including but not limited to the factors
identified above. Baird Equity Asset Management
may enter into other fee arrangements with
eligible clients.
Clients with a dual contract arrangement pay to
Baird Equity Asset Management an advisory fee in
addition to the wrap fee they pay to the Program
Sponsor. Baird Equity Asset Management’s
advisory fee under a dual contract arrangement is
negotiable and may vary depending upon the
investment strategies being pursued, the amount
of client assets involved, and the level of services
to be provided. The actual fee that the client will
pay to Baird Equity Asset Management will be set
forth in the client’s investment management
agreement with Baird Equity Asset Management.
Baird Equity Asset Management will generally
calculate and charge such client fees in the
manner more fully described above.
In most cases, the wrap fee paid by a client
includes only certain trade orders executed
through the Program Sponsor. A client should be
aware that Baird Equity Asset Management may
The fee schedule set forth above is the current
fee schedule for new clients of Baird Equity Asset
Management. Baird Equity Asset Management has
had other fee schedules in effect, which may
reflect fees that are lower or higher, as the case
may be, than those shown above. As new fee
schedules are put into effect, they are made
applicable only to new clients, and fee schedules
applicable to existing clients are not affected.
Therefore, some clients may pay different fees
than those shown above.
7
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
from
related
to
the
• fees
establishment,
administration or termination of Retirement
Accounts, retirement or profit sharing plans,
trusts or any other legal entity;
frequently “trade away”
the Program
Sponsor. A client may, therefore, incur trading
costs in addition to the wrap fee paid to the
Program Sponsor. See “Brokerage Practices”
below for more information.
Other Fees and Expenses
• fees imposed by the SEC or securities markets,
including transaction fees imposed by electronic
trading platforms, which fees may be imbedded
in the price the client receives for the security;
and
imposed upon or
resulting
• taxes
from
transactions effected for a client’s account, such
as income, transfer or transaction taxes, foreign
stamp duties, or any other costs or fees
mandated by law or regulation.
about
Baird
Equity
In addition to Baird Equity Asset Management’s
fee described above, a client of Baird Equity Asset
Management may incur other fees and expenses.
The asset-based
fee only covers portfolio
management and investment advice provided by
Baird Equity Asset Management, and a client will
pay for other services, such as custody and trade
execution, separately in addition to Baird Equity
Asset Management’s fee. Please see the section
entitled “Brokerage Practices” below for more
information
Asset
Management’s trading practices.
their own
internal
A client is responsible for bearing or paying, in
addition to Baird Equity Asset Management’s fee,
the costs of all:
fees, distribution (12b-1)
• commissions, markups, markdowns,
fees, accounting
and
spreads charged by broker-dealers that buy
securities from, or sell securities to, the client’s
account (such costs may be inherently reflected
in the price the client pays or receives for such
securities), including for the CCM Strategies,
local charges, fees, commissions and taxes
imposed on
transactions
foreign securities
effected in foreign markets;
• underwriting discounts, dealer concessions or
similar fees related to the public offering of
investment products;
fee. A client
• custody fees;
• extra or special fees or expenses that may
result from the execution of odd lot trade orders
(i.e., “odd-lot differential”);
Certain investment products, such as mutual
funds, exchange traded funds (“ETFs”), and other
similar investment pools (collectively, “investment
funds”), have
fees and
expenses that are borne either directly or
indirectly by their holders, including a client.
These fees and expenses may include investment
management
fees,
shareholder servicing fees, transfer agency fees,
networking
fees, marketing
support payments, administration fees, custody
fees, expense reimbursements, and expenses
associated with executing securities transactions
for the investment product’s portfolio (“ongoing
operating expenses”). These ongoing operating
expenses are separate from, and in addition to,
Baird Equity Asset Management’s fee. As a result
of making investments in these types of products,
a client should be aware that the client is paying
multiple layers of fees and expenses on the
amount of the client’s assets so invested—the
ongoing operating expenses and Baird Equity
Asset Management’s
is also
responsible for any redemption fees or similar
fees that the fund or its sponsor may impose on
the client. A client should review the prospectus
or other applicable offering documents for each
investment fund in which the client invests for
further information.
• electronic fund fees, wire transfer fees, and
similar fees or expenses related to account
transfers;
• currency conversions and transactions;
conversions,
the
conversion
• securities
including, without
of American
limitation,
Depositary Receipts (“ADRs”) to or from foreign
ordinary shares;
• interest, fees and other costs related to margin
Clients who have accounts managed by Baird
Equity Asset Management may also have other
accounts with Baird that are not managed by
Baird Equity Asset Management. Those accounts
may be subject to fees, commissions or other
expenses that are entirely separate from the
payment of fees and expenses for the services
provided by Baird Equity Asset Management.
accounts, short sales and options trades;
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Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Mutual Funds
As compensation for their services, Baird Equity
Asset Management and CCM receive fees from
each mutual fund they advise, which fees are
disclosed in each fund’s prospectus and statement
of additional information. Other fees that are
payable as an investor in a mutual fund are
described in the fund’s prospectus and statement
of additional information.
investments
expenses
by
in
each
investor’s
the standard
Private Funds
As compensation for CCM’s services in managing
the Chautauqua Private Funds, Baird charges a
monthly fee in arrears that is calculated based on
a pro‑rata share of the Chautauqua Private Fund’s
net asset value held by each investor as of the
close of business on the prior month’s valuation
date, reduced by any redemptions on such date
and increased by any capital contributions on the
open date immediately succeeding such prior
month’s valuation date (i.e., on the open date for
the current month). The first business day of each
month will be the Fund’s “open date” and the
close of business on the immediately prior
business day will be the Fund’s “valuation date”.
Redemptions and new subscriptions will occur
once a month. Each investor’s annual fee will be
disclosed
subscription
agreement and CCM may alter, reduce or waive
entirely the management fee to any investor at its
fee
sole discretion. However,
schedule is as follows:
Management Fee Schedule
Chautauqua International Growth Equity QP Fund, LP
Chautauqua Global Growth Equity QP Fund, LP
accrue as expenses of the Chautauqua Private
Funds and will be taken into account when
determining each investor’s account’s net asset
value. Accounts under $25,000,000 may pay
more than the standard fee. In addition to the
management fees charged by Baird to the
Chautauqua Private Funds,
the Chautauqua
Private Funds will also pay or reimburse Baird, as
general partner or manager, for Chautauqua
Private Fund expenses incurred in connection with
the business of the Funds. The Chautauqua
Private Funds’ expenses may include, but are not
limited to, insurance costs, legal, administration
and accounting fees, custodial fees, brokerage
commissions and securities transaction costs, the
expenses of printing and mailing reports to
investors, transfer and distribution agent charges,
expenses of any security holders’ meetings,
interest and taxes, advisory fees paid with respect
to
in any non‑affiliated money
market mutual fund, any and all costs incurred in
connection with computing the value of the
assets, any and all costs and expenses incurred in
connection with the dissolution, winding up, or
the Funds and any other
termination of
extraordinary
the
incurred
Chautauqua Private Funds in their course of
business. Until each of the Chautauqua Global
Growth Equity QP Fund, LP and the Chautauqua
International Growth Equity QP Fund, LP has a
total of at least $25,000,000 in assets, and at all
times for the New World Growth Equity Series, a
series of the Chautauqua Series Fund, LLC, CCM
will bear routine
tax, administrative,
legal,
accounting, insurance, and all other costs of the
Fund to the extent these costs exceed 1/12th of
.25% of the Fund’s net asset value as of each
monthly valuation date.
Value of Assets
Annual Fee Rate
On the first $100,000,000
0.70%
On the next $200,000,000
0.50%
On the remaining assets
0.30%
Chautauqua New World Growth Equity Series
in
Value of Assets
Annual Fee Rate
All assets
1.00%
An investor may, on any valuation date redeem
all or a portion of its interests with thirty (30)
days written notice to CCM. Investors in the
Chautauqua Private Funds will be subject to
restrictions on transferability and resale of their
the Chautauqua Private Funds.
interest
Additionally, there may be specific limitations on
the
redemptions and withdrawals. Limited
partners should refer to the Confidential Offering
Memorandum and Chautauqua Private Fund
Agreement for details regarding redemptions,
withdrawals, transfers, and re‑sales.
Collective Investment Trusts
The management fees are negotiable and some
investors pay management fees that are different
from the standard fee rates and an investor in the
Chautauqua International Growth Equity QP Fund,
LP pays management fees that include or consist
of a performance fee. The management fees will
9
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
compensation
and
other
information about
client). For more specific
Baird’s
benefit
arrangements and how Baird addresses the
potential conflicts of interest, please see the
sections “Other Financial Industry Activities and
Affiliations” and “Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
As compensation for their services, Baird Equity
Asset Management and CCM receive fees from
each series of the Reliance Trust they advise.
Additional information about each series of the
Reliance Trust, including information relating to
the fees paid by each series to Baird Equity Asset
Management or CCM, as the case may be, for
investment management services, is available in
the offering documents for the applicable series of
the Reliance Trust.
Baird Equity Asset Management will purchase for
client accounts, or will recommend the purchase
of, various investment products, including “no
load” mutual funds or mutual funds with waived
sales loads. A client has the option to purchase
investment products through other brokers or
agents that are not affiliated with Baird.
Other Compensation Received by Baird
Equity Asset Management and Baird
Baird Equity Asset Management. Baird Equity
Asset Management and its associates generally do
not receive compensation based upon the sale of
securities or other investment products, and the
compensation Baird pays to Baird Equity Asset
Management’s associates generally remains the
same regardless of the type of investment
product recommended to clients or purchased for
client accounts.
to
a
performance-based
fee
arrangements
Baird. Baird is registered as a broker-dealer under
the Securities Exchange Act of 1934, as amended
(the “Exchange Act”), and in such capacity, Baird
provides brokerage and related services to clients,
including the purchase and sale of individual
stocks, bonds, mutual funds, private investment
funds, and other securities, and sales of life
insurance policies and annuities. Baird receives
compensation based upon the sale of such
securities and other
investment products,
including asset-based sales charges and service
fees on the sale of mutual funds.
Performance-Based Fees and Side-By-
Side Management
Baird Equity Asset Management and Baird advise
client accounts that are subject to performance-
based fee arrangements. Performance-based fee
arrangements involve the payment of fees based
upon the capital gains or capital appreciation of a
client’s account. Any such fee arrangements are
made in compliance with applicable provisions of
Rule 205-3 under the Advisers Act. A client’s
agreement
fee
arrangement may create an incentive for Baird
Equity Asset Management to recommend or invest
a client’s account in riskier or more speculative
products than would be the case in the absence of
arrangement.
performance-based
a
Performance-based
also
fee
present a potential conflict of interest for Baird
Equity Asset Management and Baird with respect
to client accounts they also manage that are not
subject to performance-based fee arrangements
because such arrangements give Baird Equity
Asset Management and Baird an incentive to favor
client accounts subject to performance-based fees
over client accounts that are not subject to
performance-based fees. Performance-based fee
arrangements could also create an incentive for
Baird to over‑value certain assets held by clients.
generally
addresses
The compensation received by certain Baird
Equity Asset Management sales professionals and
Baird described above presents a conflict of
interest because it gives Baird and those Baird
Equity Asset Management sales professionals an
incentive to recommend investment products
based upon the compensation received rather
than on a client’s needs. However, when
providing investment advisory services to clients,
Baird Equity Asset Management and Baird are
fiduciaries and are required to act solely in the
best
interest of clients. Baird Equity Asset
Management and Baird address this conflict
through disclosure in this Brochure and by
adopting internal policies and procedures that are
designed to ensure that investments made for
client accounts are appropriate for the client
(based upon the information provided by the
In addition to complying with its fiduciary duties
by disclosing this conflict of interest to clients
this Brochure, Baird Equity Asset
through
Management
potential
conflicts of interest posed by performance-based
fee arrangements by capping the amount of
performance-based fees that may be earned with
to a client’s account. By capping
respect
10
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
high-quality
products. Baird
industries
conflicts
of
interest
to make securities allocations
performance-based
fees, Baird Equity Asset
Management attempts to reduce the incentive to
invest a client’s account in riskier or more
Equity Asset
speculative
Management and Baird attempt to minimize
potential
posed by
performance-based fee arrangements through
internal trade allocation procedures that are
to
designed
discretionary client accounts in a manner such
that all such clients receive fair and equitable
treatment over time. Baird has also adopted
policies and procedures reasonably designed to
support fair valuations of securities in client
accounts.
Small/Mid Cap Growth Portfolio. The Small/Mid
Cap Growth Portfolio primarily invests in small-
and medium-sized,
growth
companies holding leadership positions within
their
that Baird Equity Asset
Management’s portfolio managers believe are
capable of producing above average growth in a
variety of market environments. The Portfolio will
emphasize companies with a market capitalization
within the range of companies in the Russell
2500® Growth Index at the time of investment.
As of February 28, 2026, the market capitalization
of companies in the Russell 2500® Growth Index
ranged from $7 million to $50.3 billion. In an
attempt to minimize risk, the Portfolio is generally
diversified among companies in a broad range of
industries and economic sectors.
or Similar
or
other
business
investment
trusts; and
Cash
Investments; Temporary
Strategies. Under normal market conditions, up to
10% of a client’s portfolio may be invested in
cash or similar short-term, investment grade debt
obligations such as U.S. government obligations,
repurchase agreements, commercial paper or
certificates of deposit. In addition, Baird Equity
Asset Management may invest all of a client’s
assets in cash or short-term, investment grade
debt obligations as a temporary defensive position
during adverse market, economic or political
conditions and in other limited circumstances.
Types of Clients
Baird Equity Asset Management offers its services
to all types of current or prospective clients,
including, but not limited to: individuals; banks or
thrift institutions; pension and profit sharing
plans; trusts; estates; charitable organizations;
corporations
entities;
government entities; endowments; private funds;
collective
registered
investment companies. Applicable requirements
for opening or maintaining an account with Baird
Equity Asset Management, such as minimum
account size, are discussed in the section entitled
“Fees and Compensation—Advisory Fee” above.
Specialized Asset Management Portfolio
Strategies
SAM Large Cap Core Portfolios
Portfolio will
emphasize
Methods of Analysis, Investment
Strategies and Risk of Loss
Investment Strategies
Baird Equity Asset Management Growth
Strategies
in
Mid Cap Growth Portfolio. The Mid Cap Growth
Portfolio primarily invests in medium-sized, high-
leadership
quality growth companies holding
positions within their industries that Baird Equity
Asset Management’s portfolio managers believe
are capable of producing above average growth in
a variety of market environments. The Portfolio
will emphasize companies with a market
capitalization within the range of companies in the
Russell Midcap® Growth Index at the time of
investment. As of February 28, 2026, the market
the Russell
capitalization of companies
MidCap® Growth Index ranged from $1.2 billion
to $105.4 billion. In an attempt to minimize risk,
the Portfolio
is generally diversified among
companies in a broad range of industries and
economic sectors.
SAM Dividend Growth Portfolio. The Dividend
Growth
large-
capitalization, high-quality growth companies
holding leadership positions within their industries
that the portfolio managers believe are capable of
consistent dividend growth and
producing
performance in a variety of market environments.
The Portfolio will emphasize companies with a
market capitalization over $5 billion. The Portfolio
will strive to achieve a dividend yield equal or
greater than the S&P 500. The Portfolio will not
invest in MLPs, preferred stocks, options or
convertible securities. In an attempt to minimize
risk, the Portfolio is diversified in a broad range of
industries and economic sectors. The limit for any
one sector is the greater of 30% of the Portfolio
or double the weighting of the applicable sector in
the S&P 500 Index. The Portfolio may not have
full exposure to sectors where satisfactory growth
opportunities are not available. Investments in
11
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
American Depositary Receipts
(ADRs) will
generally be limited to no more than 15% of
equity assets.
SAM Strategic or Custom Portfolio provides for
specific levels of investment across different asset
classes, such as:
• equity securities issued by U.S. large cap, mid
cap and small cap companies (which may
include value and growth companies);
income
• short-term, intermediate-term and long-term
fixed
issued by U.S.
securities
companies and obligations issued by U.S. or
state governments or their agencies (which may
include high-yield corporate bonds, asset-
backed securities, and municipal securities);
it
• equity and fixed income securities issued by
foreign companies and governments (which
may include companies and governments in
emerging markets);
• non-traditional assets or specialty investments
(“Specialty Investments”), which may include:
Large Cap Core Growth Portfolio. The Large Cap
Core Growth Portfolio emphasizes large cap, high-
quality growth companies holding
leadership
positions within their industries that Baird Equity
Asset Management’s portfolio managers believe
are capable of producing consistent performance
in a variety of market environments. The Portfolio
will emphasize companies with a market
capitalization over $5 billion. However, a portion
of the equities may be allocated to small- and
medium-sized company stocks when, in Baird
Equity Asset Management’s opinion,
is
appropriate. In an attempt to minimize risk, the
Portfolio is generally diversified among companies
in a broad range of industries and economic
sectors, with sector limits for any one sector at
the greater of 30% of the Portfolio or double the
weighting of the applicable sector in the S&P
500® Index. The Portfolio may not have full
exposure to sectors where satisfactory growth
opportunities are not available.
• real estate (which may include U.S. and
trusts
real estate
investment
foreign
(“REITs”));
• investment products
complex
or
the equity
that pursue non-
alternative
traditional,
investment
(“Alternative
strategies
Strategies”) or that involve special risks not
apparent in more traditional investments
(“Alternative Investment Products”); and
• commodities, commodity-linked instruments,
currencies and currency-linked instruments;
and
• cash and cash equivalents.
rating
The amount allocated to each asset class and type
of investment varies by Portfolio. However, some
Portfolios may have no allocation to one or more
asset classes or types of investments described
above.
In order
Large Cap Balanced Portfolio. The equity portion
of the Large Cap Balanced Portfolio includes the
same types of securities utilized in the Large Cap
Core Growth Portfolio or SAM Dividend Growth
the absence of specific client
Portfolio. In
guidelines,
investments generally
range from 45% to 90% of total Portfolio value
over a full market cycle. The fixed income portion
of the Portfolio consists of high-quality securities,
which may include a mix of U.S. Treasury, U.S.
government agency, corporate bonds or municipal
bonds selected to provide a consistent source of
income and reduced principal risk. Individual fixed
income securities must be rated investment grade
or better at the time of purchase by a nationally
recognized
organization,
statistical
indirectly hold below
although clients may
investment grade or unrated
income
fixed
securities through their mutual fund and ETF
holdings.
to achieve adequate
diversification, mutual funds managed or selected
by Baird that satisfy the foregoing guidelines may
be used. ETFs may also be utilized.
SAM Strategic and SAM Custom Portfolios
Baird Equity Asset Management may invest the
account in individual securities to implement the
asset allocation. Baird Equity Asset Management
may also use mutual funds and ETFs in order to
achieve diversification across different asset
classes. Baird Equity Asset Management believes
broad
mutual
funds
and
ETFs
provide
The SAM Strategic and Custom Portfolio
Strategies are model asset allocation portfolios
that have different investment objectives. Each
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
diversification, which contributes to Portfolio risk
control.
funds and ETFs
securities, foreign equity securities and Specialty
Investments and 20% fixed income securities,
foreign fixed income securities and cash. Under
normal market conditions, this Portfolio primarily
invests its assets in equity securities, fixed
income securities and foreign securities and
mutual funds and ETFs that in turn principally
invest in those securities. This Portfolio normally
will have a significantly higher underlying asset
allocation to equity securities than fixed income
securities. This Portfolio may also invest in other
asset classes described above, including Specialty
Investments and cash.
(which may
or municipal
Depending on the SAM Portfolio, the SAM
Strategic or Custom Portfolio may invest in
mutual
that have various
investment objectives and strategies, including
but not limited to, the following: large cap, mid
cap and small cap strategies (which may include
value, growth or core strategies), short-term,
intermediate-term and long-term fixed income
include high-yield
strategies
strategies);
bond
corporate
international and global equity and fixed income
strategies, real estate strategies, commodities
strategies, currency strategies, and Alternative
Strategies. For additional information regarding
the characteristics of the mutual funds and ETFs
used in a SAM Strategic or Custom Portfolio,
clients should contact Baird Equity Asset
Management or review the applicable prospectus.
SAM Capital Growth Portfolio (Tax-Exempt)
(80/20). The SAM Capital Growth Portfolio (Tax-
Exempt) has the same objective, underlying
investments, target allocations and risk profile as
the SAM Capital Growth Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in municipal securities and
mutual funds and ETFs that in turn principally
invest in those securities.
The SAM Strategic or Custom Portfolio Strategies
generally accommodate both taxable and tax-
exempt accounts of clients.
“Other Financial
Baird Equity Asset Management may use mutual
funds and ETFs affiliated with Baird, including
mutual funds in the Baird Funds family. This
interest. For more
presents a conflict of
Industry
see
information,
Affiliations and Activities” below.
SAM Strategic Portfolios. The SAM Strategic
Portfolios are described below.
SAM Moderate Growth Portfolio (70/30). The SAM
Moderate Growth Portfolio seeks to provide
capital. Under normal market
growth of
conditions, this Portfolio seeks a target allocation
of 70% equity securities, foreign equity securities
and Specialty Investments and 30% fixed income
securities, foreign fixed income securities and
cash. Under normal market conditions, this
Portfolio primarily invests its assets in equity
securities, fixed income securities and foreign
securities and mutual funds and ETFs that in turn
principally invest in those securities. This Portfolio
normally will have a
significantly higher
underlying asset allocation to equity securities
than fixed income securities. This Portfolio may
also invest in other asset classes described above,
including Specialty Investments and cash.
SAM All Growth Portfolio. The SAM All Growth
Portfolio seeks to provide aggressive growth of
capital. Under normal market conditions, this
Portfolio seeks a target allocation of 98% equity
securities, foreign equity securities and Specialty
Investments and 2% cash. Under normal market
conditions, this Portfolio generally invests nearly
all of its assets in equity securities and foreign
equity securities and mutual funds and ETFs that
in turn principally invest in those securities. This
Portfolio may also invest in other asset classes
described above, including Specialty Investments
and cash.
SAM Moderate Growth Portfolio (Tax-Exempt)
(70/30). The SAM Moderate Growth Portfolio
(Tax-Exempt) has the same objective, underlying
investments, target allocations and risk profile as
the SAM Moderate Growth Portfolio described
above, except that this Portfolio primarily invests
its fixed income allocation in municipal securities
and mutual funds and ETFs that in turn principally
invest in those securities.
SAM Balanced Growth Portfolio (60/40). The SAM
Balanced Growth Portfolio seeks to provide
SAM Capital Growth Portfolio (80/20). The SAM
Capital Growth Portfolio seeks to provide growth
of capital. Under normal market conditions, this
Portfolio seeks a target allocation of 80% equity
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
mutual funds and ETFs that in turn principally
invest in those securities.
moderate growth of capital and some current
income. Under normal market conditions, this
Portfolio seeks a target allocation of 60% equity
securities, foreign equity securities and Specialty
Investments and 40% fixed income securities,
foreign fixed income securities and cash. Under
normal market conditions, this Portfolio primarily
invests its assets in equity securities, fixed
income securities and foreign securities and
mutual funds and ETFs that in turn principally
invest in those securities. This Portfolio normally
will have a higher underlying asset allocation to
equity securities than fixed income securities. This
Portfolio may also invest in other asset classes
described above, including Specialty Investments
and cash.
SAM Conservative Growth Portfolio (50/50). The
SAM Conservative Growth Portfolio seeks to
provide modest growth of capital and some
current income. Under normal market conditions,
this Portfolio seeks a target allocation of 50%
equity securities, foreign equity securities and
Specialty Investments and 50% fixed income
securities, foreign fixed income securities and
cash. Under normal market conditions, this
Portfolio primarily invests its assets in equity
securities, fixed income securities and foreign
securities and mutual funds and ETFs that in turn
principally invest in those securities. This Portfolio
normally will have a similar asset allocation to
equity securities as fixed income securities. This
Portfolio may also invest in other asset classes
described above, including Specialty Investments
and cash.
SAM Balanced Growth Portfolio (Tax-Exempt)
(60/40). The SAM Balanced Growth Portfolio
(Tax-Exempt) has the same objective, underlying
investments, target allocations and risk profile as
the SAM Balanced Growth Portfolio described
above, except that this Portfolio primarily invests
its fixed income allocation in municipal securities
and mutual funds and ETFs that in turn principally
invest in those securities.
SAM Conservative Growth Portfolio (Tax-Exempt)
(50/50). The SAM Conservative Growth Portfolio
(Tax-Exempt) has the same objective, underlying
investments, target allocations and risk profile as
the SAM Conservative Growth Portfolio described
above, except that this Portfolio primarily invests
its fixed income allocation in municipal securities
and mutual funds and ETFs that in turn principally
invest in those securities.
SAM Custom Portfolio. A SAM Custom Portfolio
provides a client with a customized level of
investment across one or more of the asset
classes described above. The custom model asset
allocation strategy is determined by the client
with
the assistance of Baird Equity Asset
Management.
SAM Strategic Income (60/40). The SAM Strategic
Income Portfolio seeks to provide growth of
capital and current income via interest and
dividends. Under normal market conditions, this
Portfolio seeks a target allocation of 60% equity
securities, foreign equity securities and Specialty
Investments and 40% fixed income securities,
foreign fixed income securities and cash. Under
normal market conditions, this Portfolio primarily
invests its assets in equity securities, fixed
income securities and foreign securities and
mutual funds and ETFs that in turn principally
invest in those securities. This Portfolio normally
will have a higher underlying asset allocation to
equity securities than fixed income securities. This
Portfolio may also invest in other asset classes,
including Specialty Investments and cash. The
SAM Strategic Income Portfolio will invest a
significant portion of its assets in the SAM
Dividend Growth Portfolio described above.
to many
The descriptions of the SAM Strategic Portfolios
are current as of the date of this Brochure.
However, Baird Equity Asset Management may
change the objective, investments, or target
allocations for any Portfolio at any time. Baird
Equity Asset Management may also offer other
model portfolios from time to time. A client should
note that the client’s actual asset allocation will
vary over time from the target asset allocation
due
including market
factors,
appreciation or depreciation of the assets in the
client’s portfolio, deposits and withdrawals made
by the client, and investment restrictions, if any,
imposed by the client.
SAM Strategic Income (Tax Exempt)(60/40). The
SAM Strategic Income Portfolio (Tax-Exempt) has
the same objective, underlying
investments,
target allocations and risk profile as the SAM
Strategic
Income Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in municipal securities and
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
include
strategy is currently the MSCI ACWI ex-US
Index®.
located
Some SAM Strategies
target asset
allocation percentages for equity and/or fixed
income investments in the names or descriptions
of the strategies (e.g., 80-20, 60-40, 40-60, 20-
80, etc.). A client should note that those
percentages are intended to be asset allocation
targets only. There is no guarantee that accounts
following asset allocation strategies will be
invested strictly in accordance with target asset
allocations. It is likely that the actual investments
in accounts following those strategies will vary,
sometimes significantly, from the target asset
allocations and may include other asset classes
due to market conditions and Baird Equity Asset
Management’s assessment of how to best invest a
client’s accounts.
CCM Strategies
the
regions around
growth
prospects
and
Global Growth Equity Portfolio. Under normal
market conditions, the Global Growth Equity
Portfolio primarily invests its assets in equity
securities of companies
in different
regions around the world. Equity securities may
include common or ordinary shares, and
depositary receipts representing an ownership
interest in ordinary shares, preferred stocks. The
Global Growth Equity strategy may include U.S.
headquartered companies. The Portfolio invests
primarily in developed markets but may invest in
emerging and
less developed markets. The
Portfolio seeks to own securities that CCM expects
to exhibit higher than average growth. The
Portfolio uses a simultaneous assessment of top-
down and bottom-up factors to determine which
securities to purchase. The companies in which
the Portfolio invests tend to have medium to large
market capitalizations, with higher earnings
growth rates, better profitability, and less debt
than their benchmarks, and are purchased at
valuations CCM believes are reasonable relative to
their
competitive
advantages. As of December 31, 2025, the
median market capitalization of companies held in
the Global Growth Equity
Portfolio was
approximately $66.35 billion. The Global Growth
Equity Portfolio generally invests in a limited
number of securities, typically ranging between
35‑45 companies, but seeks to be diversified in
terms of currencies, regions and economic
sectors. Under normal market conditions, CCM
expects that annual turnover in the Portfolio will
generally be below 25%. The benchmark for the
Global Growth Equity strategy is currently the
MSCI ACWI Index®.
or Similar
of
companies held
in
sectors. Under
Cash
Investments; Temporary
Strategies. Under normal market conditions, up to
10% of a client’s portfolio may be invested in
cash or similar short-term, investment grade debt
obligations such as U.S. government obligations,
repurchase agreements, commercial paper or
certificates of deposit. In addition, CCM may
invest all of a client’s assets in cash or short-
term, investment grade debt obligations as a
temporary defensive position during adverse
market, economic or political conditions and in
other limited circumstances.
International Growth Equity Portfolio. Under
normal market conditions,
International
Growth Equity Portfolio primarily invests its assets
in equity securities of companies located in
different
the world. Equity
securities may
include common or ordinary
shares, and depositary receipts representing an
ownership interest in ordinary shares, preferred
stocks. The International Growth Equity strategy
typically excludes U.S. headquartered companies.
The Portfolio
in developed
invests primarily
markets but may invest in emerging and less
developed markets. The Portfolio seeks to own
securities that CCM expects to exhibit higher than
average growth. The Portfolio uses
a
simultaneous assessment of
top-down and
bottom-up factors to determine which securities
to purchase. The companies in which the Portfolio
invests tend to have medium to large market
capitalizations, with higher earnings growth rates,
better profitability, and less debt than their
benchmarks, and are purchased at valuations
CCM believes are reasonable relative to their
growth prospects and competitive advantages. As
of December 31, 2025, the median market
capitalization
the
International Growth Equity Portfolio was
approximately $48.05 billion. The International
Growth Equity Portfolio generally invests in a
limited number of securities, typically ranging
between 25‑35 companies, but seeks to be
diversified in terms of currencies, regions and
economic
normal market
conditions, CCM expects that annual turnover in
the Portfolio will generally be below 25%. The
benchmark for the International Growth Equity
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
The International Growth Equity Portfolio and the
Global Growth Equity Portfolio alone are not
intended to satisfy a client’s entire portfolio
diversification needs. Those Portfolios involve
investments in a limited number of securities and
are subject to concentration risks. See the Section
titled “Principal Risks-Concentration Risks” below
for more information.
Other Baird Equity Asset Management
Strategies
FactSet, MarketSurge and William O’Neil) may
provide data for security analysis and general
economic
information. Baird Equity Asset
Management may also utilize research reports
created by other departments of Baird. Baird
Equity Asset Management may also employ the
use of computers and third party application
software to more readily display information and
to assist with the evaluation and analysis.
Although Baird Equity Asset Management uses
information and tools that Baird Equity Asset
Management deems reliable, Baird Equity Asset
Management does not independently verify or
guarantee the accuracy of the information or tools
used.
Baird Equity Asset Management also manages
client assets in accordance with other investment
strategies specifically designed for a client in light
of a client’s particular needs.
Other Manager Strategies
Clients that are considering engaging an Other
Manager are urged to review the Other Manager’s
Form ADV Part 2A Brochure (“Other Manager
Brochure”) for information about the strategies
the Other Manager offers. Other Manager
Brochures may be obtained by contacting Baird
Equity Asset Management at the phone number
listed on the cover of this Brochure.
tax-exempt
Benchmarks
Baird Equity Asset Management provides portfolio
advice and management for investors desiring
long-term investments and does not service
speculators seeking to optimize results through
short-term trading. Consequently, Baird Equity
Asset Management focuses on the investment
rather than speculative value of equity and debt
securities. Nevertheless, changing
investment
viewpoints, security prices or other factors might
lead at times to short holding periods for selected
institutional
securities. Certain
portfolios which target investment returns in
relationship to specified benchmarks will, because
of the specialized nature of their objectives,
frequently employ investment strategies that
produce a higher turnover of investment holdings.
A Portfolio may target the annual rate of return of
a specific benchmark index or indices that Baird
Equity Asset Management determines relevant.
The benchmark may also be a blended benchmark
that combines the returns for two or more
indices. The securities selected by Baird Equity
Asset Management generally will not mirror the
assets in their respective benchmark indices.
There can be no assurance that any particular
portfolio strategy will be successful in achieving
the client’s investment goals and objectives.
Baird Equity Asset Management will refrain from
providing services to clients who have an
investment objective that does not match an
investment style or philosophy of Baird Equity
Asset Management, set unrealistic expectations
considering
current market and economic
conditions, prescribe unreasonable investment
restrictions, or utilize benchmarks
that are
inappropriate for their stated objectives and
goals. Baird
Equity Asset Management’s
investment philosophy and processes are further
described below.
releases and other
(“AI”)
and
Federal
Reserve
sources
in
formulating
Methods of Analysis
Baird Equity Asset Management both develops its
own research and valuation systems and uses
such services provided by others. Information
includes company-issued
provided by others
literature (e.g., annual reports, prospectuses,
press
information) and
analyses by many outside investment firms.
Bank
Government
publications, financial and other newspapers,
journals and corporate ratings services (e.g.,
Moody's, Standard and Poor’s) as well as
electronic data
(e.g.,
information
Bloomberg, Morningstar, Dow Jones, Reuters,
Baird Equity Asset Management may use artificial
intelligence
tools, such as machine
learning, predictive analytics and probabilistic
modeling tools, data processing and automation
tools, generative AI tools, visual, speech and
audio tools, specialized domain tools, and other
similar technologies and tools (collectively, “AI
investment decisions.
Tools”),
Generally, the use of AI Tools is limited to certain
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
reflect PRIME
summarization,
analysis
Baird Equity Asset Management seeks
to
construct each Baird Equity Asset Management
Growth Strategy Portfolio so that is comprised of
investment
companies which
factors. These factors are analyzed as part of
Baird Equity Asset Management’s investment
process and are represented in the following
ways:
Profitability.
Companies
• Durable
in
before
outputs
with
advantaged competitive positions have greater
potential to generate attractive and increasing
margins, and high returns.
aspects of Baird Equity Asset Management’s
investment process, such as assisting with
drafting of materials, automation of workflow
processes, and the compilation, reproduction,
organization,
and
interpretation of information. The use of AI Tools
is only supportive of Baird Equity Asset
Management’s investment process and does not
replace the professional judgment of Equity Asset
Management’s investment professionals. All AI
Tool-assisted outputs used
the portfolio
management process are subject to human
inform
such
review
recommendations or investment decisions.
• Sustainable Revenue Growth. Solid barriers to
entry, favorable pricing power and an effective
strategy can support top-line prospects, and
superior earnings growth.
• Favorable Industry dynamics. Baird Equity
Asset Management leverages its intellectual
capital by identifying favorable end-market
demand, making investments across sectors.
could negatively
influence
integrity,
• Strong Management. A critical element of a
high-quality company. Baird Equity Asset
governance practices
Management seeks
promoting
and
accountability,
shareholder alignment. Growth, profitability,
and balance sheet strength provide insight into
management effectiveness.
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations,
deceptive behaviors and other flaws due to the
construction of their underlying models and the
composition of their training data, which can
result in outputs that seem plausible but are in
fact inaccurate, incomplete, or misleading. The
use of AI Tools creates a risk that erroneous
information
the
portfolio management process. Baird has
established policies and procedures designed to
address the risks posed by AI Tools, which include
requirements that AI Tools pass a Baird-level due
diligence process and that Baird associates obtain
training and independently verify AI Tool outputs.
However, such measures cannot completely
eliminate the risks posed by AI Tools.
Baird Equity Asset Management Growth and
SAM Strategies
Equity Investments
• Market Expectations. Important in assessing
risk/return opportunities and portfolio capital
allocation. Strengthening fundamental trends
can expand valuation potential.
for
Baird Equity Asset Management believes an
analysis of these PRIME factors yields insights to
the competitive strength of a business model.
Baird Equity Asset Management applies the
following strategies when purchasing securities for
a Portfolio:
avoiding
short-term trading
• Intentionally
strategies and rapid shifts in industry positions.
• Leveraging key tools, such as Baird Equity Asset
Management’s proprietary tier board, which
provides a visual representation of portfolio
positions and enables discussion on relative
weights of our underlying positions.
For the purpose of selecting individual equity
investments
the Baird Equity Asset
Management Growth and SAM Strategies, Baird
Equity Asset Management relies principally on
fundamental analysis to evaluate the relative
strength of companies and to isolate a universe of
desirable securities. The investment philosophy of
Baird Equity Asset Management is based on the
belief that the value of a business over the long-
term is primarily determined by the earnings
growth and profitability of that business. Baird
Equity Asset Management’s approach in applying
this philosophy is to focus on the long-term, to
invest in quality, growth companies, and to
control
investment risk. Baird Equity Asset
Management’s philosophy is applied consistently
across all growth equity products.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• Setting sector limits at the greater of 30% of
the Portfolio’s style or double the weighting of
the Portfolio’s benchmark index in any one
sector, as defined by such index.
considers
• Typically holding the securities of fewer than 70
companies with exposure to approximately 20
industries.
international
• Seeking securities whose growth prospects, in
the Advisor’s opinion, are not reflected in their
current stock prices.
Asset Management may use technical analysis
(which includes insider transaction data and
graphic representations of price, volume and
other characteristics for a security) to assist in
determining the timing of purchases or sales of
securities after an analysis of fundamental or
cyclical factors relevant to the security. Baird
Equity Asset Management
the
role of government worthy of
expanding
continuing review from both a macro- and micro-
economic standpoint, and at times, its analysis of
domestic or
factors related to
political and regulatory influences on economic
processes is an important factor in investment
decisions.
Fixed Income Investments
For the purpose of selecting individual fixed
income investments for the Baird Equity Asset
Management Growth and SAM Strategies, Baird
Equity Asset Management focuses on what it
considers to be high-quality securities, which may
include a mix of U.S. Treasury, U.S. government
agency, corporate bonds or municipal bonds.
Individual fixed income securities must generally
be rated investment grade or better at the time of
purchase by a nationally recognized statistical
rating organization, although
clients may
indirectly hold below investment grade or unrated
fixed income securities through their mutual fund
and ETF holdings.
Mutual Fund and ETF Investments
• Limiting the size of any one new position. No
new security will represent more than 5% of the
Portfolio total assets at the time the security is
initially purchased for the model Portfolio unless
the security represents more than 5% of the
total assets of the Portfolio’s benchmark index,
in which event the security may represent more
than 5% of the Portfolio if Baird Equity Asset
Management determines to invest above such
level. This limitation does not apply to the
purchase of a security for a newly established
account if the security’s weighting in the
Portfolio strategy selected for the new account
already exceeds 5% (i.e., new accounts will be
invested in accordance with the then-current
weightings of the Portfolio strategy selected for
the account, which may exceed the weightings
of the benchmark). This limitation only applies
to new positions in a Portfolio and does not
restrict Baird Equity Asset Management from
adding to an existing position that represents
more than 5% of the Portfolio total assets.
it
relates
to
factors) on
forecasts.
Issues
and
to business cycles may
As
the Baird Equity Asset
Management Growth Strategies, Baird Equity
Asset Management bases the valuation of a
security (i.e., the determination of whether a
security is “cheap” or “expensive” in terms of its
historical profitability, long-range prospects and
fundamental analysis and
other
economic
industry
groupings that have historically demonstrated
sensitivity
require
valuation adjustments. Baird Equity Asset
Management may sell a security due
to
achievement of valuation targets, significant
change in the initial investment premise, or
fundamental deterioration.
it
relates
to
As
the Baird Equity Asset
Management Growth Strategies, Baird Equity
For the purpose of selecting mutual funds and
ETFs for the Baird Equity Asset Management
Growth and SAM Strategies, Baird Equity Asset
starts with Baird’s
Management generally
Recommended Mutual Fund List, which
is
designed to include mutual funds and ETFs across
numerous asset classes. When selecting funds for
inclusion on the List, Baird generally seeks mutual
funds and ETFs that have investment managers
with tenure of at least five (5) years and have
underlying investments that adhere to the fund’s
market capitalization policy and are consistent
with the manager’s stated investment process
and philosophy. Baird generally looks for funds
that are among the top-performing funds in a
style category in terms of risk-adjusted returns or
that are managed by individuals or firms that
have demonstrated success in other, related asset
classes; that have performance histories showing
sufficient ability to achieve returns in excess of
their respective style index; and that have
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
It also
Investment Committee
limited
for
inclusion
investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird’s
Asset Manager Research Department is primarily
for assisting with selecting and
responsible
evaluating mutual funds included on the List.
Baird’s
is ultimately
responsible for selecting funds included on the
List. The Baird Ultra Short Bond Fund, Baird
Short-Term Bond Fund, Baird Aggregate Bond
Fund, Baird Quality Intermediate Municipal Bond
Fund, Baird Core Intermediate Municipal Bond
Fund, and Baird Mid Cap Growth Fund, mutual
funds affiliated with Baird, have been selected by
Baird
in Baird’s Recommended
Mutual Fund List. This presents a conflict of
interest. However, the criteria used by Baird in
deciding to select affiliated mutual funds for
Baird’s Recommended Mutual Fund List are the
same as those used for unaffiliated mutual funds.
performance
does
or
when
valuations
further analysis. Before making an investment,
CCM will consider the reasonableness of the
company’s valuation.
incorporates
environmental, social and governance (“ESG”)
factors into its investment process and seeks to
understand the ESG topics most relevant to each
company under consideration, recognizing these
factors can affect investment returns to varying
degrees. As part of its company analysis, CCM
evaluates the ESG issues most material to a
business’s key profit drivers, valuation, and ability
to manage related risks. Examples include, but
to, corporate governance
are not
structure, climate change, supply chain integrity,
labor practices and human resource management.
CCM will typically sell or reduce a position to
mitigate specific risk, to take advantage of better
opportunities, to avoid country risks, when
not meet
operational
expectations
are
unreasonable.
Other Manager Strategies
that have demonstrated
Clients that are considering engaging an Other
Manager are urged to review the Other Manager’s
Brochure for information about its methods of
analysis and how the Other Manager selects
investments. Other Manager Brochures may be
obtained by contacting Baird Equity Asset
Management at the phone number listed on the
cover of this Brochure.
Baird Equity Asset Management then performs an
additional level of review and selects mutual
funds and ETFs that meet its criteria. Generally,
Baird Equity Asset Management seeks funds and
ETFs:
investment
consistency; that provide upside capture; that
have relatively good long-term performance; that
have a strong organization and investment team
and significant manager tenure; and that have
relatively lower management fees and turnover
ratio. When selecting ETFs, Baird Equity Asset
Management prefers ETFs that have relatively
lower expense ratios and prices per share.
CCM Strategies
Portfolio Investments
Baird Equity Asset Management Growth
Strategies
CCM constructs and manages quality growth
international (non U.S.) and global (worldwide)
portfolios with the primary objective of long-term
capital appreciation. Investments are generally
made in the securities of companies that possess
long-term appreciation potential on a risk-
adjusted basis. CCM seeks companies that it
believes are positioned to benefit from long-term
secular growth trends and durable competitive
advantages. CCM’s investment process involves a
simultaneous assessment of both top-down and
bottom-up factors. The objective of CCM’s top
down analysis is to identify trends in economic
and business developments and to understand the
economic and currency impacts in the countries
where the companies are doing business. With
respect to its bottom-up research, CCM evaluates
both qualitative factors as well as quantitative
screens to aid in the selection of companies for
Baird Equity Asset Management may invest client
accounts in, and provides advice on, the following
types of securities: equity securities (exchange-
listed, over-the-counter, ADRs, and
foreign-
corporate debt
issued), warrants, options,
securities, commercial paper, certificates of
deposit, municipal securities, mortgage- and
asset-backed securities, collateralized mortgage
obligations and United States government and
United States Federal Agency securities. In some
instances, clients may be invested in non-
investment grade bonds (sometimes referred to
as “high yield” or “junk” bonds). In addition, Baird
Equity Asset Management may invest client
assets in securities of investment companies,
such as money market funds, mutual funds, ETFs,
other registered investment companies, and other
investment pools that invest in securities or track
securities-related indices.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Other Manager Strategies
in
other
registered
Other Managers generally invest client accounts
in, and provides advice on, equity securities
(exchange-listed, over-the-counter, ADRs, and
foreign-issued). In addition, Other Managers may
invest client assets in securities of investment
companies, such as money market funds, mutual
investment
funds, ETFs,
companies, and other investment pools that
invest in securities or track securities-related
indices. Other Managers may also invest client
accounts in other types of investments, such as
warrants, options, debt securities, commercial
paper, and certificates of deposit, in certain
circumstances. Clients are urged to review the
Other Manager’s Brochure for more information.
Additional Important Information
Baird Equity Asset Management may also invest a
client’s account in REITs, commodities and other
non-traditional assets. Baird Equity Asset
its
Management does not normally use
discretionary authority to purchase interests in
limited partnerships. However,
certain
circumstances, Baird Equity Asset Management
may invest a client’s account in hedge funds or
other private funds. Short sales and margin
transactions are not generally used. However, a
client may specifically request Baird Equity Asset
Management to consider using those strategies.
Baird Equity Asset Management may include
investments in options or futures contracts as a
normal part of
its portfolio advice and
management services, but will only offer such
services in limited instances. The use of these
strategies and products involves special risks, and
a client should not engage in these strategies
unless the client understands these risks. See
“Principal Risks” below for more information.
SAM Strategies
the heading
Asset
The types of investments used by Baird Equity
Asset Management for the SAM Portfolios is
“Investment
described under
Strategies—Specialized
Management
(“SAM”) Portfolio Strategies” above.
CCM Strategies
Investment
Additional
information
their equivalent).
Alternative Strategies involve special risks not
apparent in more traditional investments like
stocks and bonds. Some Alternative Strategies
invest in non-traditional assets, such as real
estate, commodities (which may include metals,
mining, energy and agriculture products), and
currencies. Some Alternative Strategies engage in
the use of margin or leverage or selling securities
short (“short sales”). Some Alternative Strategies
invest in derivative instruments such as options,
convertible securities, futures, swaps, or forward
contracts. Alternative
Products
generally engage in one or more Alternative
Strategies.
about
Alternative Strategies and Alternative Investment
Products is provided below
Receipts
(“GDRs”),
Non-Traditional Assets
assets,
like
real
CCM invests primarily in common stocks but may
also invest in other equity securities (including
preferred stocks and
In
addition, when CCM invests in foreign issuers, it
may use foreign ordinary shares, ADRs, Global
Depositary
European
Depositary Receipts (“EDRs”) and other similar
investment instruments. In certain instances,
CCM may implement its strategies using ADRs
instead of using securities that are traded in
foreign markets.
Non-traditional
estate,
commodities, and currencies, may be used for
diversification purposes. They may also be used
to try to reduce market and inflation risk. The
performance of non-traditional assets may not
correspond to the performance of the stock
markets generally, and investments in non-
impact an
traditional assets will generally
account’s returns differently than more traditional
investments like stocks or bonds.
Leverage
CCM could use derivative instruments, including
foreign currency contracts, options,
forward
futures, ETFs and certain other derivative
instruments. Such instruments would principally
be used for hedging and risk management
purposes, including hedging the international
stock investments from the risk of a strong U.S.
dollar. Such instruments may also be used to
serve as a substitute for underlying securities or
currency positions to enable market participation
or provide liquidity.
Leverage generally attempts to obtain investment
exposure in excess of available assets through the
use of borrowings, short selling and other
leverage can
derivative
can also
it
potentially enhance
instruments. While
returns,
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
exacerbate losses if changes in the markets, or
the values of the investments subject to the
leverage, are adverse to the strategy being
pursued. The use of leverage may also increase
an account’s volatility.
Short Sales
In addition, a client should be aware that more
traditional investments, such as mutual funds,
and ETFs may also pursue Alternative Strategies,
thereby making them Alternative Investment
Products. A client should carefully review the
prospectus or other offering document for each
investment and understand the strategy being
pursued before deciding to invest.
Additional Important Information
losses
in
Certain mutual funds and ETFs in a client’s
account may engage in short selling. When selling
securities short, a firm borrows securities from a
broker-dealer and sells them at a particular price
on the belief it will be able to buy the securities at
a lower price in the future, make a profit and
close out the loan. Short selling thus runs the risk
of loss if the price of the securities sold short does
not decline below the price at which they were
originally sold. This risk of loss is theoretically
unlimited, as there is no cap on the amount that
the price of a security may appreciate.
those
Options and Other Derivative Instruments
Derivative Instruments
The use of Alternative Strategies or Alternative
Investment Products is not appropriate for some
clients because they involve special risks. A client
should not engage in those strategies or invest in
those products unless the client is prepared to
experience significant
the client’s
portfolio. This is especially true for short selling,
which can result in unlimited losses as there is no
limit to the amount borrowed securities can rise in
value. See “Principal Risks” below for more
information. Before using
types of
strategies or products, a client is strongly urged
to discuss
them with Baird Equity Asset
Management.
instruments,
securities,
futures,
The use of Alternative Strategies or Alternative
Investment Products has a unique impact upon
the calculation of a client’s asset-based Advisory
Fee. See “Fees and Compensation—Separate
Accounts—Advisory Fees” above
for more
information.
than,
the
traditional
investments.
Investing
involves
Certain mutual funds and ETFs in a client’s
instruments.
account may use derivative
Derivatives
such as options,
swaps, and
convertible
forward contracts are financial contracts that
derive value based upon the value of an
underlying asset, such as a security, commodity,
currency, or index. Derivative instruments may be
used as a substitute for taking a position in the
underlying asset. Derivative instruments may also
be used to try to hedge or reduce exposure to
other risks. They may also be used to make
speculative investments on the movement of the
value of an underlying asset. The use of
derivative instruments involves risks different
from, or possibly greater
risks
associated with investing directly in securities and
in
other
derivatives also generally
leverage.
Derivatives are also generally less liquid, and
subject to greater volatility compared to stocks
and bonds.
Alternative Investment Products
Alternative Investment Products typically invest
primarily in non-traditional assets or engage in
one or more Alternative Strategies. Alternative
Investment Products include, but are not limited
to: REITs and mutual funds and ETFs that engage
in Alternative Strategies.
Principal Risks
Risk is inherent in any investment in securities
and Baird Equity Asset Management does not
guarantee any level of return on a client’s
investments. There is no assurance that a client’s
investment objectives will be achieved. A Baird
Equity Asset Management client may be subject
to certain risks, including, but not limited to, the
risks described below. The risks discussed below
vary by investment style or strategy, and the
investments in the client’s portfolio, and each risk
may or may not apply to a client. A client should
also review the prospectuses or other disclosure
documents for the securities purchased for the
client’s account, as they will contain important
information about the risks associated with
investing in such securities. Clients pursuing an
Other Manager Strategy are also urged to review
the Other Manager’s Brochure for more specific
information about the risks that may apply to
them.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the value of
the relative strength of
Market Risks. A client’s portfolio may change in
value due to overall market fluctuations. General
economic conditions, political developments,
international events and other factors may cause
the overall market to decline, which in turn may
the client’s portfolio
reduce
regardless of
the
securities held in the portfolio. Securities prices
often vary for reasons unrelated to matters
directly affecting the issuers of the securities.
Sector Risks. A manager’s investment processes
may not limit exposure in any individual economic
sector. At times, a client’s account may be
weighted towards one or more economic sectors.
When weighted towards one or more economic
sectors, the account is subject to the risk that
adverse events, changes or developments within
a particular sector or major companies in that
sector may result in a meaningful decline in the
value of the account.
Risks.
Equity
about
Asset
Baird
Management
the
judgments
Management’s
attractiveness, value and potential appreciation of
particular companies’ stocks may prove to be
incorrect. Such errors could result in a negative
return and a loss to clients.
Equity Securities Risks. Equity securities may
experience sudden, unpredictable drops in value
or long periods of decline in value. This may occur
because of factors that affect the securities
markets in general, such as adverse changes in
economic conditions, the general outlook for
corporate earnings, interest rates or investor
sentiment. Equity securities may also lose value
because of factors affecting an entire industry or
sector, such as increases in production costs, or
factors directly related to a specific company,
such as decisions made by its management.
Investment Objective and Asset Allocation Risks.
A client’s
investment objective and asset
allocation strategies involve the risk that certain
asset classes selected for the client’s Account may
not perform as well as other asset classes during
varying periods. In addition, clients who pursue
more aggressive investment objectives and asset
allocation strategies, while hoping to achieve high
returns, may face greater risk of loss than clients
with more conservative objectives and strategies.
In developing investment objectives and asset
allocation strategies, clients should carefully
consider their financial situation and needs,
investment goals, investment time horizon and
risk tolerance.
Stock Market Risks. Equity security prices vary
and may fall, thus reducing the value of a
portfolio’s investments. Certain stocks selected
for a portfolio may decline in value more than the
overall stock market.
Common Stock Risks. Common stocks are
susceptible to general stock market fluctuations
and to volatile increases and decreases in value
as market confidence in and perceptions of their
issuers change. These investor perceptions are
based on various and unpredictable
factors
including: expectations regarding government,
economic, monetary and fiscal policies; inflation
and
interest rates; economic expansion or
contraction; and global or regional political,
economic and banking crises. Holders of common
stocks are generally subject to greater risk than
holders of preferred stocks and debt obligations of
the same issuer because common stockholders
generally have inferior rights to receive payments
from issuers in comparison with the rights of
preferred stockholders, bondholders and other
creditors.
Growth-Style Investing Risks. Different types of
stocks tend to shift into and out of favor with
stock market investors depending on market and
economic conditions. Because each portfolio
focuses on growth-style stocks, a portfolio’s
performance may at times be better or worse
than the performance of investments that focus
on other types of stocks or that have a broader
investment style. Growth stocks are often
characterized by high price-to-earnings ratios,
which may be more volatile than stocks with
lower price to-earnings ratios.
less
than
typical of
Capitalization Size Risks. Certain portfolios invest
primarily in large cap stocks, which perform
differently from, and at times worse than, stocks
of medium and smaller cap companies. Other
portfolios invest primarily in small and mid cap
stocks, which are often more volatile and less
liquid than investments in larger companies. The
frequency and volume of trading in securities of
companies may be
small- and mid-size
substantially
larger
is
companies. Therefore, the securities of small- and
mid-size companies may be subject to greater
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
uncertainties. All of these factors can make
emerging market securities more volatile and
potentially less liquid than securities issued in
more developed markets.
them more susceptible
and more abrupt price fluctuations. In addition,
small- and mid-size companies may lack the
management experience, financial resources and
larger companies,
product diversification of
making
to market
pressures and business failure. Small- and mid-
size companies may also be in the early stages of
development and may not yet be profitable.
Concentration Risks. A client’s portfolio, especially
one pursuing a CCM Strategy, may consist of a
limited number of securities or may be
concentrated in an issuer or group of issuers, an
industry or economic sector or group of related
industries or sectors, or concentrated in limited
asset classes. Client accounts with concentrated
positions are susceptible to greater volatility and
increased risk of loss than an account that is
diversified across several issuers and industries or
sectors and asset classes.
Investors
in
in
Transaction Risk. For both the International
Growth Equity and the Global Growth Equity
Portfolios, CCM may,
certain market
environments, trade securities more actively,
which could increase a client’s transaction costs
(thereby lowering a portfolio’s performance) and
may increase the amount of taxes that a client
pays on the investment.
forgo opportunities
invest
to
to gain exposure
ESG Considerations Risk. Consideration of ESG
factors in the investment process may cause CCM
in certain
to
companies or
to certain
industries or regions and, therefore, carries the
risk that, under certain market conditions, a CCM
portfolio may underperform portfolios that do not
consider such factors. There are not universally
accepted ESG factors and CCM will consider them
in its discretion.
standards
comparable
to
confiscatory
Foreign Issuer and Investment Risks. Securities of
foreign issuers, ADRs, GDRs and EDRs and
investments in foreign markets generally are
subject to certain inherent risks, such as political
or economic instability of the country of issue, the
difficulty of predicting international trade patterns
and the possibility of imposition of exchange
controls. Such securities may also be subject to
greater fluctuations in price than securities of
domestic corporations.
foreign
markets may face delayed settlements, currency
controls and adverse economic developments as
well as higher overall transaction costs. In
addition, fluctuations in the U.S. dollar’s value
versus other currencies may enhance, erode,
reverse gains or widen losses from investments
denominated in foreign currencies. For instance,
limit or prevent
foreign governments may
investors from transferring their capital out of a
country. This may affect the value of a client’s
investment in the country that adopts such
currency controls. Exchange rate fluctuations also
may impair an issuer’s ability to repay U.S. dollar
denominated debt, thereby increasing the credit
risk of such debt. In addition, there may be less
publicly available information about a foreign
than about a domestic company.
company
Foreign companies generally are not subject to
financial
uniform accounting, auditing and
reporting
those
applicable to domestic companies. With respect to
certain foreign countries, there is a possibility of
expropriation or
taxation, or
diplomatic developments, which could affect
investment in those countries.
Fixed Income Security Risks. Fixed
income
securities are subject to certain risks, including
interest rate risk, credit risk and liquidity risk. In
addition, they are subject to maturity risk.
Generally, the longer a bond’s maturity, the
greater the interest rate risk and the higher its
yield. Conversely, the shorter a bond’s maturity,
the lower the interest rate risk and the lower its
yield. Non-rated, split-rated, below investment
grade, and asset-backed securities, including
mortgage-backed and collateralized mortgage
obligations (“CMOs”), have additional, special
risks.
market
depth,
Interest Rate Risk. The value of some investment
products, particularly fixed income securities, is
affected significantly by changes in interest rates.
Emerging Markets Risks. Investments in emerging
markets can involve risks in addition to and
greater than those generally associated with
investing in more developed foreign markets. The
extent of economic development, political
stability,
infrastructure,
capitalization, and regulatory oversight can be
less than in more developed markets. Emerging
market economies can be subject to greater
regulatory, and political
social, economic,
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Generally, when interest rates rise, the product’s
market value declines and when interest rates
decline, its market value rises. In addition, a rise
in interest rates may have a negative impact on
the issuer, which, in turn, could have a negative
impact on the market value of the investment
product.
or
penalties,
reputational
investigate,
or
remediate
in
the
section
titled
their
own
information
related
incidents
incidents,
Credit Risk. The value of some investment
products, particularly fixed income securities, is
affected by changes in the product’s credit quality
rating or the issuer’s financial condition. If the
credit quality rating or the issuer’s financial
condition declines, so may the value of the
investment product. Issuers may experience
unanticipated financial problems and may be
unable to meet its payment obligations. Municipal
obligations in particular may be adversely affected
by political and economic conditions and
developments (for example, legislation reducing
state aid to local governments.) Bonds receiving
the lowest investment grade rating or a non-
investment grade rating may have speculative
characteristics and, compared to higher grade
debt obligations, may have a weakened capacity
to make principal and interest payments due to
changes in economic conditions or other adverse
circumstances. Ratings agencies such as Moody’s,
Fitch and S&P provide ratings on bonds based on
their analyses of information they deem relevant.
Ratings are essentially opinions or judgments of
the credit quality of an issuer and may prove to
be inaccurate. In addition, there may be a delay
between events or circumstances adversely
affecting the ability of an issuer to pay interest
and/or repay principal and an agency’s decision to
downgrade a security.
degradation, or destruction of systems or data
(such as
through hacking, malware, social
engineering or theft of digital devices); or the
disruption of systems access to authorized users
(such as through denial of service attacks). Such
events can impede critical functions, compromise
sensitive business and protected customer
information, and may result in financial losses,
business interruptions, impediments to the ability
to process transactions, breaches of applicable
privacy, data protection, or other laws, regulatory
fines
harm,
reimbursement or other remediation costs, and
increased compliance or operational expenses.
Substantial costs may be incurred to prevent,
detect,
future
technology related incidents. Issuers’ increasing
use of AI systems introduces additional risks
discussed
“Artificial
Intelligence Risks” below. Issuers may also rely
on third party or cloud based platforms that
security,
present
cybersecurity, and other technology‑related risks.
Similar adverse consequences may arise from
technology
affecting
governmental authorities,
regulatory bodies,
financial market systems, exchanges, brokers-
dealers, banks, insurance companies, custodians,
or other market participants. Although issuers and
their service providers may adopt business
continuity plans, information security controls,
and risk management programs designed to
prevent or mitigate such
these
measures are subject to inherent limitations,
including the possibility that certain risks may not
be identified or fully addressed. As a result, client
Accounts and investments may be negatively
affected.
Security,
Cybersecurity
the
that
could
compromise
technology
Such
incidents may
Artificial Intelligence Risks. Issuers of investments
increasingly use AI systems in various aspects of
their business operations, creating competitive
market pressures to increase the development
and use of AI systems. Failure to effectively
develop or use AI systems may place an issuer at
a competitive disadvantage. At the same time, AI
systems present significant risks that could
materially affect an issuer’s business and financial
performance. AI Tools rely on complex models,
large datasets, and evolving algorithms. AI Tools
are highly-useful but complex and fallible systems
that can exhibit bias, hallucinations, deceptive
behaviors and other flaws due to the construction
of their underlying models and the composition of
their training data, which can result in outputs
Information
and
Technology-Related Risks. As issuers and their
service providers increasingly rely on digital
technologies, such as
Internet, cloud
computing, and AI‑enabled systems, they face
heightened information security, cybersecurity,
including
and other technology‑related risks,
incidents
the
confidentiality, integrity, or availability of their
systems, data, or
infrastructure.
Technology-related incidents may result from
deliberate adversarial actions (such as cyber
attacks) or unintentional events (such as systems
or human error) and could have a materially
adverse impact on the issuer’s performance and
involve
operations.
unauthorized access, disclosure, use, corruption,
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
tools
timely access
only by the discretionary authority of the U.S.
government. While the U.S. government provides
financial support to various U.S. government-
sponsored agencies and instrumentalities, such as
those listed above, no assurance can be given
that it will always do so.
involve
periods
of
economic
it
less desirable
for
those
use
protected
Illiquid Securities and Liquidity Risks. Liquidity
risk is the risk that certain investments may be
difficult or impossible to sell at the time and price
that a client would like to sell. Clients may have
to lower the price, sell other investments or
forego an investment opportunity, any of which
may have a negative effect on the management
or performance of client accounts. The liquidity of
a particular investment depends on the strength
of demand for the investment, which is generally
related to the willingness of broker-dealers to
make a market for the investment as well as the
interest of other investors to buy the investment.
During
uncertainty,
significant economic and market downturns and
periods in which financial services firms are
unable to commit capital to make a market in, or
otherwise buy, certain investments, a client may
experience challenges in selling such investments
at optimal prices. In addition, recent regulatory
changes applicable to financial intermediaries that
make markets in debt securities have restricted or
made
financial
intermediaries to hold large inventories of debt
securities. Because market makers provide
stability to a market through their intermediary
services, a reduction in dealer inventories may
lead to decreased liquidity and increased volatility
in the fixed income markets.
that seem plausible but are in fact inaccurate,
incomplete, or misleading. The use of erroneous
outputs can undermine customer trust and
expose issuers to litigation, regulatory scrutiny,
substantial remediation costs, and reputational
harm. AI
to
require
high‑quality, compliant data, and any disruption in
data availability can impair or disable AI Tool
functionality. Issuers often rely on third-party AI
systems, infrastructure, and data, which can
create vendor dependency, limit visibility into and
validation of AI model performance, and increase
the risk of disruption in data availability. The
regulatory environment for AI is rapidly evolving
inconsistent or conflicting
and may
requirements across
jurisdictions. Compliance
may require significant investment, changes to AI
the discontinuation of certain
systems, or
AI‑enabled features. Non‑compliance may lead to
fines, enforcement actions, or operational
constraints. AI systems are vulnerable
to
cyberattacks or other adversarial actions that can
impair system performance and integrity and
compromise sensitive business and protected
customer information. The impairment of AI
systems or
the unauthorized disclosure of
sensitive business or protected information can
result in material disruption and damage to
legal and
significant
business operations,
regulatory
remediation
liabilities, substantial
expenses, and reputational harm. AI systems may
inadvertently
information,
potentially giving rise to intellectual property
infringement claims and substantial damages.
Public concerns regarding fairness, transparency,
and responsible use of AI may reduce demand for
an issuer’s products or services. Failure to use AI
responsibly may harm an issuer’s reputation and
competitive position.
and/or
repurchase
issued by
Government Obligation Risks. Client assets may
be invested in securities issued, sponsored or
guaranteed by the U.S. government, its agencies
and instrumentalities. However, no assurance can
be given that the U.S. government will provide
financial support to U.S. government-sponsored
agencies or instrumentalities where it is not
obligated to do so by law. For instance, securities
issued by the Government National Mortgage
Association (“Ginnie Mae”) are supported by the
faith and credit of the United States.
full
Securities
the Federal National
Mortgage Association (“Fannie Mae”) and the
Federal Home Loan Mortgage Corporation
(“Freddie Mac”) have historically been supported
Money Market Fund Risks. A money market fund
is a type of mutual fund that generally invests in
short-term debt instruments. Many investors use
money market funds to store cash. There are
three primary types of money market funds: (1)
government money market funds (funds that
invest nearly all assets in cash, government
agreements
securities,
collateralized by cash or government securities);
(2) retail money market funds (funds that have
policies and procedures reasonably designed to
limit beneficial ownership to natural persons); and
(3) institutional money market funds (funds that
permit beneficial ownership by institutions and
natural persons). The rules governing money
market funds vary based on the type of money
market fund. Government and retail money
market funds generally try to keep their net asset
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
downturn than other instruments. Asset-backed
securities also can be more sensitive to interest
rate risk than other types of fixed income
securities. Modest movements in interest rates
(both increases and decreases) may quickly and
significantly reduce the value of certain types of
these securities. Asset-backed securities are
subject to a number of other risks, including, but
not limited to, market and valuation risks,
liquidity risk, and prepayment risk.
the
fund's shareholders. This
risks associated with
Non-Rated, Split-Rated, and Below Investment
Grade Securities (High Yield or “Junk” Bonds)
Risks. Investing in securities or other investment
products that are not rated, split-rated or are
below investment grade (also known as high yield
or “junk” bonds) involve significant, special risks.
As a result, they may not be suitable for all
clients. The
these
investments include, but not limited to, price
volatility risk, credit risk, default risk, and liquidity
risk. Clients investing in securities or other
investment products that are not rated, split-
rated or are below investment grade should have
a high tolerance for risk, including the willingness
and ability to accept significant price volatility,
potential lack of liquidity and potential loss of
their investment.
equity,
value (NAV) at a stable $1.00 per share using
special pricing and valuation
conventions.
Institutional money market funds are required to
calculate their NAV in a manner such that the NAV
will vary based upon the market value of assets
and liabilities of the fund (also known as a
“floating NAV”). An investment in a money
market fund is not insured or guaranteed by the
FDIC or any other government agency. Although
some money market funds seek to preserve the
value of an investment at $1.00 per share, there
can be no assurance that will occur, and it is
possible to lose money should the fund value per
share fall. In some circumstances, money market
funds may be forced to cease operations when
the value of a fund drops. In that event, the
fund's holdings may be liquidated and distributed
liquidation
to
process could take time to complete. During that
time, the amounts a client has invested in the
money market fund would not be available for
purchases or withdrawals. In addition, retail and
institutional money market funds are required to
impose redemption fees (also known as liquidity
fees) and suspend redemptions (also known as
redemption gates)
in certain circumstances.
funds may also
Government money market
impose redemption fees and suspend redemptions
in those same circumstances. More specific
information about how a money market fund
calculates its NAV and the circumstances under
which it will impose a redemption fee or suspend
redemptions is set forth in the prospectus for that
money market fund.
Mutual Fund Risks. Mutual funds can have many
different investment objectives and strategies,
including
income, balanced,
fixed
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. Mutual funds have risks, which
may
include market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, and emerging market
risk. Certain mutual funds pursue Alternative
Strategies, which are subject to special risks. The
degree of these and other risks will vary
depending on the type of mutual fund selected.
Also, investment return and principal value will
fluctuate, and shares, when redeemed, may be
worth more or less than their original cost.
Asset-Backed Securities Risks. Asset-backed
securities are securities secured or backed by
mortgage loans, student loans, automobile loans,
installment sale contracts, credit card receivables
or other assets and are issued by entities such as
commercial banks, trusts, financial companies,
finance subsidiaries of
industrial companies,
savings and loan associations, mortgage banks
and investment banks. These securities represent
interests in pools of assets in which periodic
payments of interest or principal on the securities
are made, thus, in effect passing through periodic
payments made by the individual borrowers on
the assets that underlie the securities, net of any
fees paid to the issuer or guarantor of the
securities. Asset-backed securities are issued in
multiple classes (or tranches) and their relative
payment rights may be structured in many ways.
Asset-backed securities may be subject to greater
risk of default during periods of economic
Exchange Traded Fund Risks. An ETF is different
from a mutual fund in that an ETF does not sell its
shares directly to public investors and does not
redeem shares from public investors. Rather,
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
tariffs
and
other
traditional securities. The commodities markets
are impacted by a variety of factors, including
changes in overall market movements, domestic
and foreign political and economic conditions,
interest rates, inflation rates and investment and
trading activities
in commodities. Prices of
commodities may also be affected by factors such
as drought, floods, weather, livestock disease,
regulatory
embargoes,
developments. The prices of commodities can also
fluctuate widely due to supply and demand
disruptions in major producing or consuming
regions. Certain commodities may be produced in
a limited number of countries and may be
controlled by a small number of producers or
groups of producers. As a result, political,
economic and supply related events in such
countries could have a disproportionate impact on
the prices of such commodities. No active trading
market may exist
for certain commodities
investments, which may impair the value of the
investments.
shares of an ETF are commonly purchased or sold
in the secondary market on a securities exchange,
like common stocks. An ETF maintains a net asset
value but, based on demand and other factors,
the market price of shares of an ETF may vary
from its net asset value. ETFs invest in and hold
securities and other assets, such as stocks,
bonds, commodities and currencies, and have
investment objectives and principal
stated
strategies. ETFs can have many different
investment objectives and strategies, including
equity, fixed income, balanced, international, and
global strategies, and strategies that focus on a
particular market capitalization, investment style,
economic
industry or sector, or geographic
region. Many ETFs seek to track the performance
of an index or other underlying benchmark.
Passively managed ETFs will not be able to
replicate exactly the performance of the indices
the ETFs track because the total return generated
by the securities will be reduced by management
fees, transaction costs and other expenses
incurred by the ETF. ETFs have other risks, which
may
include market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, and emerging market
risk. Certain ETFs pursue Alternative Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of ETF selected.
in
that
Currency Risks. Investments in currencies, and
investments in securities or other instruments
denominated in or indexed or linked to currencies,
are subject to certain risks. Those investments
are subject to all of the risks associated with
foreign investing generally. In addition, currency
markets generally are not as regulated as
securities markets. Also, changes in currency
exchange rates could adversely
impact the
investment. Devaluation of a currency by a
country will also have a significant negative
impact on
investment
the value of any
currency. Currency
denominated
investments may also be positively or negatively
affected by a country’s strategies intended to
make its currency stronger or weaker relative to
other currencies.
traditional
Non-Traditional Assets Risks. Non-traditional
assets, such as
real estate, commodities,
currencies and private companies, are subject to
risks that are different from, and in some
instances, greater than, other assets like stocks
and bonds. Some non-traditional assets are less
transparent and more sensitive to domestic and
foreign political and economic conditions than
more
investments. Non-traditional
assets are also generally more difficult to value,
less liquid, and subject to greater volatility
compared to stocks and bonds.
Leverage and Margin Risks. Leveraging strategies
may amplify the impact of any decrease in the
value of underlying securities in the client’s
portfolio, thereby increasing a client’s risk of loss.
The use of
increase a
leverage may also
portfolio’s volatility. Strategies involving margin
can cause a client to lose more money than
deposited in the client’s margin account. A client
should not engage in strategies involving leverage
or margin unless the client is prepared to
experience significant losses in the value of the
client’s portfolio.
Commodities Risks. Investments in commodities
markets or a particular sector of the commodities
markets, and investments in securities or other
instruments denominated in or indexed or linked
to commodities, are subject to certain risks.
Those investments generally will subject a client
portfolio to greater volatility than investments in
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Hedging Risks. When a derivative instrument is
used as a hedge against an opposite position, any
loss on the derivative instrument should be
substantially offset by gains on the hedged
investment, and vice versa. Although hedging can
be an effective way to reduce the investment risk,
it may not always perfectly offset one position
with another. As a result, there is no assurance
that hedging transactions will be effective.
Short Sales Risks. Short selling runs the risk of
loss if the price of the securities sold short does
not decline below the price at which they were
originally sold. This risk of loss is theoretically
unlimited, as there is no cap on the amount that
the price of a security may appreciate. In
addition, a
lender may request, or market
conditions may dictate, that securities sold short
be returned to the lender on short notice, which
may result having to buy the securities sold short
at an unfavorable price. A client should not
engage in short sales unless the client is prepared
to experience significant losses in the client’s
portfolio.
contracts
other
data
centers,
instruments
Derivative Instrument Risks. The values of
options, convertible securities, futures, swaps,
derivative
and
forward
instruments is derived from an underlying asset,
such as a security, commodity, currency, or
index. Derivative instruments often have risks
similar to the underlying asset, however, in
certain cases, those risks are greater than the
risks presented by
the underlying asset.
Derivative instruments may experience dramatic
price changes and imperfect correlations between
the price of the derivative and the underlying
asset, which may increase volatility. Derivatives
generally create leverage, and as a result, a small
movement in the underlying asset's value can
result in large change in the value of the
derivative instrument. Derivatives are also subject
to liquidity risk, interest rate risk, market risk,
credit risk, management risk and counterparty
risk. The use of these
is not
appropriate for some clients because they involve
special risks. A client should not invest in these
instruments unless the client is prepared to
experience volatility and significant losses in the
client’s portfolio.
in which
they are
the underlying security or
risk, growth
Options Risks. In purchasing a put or call option,
the purchaser faces the risk of loss of the
premium paid for the option if the market price
moves in a direction opposite to what the
purchaser had expected. In selling or writing an
option, the seller faces significantly more risk. A
seller of a call option faces the risk of significant
if the prevailing market price of the
loss
underlying security or index increases above the
strike price, and a seller of a put option faces the
risk of significant loss if the prevailing market
price of
index
decreased below the strike price.
Real Estate Investment Trusts Risks. A REIT is a
corporation, trust or association that owns and
typically operates income-producing real estate or
real estate-related assets. The income-producing
real estate assets owned by a REIT may include
office buildings, shopping malls, multi-family
housing,
resorts,
student housing, hotels,
hospitals and health care facilities, self-storage
facilities,
warehouses,
telecommunications facilities, and mortgages or
loans. Many REITs are registered with the SEC
and their common stock and preferred stock are
publicly traded on a stock exchange. These are
known as publicly traded REITs. Others may be
registered with the SEC but are not publicly
traded. These are known as private REITs (also
known as non-traded or non-exchange traded
REITs). Private REITs are generally subject to
limited regulation and offer limited disclosure and
transparency. The shareholders of a REIT are
responsible for paying taxes on the dividends that
they receive and on any capital gains associated
with their investment in the REIT. Dividends paid
by REITs generally are treated as ordinary income
and are not entitled to the reduced tax rates on
other types of corporate dividends. Prices of REIT
securities and trading volumes may be more
volatile that other investments. Many REITs focus
on a particular sector of the real estate market,
such as apartments, student housing, hotels and
hospitality, health care, office buildings, shopping
malls, warehouses, self-storage facilities and the
like. Those REITs are subject to risks associated
with sectors
focused.
Additionally, many REITs may own properties that
are concentrated in a particular geographic region
or regions, which subject them to the risk of
deteriorating economic conditions in those areas.
Investing in REITs involves other special risks,
including, but not limited to, real estate portfolio
risk
(including development, environmental,
competition, occupancy and maintenance risk),
liquidity risk, leverage risk, distribution risk,
risk,
capital markets access
interest risk,
counterparty risk, conflicts of
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Middle East persist, and relations between the
U.S. and other countries are strained.
risk, credit
risk,
foreign
dependence upon key personnel
risk, and
regulatory risk. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, interest
rate
issuer and
investment risk, and emerging market risk. REITs
involve significant, special risks and may not be
suitable for some clients. Clients investing in
REITs should have a high tolerance for risk,
including the willingness and ability to accept
significant price volatility and volatility of regular
distribution amounts, potential lack of liquidity
and potential loss of their investment.
Rapid advancements in artificial intelligence (AI)
and automation are increasingly influencing global
economic trends, corporate decision making, and
financial market dynamics. Expanding investment
in these technologies is contributing to shifts in
how industries operate, compete, and allocate
resources. The fast pace of technological change,
potential disruptions to existing business models,
and evolving regulatory responses
introduce
additional uncertainty and may contribute to
market volatility.
and
Taken together, these developments may have a
significant negative impact upon global economic
conditions and contribute to a heightened risk
environment. As a result, fluctuations in asset
prices may increase, and such volatility could
adversely affect the value of a client’s portfolio.
Recent Events. Global financial markets have
continued to experience periods of elevated
volatility, driven by a combination of economic,
macroeconomic
broader
political,
developments.
across major
Conditions
economies have been influenced by shifting policy
priorities, changes in geopolitical relationships,
and evolving investor expectations.
Within the United States, the current U.S.
administration has demonstrated
intent on
implementing policy changes through executive
orders and legislation, contributing to a less
certain policy environment. Potential adjustments
to federal programs, regulatory initiatives, and
legislative priorities create additional factors for
markets to assess, which may cause meaningful
inflation reduction
market uncertainty. While
remains a central
for policymakers,
focus
achieving the U.S. Federal Reserve Board’s long
term inflation target of 2% continues to prove
challenging. Although annual price increases have
generally moderated, the price of many goods
and services remains elevated compared to levels
from a few years ago. Leadership changes at the
Federal Reserve and political divisions and discord
add further uncertainty to the economic outlook.
Internationally, geopolitical risks have increased
as the U.S. and Israel are engaged in a military
conflict with Iran. The conflict has disrupted
global trade and caused an increase in the price
of oil. The continuation or escalation of military
strikes could lead to a lengthy period of military
conflict, and Iran’s military attacks and other
hostile actions against other countries present a
risk of widening the conflict. In addition, the war
between Ukraine and Russia is now passing its
fourth anniversary, instability in parts of the
Disciplinary Information
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 SEC’s
the commencement of
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. While Baird had
policies and procedures in place prohibiting such
off-channel communications, 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, and the
findings were reported to the SEC. Baird took
steps prior to and after the SEC’s review,
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and procedures,
to
including implementing a new communication tool
designed for Baird associates’ personal devices,
conducting training, and periodically requiring
requisite associates to provide an attestation
relating to their business-related communications.
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
training,
surveillance program, technology solutions and
similar matters
off-channel
related
communications.
supervise a former Financial Advisor who misused
a customer’s funds. The findings stated that the
supervisor did not reasonably follow-up on red
flags associated with a trade correction request
submitted by the Financial Advisor that should
have alerted him to the Financial Advisor's misuse
of a customer’s funds. The supervisor also did not
follow certain of Baird’s written supervisory
procedures (“WSPs”) relating to trade corrections.
After the supervisor realized that the Financial
Advisor misused the customer’s funds, Baird
reimbursed the customer for the loss. The
findings also included that Baird 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.
Baird was censured and fined $200,000.
The following information pertains to Baird’s
Private Wealth Management (“PWM”) business.
certain of
the
its
to adopt or
to
designed
provide
to Baird’s clients and
In April 2016, Baird, without admitting or denying
the findings, consented to the sanctions and
findings of FINRA that it violated NASD Conduct
Rule 3010, FINRA Rule 3110, and FINRA Rule
2010, by failing to establish and maintain a
supervisory system and procedures reasonably
designed to ensure that customers who purchased
mutual fund shares received the benefit of
applicable sales charge waivers. In May 2015,
Baird began a review to determine whether Baird
had provided available sales charge waivers to
eligible customers. Based on this review, in May
2015, Baird self-reported to FINRA that various
eligible customers had not received available
sales charge waivers. Baird was found to have
retirement plan and
disadvantaged certain
charitable organization customers
that were
eligible to purchase Class A shares in certain
mutual funds without a front-end sales charge.
The findings also stated that these customers
were instead sold Class A shares with a front-end
sales charge or Class B or C shares with higher
ongoing fees and the potential application of a
contingent deferred sales charge. Baird was
censured and required to pay restitution to
affected customers estimated to be approximately
$2.1 million including interest.
supervisor within
In September 2016, the SEC announced that
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
subadvisors
practices by
participating in Baird’s wrap fee programs offered
through
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
implement policies and
failed
specific
procedures
information
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. Baird also was ordered to cease
and desist committing or causing any violations
and any future violations of Section 206(4) of the
Advisers Act and Rule 206(4)-7 thereunder and
In July 2016, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that the firm and a
its Private Wealth
firm
reasonably
Management business did not
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
pay a civil money penalty in the amount of
$250,000.
Additional information about Baird’s disciplinary
history is available on the SEC’s website at
www.adviserinfo.sec.gov.
Initiative.” Under
Other Financial Industry Activities and
Affiliations
Baird is registered with the SEC as a broker-
dealer under the Exchange Act and as an
investment adviser under the Advisers Act. Baird
is also affiliated with or related to certain broker-
dealers,
financial
investment advisors, other
services firms and investment products and
services that are identified below. Certain Baird
associates and certain management persons of
Baird may invest in those investment products.
time
to
through disclosure
in
time, Baird Equity Asset
From
Management and Baird may recommend that
clients retain the services of financial services
firms or invest in investment products that are
affiliated with or related to Baird. Such a
recommendation of affiliated or related financial
services firms or investment products creates a
potential conflict of interest because Baird Equity
Asset Management, Baird and related parties may
receive higher aggregate compensation if clients
retain those firms or invest in those investment
products instead of retaining unrelated firms or
investing in unrelated investment products. Baird
Equity Asset Management and Baird address this
this
potential conflict
Brochure. Further, when acting as fiduciaries,
Baird Equity Asset Management and Baird are
required to select or recommend investment
products only when they determine it to be in the
client’s best interest to do so. The criteria used by
them in deciding to select or recommend affiliated
or related investment products are generally the
same as those used for unrelated investment
products.
through
(“PWM”),
Baird’s Broker-Dealer Activities
Baird is engaged in a broad range of broker-
its Private Wealth
dealer activities
Management
Investment Banking,
Public Finance and Institutional Equities Services
Businesses.
(“PWM”)
investment
registered
In March 2019, Baird, without admitting or
denying the findings, consented to an order of the
SEC, which found that it violated Sections 206(2)
and 207 of
for making
the Advisers Act
inadequate disclosures to advisory clients about
mutual fund share classes. The order was part of
a voluntary self-reporting program initiated by the
SEC called the “Share Class Selection Disclosure
(or SCSD)
the program,
firms were offered the
investment advisory
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 settlement terms imposed by the
including returning money to affected
SEC,
investment advisory clients. The central issue
identified by the SEC was that, in many cases,
investment advisers bought for or recommended
to their investment advisory clients mutual fund
share classes that had distribution or service fees
(commonly known as 12b-1 fees) paid out of fund
assets to the advisers when lower-cost share
classes were available to those advisory clients,
and the investment advisers did not adequately
disclose their receipt of 12b-1 fees and/or the
conflict of interest associated with those 12b-1
paying share classes. Baird and many other firms
self-reported under the program and entered into
substantially identical orders. By self-reporting
and consenting to the order, Baird agreed to a
censure and to cease and desist from committing
or causing any violations and future violations of
Sections 206(2) and 207 of the Advisers Act.
Baird also agreed to establish a distribution fund
and to deposit into that fund the improperly
disclosed 12b-1 fees received by Baird plus
prejudgment interest, which will be paid to
affected advisory clients. More information about
the order is contained in Baird’s Form ADV, which
is available on the SEC’s Investment Advisory
Public Disclosure website at https://www.
adviserinfo.sec.gov/IAPD/Default.aspx or in the
SEC’s press release about the SCSD Initiative at
https://www.sec.gov/news/press-release/2019-
28. The order pertains to Baird’s Private Wealth
Management
advisory
business and PWM’s Cash Sweep Program. Baird
Equity Asset Management’s business was not
impacted by the order, except for certain high net
worth clients with accounts custodied at Baird and
enrolled in a Baird PWM advisory program or its
Cash Sweep Program.
Certain Baird and Baird Equity Asset Management
associates and certain management persons of
Baird and Baird Equity Asset Management are
registered, or have an application pending to
representatives and
register, as
the extent
associated persons of Baird
to
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
favor Greenhouse and Greenhouse GP
necessary or appropriate to perform their job
responsibilities.
to
investment products and services.
Affiliated Mutual Funds, ETFs and
Investment Companies
factors,
Baird’s Other Investment-Related
Activities
Baird PWM and its Financial Advisors may, from
time to time refer clients to Baird Equity Asset
Management or CCM, or to Baird Advisors,
another investment management department of
Baird. Baird PWM Financial Advisors are eligible
for referral compensation to be paid by Baird that
is based upon, among other
the
compensation received by Baird.
Fund. CCM
Funds
pursuing
global
investment
strategies
Baird offers other
investment products and
services through its other business units, such as
retail-investor-oriented investments products and
services provided by PWM and private equity
funds offered by Baird Capital. Baird Equity Asset
Management does not use those investment
products and services when managing client
accounts.
and
statement
of
Certain Affiliated and Related Parties
Affiliated Investment Advisors
certain
Baird
common
control, with
information about Riverfront
to
such
incentive
Baird is the investment adviser and principal
underwriter for the Baird Funds. Baird Advisors
provides investment management, administrative,
and other services
to certain Baird Funds
investing primarily in fixed income securities (the
“Baird Bond Funds”). Baird Equity Asset
Management provides investment management
to certain Baird Funds
and other services
investing primarily in equity securities (the “Baird
Equity Funds”), and Greenhouse is the investment
subadvisor to one of those Funds, the Baird
provides
Equity Opportunity
investment management and other services to
certain Baird
or
international
(the
“Chautauqua Funds”). As compensation for its
services, Baird receives fees from each Baird
Fund, which fees are disclosed in each Fund’s
prospectus
additional
information available on Baird’s website at
Baird
bairdassetmanagement.com/baird-funds.
incentivizes
Asset
Equity
Management sales professionals to recommend to
clients certain Baird Equity Funds over other Baird
Equity Asset Management products and services.
compensation
Due
arrangements,
certain Baird Equity Asset
Management sales professionals have a financial
incentive to favor Baird Equity Funds.
Baird is affiliated, and may be deemed to be
under
Riverfront
Investment Group, LLC ("Riverfront") by virtue of
indirect ownership by BFG.
their common
is
Additional
available in Riverfront’s Form ADV Part 2A
Brochure. From time to time, Baird Equity Asset
Management may use or recommend Riverfront
investment products and services. Due to its
affiliation with Riverfront, Baird has a financial
incentive to favor Riverfront investment products
and services.
information about
those
funds
for
and
statement
of
CCM serves as investment sub-adviser to a
mutual fund series of the Pace® Select Advisors
Trust and Baird receives compensation for those
services. Additional
those
mutual funds, including information relating to the
fees paid by
investment
management services, is available in the funds’
prospectus
additional
information.
products
certain
and
Baird
Equity
funds and ETFs,
those
funds
for
Riverfront acts as investment sub-adviser for
certain mutual fund series of the Financial
Investors Trust and certain ETFs that are part of
the ALPS ETF Trust and First Trust Exchange-
Traded Fund III. Additional information about
those mutual
including
information relating to the compensation paid to
Riverfront by
investment
management services, is available in each fund’s
Baird is related to Greenhouse and Greenhouse
Fund GP LLC (“Greenhouse GP”) by virtue of
BFG’s indirect minority ownership of Greenhouse
and BFG’s representation on the board of
managers of Greenhouse GP. From time to time,
Baird Equity Asset Management may use or
recommend Greenhouse or Greenhouse GP
services. Baird
investment
incentivizes
Asset
Management sales professionals to recommend to
clients advisory products and services offered by
Greenhouse. Due to the incentive compensation
arrangements relating to Greenhouse and Baird’s
relation to Greenhouse and Greenhouse GP,
certain Baird Equity Asset Management sales
professionals and Baird have a financial incentive
32
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and
statement
of
Greenhouse and Greenhouse GP, Baird has a
financial incentive to favor those hedge funds.
Other Affiliated Financial Services Firms
prospectus
additional
information. From time to time, Baird Equity
Asset Management may use or recommend
Riverfront mutual funds and ETFs. Due to its
affiliation with Riverfront, Baird has a financial
incentive to favor funds managed by Riverfront.
Affiliated Private Funds
Baird is affiliated with other investment advisors,
broker-dealers, a trust company and other
financial services firms that offer their own
investment products and services. A list of Baird’s
affiliates is available in Baird’s Form ADV Part 1A
available at https://adviserinfo.sec.gov. Baird
Equity Asset Management does not use those
investment products and services when managing
client accounts.
funds are private pooled
Management.
Other
CCM acts as investment manager for, and Baird is
the general partner or manager of,
the
Chautauqua International Growth Equity QP Fund,
LP, the Chautauqua Global Growth Equity QP
Fund, LP and the Chautauqua New World Growth
Equity Series (a series of Chautauqua Series
Fund, LLC) (the “Chautauqua Private Funds”).
Those
investment
vehicles that are not required to be registered
with the SEC as investment companies. Due to
their affiliation with the Chautauqua Private
Funds, Baird Equity Asset Management, CCM and
Baird have a financial incentive to favor those
funds.
Affiliated Collective Investment Trusts
Other Financial Industry Activities
Baird has business relationships with investment
managers separate and apart from Baird Equity
Asset
investment
management firms may select Baird, in its
capacity as a broker-dealer, to execute portfolio
trades for their clients, including for investment
funds they advise. Investment management firms
may also select Baird to provide custody, research
or other services. Baird receives compensation for
those services. That compensation is not paid to
Baird Equity Asset Management or its associates.
Baird Equity Asset Management, CCM and other
departments of Baird serve as investment adviser
to certain, different series of the Reliance Trust
Institutional Retirement Trust (“Reliance Trust”),
a collective investment trust (“CIT”). Additional
information about each series of the Reliance
Trust, including information relating to the fees
paid by each series of the Reliance Trust to Baird
Equity Asset Management, CCM or other
departments of Baird, as the case may be, for
investment management services, is available in
the offering documents for the applicable series of
the Reliance Trust. Due to their management of
certain series of the Reliance Trust, Baird Equity
Asset Management, CCM and Baird have a
financial incentive to favor those series of the
Reliance Trust managed by them.
Related Hedge Funds
Code of Ethics, Participation or
Interest in Client Transactions and
Personal Trading
Code of Ethics
Subject to the restrictions described below, Baird
and its affiliates and associates may engage in
securities transactions for their own accounts,
including the same or related securities that are
recommended to or owned by Baird clients. These
transactions may include trading in securities in a
manner that differs from, or is inconsistent with,
the advice given to Baird clients, and the
transactions may occur at or about the same time
that such securities are recommended to or are
purchased or sold for client accounts. This creates
a potential for a conflict between the interest of
clients and the interests of Baird and its affiliates
and associates.
Greenhouse acts as investment manager for, and
Greenhouse GP is the general partner of, the
Greenhouse Master Fund LP and the Greenhouse
Onshore Fund LP. Greenhouse also acts as
investment adviser for the Greenhouse Overseas
Fund Ltd. Those funds are hedge funds that are
not required to be registered with the SEC as
investment companies. From time to time, Baird
Equity Asset Management may use or recommend
Greenhouse hedge funds. Due to its relation to
To address the potential for conflicts of interest,
Baird has adopted a Code of Ethics (the “Code”)
that applies to
its associates that provide
investment advisory services to clients, including
Baird Equity Asset Management associates, and
certain associates who have access to non-public
information relating to advisory client accounts
33
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
or
by
Baird’s
because the profitability of underwritten offerings
to Baird depends upon Baird’s ability to sell the
securities allocated to Baird in the offering.
However, Baird Equity Asset Management will
only recommend such securities to a client when
it believes it is in a client’s best interest to do so.
Also, in accordance with applicable law and
Baird’s policies, any securities underwritten by
Baird will be sold to a client by Baird Equity Asset
Management in a principal capacity only if the
client consents to the transaction in writing and
Baird has provided the client with all material
information regarding Baird’s interest in the
transaction. For more information, please see
“Brokerage Practices—Trade Execution Services
Performed by Baird—Principal Transactions”
below.
(“Access Persons”). The Code prohibits Access
Persons from using knowledge about advisory
client account transactions to profit personally,
directly, or indirectly, by trading in his or her
personal accounts. In addition, an Access Person
must generally pre-clear his or her trades or
obtain prior authorization from Baird’s Compliance
Department before executing a trade. The Code
also generally prohibits Access Persons from
executing a security transaction for their personal
accounts during a blackout period that starts
seven days before and ends seven days after the
date that a client transaction in that same
security is executed. The Code provides for
certain exceptions deemed appropriate by Baird
management
Compliance
Department. A copy of the Code is available to
clients or prospective clients upon request.
Allocations of IPOs and Other Public Offerings
Baird also has the incentive to favor some clients
over other clients when allocating shares issued in
public offerings, particularly those clients with
larger accounts or accounts that generate high
fees and compensation, as a reward for their past
business or to generate future business.
Research Activities
Baird has also implemented certain policies and
procedures relating to Baird’s and its associates’
trading activities that are designed to prevent
them from improperly benefiting from the trading
activities of Baird’s advisory clients. In addition,
Baird’s Compliance Department monitors the
personal trading activities of all of Baird’s
associates providing advisory-related services to
clients.
Other Potential Conflicts
Baird’s Global Investment Banking, Public Finance
and Institutional Equities Services Activities
The investment advice provided to a client may
be based on the research opinions of Baird’s
research departments. Baird does, and seeks to
do, business with companies covered by those
research departments and as a result, Baird may
have a conflict of interest that could affect the
content of its research reports.
Other Client Relationships
related
services
Certain client accounts managed by Baird Equity
Asset Management and Baird have similar
investment objectives and strategies but may be
subject to different fee schedules. Thus, Baird
Equity Asset Management and Baird have an
incentive to favor client accounts that generate a
higher level of compensation.
Through its Global Investment Banking, Public
Finance and
Institutional Equities Services
Departments, Baird provides investment banking,
municipal advisory, securities underwriting, stock
to various
buyback and
corporate, municipal, and other
issuers of
securities. Baird receives compensation and fees
from such entities in connection with the services
it provides. Baird may, therefore, have an
incentive to favor the securities of issuers for
which Baird provides such services over the
securities of issuers for which Baird does not
provide such services.
Baird’s Broker-Dealer and Related Activities
Baird Underwritten Offerings
related services
purchase
securities
in
bonds, mutual
funds,
tends
to be higher
than
In its broker-dealer capacity, Baird provides
brokerage and
to clients,
including the purchase and sale of individual
stocks,
alternative
investment products and other securities. Baird
receives compensation based upon the sale of
such investment products. From time to time
Baird also has an incentive to recommend that
offerings
clients
underwritten by Baird because the underwriting
compensation that Baird will earn on those
offerings
the
compensation it would normally receive if clients
were to buy them in the secondary market, and
34
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird Equity Asset Management may use Baird, as
broker-dealer, to execute trades for clients.
orders routed away for execution, including the
type and the identity of the broker-dealers or
exchanges receiving such orders. This summary
as well as other important information about
Baird’s order routing practices are available at:
http://www.rwbaird.com/help/account-
disclosures/routing-equity-orders.aspx.
from
time
time
that
investments
Baird and its affiliates and associates may buy or
sell investments that are recommended to or
owned by a client for their own accounts, or they
may act as broker or agent for other clients
investments. Those
buying or selling those
transactions may
include buying or selling
investments in a manner that differs from, or is
inconsistent with, the advice given to a client, and
those transactions may occur at or about the
are
such
same
recommended to or are purchased or sold for a
client’s account. Baird Equity Asset Management
and Baird may also engage in agency cross
transactions and principal transactions with clients
as further described under “Brokerage Practices—
Trade Execution Services Performed by Baird”
below.
Baird and its associates, by reason of Baird’s
investment banking or other
broker-dealer,
activities, may
time acquire
to
information deemed confidential, material and
non-public, about corporations or other entities
and their securities. Baird and its associates are
prohibited by applicable law or agreements from
disclosing such information to clients or acting
upon such information with respect to any client
account. Baird’s other activities thus present a
interest because such
potential conflict of
activities may
Equity Asset
limit Baird
Management’s ability to advise or manage client
accounts.
Other Interests
As a registered broker-dealer, Baird effects
transactions in securities on a national exchange
and may receive and retain compensation for
such services, subject to the limitations and
restrictions made applicable to such transactions
by Section 11(a) of the Exchange Act and Rule
11a2-2(T) thereunder.
securities exchanges
Other sections of this Brochure also describe
instances when Baird Equity Asset Management
or Baird may recommend to clients, and may buy
and sell for client’s accounts, securities in which
Baird and its affiliates and associates have a
material financial interest. For more information,
please see “Other Financial Industry Activities and
Affiliations” above and “Brokerage Practices” and
“Client Referrals and Other Compensation” below.
Addressing Conflicts
transactions; and
to make securities allocations
to prevent
them
from
The foregoing activities could create a conflict of
interest with clients. Baird addresses these
potential conflicts through disclosure in this
Brochure and by adopting internal policies and
procedures for Baird and its associates that
require them to provide investment advice that is
appropriate for advisory clients (based upon the
information provided by such clients); that
require them to seek to obtain “best execution” of
that are
advisory client
designed
to
discretionary client accounts in a manner such
that all such clients receive fair and equitable
treatment over time. In addition, Baird has
adopted a Code of Ethics and other internal
trading policies and procedures relating to Baird’s
and its associates’ trading activities that are
improperly
designed
benefiting from the trading activities of Baird’s
Baird may route certain securities orders to other
for
broker-dealers or
execution. Baird selects execution venues based
on the size of the order, trading characteristics of
the security, speed of execution, likelihood of
price
improvement, availability of efficient
automated transaction processing, guaranteed
automatic execution levels, and other qualitative
factors. Baird receives remuneration in the form
of payment or liquidity rebates on certain options
or equity securities orders routed to some venues
(commonly known as “payment for order flow”).
This compensation, although not material to
Baird’s trading business, gives Baird an incentive
to route client orders for securities transactions to
those venues that provide Baird the greatest
levels of compensation. At a client’s request,
Baird will make available certain information
about the routing of such client’s orders routed
for execution in the six months prior to the
request. Such information will include the identity
of the venue to which orders were routed,
whether such orders were directed or non-
directed and the time of the transactions, if any,
from such orders. Baird also
that resulted
prepares a quarterly summary discussing certain
35
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Soft Dollar Benefits
advisory clients. See “Code of Ethics, Participation
or Interest in Client Transactions and Personal
Trading—Code of Ethics” above.
Brokerage Practices
Baird Equity Asset Management’s Trading
Practices
Broker-Dealer Selection
respect
to
provide
in return
instructions
Baird Equity Asset Management may receive
research (in addition to execution services) from
broker-dealers in connection with its clients’
securities transactions. These research benefits
are commonly referred to as “soft dollar benefits”.
In accordance with applicable law and Baird’s
policies, Baird Equity Asset Management may
cause clients to pay commissions (or markups or
markdowns) higher than those charged by other
broker-dealers who
execution-only
services
for soft dollar benefits.
However, Baird Equity Asset Management will
seek to obtain commission rates that it considers
appropriate for each client for the level and
quality of service received from brokerage firms.
on
equity
capability
and
past
The research services received by Baird Equity
Asset Management may be proprietary research,
which is research offered by the broker or dealer
executing a client transaction, or it may be third
party, which is research prepared by a third party
firm that is provided by the broker or dealer
executing a client transaction. Nearly all of the
brokerage commissions paid by Baird Equity Asset
Management clients are paid to brokers and
dealers who provide research services to Baird
Equity Asset Management. The brokerage
commissions
security
foreign
transactions are expected to generally range
between 1 to 15 basis points. The brokerage
commissions on other U.S. equity security
transactions are expected to generally range
between $0.01 and $0.04 per share.
standing of executing
in
risk;
timeliness
Baird Equity Asset Management does not
anticipate utilizing any
formal soft dollar
arrangements to obtain third party research in
2026, although it anticipates obtaining proprietary
research from executing broker-dealers.
and
Personal
Some broker-dealers indicate the amount of
commissions they expect to receive in exchange
for the provision of a particular research service.
Although Baird Equity Asset Management does
not agree
to direct a specific amount of
commissions to a firm in that circumstance, it
maintains an internal procedure to identify the
broker-dealers that provide Baird Equity Asset
Management with research services and the value
of those research services, and seeks to direct
sufficient commissions to ensure the continued
receipt of research services it feels are valuable.
With
the Baird Equity Asset
Management Strategies, Baird Equity Asset
Management will select the broker-dealers, which
may include Baird, that will execute trade orders
for a client’s accounts unless the client has
provided
to Baird Equity Asset
Management to the contrary. As an investment
adviser, Baird Equity Asset Management has an
obligation to seek “best execution” of client trade
orders. “Best execution” means that Baird Equity
Asset Management must place client trade orders
with those broker-dealers that Baird Equity Asset
Management believes are capable of providing the
best qualitative execution of client trade orders
under the circumstances, taking into account the
full range and quality of the services offered by
the broker-dealer. When selecting a broker or
dealer, Baird Equity Asset Management may
consider the following factors: client preferences;
research services (including strategy reviews,
domestic and international economic analysis,
technical commentary and other materials);
execution
execution
performance; access to liquidity and ability to
minimize market price impact; commission rates;
financial
firm and
rendering
counterparty
services; availability, cost and quality of custodial
services; and continuity and quality of the overall
provision of services. It is important to note that
Baird Equity Asset Management’s best execution
obligation does not require Baird Equity Asset
Management to solicit competitive bids for each
transaction or to seek the lowest available cost of
trade orders, so long as Baird Equity Asset
Management reasonably believes that the broker-
dealer selected can be reasonably expected to
provide clients with the best qualitative execution
under the circumstances. From time to time Baird
Equity Asset Management may use Baird, as
broker-dealer, to execute trades for clients. This
presents a potential conflict of interest. See “Code
of Ethics, Participation or Interest in Client
Transactions
Trading—Baird’s
Participation or Interest in Client Transactions”
above
36
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Management’s trading desk takes the commission
budget and evaluations into consideration, as part
of Baird Equity Asset Management’s obligation to
seek best execution, when selecting broker-
dealers to execute portfolio transactions for Baird
Equity Asset Management clients. To the extent
is considered
more than one broker-dealer
capable of providing best execution
for a
particular client transaction, Baird Equity Asset
Management may direct the client transaction to a
broker-dealer based upon the target commission
amounts then in effect.
information so received
is
to generate all of
During Baird’s last fiscal year ended December
31, 2025, Baird Equity Asset Management
received the following soft dollar benefits in
connection with effecting client transactions:
economic analysis and forecasts, financial market
analysis and forecasts, industry and company
specific analysis, interest rate forecasts; and
analysis of pending and proposed governmental
legislation and regulations. The research Baird
Equity Asset Management received
included
proprietary research (i.e., research created or
developed by
the broker-dealer). Research
services were received primarily in the form of
written reports, computer generated services,
telephone contacts, and personal meetings with
security analysts. Research services were also
provided in the form of meetings arranged with
corporate and industry spokespersons, invitations
to conferences and were generated by third
parties but are provided to Baird Equity Asset
Management by or through broker-dealers.
to execute client
The research
in
addition to, and not in lieu of, services performed
by Baird Equity Asset Management and does not
reduce the advisory fees payable to Baird Equity
Asset Management by clients. As a practical
matter, it would not be possible for Baird Equity
Asset Management
the
information presently provided by brokers and
dealers. When Baird Equity Asset Management
uses client brokerage commissions (or markups or
markdowns) to obtain research, Baird Equity
Asset Management receives a benefit because
Baird Equity Asset Management does not have to
produce or pay for the research itself. Baird
Equity Asset Management, therefore, may have
an incentive to select or recommend a broker-
dealer based on Baird Equity Asset Management’s
interest in receiving soft dollar benefits, rather
than on clients’
in receiving most
interest
favorable execution. However, Baird Equity Asset
Management seeks to select broker-dealers based
upon the broker’s or dealer’s ability to provide
best execution. Furthermore, Baird Equity Asset
Management does not select broker-dealers to
execute transactions for client accounts based
upon client referrals received from broker-dealers.
the
Baird
Equity
Asset Management
During Baird’s last fiscal year ended December
31, 2025, Baird Equity Asset Management used
the procedures described below to direct client
transactions to broker-dealers in return for the
soft dollar benefits that Baird Equity Asset
received. Baird Equity Asset
Management
Management
to allocate brokerage
seeks
commissions to broker-dealers in a way that, in
judgment,
Baird Equity Asset Management’s
reflects the quality and consistency of service
provided by broker-dealers and research service
providers. At the beginning of each year, a
commission budget is established. Baird Equity
Asset Management investment professionals then
jointly determine which broker-dealers will be
eligible
transactions and
establish a target commission amount for each
total
such broker-dealer based upon
commission
Asset
budget.
Management investment professionals periodically
review and vote on, rank or otherwise evaluate
the broker-dealers and their services throughout
the year, generally at least semi-annually. When
evaluating the broker-dealers, the Baird Equity
Asset Management
investment professionals
generally take into consideration the following
criteria: execution quality, trade errors, quality of
research, and access to analysts and company
management. Based upon that evaluation, Baird
Equity
then makes
adjustments to target commission amounts, if
any, and adds or removes broker-dealers based
upon the evaluation results. Baird Equity Asset
Research services provided by
internal and
external sources are used in managing client
accounts and, in the business judgment of Baird
Equity Asset Management, are important to each
client; although, perhaps, in differing degrees at
different times. As a general matter, such
research services, including soft dollar benefits,
are used to service all Baird Equity Asset
Management client accounts. However, each and
every research service may not be used to service
each and every account managed by Baird Equity
Asset Management, and Baird Equity Asset
Management does not allocate soft dollar benefits
to client accounts proportionately to the soft
dollar credits the accounts generate. Accordingly,
37
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
research that Baird Equity Asset Management
receives
for a particular client’s securities
transactions may not be useful for that client or
may be useful not only for that client, but for
other clients as well. Similarly, clients may benefit
from the research received from the transactions
of other clients. Research information and its
application and the interpretation of its worth are
matters of professional judgment made by Baird
Equity Asset Management.
may be used when allocating purchases and sales
to a client’s account because such securities may
be purchased and sold at different prices in a
series of block transactions. As a result, the
average price received by a client may be higher
or lower than the price the client may have
received had the transaction been effected for the
client independently from the block transaction.
In addition, a client’s transaction costs may vary
depending upon, among other things, the type of
security bought or sold, and the commission or
markup or markdown charged by the executing
broker-dealer.
Trade Aggregation, Allocation and Rotation
Practices
in
to make securities allocations
Baird Equity Asset Management may aggregate
contemporaneous buy and sell orders for the
accounts over which it has discretionary authority
(a practice also known as bunching trades or
block transactions). This practice may enable
Baird Equity Asset Management to obtain more
favorable execution, including better pricing and
enhanced investment opportunities, than would
if orders were not
otherwise be available
aggregated. Using block transactions may also
assist Baird Equity Asset Management
in
potentially avoiding an adverse effect on the price
of a security that could result from simultaneously
placing a number of separate, successive or
competing, client orders.
consideration
client’s
risk
strategies
into
consideration
account
Baird Equity Asset Management generally
aggregates buy and sell orders when executing
trades for client accounts under its discretionary
management when it has the opportunity to do
so. However, Baird Equity Asset Management
determines whether or not to utilize block
transactions for a client in its sole discretion and
Baird Equity Asset Management’s decision is
subject to its duty to seek best execution. Baird
Equity Asset Management will aggregate a client’s
trade orders only when Baird Equity Asset
Management deems it to be appropriate and in
the best interests of the client, consistent with a
client’s investment objectives and risk tolerance,
and permitted by regulatory requirements. In
determining the amount to be allocated to an
account, if any, Baird Equity Asset Management
takes
specific
investment restrictions, undesirable position size,
account portfolio weightings, client tax status,
client cash positions and client preferences.
The amount of securities available
the
marketplace, at a particular price at a particular
time, may not satisfy the needs of all clients
participating in a block transaction and may be
insufficient to provide full allocation across all
client accounts. To address this possibility, Baird
Equity Asset Management has adopted trade
that are
allocation policies and procedures
designed
to
discretionary client accounts in a manner such
that all such clients receive fair and equitable
treatment over time. If a block transaction cannot
be executed in full at the same price or time, the
securities actually purchased or sold by the close
of each business day will generally be allocated
pro rata among the clients participating in the
block transaction. However, Baird Equity Asset
Management may also make random allocations
to client accounts in certain circumstances, such
as when Baird Equity Asset Management deems a
partial fill for the total block order to be low.
Adjustments may also be made to avoid a
nominal allocation to client accounts. When
making an allocation of debt obligations, Baird
Equity Asset Management, in its discretion, takes
investment
a
into
objectives,
and
tolerance,
investment guidelines and restrictions; the client’s
cash needs and expected cash flows; and the
composition of the client’s investment portfolio,
including its issuer and sector representation and
its average maturities and duration, and the
liquidity of the position size. Baird Equity Asset
Management may conduct a series of transactions
in debt obligations with similar characteristics to
meet the needs of clients not receiving an
allocation in a block transaction.
All advisory clients participating
in a block
transaction will receive the same execution price
for the security bought or sold. Average prices
When Baird Equity Asset Management is not able
to aggregate trades (including when Baird Equity
Asset Management provides a model portfolio to
38
Baird EAM Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the Program Sponsor. This practice is frequently
referred to as “trading away” and these types of
trades are frequently called “step out trades”.
Trading away from the Program Sponsor provides
Baird Equity Asset Management the ability to
aggregate trade orders for wrap fee program
clients with trade orders for other Baird Equity
Asset Management clients. Baird Equity Asset
Management trades away from the Program
Sponsor when it believes that another broker-
dealer will provide more favorable execution of
the client’s trades, taking into consideration the
factors listed above.
the Program Sponsor), Baird Equity Asset
Management generally uses a trade rotation
process that is designed to be fair and equitable
to its clients over time. However, a client should
be aware that Baird Equity Asset Management’s
trade rotation practices may at times result in a
transaction being effected for the client’s portfolio
that occurs near or at the end of the rotation and,
trade orders will
in such event, client’s
significantly bear the market price impact, if any,
of those trades executed earlier in the rotation,
and, as a result, the client may receive a less
favorable net price for the applicable trade.
Further, model delivery clients of CCM are notified
of model changes (subject to a rotation within this
group of clients) following the completion of
trading for client accounts in which it has
discretionary trading authority.
the
In some instances, step out trades may be
executed by the other firm without any additional
commission or markup or markdown, but in other
instances, the executing firm may impose a
commission or a markup or markdown on the
trade. If Baird Equity Asset Management places
trade orders for the client’s account with a firm
other than the Program Sponsor, and the other
firm imposes a commission or a markup or
markdown on the trade, the client will incur
trading costs in addition to the wrap fee the client
pays to the Program Sponsor.
Because Baird Equity Asset Management is unable
to buy or sell any security for a client’s non-
client’s
discretionary accounts without
authorization, Baird Equity Asset Management
generally does not aggregate or bunch trades for
those accounts with the same or similar trades for
other client accounts. Because similar orders for
the client and Baird Equity Asset Management’s
other clients may be placed and filled at different
times, the client may buy or sell securities at
prices that are different from the prices obtained
by other clients who received the same or similar
advice from Baird Equity Asset Management.
Wrap Fee Programs
in wrap
During the year ended December 31, 2025, all of
Baird Equity Asset Management’s step out trades
were executed without any additional commission
or markup or markdown being passed on to wrap
fee program clients by the executing broker-
dealer. However, there can be no assurance that
a wrap fee program client will not incur increased
trading costs relating to step out trades in the
future.
trades resulting
to
trade volumes or
With respect to some wrap fee programs, Baird
Equity Asset Management may not be able to
aggregate client trades using a trade away
process. Typically this occurs in situations in
which the Program Sponsor has directed Baird
Equity Asset Management to place all trades with
the Program Sponsor or Baird Equity Asset
Management only provides a model portfolio to
the Program Sponsor (and does not place trades
for client accounts). In other instances, Baird
Equity Asset Management may not be able to
trade away using third party brokers because
such brokers will not accommodate trade aways
due
the proposed
compensation to be received by the broker. In
those instances, Baird Equity Asset Management
fee
Generally, clients participating
programs pay the Program Sponsor a wrap fee
that includes trade execution services performed
by Program Sponsor as broker-dealer. Because
clients may incur trading costs in addition to the
wrap fee if trade orders were to be executed by
another broker-dealer
firm, clients generally
receive a cost advantage whenever their Program
Sponsor executes client transactions. For this
reason, Baird
Equity Asset Management
anticipates that it will place some trade orders for
the client’s account with the applicable Program
Sponsor, such as
from a
contribution to, or distribution from, a client’s
account. However, in order to comply with its
duty to seek best execution, Baird Equity Asset
Management anticipates that it will frequently
place client trades resulting from model changes
to Baird Equity Asset Management’s Growth
Strategies with a broker-dealer firm other than
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
generally uses a trade rotation process that is
designed to be fair and equitable to all Baird
Equity Asset Management clients.
A wrap fee program client should consider this
information carefully and discuss it with the
client’s Program Sponsor when selecting a
manager to manage the client’s accounts.
Directed Brokerage
transaction costs
that Baird Equity Asset
Management may obtain for its other clients. A
client should further note that Baird Equity Asset
Management may or may not include such client
trade orders in its trade rotation process and that
Baird Equity Asset Management may place the
client’s trade orders with the directed broker-
dealer after Baird Equity Asset Management
completes its trading for other Baird Equity Asset
Management client accounts. The client’s trade
orders will significantly bear the market price
impact, if any, of those trades executed earlier in
Baird Equity Asset Management’s rotation. As a
result, the client may receive a less favorable net
price for the trade.
Baird Equity Asset Management will comply with
any guidelines and/or
limitations reasonably
requested by a client relating to brokerage for the
client’s account. Specific guidelines and/or
limitations requested by clients vary from client to
client based upon a client’s particular objectives
and other factors.
in
a
directed
If Baird Equity Asset Management aggregates a
client’s directed brokerage trade orders with trade
orders for other Baird Equity Asset Management
clients, Baird Equity Asset Management may
employ the use of “step-outs” to satisfy the
client’s directed brokerage arrangement. A “step-
out” occurs when an executing broker executes
the trade and then “steps out” the trade to a
clearing broker (which would be the directed
broker-dealer
brokerage
arrangement) that confirms and settles the trade.
In such a case, a client will bear the costs of any
commissions, markups or markdowns imposed by
the executing broker-dealer in addition to the
costs of any commissions, markups or markdowns
imposed by the directed broker-dealer. As a
result, a directed brokerage arrangement may be
more costly to a client, as it may result in the
client paying higher commissions, markups,
markdowns and greater bid/offer spreads, or
receiving a less favorable net price.
if
If a client directs Baird Equity Asset Management
to use a particular broker-dealer, and if the
particular broker-dealer referred the client to
Baird Equity Asset Management or
the
particular broker-dealer refers other clients to
Baird Equity Asset Management or Baird in the
future, Baird Equity Asset Management or Baird
may benefit from the client’s directed brokerage
arrangement. Because of these potential benefits,
Baird Equity Asset Management and Baird may
have an economic interest in having the client
continue the directed brokerage arrangement.
The benefits that Baird Equity Asset Management
and Baird receive conflict with the client’s interest
in having Baird Equity Asset Management or Baird
recommend that the client utilize another broker-
In some cases, a client may direct Baird Equity
Asset Management to use a particular broker-
dealer for execution of the client’s trade orders (a
“directed brokerage arrangement”), and Baird
Equity Asset Management may agree to the
arrangement. This may occur when a client’s
portfolio is held at a broker-dealer firm and a
client directs Baird Equity Asset Management to
execute trades through such firm, or when a
client’s Retirement Account or other account is
maintained on a platform operated and managed
by a third party unaffiliated with Baird Equity
Asset Management or Baird and trades must be
executed through that platform. A client should
understand that Baird Equity Asset Management
considers such arrangements to be directed
brokerage arrangements. A client should also
understand that if the client has a directed
brokerage arrangement, Baird Equity Asset
Management may be unable to achieve best
execution for the client’s transactions. A client
should note that any costs related to the directed
brokerage arrangement are not included in Baird
Equity Asset Management’s fee and that the client
will be solely
for monitoring,
responsible
evaluating and reviewing the arrangement with
the directed broker-dealer and paying any
commissions or markups or markdowns or other
costs imposed by the directed broker-dealer. A
client should also note that Baird Equity Asset
Management may not be able to aggregate the
client’s directed brokerage trade orders with
orders for other Baird Equity Asset Management
clients. As a result, a client’s transaction costs
may be higher because the client will not benefit
from any volume discounts or other reduced
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
dealer to execute some or all transactions for the
client’s account.
error results in a gain, the gain may be retained
by Baird but such gain is not given to or shared
with any Baird Equity Asset Management or Baird
associate.
consider
of
the possible
directed
Before directing Baird Equity Asset Management
to use a particular broker-dealer, a client should
costs or
carefully
disadvantages
brokerage
arrangements.
in other programs trading
Cross Trading Involving Advisory Accounts
Baird Equity Asset Management and Baird offer
many services and, from time to time, may have
in
other clients
opposition to a client. To avoid favoring one client
over another client, Baird attempts to use
objective market data in the correction of any
trading errors.
in cross transactions
the
Other Managers’ Trading Practices
With respect to the Other Manager Strategies, the
Other Manager managing the client’s portfolio will
select the broker-dealers, which may include
Baird, that will execute trade orders for a client’s
accounts unless
client has provided
instructions to Baird Equity Asset Management
and to the Other Manager to the contrary.
Additional information about an Other Manager’s
trading practices is contained in the Other
Manager’s Brochure.
seeks
comply with
Baird Equity Asset Management generally does
not engage
for client
accounts. However, in certain instances when one
or more clients need to buy and one or more
clients need to sell the same investment, Baird
Equity Asset Management may engage in cross
transactions to the extent Baird Equity Asset
Management believes it is in all applicable clients’
best interests to do so. Also, from time to time,
Baird Equity Asset Management may engage in
in-kind transactions involving a client’s purchase
or sale of investments from or to a Baird Equity
Fund in exchange for shares of such Baird Equity
Fund. Baird Equity Asset Management will only
engage in such a transaction when Baird Equity
Asset Management believes that the transaction is
consistent with the client’s best interest. When
effecting such transactions, Baird Equity Asset
Management
the
to
requirements of the Baird Equity Funds’ in-kind
transaction procedures, or other applicable SEC
guidance.
Trade Error Correction
Trade Execution Services Performed by
Baird
If Baird provides trade execution services for a
client’s account, Baird will generally act as agent
when routing client trade orders for execution.
However, Baird may cross trades between client
accounts or may act as principal for its own
account in certain circumstances to the extent
permitted by applicable law as is more fully
described below.
reallocating
the
transaction
in addition
A client should understand that certain securities,
such as securities traded over-the-counter and
fixed income securities, are primarily traded in
dealer markets. When Baird purchases or sells
these types of securities for client accounts, it
generally does so through broker-dealer firms
acting as a dealer or principal. Dealers executing
include a markup,
principal trades typically
markdown or spread in the net price at which
transactions are executed. A client bears such
costs
to Baird Equity Asset
Management’s fee.
Agency Cross Transactions
It is Baird’s policy that if there is a trade error for
which Baird is responsible, Baird will take actions,
based on the facts and circumstances surrounding
the error, to put the client’s account in the
position that it would have been in as if the error
had not occurred, including by adjusting or
reversing the transaction, entering an offsetting
transaction,
to
another account (subject to the review and
approval of the Compliance Department), or other
methods that may be deemed appropriate by
Baird. Errors caused by Baird Equity Asset
Management or Baird will be corrected at no cost
to client’s account, with the client’s account not
recognizing any loss from the error. Baird may
net gains and losses from a single error event
involving more than one transaction in a security
or transactions in multiple securities. The client’s
account will be fully compensated for any losses
incurred as a result of an error event. If the trade
Baird Equity Asset Management generally does
not engage in agency cross transactions for client
accounts. In certain circumstances and to the
extent permitted by applicable law and regulation,
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird Equity Asset Management and Baird may
effect “agency cross” transactions with respect to
a client’s account. An “agency cross” transaction
is a transaction in which Baird or its affiliates act
as broker for the party or parties on both sides of
the transaction. As compensation for brokerage
services, Baird Equity Asset Management and
Baird may receive compensation from parties on
both sides of an agency cross transaction, the
amount of which may vary. Therefore, Baird
Equity Asset Management and Baird may have a
conflicting division of loyalties and responsibilities.
in all cases, Baird Equity Asset
However,
Management and Baird will seek to obtain the
best execution for each respective advisory client
and will effect agency cross transactions only in
accordance with the requirements of Rule 206(3)-
2 or other rules or SEC guidance under the
Advisers Act. Furthermore, Baird Equity Asset
Management and Baird will comply with additional
regulations applicable to Retirement Accounts.
Principal Transactions
by the client. Principal trades also allow Baird to
sell securities from its account that it deems
undesirable and to buy securities for its account
that it deem desirable. Thus, in trading as
principal with a client, Baird Equity Asset
Management and Baird will have potentially
conflicting division of loyalties and responsibilities
regarding Baird Equity Asset Management’s and
Baird’s own interests and the interests of the
client. This profit potential may give Baird Equity
Asset Management and Baird an incentive to
recommend a transaction in which Baird Equity
Asset Management and Baird act as principal over
other transactions. Nonetheless, Baird Equity
Asset Management and Baird have a fiduciary
duty to act in the client’s best interest and to seek
best execution for advisory clients. Baird Equity
Asset Management and Baird address this conflict
through disclosure in this Brochure. Furthermore,
Baird has adopted
internal procedures that
require Baird Equity Asset Management and
Baird, when acting in a principal capacity, to
disclose all material information regarding Baird’s
interest in the transaction, and obtain the client’s
approval of the transaction prior to settlement.
to
the
Baird Equity Asset Management and Baird may
also act as principal in selling securities to a
client’s account during offerings underwritten by
Baird as further described above. In each such
instance, Baird will provide certain disclosures
about the transaction and obtain the client’s
consent to the trade.
Baird
Equity
portfolio management
Baird Equity Asset Management generally does
not engage in principal trading with clients.
requirements of
However, subject
applicable law, Baird Equity Asset Management
and Baird may execute transactions for a client’s
portfolio while acting as principal for Baird’s own
account. Baird acts as principal when Baird Equity
Asset Management or Baird sell a security from
Baird’s inventory to a client, or Baird Equity Asset
Management or Baird purchase a security from a
client for Baird’s inventory. Baird also acts as
principal when it sells new issue securities to
clients in offerings underwritten by Baird as
further described below. Baird also acts as
principal in riskless principal transactions. Riskless
principal transactions refer to transactions in
which Baird, after having received a client’s order,
executes an identical order in the marketplace to
fill the client’s order while acting as principal.
include
in
terms of
Review of Accounts
Portfolios Managed by Baird Equity Asset
Management
If the client’s portfolio is managed by Baird Equity
Asset Management,
Asset
team
Management’s
reviews Baird Equity Asset Management’s client
portfolios. Baird Equity Asset Management
portfolio managers monitor client portfolios to
evaluate the impact of changing economic and
market conditions on the client's securities and
investment objectives. Major factors considered in
all reviews
the market activity of
individual securities and industries; the mix
among cash alternatives, fixed income, and equity
instruments; and the appropriateness of the
portfolio’s holdings
long-term
objectives such as income, risk and growth.
Baird Equity Asset Management and Baird may
realize profits from principal transactions with a
client based on the difference between the price
Baird paid for the security and the price at which
Baird sold the security, which may include a
markup, markdown or spread from the prevailing
market price, an underwriting fee, selling dealer
concession, or other incentive to execute the
transaction. Any compensation received by Baird
Equity Asset Management and Baird in a principal
transaction is in addition to the advisory fee paid
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
focusing on
from the description of those services provided by
Baird Equity Asset Management above. Clients
participating in a wrap fee program should
contact the sponsor for specific information about
the account reviews to be performed and the
performance reports, if any, that will be provided.
investment objective,
At least quarterly, Baird Equity Asset Management
portfolio managers review client portfolios for
allocation of client assets among cash, equity
securities, and fixed income holdings and review
each managed portfolio
the
appropriateness of the client’s investments in light
of each client’s
risk
tolerance, and income requirements. Additional
reviews performed by Baird Equity Asset
Management associates include drift reports for
wrap program accounts, which are generally
performed quarterly, and an asset allocation
review that compares a client’s investment policy
statement to the client portfolio’s investment
allocation, which is performed at least annually.
CCM also reviews drift reports for client portfolios
pursuing a CCM Strategy, which are generally
performed at least quarterly.
Accounts Managed by Other Managers
If a client portfolio is managed by an Other
Manager, Baird Equity Asset Management and
Baird generally only review drift reports and
performance reports for the client’s portfolio as
described above. They generally do not provide
performance or other reports to such clients,
unless such clients are participating in a wrap
program sponsored by Baird. Such clients should
review the Other Manager’s Form ADV Part 2A
Brochure for information about the types of
reviews performed, and reports provided, by the
Other Manager.
reviews
portfolio’s
Baird Equity Asset Management portfolio
managers generally review trading in a client’s
portfolio each day there is a trade in the client’s
team
portfolio. The portfolio management
typically
relative
each
performance compared to a relevant benchmark
index at least quarterly.
reviews
are
Reviews for variance in a portfolio’s performance
compared to the portfolio’s composite are also
performed.
generally
These
performed monthly.
regarding market and
Other Information
A client’s portfolio performance may be compared
to a benchmark market index or indices. The
benchmark may be a blended benchmark that
combines the returns for two or more indices.
Benchmarks shown in performance reports are for
informational purposes only. Baird Equity Asset
Management’s selection and use of benchmarks is
not a promise or guarantee that the performance
of a client’s portfolio will meet or exceed the
stated benchmark. When the client compares
portfolio performance to the performance of a
market index, the client should recognize that a
market index merely reflects the performance of a
list of unmanaged securities included in the index
and the index performance does not take into
account management fees, execution costs, and
other expenses related to the operation of a
portfolio. The securities included in a client’s
portfolio generally do not exactly mirror the
securities included in the index.
Baird Equity Asset Management generally
provides written performance reports to clients on
a quarterly basis. These quarterly performance
reports contain the client portfolio’s performance,
portfolio valuation, and portfolio manager
commentary
sector
performance. Clients pursuing a Baird Equity
Asset Management Growth or SAM Strategy may
also receive a list of portfolio holdings as part of
the quarterly
report. Baird Equity Asset
Management may provide additional information
in the performance report to meet the specific
reporting needs of a client as the client and Baird
Equity Asset Management may agree.
If Baird provides transaction execution services to
a client, Baird will generally provide the client
with a monthly brokerage account statement
when activity occurs during
that month.
Otherwise, Baird will provide the client with a
quarterly statement if there has not been any
intervening monthly transaction activity.
Special Note for Wrap Fee Program Clients. The
sponsor of the wrap fee program generally
controls the frequency of client account reviews
and performance reports and the content of those
reports. The account reviews performed by, and
the performance reports provided by, wrap fee
program sponsors to clients may differ materially
If Baird has custody of a client’s account assets,
Baird will generally rely on third party pricing
services to determine the value of such assets.
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
These values are shown on client’s account
statements and are used in preparing a client’s
performance reports. However, if the client has its
assets held by a custodian other than Baird and if
the third party pricing service does not provide a
price for assets in the client’s account, Baird
Equity Asset Management will rely upon the price
reported by the client’s third party custodian. If a
client has assets held by a third party custodian,
the prices shown on a client’s account statements
provided by the custodian could be different from
the prices shown on statements and reports
provided by Baird Equity Asset Management. See
“Custody” below for more information.
Custody
Separate Accounts
Each client is responsible for appointing the
client’s custodian, which will have possession of
the assets of the client’s account and settle
transactions for the account. Clients may choose
Baird or a service provider unaffiliated with Baird
to serve as custodian. While Baird Equity Asset
Management does not act as custodian when the
client selects a third party custodian, Baird Equity
Asset Management may be deemed under Rule
206(4)-2 of the Advisers Act to have custody of
client assets in certain circumstances, such as
when the client has authorized Baird Equity Asset
Management to deduct its advisory fees directly
from a client's custody account.
result,
Special Note for Wrap Fee Program Clients. The
benchmarks used by Baird Equity Asset
Management with respect to a client’s portfolio
may differ from the benchmarks used by the wrap
fee Program Sponsor. As a
the
performance comparisons in Baird Equity Asset
Management’s performance reports may differ
from reports provided to clients directly by the
Sponsor.
limit
level
based
relationship and
Client Referrals and Other
Compensation
Baird or Baird Equity Asset Management may
provide compensation to individuals who refer
clients in some instances. When applicable, the
compensation paid is a percentage of the client’s
fee payments or the value of the client’s account.
The amount of compensation will vary, with the
specific
upon
determined
consideration of various factors including, but not
limited to, the individual’s role in developing the
client
the assets under
management. Baird may pay these fees to
registered representatives of Baird and
its
affiliates as well as to unaffiliated solicitors that
have entered into a written agreement with Baird.
A client should understand that Baird Equity Asset
Management does not monitor, evaluate or
review any third party custodian. The client
should also understand that the client will pay a
custody fee in addition to the fee paid to Baird
Equity Asset Management. Further, such third
party custody arrangements may
the
services made available to the client. In addition,
a client should understand that: (a) each third
party custodian has exclusive control over the
investment options made available to client
accounts on the custodian’s platform; (b) Baird
Equity Asset Management has no authority or
ability to add to, or remove from, a custodian’s
platform any investment option; (c) any advice
given by Baird Equity Asset Management with
respect to the account is inherently limited by the
options available through a custodian’s platform;
(d) Baird Equity Asset Management may have
provided different investment advice with respect
to the account had they not been limited to the
investment options made available through the
custodian’s platform; and (e) certain investments,
such as mutual fund shares, could be more or less
expensive than if the investment was obtained
from Baird or another firm.
Interest
and
Personal
Trading”
Baird Equity Asset Management and Baird and
Baird’s affiliates and associates may receive
certain economic benefits in connection with
providing advisory services to clients, which are
described in the sections entitled “Other Financial
Industry Activities and Affiliations”, “Code of
in Client
Ethics, Participation or
Transactions
and
“Brokerage Practices” above.
A client who uses a third party custodian
authorizes Baird Equity Asset Management to give
instructions to the client’s custodian for all actions
necessary or incidental to the purchase, sale,
exchange, and delivery of securities held in the
client’s account. Also, all clients for whom Baird is
deemed to have custody will receive account
statements, at least quarterly, directly from the
client’s selected custodian. A client should
carefully review those account statements and
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
of the client’s account without consulting the
client.
compare them with any account statements
provided by Baird Equity Asset Management or
Baird. A client should note that the prices shown
on a client’s account statements provided by the
custodian could be different from the prices
shown on statements and reports provided by
Baird Equity Asset Management due to a variety
of factors, including the use of different valuation
sources and/or accounting methods (e.g., trade
or settlement date accounting) by the custodian
and Baird Equity Asset Management.
Private Funds
Baird is deemed under the federal securities laws
to have custody of the assets of the Chautauqua
Private Funds by virtue of its role as general
partner or manager of those Funds. The assets of
each Chautauqua Private Fund are held by the
Funds’ custodian. The financial statements of the
Chautauqua Private Funds are audited by an
independent accounting firm. Each investor will
receive audited financial statements from Baird.
or
an Other Manager
If a client selects an Other Manager Strategy, the
client authorizes the Other Manager to manage
the assets in the client’s portfolio and grants to
the Other Manager the authority to determine the
amount, type and timing with respect to buying,
holding, exchanging, converting and selling
securities and other assets
for the client’s
portfolio, subject to the client’s portfolio strategy.
The client also grants to the Other Manager
complete and unlimited trading authorization and
appoints the Other Manager as agent and
attorney-in-fact with respect to the client’s
portfolio and all related trading and other
decisions. Pursuant to such authorization, the
Other Manager may, in its sole discretion and at
the client’s risk, purchase, sell, exchange, convert
and otherwise trade the securities and other
investments in the portfolio, as well as arrange
for delivery and payment in connection with the
above, and act on the client’s behalf in all matters
necessary or incidental to the handling of the
portfolio without prior notice to the client. Baird
Equity Asset Management does not have
discretion over the assets in a client’s portfolio
that is managed by an Other Manager and cannot
purchase or sell any securities or other
investments in that portfolio.
to
buying,
holding,
strategy. The
client’s
authorization,
Baird
Equity
A client has the ability to impose reasonable
investment restrictions on the management of a
portfolio, including the designation of particular
securities or types of securities that should not be
purchased for the client’s account, but a client
may not require that particular funds or securities
(or types) be purchased for the client’s portfolio.
Reasonable investment restrictions requested by
a client will apply only to those assets over which
Baird Equity Asset Management or an Other
Manager has discretion. Any such limitations
agreed to by client and Baird Equity Asset
Management are generally included in the client’s
investment policy statement or in a separate
letter of understanding. When possible, Baird
Equity Asset Management will also attempt to
observe any non-binding statement of client
preferences with respect to factors such as
brokerage direction, holding periods, and
securities selection.
Investment Discretion
Clients generally give Baird Equity Asset
the
Management
discretionary investment authority to determine
independently the specific securities purchased or
sold, and the amount of securities purchased or
sold. By executing an investment management
agreement with Baird Equity Asset Management
and selecting a Baird Equity Asset Management
Strategy, a client authorizes Baird Equity Asset
Management to make investment decisions for
the client’s account, with the authority to
determine the amount, type and timing with
respect
exchanging,
converting and selling securities and other assets
for the client’s account, subject to the client’s
investment
portfolio
management agreement also grants to Baird
Equity Asset Management complete and unlimited
trading authorization and appoints Baird Equity
Asset Management as agent and attorney-in-fact
with respect to the client’s accounts and all
related trading and other decisions. Pursuant to
such
Asset
Management may, in its sole discretion and at the
client’s risk, purchase, sell, exchange, convert
and otherwise trade the securities and other
investments in the client’s account, as well as
arrange for delivery and payment in connection
with the above, and act on the client’s behalf in
all matters necessary or incidental to the handling
In the event that a client’s account is restricted
from investing in certain securities, Baird Equity
Asset Management or the Other Manager will
45
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
accounts without
restrictions
about the criteria used by Baird Equity Asset
Management, clients should review the section of
the Brochure entitled “Methods of Analysis,
Investment Strategies and Risk of Loss” above.
For more information about the criteria used by
Baird’s affiliates, clients should review
the
affiliate’s Form ADV Part 2A Brochure. A client’s
consent may be revoked at any time.
select such other replacement securities, if any,
as
they deem appropriate. Accounts with
investment restrictions may perform differently
and
from
performance may be poorer. In addition, in the
event there is a change in the classification or
credit rating of a security held in the client’s
account, a client’s investment restrictions may
force Baird Equity Asset Management or the Other
Manager to sell such security at an inopportune
time, possibly negatively
impacting account
performance and causing the client’s account to
realize taxable gains or losses, which could be
significant. A client should also be aware that, if
the client’s account holds any investment vehicle
(such as a mutual fund or ETF), any investment
restrictions the client places on the client’s
account may not flow through to the securities
owned by that investment vehicle.
Voting Client Securities
Baird Equity Asset Management and CCM
Clients pursuing Baird Equity Asset Management
Strategies may elect in their contract whether to
authorize and delegate the right to Baird to vote
proxies with respect to the securities held in their
accounts. Unless a client makes that election, the
client will be responsible for voting proxies and
otherwise addressing all matters submitted for
consideration by security holders, and Baird
Equity Asset Management and Baird are under no
obligation to take any action or render any advice
regarding such matters. Baird Equity Asset
Management and Baird generally do not permit
clients to direct particular votes once they have
granted Baird discretionary voting authority.
Clients wishing to vote securities may do so by
terminating the discretionary voting authority
granted to Baird.
Baird Equity Asset Management and Baird’s
affiliates may use the discretionary authority
granted to them by a client to invest the client’s
account in investment products affiliated with
Baird or that pay fees to Baird or to any of its
affiliates for investment advisory or other services
they provide (“affiliated investment products”). In
addition, if the client participates in cash sweep
services provided by Baird, short-term cash
balances in the client’s account may be invested
in one or more money market mutual funds and
individual deposit accounts offered by Baird, its
affiliates, or a third party. Baird and its affiliates
may receive fees or other compensation related to
such cash balance investments made by the
client.
signing
an
Baird Equity Asset Management has adopted
that are
written policies and procedures
reasonably designed to ensure that Baird votes
client securities in the best interests of clients.
Those procedures address material conflicts of
interest that may arise between Baird Equity
Asset Management’s or Baird’s interests and
those of their clients. Although a description of
Baird Equity Asset Management’s proxy voting
policies and procedures is provided below, Baird
Equity Asset Management will furnish a copy of its
proxy voting policies and procedures to clients
upon their request. Additionally, clients may
obtain information on how Baird actually voted
proxies with respect to the securities held in their
accounts by contacting Baird Equity Asset
Management by calling (414) 765-3500.
interests. Baird utilizes
In situations in which a client has delegated to
Baird voting authority with respect to securities in
the client’s account, Baird will vote proxies in a
manner that Baird believes is consistent with the
client’s best
an
independent provider of proxy voting and
currently
corporate
governance
services,
By
investment management
agreement with Baird Equity Asset Management,
to Baird Equity Asset
a client consents
Management and Baird’s affiliates investing all or
a portion of the client’s account in affiliated
investment products. The amount of fees received
by Baird and its affiliates is generally described in
the prospectus or other offering or disclosure
documents for the investment product. Baird
Equity Asset Management and Baird’s affiliates
will use their discretionary authority to invest the
client’s account in affiliated investment products
when they determine it to be in the client’s best
interest to do so. Generally, the criteria used by
them in deciding to invest in affiliated investment
products are the same as those used in deciding
to invest a client’s assets in investment products
unaffiliated with Baird. For more information
46
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
voting
recommendations.
client’s
account
believes
the
The proxy voting policies and procedures also
address instances in which Baird’s interests may
appear to conflict with client interests, such as
when Baird Equity Asset Management, Baird or an
affiliate of Baird is managing or administering (or
seeking to manage or administer) a corporate
retirement, pension or employee benefit plan or
providing (or seeking to provide) advisory or
other services to a company whose management
is soliciting proxies. In such instances, there may
be a concern that Baird would be inclined to vote
in favor of management because of Baird’s
relationship or pursuit of a relationship with the
company. In situations where there is a potential
conflict of interest, Baird’s Proxy Voting Sub-
Committee will determine
the nature and
materiality of the conflict. If the conflict is
the Sub-
to not be material,
determined
Committee will vote the proxy in a manner the
Sub-Committee believes is in the best interests of
the client and without consideration of any benefit
to Baird or its affiliates. If the potential conflict is
determined to be material, Baird’s Proxy Voting
Sub-Committee will take one of the following
steps to address the potential conflict: (1) cast
the vote in accordance with the recommendations
of ISS or other independent third party; (2) refer
the proxy to the client or to a fiduciary of the
client for voting purposes; (3) suggest that the
client engage another party to determine how the
proxy should be voted; (4) if the matter is not
addressed by ISS, vote in accordance with
management’s recommendation; or (5) abstain
from voting.
Institutional Shareholder Services (“ISS”), to
analyze proxy materials and votes and make
independent
ISS
provides proxy voting guidelines regarding its
position on various matters presented by
companies to their shareholders for consideration.
Baird will typically vote shares in accordance with
the recommendations made by ISS. However,
ISS’s guidelines are not exhaustive, do not
address all potential voting issues, and do not
necessarily correspond with the opinions of the
Baird Equity Asset Management portfolio
managers. In the event the portfolio manager for
a
ISS
recommendation is not in the best interest of the
client, the portfolio manager will bring the issue
to Baird’s Proxy Voting Sub-Committee through a
proxy challenge process. The Sub-Committee will
then be responsible for determining how the vote
will be cast. The decision made by the Proxy
Voting Sub-Committee on the proxy challenge
applies to all advisory accounts managed by the
portfolio manager
team of portfolio
(or
managers), unless the client has directed Baird
Equity Asset Management or Baird to utilize
specific voting guidelines (e.g., Taft-Hartley
guidelines). For those matters for which the
independent proxy voting service does not
provide a specific voting recommendation, each
portfolio manager will cast the vote in a manner
he or she believes is in the best interest of clients.
The votes cast for a client’s account may differ
from those votes cast for other Baird Equity Asset
Management or Baird clients based on differing
views of portfolio managers.
While Baird uses its best efforts to vote proxies,
there are instances when voting is not practical or
is not, in Baird’s or the portfolio managers’ view,
in the best interest of clients. For example,
casting a vote on a foreign security may involve
additional costs or may prevent, for a period of
time, sales of shares that have been voted. Also,
when a client has entered into a securities lending
program, Baird generally will not seek to recall
the securities on loan for the purpose of voting
the securities; however, Baird reserves the right
to recall the shares on loan on a best efforts basis
if the portfolio manager becomes aware of a
proxy proposal where the proxy vote is materially
important to the client’s account.
Baird uses ISS’s electronic vote management
system to cast votes on behalf of clients. In
connection with Baird’s use of that system, ISS
pre-populates how client votes should be cast
based upon ISS’s voting recommendations. The
system allows Baird to change the pre-populated
vote (to the extent permitted by Baird’s proxy
voting policies) up until a certain time prior to the
applicable meeting (the “voting cut-off time”).
Baird’s proxy voting policies are designed to
address situations when additional information
becomes available after the votes are pre-
populated in the system and before the voting
cut-off time. However, there is no guarantee that
all information that could affect Baird’s proxy
voting decision will be received or considered by
Baird prior to a vote being cast.
In addition to the services described above, Baird
has engaged ISS for vote execution and record-
keeping services.
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
available
for
investment
to
including,
of
Labor
without
(“DOL”)
of the client should understand that Baird Equity
Asset Management or Baird may invest for the
client, recommend that the client invest in, or
plan
make
participants, affiliated investment products, that
Baird and its affiliates will receive fees or other
compensation related to such investments, and
that they will retain such compensation to the
extent permitted by applicable law, rule or
limitation,
regulation,
Department
Prohibited
Transaction Exemption (“PTE”) 77-4, DOL PTE
2020-02 or other advisory opinions issued by the
DOL.
Baird Equity Asset Management will not take any
action or submit any forms or other applications
for or on behalf of its separately managed
account clients regarding any class action lawsuits
or other legal claims (including notices of claims
against companies in bankruptcy) to which clients
may be entitled to participate. Rather, Baird
Equity Asset Management, if it receives any
written materials related to the foregoing, will
forward to clients or its custodian any written
materials it receives related to the foregoing. At
the client’s specific request, Baird Equity Asset
information and
Management may provide
assistance to the client
in considering and
responding to the materials. Baird Equity Asset
Management does not offer legal or tax advice
regarding clients’ investments, and a proper
assessment or evaluation of the advantages and
disadvantages of participating in class action
lawsuits or of bringing other legal claims (and
filing notices of claims in bankruptcy) require
capable legal counsel.
Other Manager Strategies
With respect to the Other Manager Strategies, a
client may retain the right to vote proxies with
respect to the securities held in the client’s
portfolio, or the client may delegate such right to
the Other Manager. A client may select either
option by making the appropriate election in the
information
client’s advisory agreement. For
about the Other Manager’s voting policies and
procedures, clients should review the Other
Manager’s Brochure.
Financial Information
Baird Equity Asset Management does not require
or solicit prepayment of more than $1,200 in fees
per client six months or more in advance and,
thus, has not included a balance sheet of Baird’s
most recent fiscal year. Neither Baird nor Baird
Equity Asset Management
is aware of any
financial condition that is reasonably likely to
impair their ability to meet their contractual
commitments to clients, nor has either been the
subject of a bankruptcy petition at any time
during the past ten years.
Special Considerations for Retirement
Accounts
If a client’s account is a Retirement Account, each
owner, trustee, responsible plan fiduciary, or
other fiduciary (“Retirement Account Fiduciary”)
To the extent Baird Equity Asset Management,
Baird or their affiliates rely upon PTE 77-4, each
Retirement Account Fiduciary should understand
that when Baird Equity Asset Management or
Baird invests the assets of a Retirement Account
in an affiliated investment product that pays
investment advisory fees to Baird or any of its
affiliates, Baird and its affiliates may receive such
investment advisory fees in accordance with the
terms of DOL PTE 77-4, and, as required thereby,
Baird Equity Asset Management will waive its
advisory fees on that portion of the assets
invested in the affiliated investment product for
such period of time so invested or Baird Equity
Asset Management will offset the investment
advisory fees received by Baird or any of its
affiliates from the affiliated investment product
against the advisory fee that Baird Equity Asset
Management charges to the client. For the
purpose of complying with the terms of DOL PTE
77-4, the client and each Retirement Account
Fiduciary of the client acknowledge in the client’s
investment management agreement that: (i) the
investment in affiliated investment products for
the client’s account is appropriate because of,
investment goals,
among other things, the
redeemability, liquidity, and diversification of
those products; (ii) subject to Baird Equity Asset
Management’s investment strategies, all assets of
the client’s account may be invested in one or
more of the affiliated investment products; (iii)
the client and such Retirement Account Fiduciary
received prospectuses or other offering or
disclosure documents for the affiliated investment
products that may be used in connection with the
account, each of which include a summary of all
fees that may be paid by the affiliated investment
products to Baird or its affiliates; and (iv) the
client received information concerning the nature
and extent of any differential between the rate of
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
its affiliates provides
to
such affiliated investment product fees and the
advisory fees payable by the client to Baird Equity
Asset Management. The differential between the
fees to be charged by Baird Equity Asset
Management for the investment advisory services
it provides to the client and, if applicable, the
investment advisory and other similar fees paid
by the affiliated investment product to Baird or its
affiliates with respect to the services Baird or any
of
the affiliated
investment product is the difference between
Baird Equity Asset Management’s fee disclosed in
the client’s investment management agreement
investment management,
and the applicable
investment advisory and other similar
fees
detailed in the applicable prospectus or other
offering or disclosure documents for the affiliated
investment product.
If the client’s account is a Retirement Account,
the client and each Retirement Account Fiduciary
of the client should note that the client’s
investment management agreement authorizes
Baird, in its capacity as broker-dealer, to effect or
execute securities transactions for the client’s
account and to receive commissions for such
services, subject to DOL PTE 86-128. In order to
assist the client and each Retirement Account
Fiduciary of the client with the determination as
to whether such authorization should be made,
Baird Equity Asset Management will provide the
client with a copy of DOL PTE 86-128 and the
form to be used to terminate such authorization,
as well as the description of Baird’s brokerage
placement practices, which is set forth below.
Baird Equity Asset Management also will provide
such other reasonably available information that
the client may request for such purpose.
Account;
and
the
likelihood of price
transactions, and
the duty
in certain
broker-dealer,
and
terminating
monitoring
a
funds. Baird may place orders
is not
responsible
If the client’s account is a Retirement Account and
if Baird Equity Asset Management is directed to
implement a directed brokerage arrangement for
the account, each Retirement Account Fiduciary of
the client should understand: that the directed
brokerage arrangement must be for the exclusive
benefit of participants and beneficiaries of the
fiduciary
Retirement
responsibilities discussed
in ERISA Technical
Bulletin 86-1. Each Retirement Account Fiduciary
should also understand that such Fiduciary is
solely responsible for complying with all fiduciary
in ERISA Technical
responsibilities discussed
Bulletin 86-1, including, without limitation, the
duty to make an initial determination that the
directed broker-dealer is capable of providing best
execution for the client’s brokerage transactions,
the duty to monitor the services provided by the
directed broker-dealer so as to assure that the
client has received best execution of the client’s
brokerage
to
determine that the commissions paid by the client
and any other fees or costs incurred by the client
are reasonable in relation to the value of the
brokerage and other services received by the
client. The client and each Retirement Account
Fiduciary of the client should also understand that
the client and the client’s Retirement Account
Fiduciaries are solely responsible for engaging a
its
directed
directed
performance
brokerage arrangement, and that Baird Equity
Asset Management
for
determining whether a directed broker-dealer is
capable of providing best execution.
When placing orders for securities transactions for
clients as a broker-dealer pursuant to DOL PTE
86-128, Baird has an obligation to use reasonable
diligence to ascertain the best market for the
subject security and to buy or sell in such market
so that the resultant price to the client is as
favorable as possible under prevailing market
conditions. Baird routes or places client orders to
various market makers, exchanges and other
execution venues based on their quality of
execution and execution capabilities in order to
obtain the best possible price and speed of
execution
for clients. Baird selects market
makers, exchanges and other execution venues
based on the size of the order, the trading
characteristics of the particular security, speed of
execution,
improvement,
availability of efficient automated transaction
processing, guaranteed automatic execution level
factors. Order routing
and other qualitative
decisions are not based on the availability of
payment for order flow or other remuneration,
although Baird receives payments for order flow
or other remuneration
instances.
Additional information about Baird’s routing of
equity orders is available on Baird’s website at
bairdwealth.com/retailinvestor. Baird does not
place orders with market makers or other third
parties for the purpose of compensating such
firms for their efforts in marketing Baird-affiliated
mutual
for
securities transactions with third party broker-
dealers and other firms that provide research
products and services to Baird.
49
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Additional Brochure: BAIRD FINANCIAL PLANNING SERVICES (2026-03-27)
View Document Text
Baird Private Wealth Management
Brochure
March 27, 2026
Financial Planning Services
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue
Milwaukee, WI 53202
1-800-792-2473
rwbaird.com
Member FINRA & SIPC
SEC File No. 801-7571
This brochure (“Brochure”) provides information about the qualifications and business practices of
Robert W. Baird & Co. Incorporated (“Baird”) and its Private Wealth Management Department’s
Financial Planning Services. Clients should carefully consider this information before becoming a client
of Baird. If you have any questions about the contents of this Brochure, please contact us at the toll-
free phone number listed above. The information contained in this Brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities authority.
Additional information about Baird is available on the SEC’s website at www.adviserinfo.sec.gov.
Material Changes
Robert W. Baird & Co. Incorporated (“Baird”) updated the Form ADV Part 2A brochure for its Private Wealth Management
Department’s Financial Planning Services (the “Brochure”) on March 27, 2026. The following summary discusses the
material changes that Baird has made to the Brochure since March 21, 2025, the date of the last annual update to the
Brochure.
• In January 2026, Baird’s direct parent corporation, Baird Financial Corporation (“BFC”), made a significant minority
investment in Reinhart Partners, LLC (“Reinhart”), an investment advisor that offers investment products and
services. As a result of the investment transaction, Baird and Reinhart are affiliated, providing Baird a financial
incentive to recommend Reinhart investment products and services.
• In September 2025, Baird entered into a strategic partnership with Sagard Holdings Management, Inc. (“Sagard”).
Baird’s direct parent corporation, BFC, acquired a minority ownership interest in Sagard and the right to appoint a
member to Sagard’s board of directors. Baird agreed to use best efforts, consistent with its fiduciary duties and other
regulatory responsibilities, to offer investment products managed or sponsored by affiliates of Sagard deemed
suitable by Baird for its PWM clients, providing Baird a financial incentive to recommend such investment products.
• Baird updated information about Baird’s regulatory assets under management. See the Section of the Brochure
entitled “Advisory Business—Robert W. Baird & Co. Incorporated” for more information.
• Baird updated its disclosures about the research, information and tools used by Baird PWM home office investment
professionals and Baird Financial Advisors when formulating investment advice, which may include the use of artificial
intelligence (“AI”) tools, and the related risks. See the Section of the Brochure entitled “Methods of Analysis,
Investment Strategies and Risk of Loss” for more information.
• In March 2026, Baird entered into an Offer of Settlement with the Massachusetts Securities Division to settle a
regulatory matter relating to the timing of state investment adviser representative registration approvals for two of
Baird’s Financial Advisors located in Massachusetts. The Division alleged that, for a limited period in early 2025, the
two individuals provided investment advisory services before their Massachusetts registrations were completed as a
form was missing from their application materials. 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.
• Baird updated information about firms, affiliated with, related to, or otherwise associated with Baird. See the Section
of the Brochure entitled “Other Financial Industry Activities and Affiliations” and Appendix A to the Brochure for more
information.
A client should note that the foregoing summary only discusses material changes made to the Brochure since March 21,
2025. The updated Brochure contains changes that are not listed above.
ii
Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Table of Contents
Advisory Business .......................................................................................................... 1
Robert W. Baird & Co. Incorporated .............................................................................. 1
The Client-Baird Fiduciary Relationship .......................................................................... 1
Description of Services ................................................................................................ 2
Additional Service Information ...................................................................................... 4
Fees and Compensation ................................................................................................. 5
Advisory Fees ............................................................................................................. 5
Other Fees and Expenses ............................................................................................. 8
Other Compensation Received by Baird ......................................................................... 8
Performance-Based Fees and Side-By-Side Management ............................................... 8
Types of Clients .............................................................................................................. 8
Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 8
Disciplinary Information ................................................................................................ 9
Other Financial Industry Activities and Affiliations ...................................................... 11
Baird’s Broker-Dealer Activities ................................................................................... 11
Certain Relationships and Arrangements ...................................................................... 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading...................................................................................................... 12
Code of Ethics .......................................................................................................... 12
Participation or Interest in Client Transactions .............................................................. 13
Brokerage Practices ..................................................................................................... 14
Review of Accounts ...................................................................................................... 15
Client Referrals and Other Compensation ..................................................................... 15
Custody ........................................................................................................................ 15
Investment Discretion .................................................................................................. 15
Voting Client Securities ................................................................................................ 15
Financial Information ................................................................................................... 15
Associated Investment Products and Services ............................................ Appendix A-1
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the Private Wealth Management
its services separately or
planning; investment policy development; and account
performance monitoring. Baird also offers clients
execution of brokerage transactions and administrative
services, including maintaining custody of account
assets. Clients may also negotiate other services with
Baird. Baird offers
in
combination with other services.
Baird participates in wrap fee programs, including
programs not described in this Brochure and it provides
portfolio management services in connection with those
programs. Baird receives a portion of the wrap fee paid
by clients for providing portfolio management services
under those wrap fee programs.
billion
in
regulatory
assets
As of December 31, 2025, Baird had approximately
$394.0688
under
management, approximately $289.4898 billion of which
was managed on a discretionary basis and approximately
$104.5790 billion of which was managed on a non-
discretionary basis.
amended
(“IRC”)
(collectively,
Advisory Business
This Brochure describes the Wealth Planning Services
that
(“PWM”)
Department of Robert W. Baird & Co. Incorporated
(“Baird”) offers to its clients. Separate brochures describe
those other investment advisory services and discuss the
terms and conditions, fees and costs and potential
conflicts of interest associated with those services. This
Brochure also references other documents that contain
additional important information about Baird. Those
documents describe the types of investment products and
services that Baird makes available to clients, including
the terms, conditions, fees, costs, risks, and conflicts of
interest applicable to those investment products and
services. Those documents are available on Baird’s
website at bairdwealth.com/retailinvestor. Included on
that website is Baird’s Client Relationship Booklet, which
contains Baird’s Form CRS Client Relationship Summary
and Baird’s Client Relationship Details document. The
Client Relationship Booklet also contains an important
disclosure document for retirement investors that have
retirement accounts, which include employee pension
benefit plan accounts that are subject to the Employee
Retirement Income Security Act of 1974, as amended
(“ERISA”) and individual retirement accounts (“IRAs”)
that are subject to the Internal Revenue Code of 1986,
as
“Retirement
Accounts”). A client of Baird should have already received
a copy of the Client Relationship Booklet. A client or
prospective client who wishes to obtain a brochure for
another investment advisory service provided by Baird,
or a paper copy of any of the other documents referenced
in this Brochure, including the Client Relationship
Booklet, should contact a Baird Financial Advisor or call
Baird toll-free at 1-800-792-2473.
The information contained in this Brochure is current as
of the date above and is subject to change at Baird’s
discretion. Please retain this Brochure for your records.
information
is privately-held,
Robert W. Baird & Co. Incorporated
Baird
employee-owned global
investment and wealth management firm formed in the
State of Wisconsin in 1919.
Baird is owned indirectly by its associates through several
holding companies. Baird is owned directly by Baird
Financial Corporation (“BFC”). BFC is, in turn, owned by
Baird Financial Group, Inc. (“BFG”), which is the ultimate
parent company of Baird. Associates of Baird own
substantially all of the outstanding stock of BFG.
The Client-Baird Fiduciary Relationship
Baird is registered with the Securities and Exchange
Commission (“SEC”) as an investment adviser under the
Investment Advisers Act of 1940, as amended (the
“Advisers Act”). Baird and its associates are deemed to
have a fiduciary relationship with a client when providing
the investment advisory services that are described in
this Brochure. That means that Baird and its associates
are required to act in the best interest of the client when
providing investment advisory services. From time to
time, Baird or its associates may engage in certain
business practices or may receive compensation or other
benefits that create a potential for conflict between the
interests of clients and the interests of Baird or its
associates. Baird generally addresses potential conflicts
of interest by disclosing them to clients through
documents provided to clients,
including, without
limitation, this Brochure, Brochure supplements that
contain
individuals providing
about
investment advice to clients and the services they
provide, and the agreements clients enter into with Baird.
In addition, Baird has adopted internal policies and
procedures for Baird and its associates that require them
to: provide investment advice that is suitable for advisory
clients (based upon the information provided by such
clients); make full disclosure of all potential, material
conflicts of interest; and act with utmost care and good
faith in dealings with advisory clients. The specific
business practices that create potential conflicts of
interest with clients and additional measures used by
Baird to address them are discussed in other sections of
this Brochure.
A client should note that registration as an investment
adviser does not imply a certain level of skill or training.
strategies;
research,
analysis
Baird offers various investment advisory services to
clients, including services not described in this Brochure.
The investment advisory services Baird offers include:
portfolio management and analysis; analysis and
regarding asset allocation and
recommendations
investment
and
recommendations regarding investment managers and
individual securities; investment consulting; wealth
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Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
recommends an asset allocation and/or broad categories
of investment alternatives designed to achieve Client’s
goals. Recommended investment categories may include
one or more of the following categories of assets:
Description of Services
Baird offers the services described in this Brochure (the
“Services”) through its Financial Advisors and certain of
its home office professionals in its Financial & Estate
Planning Department (the “Department”). Baird Financial
Advisors and its home office professionals tailor their
advisory services to the individual needs of clients.
• the equity securities asset category, which is comprised
of certain asset classes, such as, equity securities
issued by: U.S. large cap growth companies; U.S. large
cap value companies; U.S. large cap core companies;
U.S. mid cap growth companies; U.S. mid cap value
companies; U.S. mid cap core companies; U.S. small
cap growth companies; U.S. small cap value
companies; U.S. small cap core companies; foreign
companies located in developed markets; foreign
companies located in emerging markets; U.S. real
estate investment trusts (‘REITs”); and foreign REITs;
The Services are non-discretionary in nature and a client
retains full discretionary authority to manage the client’s
assets. The Services may be provided on an individual,
one-time basis (“Individual Planning Services”) or may be
provided on an ongoing basis (“Ongoing Planning
Services”), depending upon the selection made by the
client. Certain Baird Financial Advisors may also provide
financial analyses and related
financial consulting
services in connection with a divorce.
A client will enter into a wealth planning agreement (an
“Agreement”) with Baird, which will identify the specific
Services being provided, the advisory fee (“Advisory
Fee”) payable by the client and other terms applicable to
the client’s relationship with Baird.
• the fixed income securities asset category, which is
comprised of certain asset classes, such as: short-term
taxable bonds; intermediate term taxable bonds; long-
term taxable bonds; short-term tax-exempt bonds;
intermediate term tax-exempt bonds; long-term tax-
exempt bonds; high yield fixed income securities;
foreign fixed income securities; and broad fixed income
securities;
In certain instances, particularly if a client has selected
Ongoing Planning Services, the client will be required to
open an account (an “Account”) to hold assets at Baird
by entering into another, separate account agreement
with Baird, such as the Client Relationship Agreement.
• the non-traditional assets category, which is comprised
of certain asset classes, such as: commodities and
commodity-linked instruments; and currencies and
currency-linked instruments;
Wealth Planning Services
Individual Planning Services
Investment Advisory Services
• the alternative investment products category which is
comprised of certain asset classes, such as: hedge
funds, private equity funds and managed futures; and
• cash.
Baird offers to clients Individual Planning Services,
pursuant to which Baird prepares and delivers to the
client one wealth plan (a “Plan”) each time the client
engages Baird to provide such Services.
Each asset allocation strategy has different allocations
across each asset class, and some strategies may have
no allocation to one or more asset classes described
above.
Additional Individual Planning Services
If the client wishes to obtain Individual Planning Services
from Baird, the client will need to define his or her
financial goals, needs and objectives and gather and
provide relevant information to Baird. A client will
typically complete a wealth planning questionnaire to
help define the client’s financial goals, needs and
objectives and provide relevant information to Baird.
Upon request, a Baird Financial Advisor or other Baird
representative may provide assistance with
the
questionnaire.
In addition to the Individual Planning Services described
above, Baird and a client’s Baird Financial Advisor offer
certain additional Individual Planning Services for which
they do not act as an investment advisor or a fiduciary.
These services may include the following.
Estate Plan Analysis
Based upon information provided by the client and client’s
legal advisors, the Department may analyze the client’s
estate plan including an analysis designed to provide
information on possible gift and estate tax consequences
for the client related to the transfer of assets during his
or her lifetime or at death. This estate plan analysis may
provide guidance regarding advanced estate planning
techniques specific to high-net-worth families.
Based upon the responses to the questionnaire and other
information provided by the client, the client’s Baird
Financial Advisor and/or the Department will prepare a
Plan for the client. The contents of a Plan depend upon
the particular needs and requests of the client. A Plan
generally evaluates the client’s retirement, life insurance,
education funding, estate and/or other cash flow needs
and provides recommendations and strategies
for
meeting those needs. The Plan generally includes an
analysis of the client’s investment needs and goals and
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Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Insurance Needs Analysis
evaluation of the Plan and whether the client should
engage Baird to update the Plan.
Ongoing Planning Services
Based upon information provided by the client, Baird may
provide an insurance needs analysis. The analysis will
assess potential client needs for various insurance
coverages, including life insurance, long-term care
insurance and disability insurance. It may also provide
information about the costs of obtaining insurance
coverage.
Tax Planning Analysis
In addition to the services available in the Individual
Planning Services described above, Baird also offers
Ongoing Planning Services. The Ongoing Planning
Services made available to clients may include: a
discovery process, general wealth planning and budget
review, preparation and delivery of a Plan described more
fully above (which may include reviewing and updating a
Plan), goal setting and action planning (which may
include goals and strategies for debt reduction or savings
for education or other funding needs), goal progress
meetings, investment and asset allocation review and
retirement funding review.
A client’s Agreement will set forth the specific Services to
be provided. Generally, each Service selected by a client
will be provided once annually unless the client’s
Agreement provides otherwise.
Divorce Financial Analyst and Consulting Services
Based upon tax return and other information provided by
the client or a client’s tax advisors, Baird may provide a
tax planning analysis. The analysis may offer planning
considerations and/or illustrate the tax consequences for
the client of various
transactions and planning
techniques. Scenarios can be shown for a single year, or
multiple years
into the future. The offering and
performance of tax planning services does not constitute
tax advice. Tax planning services are provided solely
based upon the direction and information provided by a
client. Before obtaining a tax planning service or taking
action based upon that service, a client should consult the
client’s tax advisors about the tax consequences of doing
so.
Important Individual Planning Services Information
forth recommended actions
insurance
in
The Plan will set
furtherance of the client’s goals, needs and objectives. In
developing a client’s Plan, Baird does not assume or
undertake any responsibility for implementing the
recommended actions or for monitoring the actions taken
by the client unless Baird has otherwise agreed to do so
in writing.
credits
and
reimbursements,
A Baird Financial Advisor may assist the client in
implementing the Plan under a separate arrangement;
however, the client is not obligated to implement the Plan
through Baird. Clients may utilize a financial advisor of
their choice and may choose to implement only a portion
of the recommendations included in the Plan.
A Baird Financial Advisor may be engaged by a client (or
the client’s attorney) to provide financial analyses and
related financial consulting services in connection with a
divorce. These services are provided upon request and
may include: gathering of financial details relevant to the
divorce, assessment of marital/community and separate
property,
financial
income and expense analysis,
modeling, cash flow forecasts, examination of retirement
and
issues, property division analysis,
preparation of asset inventories and financial settlement
scenarios, present value calculations, and tracing of
financial statements to help categorize flow of funds or
potential
and
communications with the client’s attorneys and tax
advisers. Under certain limited circumstances approved
by Baird’s home office, a Baird Financial Advisor may also
provide testimony and reports in the divorce proceeding
as to the analytical services provided. Baird may provide
its analyses and reports to a client’s attorneys and, with
the consent of the client or the client’s attorney, as
required by law or in order to provide the services
requested by the client, to the client’s tax adviser and
other client representatives as well as
insurance
companies, mediators, judges, opposing parties and
other third parties.
A client selecting Individual Planning Services should note
that Baird only prepares and delivers one Plan to the
client, Baird’s engagement and the Agreement to provide
Individual Planning Services ends once the Plan is
delivered to the client. After a client has received the
Plan, Baird undertakes no obligation to implement the
actions recommended in the Plan, to review or monitor a
client’s investments, other assets, financial position or
returns, or to update or modify the Plan, unless the client
enters into another Agreement with Baird.
the analyses,
The divorce financial analyses and related consulting
services Baird provides are based on information
provided by the client and third parties (including without
limitation the client’s attorneys and tax advisers,
forensic accountants,
opposing parties, mediators,
actuaries, pension valuators, insurance companies and
others). Baird relies on the accuracy and completeness of
the information provided to it without independent
verification. Baird does not take responsibility for any
losses resulting from incorrect or incomplete information
A Plan is effective as of the date indicated thereon. Any
changes to a client’s financial and personal position and
needs will affect
information and
recommendations made in a Plan. Financial planning is
an ongoing process and a client should regularly consider
whether financial and personal changes warrant a re-
3
Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird receives from the client, the client’s advisers or
third parties.
individuals
Baird’s analyses and reports are effective as of the dates
indicated thereon or, if not so indicated, on the dates they
are delivered to the client or the client’s attorney. After
providing the analyses and other services requested,
Baird undertakes no obligation to review or update them.
The Services provided by Baird may also include limited
consultations with the other professionals assisting the
client, such as the client’s attorney or tax adviser. More
comprehensive wealth planning services may involve the
Baird Financial Advisor, working either independently or
with
from other Baird departments,
considering more complex issues in wealth planning and
reviewing estate planning strategies. A client’s other
professional advisers often play an integral role in the
Services.
questionnaire
and
If a client desires to engage Baird to provide additional
services, either at the time Baird is providing divorce
financial analyst and related consulting services or after
such services have been provided, the client will be
required to enter into a separate agreement with Baird
describing those additional services.
Additional Service Information
In preparing a Plan for a client or providing other
Services, Baird relies on the accuracy and completeness
of the information that the client provides in the wealth
otherwise, without
planning
independent verification. Baird is not responsible for any
inadequacies or errors contained in the Plan or other
advice provided in connection with the Services that
result from a client’s failure to provide Baird with accurate
or complete information.
implementation of
include
Baird’s advisory relationship with the client terminates
automatically upon the cessation of Services, which
occurs when Baird delivers a Plan to the client, unless
Baird has agreed in writing to provide Ongoing Planning
Services, in which event the advisory relationship
terminates upon termination of the client’s Agreement.
A client should note that the Services do not include the
analysis or recommendation of specific securities or other
investments or the
investment
strategies, although those services may be provided by
Baird and/or a Baird Financial Advisor under a separate
agreement with Baird. The Services only offer a client a
recommendation as to the allocation of the client’s
investment portfolio among various asset classes
generally, which may
recommendations
regarding allocations to complex investment products or
alternative investment asset classes.
rates,
rates of
return,
A client or prospective client may, but is not required to,
enter into a separate relationship with Baird to implement
the Plan or other recommendations made by Baird. In
some cases, the client may already have a separate
brokerage or advisory relationship with Baird while the
wealth planning Services are being provided to the client,
and the termination of wealth planning Services will not
affect that pre-existing relationship. When a client enters
into a separate relationship with Baird following the
cessation of wealth planning Services, that relationship
would generally be brokerage in nature and not advisory
unless the client or prospective client and Baird
separately agree to enter into an investment advisory
contract.
The Services are based upon certain hypothetical
assumptions about future events. Some of these
hypothetical assumptions include, without limitation,
hypothetical assumptions about future: rates of inflation,
levels of asset
interest
appreciation, dividend rates, growth rates, a client’s
income and expenditure amounts, and a client’s taxes,
tax rates, and tax filing status. These hypothetical
assumptions vary by client and market and other
conditions existing at the time the Services are provided.
For more specific information about the particular
hypothetical assumptions made when providing the
Services, a client should refer to the written Plan or other
documentation provided to the client or ask the client’s
Baird Financial Advisor.
If a client engages Baird to provide brokerage or advisory
services in addition to the preparation of a Plan or
provision of Services, Baird will earn additional
compensation in the form of fees and/or commissions.
Thus, any recommendation to use Baird to implement the
Plan or other recommendations made pursuant to the
Services presents a conflict of interest.
Additional Service Information
Custody Services
The Services will typically also reflect Baird’s and/or the
client’s Baird Financial Advisor’s analysis of different
asset classes and the different levels of risk associated
with each asset class. That analysis typically involves the
consideration of past performance of an asset class and
the use of forward-looking projections that are based
upon certain assumptions about how markets will
perform in the future.
Baird may provide custody services in connection with the
Services pursuant to a separate agreement between
Baird and the client. See “Custody” below for more
specific information.
Baird and a client’s Financial Advisor may use other third
parties to assist in the preparation of a Plan or provision
of Services, such as the use of third party planning
software and research providers. Baird will not separately
charge a client for use of these other entities except with
a client’s consent.
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Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Trust Services Arrangements
significant health
issue, or
change
objectives,
risk
tolerance,
that
trust administration services
of any significant life changes (e.g., change in marital
status,
in
employment) or if there is any change to the client’s
financial
investment
circumstances, investment needs, or other circumstances
that may affect the manner in which the client’s assets
are invested. Neither Baird nor the client’s Baird Financial
Advisor is responsible for any adverse consequence
arising out of the client’s failure to promptly inform the
client’s Baird Financial Advisor of any such changes. Since
investment goals and financial circumstances change
over time, a client should review the client’s participation
in a Service with the client’s Baird Financial Advisor at
least annually.
Legal and Tax Considerations
Baird and its associates will not provide any legal or tax
advice to a client as part of the Services and no advice
provided by Baird or any of its associates shall be deemed
to be legal or tax advice. A client is urged to consult with
the client’s personal legal and accounting professionals
regarding any Plan or other wealth planning Services
provided by Baird.
If a client obtains an estate plan analysis, the client is
urged to consult with the client’s personal legal and
accounting professionals to determine appropriate estate
planning strategies and to prepare any necessary
documents required to implement an estate plan.
Baird maintains an alliance with certain institutions, both
including Baird Trust
non-affiliated and affiliated,
trust
provide
Trust”),
(“Baird
Company
administration services, including custody, tax reporting
and recordkeeping. Baird Financial Advisors at times refer
clients seeking
to
institutions that are members of the alliance. Subject to
its fiduciary duties, the trustee oftentimes retains Baird
to provide investment advisory services to the client
trust. A client should understand that any such referral
for trust services under the Trust Alliance Program made
by Baird and its Financial Advisors is an ancillary account
service and it is not an, nor is it part of any, Advisory
Program or investment advisory service. They do not act
as investment adviser or a fiduciary to the client when
making such a referral and they will not provide advice
on or oversee any such trust services arrangement. Baird
has a financial incentive to recommend that clients use
Baird Trust, an affiliate, over other non-affiliated trust
companies. As a result of this affiliation, Baird Trust also
has a financial incentive to retain Baird to provide
investment advisory or other services on behalf of the
client. In addition, Baird and Baird Financial Advisors
have a financial incentive to recommend arrangements
that involve Baird and the Baird Financial Advisor
providing investment advisory services to the client and
the trust company only providing trust administration
services compared to an arrangement whereby a trust
company would provide both investment advisory and
trust administration services because it is more profitable
to Baird and the Baird Financial Advisor.
If a client obtains financial analyses or related financial
consulting services in connection with a divorce, the client
should understand that Baird does not provide legal or
tax advice even though Baird’s services are provided in
connection with a divorce or related legal process. Clients
are encouraged at all times to obtain legal and tax
services from licensed professionals. Baird is not
responsible for judgments, settlements, consent decrees,
awards or other decisions relating to a client’s divorce,
the division of assets or support payments. Those
matters are the responsibility of the client and the client’s
legal professionals.
In addition, outside of the Trust Alliance Program, Baird
Financial Advisors may refer a client to Baird Trust to
provide investment advisory and trust administration
services to the client. If a client enters into such a
relationship with Baird Trust, Baird and the client’s Baird
Financial Advisor typically provide ongoing relationship
management services. Baird Trust generally provides
compensation to Baird and the client’s Baird Financial
Advisor for the referral and providing ongoing services,
which may be up to 50% of the ongoing fees that a client
pays to Baird Trust, and which is credited to the client’s
Baird Financial Advisor for purposes of determining the
Financial Advisor’s compensation. The compensation paid
to Baird and a client’s Baird Financial Advisor does not
increase the fees that the client pays to Baird Trust. Due
to Baird’s affiliation with Baird Trust and
the
compensation paid to Baird and Baird Financial Advisors,
Baird and Baird Financial Advisors have a financial
incentive to favor Baird Trust over other trust companies.
Additional laws, regulations and other conditions apply to
Retirement Accounts. Each owner, trustee, named
fiduciary, responsible plan fiduciary, or other fiduciary
acting on behalf of a Retirement Account (“Retirement
Account Fiduciary”) should understand that Baird and its
associates do not provide
legal advice regarding
Retirement Accounts. A Retirement Account Fiduciary is
urged to consult with his or her own legal advisor about
the laws and regulations that may apply to Retirement
Accounts.
Client Responsibilities
Fees and Compensation
Advisory Fees
Wealth Planning
Plans and other Services are provided for a fee. The fees
for the Services are negotiated between the Baird
A client is responsible for providing information to Baird
and the client’s Baird Financial Advisor reasonably
requested by them in order to provide the services
selected by the client. Baird and the client’s Baird
Financial Advisor will rely on this information when
providing services to the client. A client is also responsible
for promptly informing the client’s Baird Financial Advisor
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Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
client an invoice for the fees and charges (“direct billing”).
A client’s Agreement will set for the specific fee amount
and terms of payment.
Divorce Financial Analytical Services
the client and Baird agree
Financial Advisor and the client. Generally, the fees are
based upon the specific Services provided by Baird to the
client. A wide range of Services are available, and the
client selects the combination of Services that best fits
his or her goals and objectives. The fees for the Services
vary based upon a number of factors, including the
complexity of the client’s Plan, if any, the other Services
to be provided, if any, and the frequency and level of
interaction that the client’s Baird Financial Advisor has
with the client’s other professional consultants, including,
among others, Certified Public Accountants (“CPAs”),
trust department personnel, and legal professionals. Fees
may vary from client to client based on a number of
factors, including, but not limited to, the factors described
above. Baird may waive all fees for Services in its sole
discretion.
Baird Financial Advisors who have been approved by
Baird may also provide financial, analytical and related
consulting services to clients in connection with a divorce
for a flat fee or at an hourly rate, or a combination
thereof. The flat fee or hourly rate is negotiated between
the Baird Financial Advisor and the client. The fee or
hourly rate is reflected in the agreement signed by the
client. The fee or hourly rate will be reflected in an invoice
sent to the client and paid within 30 days by the client
(unless
to another
arrangement, such as debiting the amount from the
client’s account at Baird).
The flat fee will normally be paid in whole or in part in
advance by the client, as reflected in the agreement
signed by the client. If reflected in the agreement signed
by the client, a flat fee may be imposed for each service
provided. If agreed to by Baird, the flat fee may be paid
upon completion of the services provided by Baird or on
an installment basis. The flat fee will be subject to a
minimum of $500 unless Baird and the client negotiate a
different minimum amount, to be reflected in the client’s
agreement.
incur additional charges
for
The Advisory Fee the client pays to Baird for the Services
and how it is to be paid will be set forth in the Agreement.
The Services related to a Plan are typically provided
under a flat fee arrangement, although hourly fee
arrangements may also be available. Currently, the flat
fee for preparing a Plan and providing related wealth
planning services generally ranges from $500 to $10,000,
but may be higher depending upon the particular Services
requested and complexity of the Plan. The flat fee is
generally paid in full following delivery of the Plan to the
client. For clients paying an hourly rate, Baird may
require a retainer (in an amount agreed to by the client)
against which the hourly rate and out of pocket expenses
will be applied. Following delivery of a Plan, clients will
generally
follow-up
consultations at a rate agreed to by the client and the
Baird Financial Advisor.
flat
The Ongoing Planning Services are typically provided
under a
fee arrangement, although other
arrangements may be available in certain circumstances.
The flat fee for Ongoing Planning Services generally
ranges from $125 to $10,000 annually, but may be
higher depending upon the particular Services requested.
The Ongoing Planning Services are typically billed and
paid quarterly out of an Account held by the client at
Baird.
The client may also negotiate fees based upon the
number hours it takes to complete a Plan. The hourly rate
is negotiated by each individual client and the rate varies
widely, depending upon the complexity of the Plan and
the persons providing the services.
As an alternative to the flat fee, or in addition to the flat
fee, Baird may provide services at an hourly rate. The
hourly rate will be reflected in the agreement signed by
the client. The hourly rate may vary depending on the
nature of the service provided. Normally, the hourly rate
will be higher for any testimony, analyses and reports
that Baird provides in the divorce proceeding. For clients
paying an hourly rate, Baird may require a retainer (in an
amount agreed to by the client) against which the hourly
rate and out of pocket expenses will be applied. Baird will
generally keep track of the time spent on the services
provided in 0.25 hour increments, and provide an invoice
each month showing the amount of time spent on the
services provided and if, applicable, the amounts charged
against the retainer and the remaining retainer balance.
If the retainer amount is exhausted, Baird may require
that an additional retainer be provided to cover the cost
of anticipated additional services. Any part of the retainer
that is not used shall be promptly refunded following
completion of the services provided or earlier termination
of the relationship; provided, however, a minimum fee of
$500 will be charged in all cases.
There is no fee for an initial consultation. Clients are not
obligated to use any other Baird service to receive an
initial consultation.
Since Baird began providing these Services, it has had
other fee ranges and schedules in effect, which may
provide fees lower or higher, as the case may be, than
those described above. As new fees are put into effect,
they are made applicable only to new clients, and fees for
existing clients are not affected. Therefore, some clients
may pay different fees than those shown above.
For Services related to a Plan, fees are generally payable
as Services are rendered. Fees associated with Ongoing
Planning Services are generally paid quarterly
in
advance. Baird’s fees and other charges relating to the
Services may be automatically deducted from a client’s
Baird account or the client may instruct Baird to issue the
6
Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
There is no minimum dollar value of assets or other
conditions required of a client to receive the Services.
from Baird and
Baird may waive any applicable minimum fee on a
temporary or indefinite basis or negotiate a fee level
different from the schedule described above or set a
different payment schedule.
Advisory Fee Payments to Baird and Baird
Financial Advisors
Baird and its associates benefit from the Advisory Fees
and charges clients pay for the services described in this
Brochure.
Baird retains the entire Advisory Fee paid by clients.
provided under the headings “Additional Information—
Other Financial Industry Activities and Affiliations” and
“Additional Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal Trading—
Participation or Interest in Client Transactions” below.
They also generally receive non-cash compensation and
other benefits
from sponsors of
investment products with which Baird does business.
Such non-cash compensation and other benefits may
include invitations to attend conferences or educational
seminars, payment of related travel, lodging and meal
expenses, reimbursement for branch and client events,
and receipt of gifts and entertainment. Receipt of such
compensation and benefits provides Baird Financial
Advisors an incentive to favor investment products and
their sponsors that provide the greatest levels of
compensation and benefits.
conferences,
business
A Baird Financial Advisor is primarily compensated on a
monthly basis based upon a percentage of the Financial
Advisor’s total production each month, which primarily
consists of the total advisory fees and transaction-based
fees paid to Baird by the Financial Advisor’s clients and
any other fees Baird earns on advisory and brokerage
accounts held by those clients, including trail fees paid by
third parties. The percentage of the Financial Advisor’s
total production actually paid to the Financial Advisor will
increase as the total amount of the Financial Advisor’s
production increases, meaning that, as the total amount
of the Financial Advisor’s production increases, the rate
and amount of compensation that Baird pays to the
Financial Advisor also increase. Baird Financial Advisors
generally also receive deferred compensation or bonuses
based on various criteria, including net new assets they
gather, performing
certain wealth management
activities, such as wealth planning, and their total
production levels. Baird Financial Advisors who achieve
certain production thresholds are eligible for professional
development
development
coaching, reimbursements, awards and recognition trips
to attractive destinations. Baird Financial Advisors are
also eligible for bonuses for achievement of professional
designations depending on a Financial Advisor’s total
production level. Thus, Baird Financial Advisors have a
general incentive to generate financial and other plans
and charge higher fees for advisory accounts and
recommend larger investments in advisory accounts.
Baird Financial Advisors generally receive recruitment
bonuses and/or special compensation from Baird when
they join Baird from another firm. The amount of such
special compensation is typically based on the Baird
Financial Advisor’s production at the prior firm for the 1-
year period prior to joining Baird or on the level of the
Financial Advisor’s client assets at the prior firm. All or a
substantial portion of the special compensation is paid in
the form of an upfront bonus when the Baird Financial
Advisor joins Baird, and the remaining portion, if any, is
paid in the form of back-end bonuses generally in equal
installments on an annual basis thereafter for a certain
number of years (generally from one to three years).
Installment payments are generally contingent upon the
Baird Financial Advisor achieving annual production or
client asset levels that exceed a significant percentage of
the Financial Advisor’s annual production for the 1-year
period prior to joining Baird or the client assets that the
Financial Advisor had prior to joining Baird. The special
compensation is intended to compensate Baird Financial
Advisors for the significant effort involved in transitioning
their business from the prior firm. This compensation
provides Baird Financial Advisors who have left another
firm additional incentive to recommend that clients of the
prior firm become Baird clients and to recommend
investment products and services that increase their
production and thus presents a conflict of interest. The
special compensation is generally structured in the form
of a forgivable loan from Baird to the Baird Financial
Advisor. Under the terms of the forgivable loan, Baird
makes the upfront or installment payment to the Baird
Financial Advisor in the form of a loan, and Baird forgives
a portion of the loan made to the Baird Financial Advisor
each month for so long as the Baird Financial Advisor
remains Baird’s employee. Should the Baird Financial
Advisor cease to be Baird’s employee prior to the
maturity date of the loan, the Baird Financial Advisor is
required to repay Baird the amount of the loan
outstanding and not forgiven by Baird. In other words,
upon leaving Baird, the Baird Financial Advisor would be
required to repay to Baird a portion of the special
compensation that the Baird Financial Advisor had
received and that had not been forgiven. The amount of
Given the structure of their compensation, they also have
an incentive to recommend that a client transfer the
client’s accounts to Baird, establish new accounts with
Baird (including IRA rollovers) and add more money into
the client’s accounts. In addition, most Baird Financial
Advisors are shareholders of Baird Financial Group, Inc.
(“BFG”), Baird’s parent company, and thus benefit
financially from Baird’s overall success. The number of
shares of BFG stock that a Financial Advisor may
purchase is based in part on the Financial Advisor’s total
production level. Baird Financial Advisors generally
receive compensation for referrals to certain affiliated
managers and products and for referrals to a limited
number of other firms. More specific information is
7
Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment product in connection with providing the
Services. A client has the option to purchase investment
products through brokers or agents that are not affiliated
with Baird.
and
performance-based
fee
fee arrangements
involve
such repayment declines over time in proportion to the
time the Baird Financial Advisor remains Baird’s
employee. Structuring this special compensation in the
form of forgivable loans provides the Baird Financial
Advisor added incentive to remain Baird’s employee and
to recommend that persons become and remain a Baird
client. Additional information about referral and non-cash
compensation and other financial incentives provided to
Baird Financial Advisors is provided under the heading
“Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading—Participation or
Interest in Client Transactions” below.
Performance-Based Fees and Side-By-Side
Management
Baird advises client accounts not participating in Services
described in this Brochure that are subject to asset-based
arrangements.
fee
Performance-based
the
payment of fees based upon the capital gains or capital
appreciation of a client’s account. However, Baird does
not offer these fee arrangements for wealth planning
services. If a client participates in other services provided
by Baird, the client should review the Form ADV Part 2A
Brochure for those services for more information about
these types of fee arrangements.
Baird addresses the conflicts described above through
disclosure in this Brochure and by adopting internal
policies and procedures for Baird and its associates that
require them to provide investment advice that is suitable
for advisory clients (based upon the information provided
by such clients).
including, but not
Types of Clients
Baird offers the Services to all types of current or
prospective clients,
limited to:
individuals, banks or thrift institutions; pension and profit
sharing plans; trusts; estates; charitable organizations;
and corporations or other business entities.
Other Fees and Expenses
The fees and charges paid to Baird by the client only
cover the preparation and delivery of the Plan, and if
applicable, the performance of the Ongoing Planning
Services. Baird’s fees and charges do not include any
costs or expenses associated with implementing the Plan
or the recommendations made by Baird in connection
with the Services, including, without limitation, fees that
may be charged by investment advisors or managers
advising the client or managing the client’s assets or
other service providers, such as custodians and broker-
dealers.
If a Baird Financial Advisor or other representative of
Baird discusses matters relating to a Plan or the Services
with a client’s tax or legal advisors, the client may be
charged a separate fee by those advisors.
to be generally
Clients may also subscribe to other services or programs
offered by Baird. Those service and programs may be
subject to fees, commissions or other expenses that are
entirely separate from the payment of fees and expenses
for the Service.
Methods of Analysis, Investment Strategies
and Risk of Loss
PWM home office investment professionals, including the
Department and Baird PWM Research Groups, and Baird
Financial Advisors use various third party information and
tools when formulating investment advice. The sources of
information and tools may include, among others,
information provided or created by issuers and their
sponsors (which may include information that is reported
publicly, provided directly to Baird, or reported through
third party platforms) and information and tools provided
by third party research firms, which may include firms
affiliated with Baird. Although Baird has deemed the
information and tools provided by third party research
firms
reliable, Baird does not
independently verify or guarantee the accuracy of the
information or tools used.
Other Compensation Received by Baird
Baird is registered as a broker-dealer under the Securities
Exchange Act of 1934, as amended (the “Exchange Act”),
and its Financial Advisors are registered broker-dealer
representatives of Baird. In such capacities, Baird and its
Financial Advisors provide brokerage and related services
to clients, including the purchase and sale of individual
stocks, bonds, mutual funds, private investment funds,
and other securities, and sales of life insurance policies
and annuities. Baird and its Financial Advisors receive
compensation in connection with such activities, including
asset-based sales charges and service fees on the sale of
mutual funds. However, Baird and its Financial Advisors
only offer asset allocation and similar investment
recommendations of a general nature when providing the
Services, and they do not recommend any particular
Baird PWM home office
investment professionals,
including the Department and Baird PWM Research
Groups, and Baird Financial Advisors may use artificial
intelligence (“AI”) tools, such as machine learning,
predictive analytics and probabilistic modeling tools, data
processing and automation tools, generative AI tools,
visual, speech and audio tools, specialized domain tools,
and other similar technologies and tools (collectively, “AI
Tools”), in formulating advice. Generally, the use of AI
Tools is limited to certain aspects of Baird’s advice
process, such as assisting with drafting of materials,
automation of workflow processes, and the compilation,
reproduction, organization, summarization, analysis and
interpretation of information. The use of AI Tools is only
supportive of Baird’s advice process and does not replace
the professional judgment of Baird PWM home office
8
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
inform
recommendations or
investment professionals or Baird Financial Advisors. All
AI Tool-assisted outputs used in formulating investment
and other advice are subject to human review before such
investment
outputs
decisions.
FINRA that various eligible customers had not received
available sales charge waivers. Baird was found to have
disadvantaged certain retirement plan and charitable
organization customers that were eligible to purchase
Class A shares in certain mutual funds without a front-
end sales charge. The findings also stated that these
customers were instead sold Class A shares with a front-
end sales charge or Class B or C shares with higher
ongoing fees and the potential application of a contingent
deferred sales charge. Baird was censured and required
to pay restitution to affected customers estimated to be
approximately $2.1 million including interest.
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations, deceptive
behaviors and other flaws due to the construction of their
underlying models and the composition of their training
data, which can result in outputs that seem plausible but
are in fact inaccurate, incomplete, or misleading. The use
of AI Tools creates a risk that erroneous information could
negatively influence the advice process. Baird has
established policies and procedures designed to address
the risks posed by AI Tools, which include requirements
that AI Tools pass a firm-level due diligence process and
that Baird associates obtain training and independently
verify AI Tool outputs. However, such measures cannot
eliminate the risks posed by AI.
that was
reasonably designed
involves
In July 2016, Baird, without admitting or denying the
findings, consented to the sanctions and to the entry of
findings of FINRA that the firm and a firm supervisor
within its Private Wealth Management business did not
reasonably supervise a former Financial Advisor who
misused a customer’s funds. The findings stated that the
supervisor did not reasonably follow-up on red flags
associated with a trade correction request submitted by
the Financial Advisor that should have alerted him to the
Financial Advisor's misuse of a customer’s funds. The
supervisor also did not follow certain of Baird’s written
supervisory procedures (“WSPs”) relating to trade
corrections. After the supervisor realized that the
Financial Advisor misused the customer’s funds, Baird
reimbursed the customer for the loss. The findings also
included that Baird did not establish and maintain a
supervisory system, including WSPs, for correcting trade
errors
to ensure
compliance with applicable securities laws, regulations
and rules. Baird was censured and fined $200,000.
Risk is inherent in any investment in securities and Baird
does not guarantee any level of return on a client’s
investments. There is no assurance that a client’s
investment objectives will be achieved if the client
decides to implement a Plan. Baird’s recommendations
are based in part upon its Capital Market Assumptions. In
determining its Capital Market Assumptions, Baird
conducts an analysis of different asset classes and the
different levels of risk associated with those investments.
That analysis
the consideration of past
performance and the use of forward-looking projections
that are based upon certain assumptions made by Baird
about how markets will perform in the future. For more
information about Baird’s Capital Market Assumptions
and any other assumptions used by a client’s Baird
Financial Advisor, a client should contact the client’s Baird
Financial Advisor. There can be no guarantee that
markets will perform in the manner assumed and the
actual performance of markets and a client’s investments
could differ materially from those assumptions. Clients
are encouraged to discuss with their Baird Financial
Advisor the risks that apply to them. A client should also
review the prospectus or other disclosure document for
any security or other investment product in which the
client invests, as it will contain important information
about the risks associated with investing in such security
or other investment product.
In September 2016, the SEC announced that 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
Disciplinary Information
In April 2016, Baird, without admitting or denying the
findings, consented to the sanctions and findings of
FINRA that it violated NASD Conduct Rule 3010, FINRA
Rule 3110, and FINRA Rule 2010, by failing to establish
and maintain a supervisory system and procedures
reasonably designed to ensure that customers who
purchased mutual fund shares received the benefit of
applicable sales charge waivers. In May 2015, Baird
began a review to determine whether Baird had provided
available sales charge waivers to eligible customers.
Based on this review, in May 2015, Baird self-reported to
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Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
procedures. Baird also was ordered to cease and desist
committing or causing any violations and any future
violations of Section 206(4) of the Advisers Act and Rule
206(4)-7 thereunder and pay a civil money penalty in the
amount of $250,000.
minimum commission amount of $100 on 7,277 retail
equity trades and failed to establish and maintain a
supervisory system reasonably designed to prevent
charging a customer a commission that is unreasonable
or unfair in violation of FINRA Rules 3110, 2121, and
2010. Baird also consented to a censure, a fine in the
amount of $150,000, and the payment of restitution of
$266,481 plus interest. The findings related to FINRA’s
routine examination of Baird in 2020. Following that
examination, Baird modified its minimum commission
schedule and supervisory procedures. Baird also took
steps to make payments to the affected customers, which
on average amounted 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.
its
that
certain Baird
In March 2019, Baird, without admitting or denying the
findings, consented to an order of the SEC, which found
that it violated Sections 206(2) and 207 of the Advisers
Act for making inadequate disclosures to advisory clients
about mutual fund share classes. The order was part of a
voluntary self-reporting program initiated by the SEC
called the “Share Class Selection Disclosure (or SCSD)
Initiative.” Under the program, 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 settlement terms imposed by the SEC,
including returning money to affected
investment
advisory clients. The central issue identified by the SEC
was that, in many cases, investment advisory firms
bought for or recommended to their investment advisory
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 advisory clients, and the
investment advisory firms did not adequately disclose
their receipt of 12b-1 fees and/or the conflict of interest
associated with those 12b-1 paying share classes. Baird
and many other firms self-reported under the program
and entered into substantially identical orders. By self-
reporting and consenting to the order, Baird agreed to a
censure and to cease and desist from committing or
causing any violations and future violations of Sections
206(2) and 207 of the Advisers Act. Baird also agreed to
establish a distribution fund and to deposit into that fund
the improperly disclosed 12b-1 fees received by Baird
plus prejudgment interest, which will be paid to affected
advisory clients. More information about the order is
contained in Baird’s Form ADV, which is available on the
SEC’s Investment Advisory Public Disclosure website at
https://www.adviserinfo.sec.gov/IAPD/Default.aspx or in
the SEC’s press release about the SCSD Initiative at
https://www.sec.gov/news/press-release/2019-28.
In June 2019, Baird, without admitting or denying the
findings, consented to the sanctions and to the entry of
findings of FINRA that between late April 2013 and early
July 2013 it published 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 and that the failure to disclose the research
analyst’s employment discussions with the issuer in the
research reports made those reports misleading. Baird
was censured and fined $150,000.
In September 2023, Baird entered into an Offer of
Settlement with the SEC, 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
business-related
associates’
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. While Baird had policies and procedures
in place prohibiting such off-channel communications, it
was discovered
supervisors
communicated off-channel using non-Baird approved
methods on their personal devices about Baird’s broker-
dealer and investment adviser businesses, and the
findings were reported to the SEC. Baird took steps prior
to and after the SEC’s review, including implementing a
new communication tool designed for Baird associates’
personal devices, conducting training, and periodically
requiring requisite associates to provide an attestation
relating to their business-related communications. 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.
In March 2026, Baird entered into an Offer of Settlement
with the Massachusetts Securities Division to settle a
In September 2022, Baird, without admitting or denying
the findings, consented to the entry of findings of FINRA,
which found that it charged certain brokerage customers
an unfair commission when it charged its published
10
Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird Asset Management
located
Baird’s Asset Management business, Baird Advisors,
Baird Equity Asset Management, and Chautauqua Capital
Management (“CCM”), part of Baird Equity Asset
Management, provide investment management services
to institutional clients and Investment Funds. Baird
Financial Advisors who refer clients to Baird Asset
Management are eligible for referral compensation to be
paid by Baird. Baird Financial Advisors, therefore, have a
financial incentive to favor the services provided by Baird
Asset Management over those provided by other
managers.
regulatory matter relating to the timing of state
investment adviser representative registration approvals
for two of Baird’s Financial Advisors
in
Massachusetts. The Division alleged that, for a limited
period in early 2025, the two individuals provided
investment advisory services before their Massachusetts
registrations were completed as a form was missing from
their application materials. 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.
Baird Funds
on
SEC’s
website
Additional information about Baird’s disciplinary history is
available
at
the
www.adviserinfo.sec.gov.
Baird is the investment adviser and principal underwriter
for Baird Funds, Inc. (the “Baird Funds”). Baird Advisors
provides investment management, administrative, and
other services to certain Baird Funds investing primarily
in fixed income securities (the “Baird Bond Funds”). Baird
Equity Asset Management and CCM provide investment
management and other services to certain Baird Funds
investing primarily in equity securities (the “Baird Equity
Funds”), and Greenhouse Funds LLLP, a party related to
Baird, is the investment subadvisor to one of those
Funds, the Baird Equity Opportunity Fund. In certain
instances, Baird Financial Advisors who refer clients to
the Baird Funds are eligible for referral compensation to
be paid by Baird. Due to the amount of referral
compensation, Baird Financial Advisors have a financial
incentive to favor the Baird Equity Funds over the Baird
Bond Funds.
Other Financial Industry Activities and
Affiliations
Baird’s Broker-Dealer Activities
Baird PWM offers brokerage accounts and related
services to its clients. Baird is also engaged in a broad
range of broker-dealer activities through other business
units, including its Global Investment Banking, Fixed
Income Capital Markets (including Baird Public Finance)
and Institutional Equities and Research Departments.
Certain Baird associates and certain management
persons of Baird are registered, or have an application
pending to register, as registered representatives and
associated persons of Baird to the extent necessary or
appropriate to perform their job responsibilities.
Baird Trust
Certain Relationships and Arrangements
Baird and Associated Parties
Baird is affiliated, and may be deemed to be under
common control, with Baird Trust, a Kentucky-chartered
trust company, because both entities are indirectly wholly
owned by BFG. Baird and Baird Financial Advisors receive
compensation from Baird Trust for referring clients and
providing ongoing relationship management services to
clients engaging Baird Trust for trust administration
services.
Baird Capital
Baird is engaged in a global private equity business
through Baird Capital (“Baird Capital”). Baird and Baird
Financial Advisors may refer clients to Baird Capital. Baird
Financial Advisors who assist in obtaining a client’s
investment in a private equity fund offered through Baird
Capital are eligible for referral compensation.
Baird PWM has relationships or arrangements with other
Baird business units and certain other parties affiliated
with, related to, or otherwise associated with Baird
(“Associated Parties”) described below, including referral
programs that pay special compensation to Baird
Financial Advisors
for eligible referrals. Additional
information about those referral programs, including the
amount of the referral compensation, is disclosed on
Baird’s website at bairdwealth.com/retailinvestor. These
relationships or arrangements present a conflict of
interest because they provide a financial incentive to
Baird and Baird Financial Advisors to use, select or
recommend the investment products and services of
Baird and Associated Parties over those of unassociated
parties and those that pay the greatest level of
compensation. Baird addresses this potential conflict
through disclosure in this Brochure. Further, when acting
as fiduciaries, Baird and Baird Financial Advisors are
required to select or recommend investment products
only when they determine it to be in the client’s best
interest to do so.
Baird has a financial incentive to the extent it would
recommend that a client invest in a portfolio company
owned by a Baird Capital private equity fund. A list of the
portfolio companies held by Baird Capital private equity
funds is located on Baird Capital’s website located at
https://www.bairdcapital.com/portfolio/baird-capital-
portfolio.aspx.
11
Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird Global Investment Banking
Baird Institutional Equities and Research
Baird Public Finance
of such Associated Party’s voting securities (or of an
entity deemed to control such Associated Party). Baird
considers itself “related” to an Associated Party when BFG
indirectly owns or controls at least 10% but less than
25% of such Associated Party’s voting securities (or of an
entity deemed to control such Associated Party). Baird
considers itself “associated” with an Associated Party
when certain other relationships or other arrangements
exist between Baird and such Associated Party that might
present a conflict of interest with clients.
Through its Global Investment Banking, Institutional
Equities and Research and Fixed Income Capital Markets
(include Baird Public Finance) Businesses, Baird provides
investment banking, municipal advisory, securities
underwriting, stock buyback and related services to
various corporate, municipal, and other issuers of
securities. Baird receives compensation from such issuers
in connection with the services it provides, and the
success of its services generally depends upon Baird’s
ability to sell the securities of such issuers. Baird may,
therefore, have an incentive to favor the securities of
issuers for which Baird provides such services over the
securities of issuers for which Baird does not provide such
services.
An Associated Party receives fees or other compensation
for investment advisory or other services that it provides
to an Associated Fund. The amount of fees and other
compensation paid by an Associated Fund to an
Associated Party is disclosed in the Associated Fund’s
prospectus or other offering document. An Associated
Party also receives fees from a client for services that it
provides related to a client’s Associated SMA Strategy.
Information about the amount of fees paid to an
Associated Party with respect to an SMA Strategy is
contained in the applicable Baird Form ADV Part 2A
Brochure, the applicable account schedule, or in some
instances, the client’s contract with the Associated Party.
rather
A Baird Financial Advisor who refers a client to Baird
Global Investment Banking for a possible transaction in
which Baird Global Investment Banking earns a financial
advisory or underwriting fee receives a portion of such
fee. A Baird Financial Advisor who refers a client to Baird
Public Finance for a municipal advisory or underwriting
opportunity receives a portion of the compensation
earned by Baird Public Finance on that opportunity. Baird
and Baird Financial Advisors thus have an incentive to
recommend the securities issued in those offerings. A
Baird Financial Advisor who refers a corporation to Baird’s
Institutional Equities and Research business for a stock
buy-back program receives a portion of the commissions
earned by Baird’s Institutional Equities and Research
business. Baird and its Financial Advisors may, therefore,
have an incentive to buy, and to recommend that clients
sell, the securities of issuers that are part of Baird’s
buyback services.
Associated Investment Products and Services
Baird and Baird Financial Advisors have a financial
incentive to use, select or recommend Associated
Investment Products and Services because Baird and BFG
benefit financially if a client utilizes those investment
than unassociated
products and services
investment products and services, and Baird Financial
Advisors benefit financially from the overall success of
Baird and BFG. Similarly, Baird and Baird Financial
Advisors also generally have a financial incentive to favor
the investment products and services of Baird over
Associated Parties and to favor those of Associated
Parties in which BFG has a materially greater indirect
ownership interest over those of Associated Parties in
which BFG has a materially lesser indirect ownership
interest. Baird addresses this potential conflict through
disclosure in this Brochure. Further, when acting as
fiduciaries, Baird and its Financial Advisors are required
to recommend investment products only when they
determine it to be in the client’s best interest to do so.
Baird makes available investment products and services
managed, advised or sponsored by Baird or its Associated
Parties. These products and services (collectively,
“Associated Investment Products and Services”) include
mutual funds, exchange traded funds, unit investment
trusts, collective investment trusts, private equity funds,
hedge funds, and other private funds managed, advised
or sponsored by Baird or Associated Parties (“Associated
Funds”) and separately managed account (“SMA”)
strategies managed or advised by Baird or Associated
Parties
(“Associated SMA Strategies”). Associated
Investment Products and Services are listed in Appendix
A to this Brochure.
Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
Code of Ethics
Subject to the restrictions described below, Baird and its
affiliates and associates may engage in securities
transactions for their own accounts, including the same
or related securities that are recommended to or owned
by Baird clients. These transactions may include trading
in securities in a manner that differs from, or is
inconsistent with, the advice given to Baird clients, and
the transactions may occur at or about the same time
that such securities are recommended to or are
purchased or sold for client accounts. This creates a
potential for a conflict between the interest of clients and
the interests of Baird and its affiliates and associates.
Certain Associated Parties are associated with Baird
because BFC, Baird’s parent corporation, owns some or
all of the Associated Parties’ voting securities. BFC’s
parent corporation
(and Baird’s ultimate parent
corporation), BFG, may be deemed to indirectly own or
control such voting securities. Baird is deemed to be
under common control and “affiliated” with an Associated
Party when BFG indirectly owns or controls 25% or more
12
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Accounts and Investments Provide Different Levels of
Compensation
including Baird Financial Advisors,
information relating
The types of accounts and investment products offered to
clients provide Baird and Baird Financial Advisors
different levels of compensation. Baird and Baird
Financial Advisors have an
incentive to generate
revenues from client accounts by selecting and
recommending account types and investment products
that will provide them the greatest level of compensation.
Trust Services Arrangements
Baird and Baird Financial Advisors have an incentive to
recommend that a client retain Baird Trust for the client’s
trust services needs rather than an unassociated firm and
to recommend arrangements that involve Baird and the
Baird Financial Advisor providing investment advisory
services to the client and Baird Trust only providing trust
administration services because it is more profitable for
them. Please see “Advisory Business—Additional Service
Information —Trust Services Arrangements” above for
more detailed information.
To address the potential for conflicts of interest, Baird has
adopted a Code of Ethics (the “Code”) that applies to its
associates that provide investment advisory services to
their
clients,
supervisors, and certain associates who have access to
non-public
to advisory client
accounts (“Access Persons”). The Code prohibits Access
Persons from using knowledge about advisory client
account transactions to profit personally, directly, or
indirectly, by trading in his or her personal accounts. The
Code also generally prohibits Access Persons from
executing a security transaction for their personal
accounts during a blackout period one business day
before or after the date that a client transaction in that
same security is executed. The Code provides for certain
exceptions deemed appropriate by Baird management or
by Baird’s Compliance Department. In addition, orders for
the accounts of Access Persons and other Baird
associates that are under discretionary management by
Baird may be aggregated with orders for other Baird
client accounts, so long as the order is executed as part
of a block transaction with client orders. A copy of the
Code is available to clients or prospective clients upon
request.
Investment Advisory and Brokerage Account and
Service Recommendations
Baird has also
implemented certain policies and
procedures relating to Baird’s and its associates’ trading
activities that are designed to prevent them from
improperly benefiting from the trading activities of Baird’s
In addition, Baird’s Compliance
advisory clients.
Department monitors the personal trading activities of all
of Baird’s associates providing advisory-related services
to clients.
Participation or Interest in Client Transactions
Investment Advisory Accounts
Asset-based Advisory Fee arrangements create an
incentive for Baird and Baird Financial Advisors to set the
applicable fee rate at a high level and to encourage clients
to add more money into their accounts. Baird and Baird
Financial Advisors also have an incentive to recommend
an investment advisory account to a client rather than a
brokerage account if the client has, or is expected to
have, lower levels of trading activity in the client’s
account. Select clients may pay a fixed dollar fee, which
presents a conflict in that such fee does not give the Baird
Financial Advisor an incentive to make recommendations
that could benefit the client’s account, or a performance
or incentive fee, which presents a conflict because it gives
the Baird Financial Advisor an incentive to recommend
riskier investments in order to achieve the level of
performance in the account that would result in payment
of the fee.
Baird and Baird Financial Advisors generally have a
financial incentive to recommend investment advisory
Accounts to clients rather than brokerage accounts
because Advisory Fee revenue is recurring, more
predictable and typically greater than the revenues Baird
earns, and the compensation Baird Financial Advisors
receive, from brokerage accounts. In addition, because
Advisory Fees are paid by a client regardless of the trade
activity in the client’s advisory Account, Baird will receive
greater revenue, and the client’s Baird Financial Advisor
will receive greater compensation, from a low trade-
activity advisory Account than from a low trade-activity
brokerage account. Baird and Baird Financial Advisors
thus have an incentive to recommend an investment
advisory Account to a client rather than a brokerage
account if the client has, or is expected to have, lower
levels of trading activity in the client’s account. However,
because Baird’s revenues and the compensation paid to
Baird Financial Advisors
from brokerage accounts
increase as the level of trading increases, Baird and Baird
Financial Advisors have an incentive to recommend a
brokerage account to a client rather than an investment
advisory Account if the client has, or is expected to have,
significant trading activity in the client’s account. Baird
Financial Advisors also have a financial incentive to
recommend certain wealth management services, such
as wealth planning. Please see “Fees and Compensation—
Advisory Fees—Advisory Fee Payments to Baird and Baird
Financial Advisors” above for more detailed information.
Account Transfers and New Accounts
Baird also periodically provides special incentives to Baird
Financial Advisors to recommend advisory products and
services to clients and to recommend that clients put
more assets into their Accounts.
Baird and a client’s Baird Financial Advisor have an
incentive to recommend that the client transfer the
client’s accounts to Baird and establish new accounts with
Baird (including IRA rollovers) because doing so will
13
Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
result in increased revenues to Baird and compensation
for the Baird Financial Advisor.
Baird does, and seeks to do, business with companies
covered by those research departments and as a result,
Baird may have a conflict of interest that could affect the
content of its research reports.
Recommendations to Open Different Types of Accounts
As a registered broker-dealer, Baird effects transactions
in securities on a national exchange and may receive and
retain compensation for such services, subject to the
limitations and restrictions made applicable to such
transactions by Section 11(a) of the Exchange Act and
Rule 11a2-2(T) thereunder.
Other Conflicts of Interest
likely
to maintain
Baird and Baird Financial Advisors have an incentive to
recommend that a client open different types of accounts
with Baird, such as individual accounts, IRA rollovers,
joint accounts, 529 plan accounts and UGMA/UTMA
accounts, because if a client has different types of
accounts with Baird, the client brings more of the client’s
investable assets to Baird, on which fees can be
generated, thereby increasing Baird’s revenues and the
client’s Baird Financial Advisor’s compensation. Also, if a
client has more account types with Baird, the client is
statistically more
the client’s
relationship with Baird and the client’s Baird Financial
Advisor for longer periods of time.
Baird Stock Ownership
Baird offers to clients other investment products and
services not described in this Brochure. These investment
products and services provide different
levels of
compensation to Baird and its Financial Advisors. Baird
and its Financial Advisors have an incentive to favor those
investment products and services that generate a higher
level of compensation than those that generate a lower
level of compensation. For more information about the
other investment products and services offered by Baird,
clients should contact Baird or a Baird Financial Advisor.
Addressing Conflicts
in
this Brochure,
The foregoing activities could create a conflict of interest
with clients. In addition to the measures described above,
Baird addresses conflicts posed by those activities
the client’s
through disclosure
agreements with Baird, the Client Relationship Booklet
and prospectuses, offering documents or other disclosure
documents provided or made available to clients. Baird
has also adopted a Code of Ethics and other internal
policies and procedures for Baird and its associates that:
• require them to provide investment advice that is
the
for advisory clients (based upon
suitable
information provided by such clients); and
• address and limit cash and non-cash benefits provided
to Baird Financial Advisors by third parties in an
attempt to avoid any question of propriety or any
conduct inconsistent with Baird’s high standards of
ethics.
Most Baird Financial Advisors own common stock of BFG,
Baird’s ultimate parent, and when offered the opportunity
to buy BFG stock they usually do so. The amount of BFG
stock that a Financial Advisor may purchase is based in
part on the Financial Advisor’s total production level. A
client’s Baird Financial Advisor thus has an incentive to
make recommendations that increase the Financial
Advisor’s total production on the client’s accounts with
Baird. Moreover, revenues from Baird’s PWM department,
in which Baird Financial Advisors operate, contribute
substantially to BFG’s overall revenues and profitability,
and the performance of BFG’s stock price is largely due
to the profitability of Baird’s PWM department. As a
result, a client’s Baird Financial Advisor’s ownership of
BFG stock creates a financial incentive to make
recommendations to the client that increase the amount
of revenues generated from the client’s accounts with
Baird, even if those recommendations will not increase
the Baird Financial Advisor’s production, so as to increase
the revenues and profitability of Baird’s PWM department
and thus of BFG, which will serve to grow the value of the
BFG stock. For example, ownership of BFG stock, the
performance of which is impacted by the success of
Associated Parties, provides a client’s Baird Financial
Advisor an incentive to use, select or recommend
Associated Investment Products and Services to a client
even though such recommendation does not increase the
client’s Baird Financial Advisor’s production.
Baird Financial Advisors Transferring to Baird
select broker-dealers
A Baird Financial Advisor joining Baird from another firm
has an incentive to recommend that a client to transfer
the client’s accounts from such firm to Baird because
doing so will increase the Baird Financial Advisor’s
compensation. Please see “Fees and Compensation—
Advisory Fees—Advisory Fee Payments to Baird and Baird
Financial Advisors” above for more detailed information.
Baird’s Other Broker-Dealer and Related Activities
Brokerage Practices
The Services provided under this Brochure only include
services related to the creation of a Plan. The Services do
not include the implementation of the Plan or the
solicitation or recommendation of specific investments or
securities transactions. As a result, Baird does not
recommend or
to effect
transactions for client accounts as part of the Services.
However, some clients elect to participate in other
advisory programs or services provided by Baird to
implement a Plan. Under those circumstances, Baird may
select broker-dealers. A client should consult with the
client’s Financial Advisor or review Baird’s Form ADV Part
The investment advice provided to a client may be based
on the research opinions of Baird’s research departments.
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Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
2A Brochure and agreement for the other advisory
program or service for more information.
full discretionary authority over client’s accounts and is
solely responsible for implementing any Plan.
Voting Client Securities
Baird does not have authority to vote proxies with respect
to the securities held in the client’s account or otherwise
act for client accounts in connection with the Services. A
client retains the right to vote proxies with respect to the
securities held in such accounts and is solely responsible
for voting any such proxies.
Review of Accounts
Unless the client and Baird otherwise agree in writing, the
client’s Financial Advisor and the Department generally
do not provide ongoing review of a Plan or the client’s
Accounts or ongoing reporting unless the client has
selected Ongoing Planning Services. If a client has
selected Ongoing Planning Services, the scope and
frequency of the review or performance of other Services
will be specified in the client’s Agreement.
If a client opens an Account with Baird, Baird will
generally provide the client with a monthly brokerage
account statement when activity occurs during that
month. Otherwise, Baird will provide the client with a
quarterly statement if there has not been any intervening
monthly transaction activity.
Financial Information
Baird does not require or solicit prepayment of more than
$1,200 in fees per client six months or more in advance
and, thus, has not included a balance sheet of its most
recent fiscal year. Baird is not aware of any financial
condition that is reasonably likely to impair its ability to
meet its contractual commitments to clients, nor has it
been the subject of a bankruptcy petition at any time
during the past ten years.
in some
instances. When applicable,
Client Referrals and Other Compensation
Baird may provide compensation to individuals who refer
clients
the
compensation paid is a percentage of the client’s fee
payments or the value of the client’s account. The
amount of compensation will vary, with the specific level
determined based upon consideration of various factors
including, but not limited to, the individual’s role in
developing the client relationship and the assets under
management. Baird may pay these fees to registered
representatives of Baird and its affiliates as well as to
unaffiliated solicitors that have entered into a written
agreement with Baird.
“Other Financial
Baird and its affiliates and associates may receive certain
economic benefits in connection with providing advisory
services to clients, which are described in the sections
entitled
Industry Activities and
Affiliations” and “Code of Ethics, Participation or Interest
in Client Transactions and Personal Trading” above.
Custody
Baird does not have custody of client assets as part of the
Services. However, some clients may elect to establish a
brokerage account or participate in other advisory
programs or services provided by Baird to implement the
advice provided by Baird or a client’s Baird Financial
Advisor. Under those circumstances, Baird may agree to
provide such services and serve as custodian under a
separate agreement. A client should consult with the
client’s Baird Financial Advisor or review Baird’s Form
ADV Part 2A Brochure and agreement for the other
advisory program or service for more information.
Investment Discretion
Baird does not have discretionary authority to buy or sell
securities for client accounts or otherwise act for client
accounts in connection with the Services. A client retains
15
Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Appendix A
Associated Investment Products and Services
Entity Type
Name
Relationship
Baird Advisors1
Baird Department
Baird Equity Asset Management1
Baird Department
Chautauqua Capital Management1
Baird Department
55I, LLC (d/b/a 55ip, “55ip”)
Associated
Investment Advisor
GAMMA Investing, LLC
Affiliated
Greenhouse Fund GP LLC
Related
Greenhouse Funds LLLP
Related
LoCorr Fund Management, LLC
Related
Reinhart Partners, LLC
Affiliated
Riverfront Investment Group, LLC
Affiliated
Dual Registrant2
Strategas Securities, LLC
Affiliated
Trust Company
Baird Trust Company1
Affiliated
Baird Funds, Inc.1
Affiliated
Bridge Builder Trust (Baird series)
Affiliated
Mutual Fund
Financial Investors Trust (Riverfront series)
Affiliated
LoCorr Investment Trust
Related
Managed Portfolio Series Trust (Reinhart series)
Affiliated
Pace® Select Advisors Trust (Baird Series)
Affiliated
Advisors’ Inner Circle Fund III (Strategas series)
Affiliated
ETF
ALPS ETF Trust (Riverfront Series)
Affiliated
First Trust Exchange-Traded Fund III (Riverfront series)
Affiliated
Automated Quantitative Analysis (AQA®) Portfolio Series
Affiliated
UIT
Dividend Income Trust (DIT) Series
Affiliated
Strategas Trust, Series 1-1
Affiliated
CIT
Reliance Trust Institutional Retirement Trust (Baird/Chautauqua series)
Affiliated
Greenhouse Master Fund LP
Related
Hedge Fund
Greenhouse Onshore Fund LP
Related
Greenhouse Overseas Fund Ltd.
Related
Chautauqua Global Growth Equity QP Fund, LP
Affiliated
Private Fund
Chautauqua International Growth Equity QP Fund, LP
Affiliated
Chautauqua Series Fund, LLC
Affiliated
Appendix A - 1
Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Venture Partners Management Company III, LLC
Baird Venture Partners III Limited Partnership
Affiliated
BVP III Affiliates Fund Limited Partnership
BVP III Special Affiliates Limited Partnership
Baird Venture Partners Management Company IV, LLC
Baird Venture Partners IV Limited Partnership
Affiliated
BVP IV Affiliates Fund Limited Partnership
BVP IV Special Affiliates Limited Partnership
Baird Venture Partners Management Company V, LLC
Baird Venture Partners V Limited Partnership
Affiliated
BVP V Affiliates Fund Limited Partnership
BVP V Special Affiliates Fund Limited Partnership
Baird Capital Partners Management Company V, LLC
Baird Capital1,3
Baird Capital Partners V Limited Partnership
Affiliated
Investment Advisor
BCP V Affiliates Fund Limited Partnership
Private Equity Fund
BCP V Special Affiliates Limited Partnership
Baird Capital Management Company, LLC
Baird Venture Partners GP VI, LLC
Baird Venture Partners VI LP
Affiliated
BVP VI Affiliates Fund LP
BVP VI Special Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management I LP
Baird Capital Global Fund I LP
Affiliated
Baird Capital Global Fund I-DE LP
BCGF I Special Affiliates LP
BCGF I Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management II LLC
Baird Capital Global Fund II Limited Partnership
Affiliated
BCGF II Affiliates Fund Limited Partnership
BCGF II Special Affiliates Limited Partnership
Appendix A - 2
Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Capital Management Company, LLC
Baird Capital Global GP III LLC
Baird Capital Global Fund III LP
Affiliated
Baird Capital1,3
BCGF III Affiliates Fund LP
Investment Advisor
BCGF III Special Affiliates LP
Private Equity Fund
Baird Capital Partners Europe Limited4
Baird Capital Partners Europe II LP
Affiliated
Baird Capital Partners Europe II Special Affiliates LP
The Growth Fund
Baird Principal Group Management Company I, LLC
Baird Principal Group5
Baird Principal Group Partners Fund I Limited Partnership
Investment Advisor
Baird Principal Group Management Company II, LLC
Affiliated
Private Equity Fund
Baird Principal Group Partners Fund II Limited Partnership
Baird Principal Group Management Company, LLC
Baird Principal Group Partners Fund III, LP
Holding Company
Sagard Holdings Management, Inc.6
Associated
1. Participates in a Baird PWM Referral Program that pays compensation to Baird Financial Advisors for eligible referrals.
2. Registered with the SEC as a broker-dealer and investment advisor.
3. Baird Capital, Baird’s private equity business.
4. Baird Capital Partners Europe Limited, an English limited company, is regulated and authorized by the Financial Conduct
Authority.
5. Baird Principal Group, a group within Baird that has private equity funds only available to Baird employees.
6. Baird has a contractual relationship with and a small minority investment in Sagard Holdings Management, Inc., a
holding company for various financial services businesses whose investment products are made available to clients. See
“Other Financial Industry Activities and Affiliations—Certain Relationships and Arrangements—Baird and Associated Parties”
above for more information.
Appendix A - 3
Baird FPS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Additional Brochure: BAIRD GENERATIONAL WEALTH GROUP (2026-03-27)
View Document Text
Baird Generational Wealth Group
Brochure
March 27, 2026
Baird Generational Wealth Group
777 East Wisconsin Avenue
Milwaukee, Wisconsin 53202
Toll Free: 800-792-2473
www.bairdfamilywealthgroup.com
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue
Milwaukee, WI 53202
1-800-792-2473
rwbaird.com
Member FINRA & SIPC
SEC File No. 801-7571
This brochure (“Brochure”) provides information about the qualifications and business practices of
Robert W. Baird & Co. Incorporated (“Baird”) and Baird Generational Wealth Group (“GWG”), a team
within Baird’s Private Wealth Management department. Clients should carefully consider this
information before becoming a client of GWG. If you have any questions about the contents of this
Brochure, please contact GWG at the toll-free phone number listed above. The information contained
in this Brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority. Additional information about Baird is available on
the SEC’s website at www.adviserinfo.sec.gov.
Material Changes
Baird Generational Wealth Group (“GWG”), a team within the Private Wealth Management department of
Robert W. Baird & Co. Incorporated (“Baird”), updated its Form ADV Part 2A brochure (the “Brochure”) on
March 27, 2026. The following summary discusses the material changes that GWG has made to the
Brochure since March 21, 2025, the date of the last annual update to the Brochure.
• In January 2026, Baird’s direct parent corporation, Baird Financial Corporation (“BFC”), made a
significant minority investment in Reinhart Partners, LLC (“Reinhart”), an investment advisor that offers
investment products and services through the Programs. As a result of the investment transaction, Baird
and Reinhart are affiliated, providing Baird a financial incentive to use, select or recommend Reinhart
investment products and services.
• In September 2025, Baird entered into a strategic partnership with Sagard Holdings Management, Inc.
(“Sagard”). Baird’s direct parent corporation, BFC, acquired a minority ownership interest in Sagard and
the right to appoint a member to Sagard’s board of directors. Baird agreed to use best efforts,
consistent with its fiduciary duties and other regulatory responsibilities, to offer investment products
managed or sponsored by affiliates of Sagard deemed suitable by Baird for its PWM clients, providing
Baird a financial incentive to recommend such investment products. See the Section of the Brochure
entitled “Other Financial Industry Activities and Affiliations—Certain Relationships and Arrangements—
Baird and Associated Parties” for more information.
• Baird updated information about Baird’s regulatory assets under management. See the Section of the
Brochure entitled “Advisory Business” for more information.
• Baird updated its description of the DC Program. The DC Program is designed to accommodate a client
who wishes to independently select an investment manager not available in the GWG Recommended
Managers Service or BSN Program to manage the assets in the client’s Account. The Program is also
designed for a client that wants to independently select a manager and negotiate the manager’s
Portfolio Fee rate directly with the manager. Certain managers offer lower Portfolio Fee rates to clients
through the DC Program compared to the BAM, GWG Recommended Managers, or BSN Programs. A
client considering an SMA Strategy should discuss with client’s GWG Consultant SMA Strategy
availability and the different Portfolio Fee rates, costs, and the types and levels of service provided in
connection with the different Programs. If a client has decided to participate in the DC Program, upon
the client’s request, the client’s GWG Consultant may assist the client with the client’s negotiation with
the manager of the Portfolio Fee rate for the applicable SMA Strategy. The Portfolio Fee negotiated by
the client could be higher or lower than the Portfolio Fee that applies to the same SMA Strategy that is
available through other Programs. The client is ultimately responsible for understanding the differences
between the SMA Programs, deciding to participate in the DC Program, selecting the SMA Strategy, and
negotiating and agreeing to the Portfolio Fee rate.
• Baird updated information about tax management and direct indexing strategies, including the
associated limitations and risks. See the Sections of the Brochure entitled “Advisory Business—
Additional Service Information—Tax Management Services” and “Methods of Analysis, Investment
Strategies and Risk of Loss—Investment Strategies” for more information.
• Baird provided additional information about possible tax consequences of a client’s investment activities.
See the Section of the Brochure entitled “Advisory Business—Additional Service Information—Legal and
Tax Considerations” for more information.
• Baird updated the rates of Portfolio Fees charged by managers under the Services. See the Section of
the Brochure entitled “Fees and Compensation—Advisory Fees” for more information.
• Baird updated its disclosures about the research, information and tools used by Baird PWM home office
investment professionals and GWG Consultants when formulating investment advice, which may include
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BGWG F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the use of artificial intelligence (“AI”) tools, and the related risks. See the Section of the Brochure
entitled “Methods of Analysis, Investment Strategies and Risk of Loss—Methods of Analysis” for more
information.
• Baird included a description of the PWM Stock Opportunities List. See the Section of the Brochure
entitled “Methods of Analysis, Investment Strategies and Risk of Loss—Methods of Analysis—Certain
Eligible Product Lists” for more information.
• Baird updated investment risk information related to information security, cybersecurity, and other
technology‑related events, issuers’ use of AI, investments in digital assets, such as cryptocurrencies,
and those associated with recent events, such as those associated with the U.S. administration’s policy
initiatives, inflation, conflicts in Iran and the Middle East, the war between Ukraine and Russia, and the
strain in relationships between the U.S. and other countries. See the Section of the Brochure entitled
“Methods of Analysis, Investment Strategies and Risk of Loss—Principal Risks” for more specific
information.
• In March 2026, Baird entered into an Offer of Settlement with the Massachusetts Securities Division to
settle a regulatory matter relating to the timing of state investment adviser representative registration
approvals for two of Baird’s Financial Advisors located in Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals provided investment advisory services before their
Massachusetts registrations were completed as a form was missing from their application materials. 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.
• Baird updated information about firms affiliated with, related to, or otherwise associated with Baird. See
the Section of the Brochure entitled “Other Financial Industry Activities and Affiliations” and Appendix A
to the Brochure for more information.
A client should note that the foregoing summary only discusses material changes made to the Brochure
since March 21, 2025. The updated Brochure contains changes that are not listed above.
iii
BGWG F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Table of Contents
Advisory Business ........................................................................................... 1
Robert W. Baird & Co. Incorporated ................................................................ 1
The Client-Baird Fiduciary Relationship ............................................................ 1
Summary of GWG’s Services .......................................................................... 2
Consulting Services ...................................................................................... 5
Financial Strategy ................................................................................... 5
Investment Strategy ............................................................................... 6
Risk Management ................................................................................... 7
Tax Planning .......................................................................................... 7
Estates and Trusts .................................................................................. 7
Philanthropic Planning ............................................................................. 7
Family Education .................................................................................... 7
Sounding Board ...................................................................................... 8
Data Aggregation .................................................................................... 8
Discretionary Services ................................................................................... 8
GWG Investment Management Service ...................................................... 8
SMA Services ............................................................................................... 9
GWG Recommended Managers Service ...................................................... 9
Baird SMA Network Program .................................................................. 11
Dual Contract Program .......................................................................... 13
Other SMA Strategy Information ............................................................. 15
Additional Service Information ..................................................................... 15
Conversion, Exchange or Sale of Certain Investments ............................... 15
Complex Strategies and Complex Investment Products .............................. 15
Permitted Investments .......................................................................... 18
Unsupervised Assets ............................................................................. 19
Special Considerations for the Services .................................................... 20
Goal Management ................................................................................. 20
Tax Management Services ..................................................................... 21
Investment Objectives ........................................................................... 23
Mutual Fund Share Class Policy ............................................................... 25
Custody Services .................................................................................. 26
Cash Sweep Program ............................................................................ 26
Trust Services Arrangements .................................................................. 27
Margin Loans ........................................................................................ 28
Securities-Based Lending Program .......................................................... 29
Other Non-Advisory Services .................................................................. 29
Client Responsibilities ............................................................................ 29
Retirement Accounts ............................................................................. 30
Legal and Tax Considerations ................................................................. 30
Account Requirements ........................................................................... 30
Fees and Compensation ................................................................................ 34
Advisory Fees ............................................................................................ 34
Fee Options and Fee Schedule ................................................................ 34
Service Account Minimums ..................................................................... 36
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Calculation and Payment of Advisory Fees ................................................ 36
Obtaining Services Separately: Brokerage or Advisory? Factors
to Consider ...................................................................................... 38
Advisory Fee Payments to Baird, GWG Consultants and
Investment Managers ........................................................................ 39
Other Fees and Expenses ............................................................................ 41
Cost and Expense Information for Certain Investment Products .................. 41
Additional Account Fees and Charges ...................................................... 41
Other Fees and Charges ........................................................................ 41
Other Compensation Received by GWG and Baird ........................................... 42
Performance-Based Fees and Side-By-Side Management .............................. 43
Types of Clients............................................................................................. 43
Methods of Analysis, Investment Strategies and Risk of Loss ....................... 43
Investment Strategies ................................................................................. 43
Equity Strategies .................................................................................. 43
Fixed Income or Bond Strategies ............................................................ 44
Balanced Strategies .............................................................................. 44
Value Strategies ................................................................................... 44
Growth Strategies ................................................................................. 44
Income Strategies ................................................................................. 44
Economic Industry or Sector Focused Strategies ....................................... 44
International Strategies ......................................................................... 44
Global Strategies .................................................................................. 44
Geographic Region or Country Focused Strategies ..................................... 45
Tactical and Rotation Strategies .............................................................. 45
Opportunity or Opportunistic Strategies ................................................... 45
Tax Management Strategies ................................................................... 45
Direct Indexing Strategies ...................................................................... 46
Alternative Strategies and Complex Strategies ......................................... 46
Asset Allocation Strategies ..................................................................... 49
Important Information about Implementation of Investment
Objectives and Investment Strategies ................................................. 51
Methods of Analysis .................................................................................... 51
Certain PWM-Managed Portfolios ............................................................. 53
Certain Recommended Lists ................................................................... 54
Certain Eligible Product Lists .................................................................. 58
Baird Trust Strategies ............................................................................ 59
The GWG Investment Process ................................................................. 60
Service Information .................................................................................... 60
GWG Investment Management Service .................................................... 60
GWG Recommended Managers Service .................................................... 61
Baird SMA Network and Dual Contract Programs ....................................... 61
Portfolio Management by GWG, Baird and Associated Managers ....................... 62
Principal Risks ............................................................................................ 63
Investment Risk Information .................................................................. 64
Risks Associated with Certain Investment Strategies ................................. 70
Non-Traditional Assets and Complex Strategies Risks ................................ 71
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Complex Investment Product Risks ......................................................... 73
Risks Associated with Certain Investment Objectives and Asset
Allocation Strategies ......................................................................... 79
Available Investment Product Risks ......................................................... 81
Recent Events ...................................................................................... 81
Disciplinary Information ............................................................................... 82
Other Financial Industry Activities and Affiliations ....................................... 84
Baird’s Broker-Dealer Activities .................................................................... 84
Certain Relationships and Arrangements ....................................................... 84
Baird and Associated Parties................................................................... 84
Associated Investment Products and Services ........................................... 86
Relationships and Arrangements with Investment Managers ............................ 87
Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading ................................................................................ 87
Code of Ethics ............................................................................................ 87
Participation or Interest in Client Transactions ............................................... 87
Investment Advisory Accounts ................................................................ 87
Accounts and Investments Provide Different Levels of
Compensation .................................................................................. 88
Recommendations of Associated Investment Products and
Services .......................................................................................... 88
Referral Compensation Paid to GWG Consultants ...................................... 88
Ongoing Product Fees ............................................................................ 88
Marketing Support and Revenue Sharing from Mutual Fund and
UIT Sponsors ................................................................................... 88
Schwab Clearing Arrangement ................................................................ 89
Baird Conference Sponsorships ............................................................... 89
GWG Consultants Receive Benefits from Product Providers ......................... 89
Cash Sweep Program ............................................................................ 90
Trust Services Arrangements .................................................................. 90
Margin Loans ........................................................................................ 90
Securities-Based Lending Program .......................................................... 90
Investment Advisory and Brokerage Account and Service
Recommendations............................................................................. 90
Account Transfers and New Accounts ...................................................... 91
Recommendations to Open Different Types of Accounts ............................. 91
Baird Stock Ownership .......................................................................... 91
Other Client Relationships ...................................................................... 91
Relationships with Issuers of Securities ................................................... 91
GWG Consultants Transferring to Baird .................................................... 91
Principal Trading ................................................................................... 91
Baird Underwritten Offerings .................................................................. 92
Allocations of IPOs and Other Public Offerings .......................................... 92
Trade Error Correction ........................................................................... 92
Baird’s Other Broker-Dealer and Related Activities .................................... 92
Other Conflicts of Interest ...................................................................... 93
Addressing Conflicts .............................................................................. 93
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Duration Compensation Will Be Received ................................................. 93
Brokerage Practices ...................................................................................... 94
GWG’s and Baird’s Trading Practices ............................................................. 94
Broker-Dealer Selection ......................................................................... 94
Trade Aggregation, Allocation and Rotation Practices ................................. 94
Directed Brokerage Arrangements........................................................... 95
Cross Trading Involving Advisory Accounts ............................................... 96
Trade Error Correction ........................................................................... 96
Soft Dollar Benefits ............................................................................... 96
Trading Practices of Investment Managers ..................................................... 96
Trade Execution Services Performed by Baird ................................................. 97
Agency Cross Transactions ..................................................................... 98
Principal Transactions ............................................................................ 98
Review of Accounts ....................................................................................... 99
Client Account Review ................................................................................. 99
Account Statements and Performance Reports ............................................... 99
Client Referrals and Other Compensation ................................................... 101
Custody ....................................................................................................... 101
Investment Discretion ................................................................................ 102
Investment Selection and Trading Authorizations .......................................... 102
Client Investment Restrictions ..................................................................... 103
Associated Investment Products .................................................................. 103
Investment Policy Statements ..................................................................... 104
Conversion, Exchange or Sale of Certain Investments .................................... 104
Voting Client Securities ............................................................................... 104
Non-Discretionary Accounts ........................................................................ 104
Separately Managed Accounts ..................................................................... 104
Discretionary Services ................................................................................ 105
Other Proxy Voting Information ................................................................... 106
Providing Baird Voting Instructions .............................................................. 106
Legal Proceedings and Corporate Actions ...................................................... 106
Financial Information.................................................................................. 106
Special Considerations for Retirement Accounts ......................................... 106
Associated Investment Products and Services ............................. Appendix A-1
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BGWG F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Robert W. Baird & Co. Incorporated
Baird is privately-held, employee-owned global
investment and wealth management firm formed
in the State of Wisconsin in 1919.
Baird is owned indirectly by its associates through
several holding companies. Baird
is owned
directly by Baird Financial Corporation (“BFC”).
BFC is, in turn, owned by Baird Financial Group,
Inc. (“BFG”), which
is the ultimate parent
company of Baird. Associates of Baird own
substantially all of the outstanding stock of BFG.
analysis
and
research,
analysis
and
planning;
investment
and
account
transactions
and
retirement
accounts, which
Baird offers various investment advisory services
to clients, including services not described in this
Brochure. The investment advisory services Baird
include: portfolio management and
offers
recommendations
analysis;
investment
regarding asset allocation and
strategies;
and
recommendations regarding investment managers
and individual securities; investment consulting;
policy
financial
development;
performance
monitoring. Baird also offers clients execution of
administrative
brokerage
services, including maintaining custody of account
assets. Clients may also negotiate other services
with Baird. Baird offers its services separately or
in combination with other services.
(“IRC”)
(collectively,
Baird participates in wrap fee programs, including
programs not described in this Brochure and it
provides portfolio management services
in
connection with those programs. Baird receives a
portion of the wrap fee paid by clients for
providing portfolio management services under
those wrap fee programs.
under management,
including
Advisory Business
This Brochure describes some of the investment
advisory services that Robert W. Baird & Co.
Incorporated (“Baird”) offers to its clients through
Baird Generational Wealth Group (“GWG”), a
team of Baird Financial Advisors
(“GWG
Consultants”) within Baird’s Private Wealth
Management (“PWM”) department. Baird and
GWG offer other investment advisory services not
described in this Brochure. Separate brochures
describe those other investment advisory services
and discuss the terms and conditions, fees and
costs and potential conflicts of interest associated
with those services. This Brochure also references
other documents that contain additional important
information about Baird. Those documents
describe the types of investment products and
services that Baird makes available to clients,
including the terms, conditions, fees, costs, risks,
and conflicts of interest applicable to those
investment products
services. Those
documents are available on Baird’s website at
bairdwealth.com/retailinvestor. Included on that
website is Baird’s Client Relationship Booklet,
contains Baird’s Form CRS Client
which
and Baird’s Client
Relationship Summary
Relationship Details document. The Client
Relationship Booklet also contains an important
disclosure document for retirement investors that
have
include
employee pension benefit plan accounts that are
subject to the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”) and
individual retirement accounts (“IRAs”) that are
subject to the Internal Revenue Code of 1986, as
“Retirement
amended
Accounts”). A client of Baird should have already
received a copy of the Client Relationship Booklet.
A client or prospective client who wishes to obtain
a brochure for another investment advisory
service provided by Baird, or a paper copy of any
of the other documents referenced
in this
Brochure,
the Client Relationship
Booklet, should contact a GWG Consultant or call
Baird toll-free at 1-800-792-2473.
As of December 31, 2025, Baird had
approximately $394.0688 billion in regulatory
assets
approximately
$289.4898 billion of which was managed on a
discretionary basis and approximately $104.5790
billion of which was managed on a non-
discretionary basis.
The information contained in this Brochure is
current as of the date above and is subject to
change at Baird’s discretion. Please retain this
Brochure for your records.
The Client-Baird Fiduciary Relationship
is registered with the Securities and
Baird
Exchange Commission (“SEC”) as an investment
adviser under the Investment Advisers Act of
1940, as amended (the “Advisers Act”). GWG and
Baird are deemed to have a fiduciary relationship
with a client when providing the investment
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BGWG F+C Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
office investment professionals or the client’s
GWG Consultant) full discretionary authority to
manage the client’s Account (“Discretionary
Services”);
provide
investment
advice
client’s
Account
• non-discretionary services, whereby GWG or
Baird
and
recommendations but the client retains full
authority with respect to the management of
the
(“Non-Discretionary
Services”); and
contain
information about
• separately managed account (“SMA”) programs
and services, whereby an investment manager
manages the client’s Account according to a
strategy (each, an “SMA Strategy”) with full
discretionary authority, and GWG and Baird
provide additional consulting services to the
client (collectively, “SMA Services”).
Depending on their particular needs or objectives,
clients may use one or more of these Services.
Aggregation
described
below.
advisory services that are described in this
Brochure. That means that GWG and Baird are
required to act in the best interest of the client
when providing investment advisory services.
From time to time GWG and Baird may engage in
certain business practices or may
receive
compensation or other benefits that create a
potential for conflict between the interests of
clients and the interests of GWG and Baird. GWG
and Baird generally address potential conflicts of
interest by disclosing them to clients through
documents provided to clients, including, without
limitation, this Brochure, Brochure supplements
that
individuals
providing investment advice to clients and the
services they provide, and the agreements clients
enter into with GWG and Baird. In addition, Baird
has adopted internal policies and procedures for
GWG and Baird that require them to: provide
investment advice that is suitable for advisory
clients (based upon the information provided by
such clients); make full disclosure of all potential,
material conflicts of interest; act with utmost care
and good faith in dealings with advisory clients;
and seek to obtain “best execution” of advisory
client transactions. The specific business practices
that create potential conflicts of interest with
clients and additional measures used by GWG and
Baird to address them are discussed in other
sections of this Brochure.
A client should note that registration as an
investment adviser does not imply a certain level
of skill or training.
The Consulting Services
include: Financial
Strategy, Investment Strategy, Risk Management,
Tax Planning, Estates and Trusts, Philanthropic
Planning, Family Education, Sounding Board, and
Data
The
Discretionary Services include: GWG Investment
Management. The SMA Services include: GWG
Recommended Managers; Baird SMA Network
(“BSN”); and Dual Contract (“DC”). The Additional
Consultant Services are only provided to certain
clients upon request by a client and agreement to
do so by GWG. GWG primarily provides
Consulting Services and recommends the GWG
Investment Management Service and GWG
Recommended Managers Service to clients when
appropriate. GWG will infrequently recommend
the other Services when GWG believes it is
appropriate for a particular client.
Summary of GWG’s Services
This Brochure describes certain
investment
advisory programs and services that GWG and
Baird offer to clients (“Services”) and applies to
each advisory account advised by GWG
(“Account”).The
investment advisory services
offered under the Services generally include
investment advice and consulting services, which
are provided by Baird PWM’s home office
investment professionals or GWG, and, depending
upon the Service that a client selects, the Service
may include portfolio management. The Services
consist of:
funds and exchange
traded
consulting
services
(“Consulting
• certain
Services”);
Generally, GWG provides clients with analysis and
recommendations on investment managers and
strategies. Investment strategies typically may
include either public or private securities, private
institutional
placements,
limited partnerships,
mutual
funds
(“ETFs”). Often these investment managers or
strategies may be affiliated with external
custodians. GWG will assist clients in evaluating
custodians and negotiating custodial fees, trading
commissions, as well as, investment management
fees.
• discretionary services, whereby a client gives
GWG or Baird (including Baird PWM’s home
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Implementation Manager will manage the client’s
Account with full discretionary authority according
to the strategy selected by the client. Otherwise,
if the client selects a Manager-Traded Strategy,
the investment manager will directly manage the
client’s Account with full discretionary authority as
more fully described below.
the client has
The SMA Services are generally offered under a
“single contract” arrangement. Under a single
contract arrangement, a client enters into an
advisory agreement with GWG and Baird, and
Baird, in turn, enters into a subadvisory or similar
agreement with the investment manager on the
client’s behalf. This type of arrangement is
frequently referred to as a single contract
arrangement because there is only one contract
between the client and GWG and Baird; the client
does not have an agreement directly with the
client’s investment manager. Under the Dual
Contract Program, a client has a “dual contract”
arrangement, meaning
two
contracts; one contract with GWG and Baird and
another contract with the client’s investment
manager.
Baird is also registered with the SEC as a broker-
dealer under Securities Exchange Act of 1934, as
amended (the “Exchange Act”). Baird, in its
capacity as broker-dealer, may also provide
clients with trade execution, custody and other
standard brokerage services. However, trade
execution services, whether provided by Baird or
another firm, are not included in the advisory fee
the client pays for the Services (“Advisory Fee”).
A client should note that the client will incur costs
in addition to the Advisory Fee. See “Fees and
Compensation—Other Fees and Expenses” below
for more information.
Certain Programs may allow a client to invest in
groups of mutual funds and ETFs (referred to as
“sleeves”) and other model portfolios of securities
managed by Baird PWM (such sleeves and model
portfolios collectively, “PWM-Managed Portfolios”).
The SMA Programs allow a client to select among
a variety of SMA Strategies offered by third party
investment managers (“Other Managers”), which
may include Other Managers affiliated with,
related to, or otherwise associated with Baird
(“Associated Managers”), or Baird to manage the
client’s Account.
tend
GWG and Baird tailor advisory services to the
individual needs of clients. Each Service is
designed to address different investment needs of
clients. All of the Services discussed in this
Brochure may not be appropriate for every client.
For example, the Services may not be appropriate
for clients who have low or no trading activity,
who desire to pay transaction-based fees, who
maintain their accounts invested in high levels of
cash or other concentrated positions, who do not
want ongoing professional investment advice or
account monitoring, who
to execute
transactions without the recommendation or
advice of an advisor, which are commonly
referred to as “unsolicited” transactions, or who
intend to utilize an investment strategy, product
or solution that is not available in a Service.
and bonds
(collectively,
Baird has engaged an overlay management firm,
Envestnet Asset Management, Inc. (the “Overlay
Manager”) to provide certain subadvisory services
to clients that participate in certain SMA Services.
The SMA Services make available two types of
SMA Strategies: (1) manager-traded strategies,
whereby the manager itself manages a client’s
Account and conducts the trading to implement
the SMA Strategy selected by the client (a
“Manager-Traded Strategy”); and (2) model-
traded strategies, whereby the manager does not
manage a client’s Account (a “Model Provider”)
but instead provides a model portfolio (“Model
Portfolio”) to an overlay management firm, which
may include the Overlay Manager, Baird or other
third party
firm (each, an “Implementation
Manager”), that in turn manages a client’s
Account and conducts the trading to implement
the SMA Strategy selected by the client (a
“Model-Traded Strategy”). If a client selects a
Model-Traded Strategy, the Model Provider will
provide the Model Portfolio and updates to the
the
Implementation
Manager,
and
Some Services offer clients the ability to pursue
alternative investment strategies (“Alternative
Strategies”) or other non-traditional or complex
investment strategies that involve special risks
not apparent in more traditional investments like
stocks
“Complex
Strategies”). Similarly, some Programs offer
clients the ability to invest in non-traditional or
real assets (“Non-Traditional Assets”). Some
Programs also offer the ability to invest in
investment products
that pursue Alternative
Strategies (“Alternative Investment Products”) or
other Complex Strategies (collectively, “Complex
these
Investment Products”). The use of
involves
strategies and
investment products
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BGWG F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
special risks, and a client should not engage in a
strategy or purchase an investment product
unless the client understands the related risks.
See “Additional Service Information—Complex
Strategies and Complex Investment Products”
and “Methods of Analysis, Investment Strategies
and Risk of Loss—Principal Risks” below for more
information.
allocation
strategies
have
been selected for inclusion in certain Services or
are made available to clients through Service
Accounts (“Associated Investment Products and
Services”). Associated Investment Products and
Services generally consist Funds managed,
advised or sponsored by Baird or Associated
Parties (“Associated Funds”) and other investment
products managed, advised or sponsored by Baird
or Associated Parties (collectively, “Associated
Investment Products”), and SMA Strategies
managed or advised by Baird or Associated
Managers (“Associated SMA Strategies”). Baird
and GWG Consultants may use, select or
recommend Associated Investment Products and
Services. This may present a conflict of interest. A
client is free at any time to select investment
products and services that are not associated with
Baird. For specific information about Associated
Parties and Associated Investment Products and
Services, see “Other Financial Industry Activities
and Affiliations” below.
include
a
client’s
age,
the
A client’s GWG Consultant will offer or
recommend appropriate Services,
investment
strategies, and investment products and services
based upon a client’s investment profile and an
Account’s investment objective, which establishes
an Account’s investment return objective and risk
investment profile will
tolerance. A client’s
generally
other
investments, financial situation and needs, tax
status, investment goals, investment experience,
investment time horizon, liquidity needs, risk
tolerance and other relevant information provided
by a client and updated from time to time.
Although a GWG Consultant may offer or
recommend appropriate options, a client will
ultimately select
investment objective,
Services, investment strategies, and investment
products and services for an Account.
Certain Services make available asset allocation
investment strategies. Asset allocation strategies
involve investing in one or more categories of
assets, such as equity securities, fixed income
securities, Non-Traditional Assets, Alternative
Investment Products and cash, and one or more
subcategories of assets, called asset classes.
Asset
varying
investment objectives and investment strategies.
Some asset allocation strategies use strategic
investment strategies, which involve investing
accounts in accordance with a predetermined
target allocation to different asset classes. Some
asset allocation strategies use tactical investing,
which typically involves tactically and actively
adjusting account allocations to different asset
classes based upon the manager’s perception of
how those asset classes will perform in the short-
term. Some asset allocation strategies involve the
use of both strategic and tactical investment
strategies, sometimes referred to as dynamic
strategies. Asset allocation strategies may be
implemented using a variety of investment types,
such as individual securities, mutual funds and
exchange traded products (“ETPs”), including
ETFs and exchange traded notes (“ETNs”). The
amount allocated to an asset class or investment
type varies by strategy, and some strategies may
have little or no allocation to one or more asset
classes or types of investments described above.
See “Methods of Analysis, Investment Strategies
and Risk of Loss—Investment Strategies—Asset
Allocation Strategies” below for more information.
funds, ETFs, unit
The Services make available many different
investment products and services offered by third
parties that are not associated with Baird, such as
mutual
investment trusts
(“UITs”), collective investment trusts (“CITs”),
private equity funds, hedge funds, private funds
and other investment pools (collectively “Funds”).
However, certain
investment products and
services managed, advised or sponsored by Baird
or other parties affiliated with, related to, or
including
otherwise associated with Baird,
Associated Managers (“Associated Parties”), have
A client that wishes to participate in a Service will
enter into a client relationship agreement or other
investment advisory agreement with GWG and
client’s
(“advisory agreement”). The
Baird
advisory agreement will contain the specific terms
applicable to the services selected by the client,
fees payable by the client, and other terms
applicable to the client’s advisory relationship with
GWG and Baird. A client should note that the
client’s advisory relationship with GWG and Baird
does not begin until they enter into the applicable
advisory agreement with the client, which occurs
when Baird PWM’s Home Office has accepted the
client’s advisory agreement and determined that
4
BGWG F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Service
all of the client’s paperwork is in order. See
“Additional
Information—Account
Requirements” below for more information.
flow. Cash
Subject to the agreement of GWG, a client may
impose reasonable restrictions on the securities or
types of securities to be held in the client’s
Account. Please see “Investment Discretion”
below for more information. Clients may negotiate
with GWG to provide other investment advisory
services.
the
“financial
comprehensive financial plan that GWG refers to
as a “financial roadmap”. The financial plan is
based upon GWG’s analysis of a client’s assets,
flows are
liabilities, and cash
determined on an after-tax basis. The goal is to
develop a financial plan that holistically considers
a client’s entire balance sheet, goals and
objectives, including liquidity needs, and a client’s
ability and willingness to accept risk. A client’s
goals, objectives, and ability and willingness to
accept risk may be determined through in person
meetings or based upon a client’s responses and
information provided to GWG through the Client
Profile Questionnaire. Using information from
Accounts held at Baird as well as other
information provided to GWG by the client, GWG
will provide the client an updated personal
balance sheet on a quarterly basis. Financial
planning and
roadmap” are
generally updated annually or on as need basis.
As mentioned above, Baird, in its capacity as
broker-dealer, may also provide GWG clients with
trade execution, custody and other standard
brokerage services. For this reason, a client may
also enter into a client relationship agreement or
other account agreement with GWG and Baird
(“account agreement”) if the client has not
already done so. The client’s account agreement
authorizes GWG and Baird to execute trades for,
and perform related brokerage and custody
services to, the client’s Account. Baird generally
does not permit a client to include assets in the
client’s Account that are held by a third party
custodian or that are otherwise held outside of a
Baird account (“Held-Away Assets”), although
GWG will provide Consulting Services on Held-
Away Assets when requested by a client and
agreed to by GWG.
Service
has
different
fixed
intermediate-term
short-term
fixed
Each
structures,
administration, types and levels of service, and
fees and expenses. In particular, a client should
note that the
investment advisory services
provided by GWG and Baird, including the depth
of
initial and ongoing research, evaluation,
monitoring and review of the investments in a
client’s Account, varies by Service and the
investments selected for the Account.
time
to
that GWG and Baird provide
The foregoing discussion of the Services is only a
summary. More specific information about the
Services and the particular investment advisory
in
services
connection with each Service are
further
described below and in the client’s advisory
agreement. Clients are encouraged to review this
Brochure and their advisory agreement carefully.
Using a variety of tools, including the financial
roadmap, GWG will develop and recommend a
for
long-term,
the client’s
target allocation
investments, known as a
strategic asset
allocation. The strategic allocation represents the
manner in which GWG believes a client’s assets
should be invested over longer periods of time,
such as five to seven years. When developing the
strategic allocation, GWG generally focuses on a
client’s allocation to, and balance between, assets
that GWG characterizes as “More Risky” and “Less
Risky”. GWG generally defines Less Risky assets
to include the following types of assets: taxable or
tax-exempt
income
income
investments,
investments and cash and cash equivalents. More
Risky assets include all other asset types, such as
equity securities, private equity investments, real
estate, hedge funds, commodities and privately-
held operating businesses should a client have
any. From
time, GWG may also
recommend tactical asset allocations based on
GWG’s perception of how certain asset classes will
perform in the shorter term. Tactical asset
allocation typically involves having allocations to
the More Risky and Less Risky asset groupings
that are either over- or under-weight compared to
the target strategic allocation for those asset
groupings, as well as over- or under-weight the
target allocations to individual asset types within
the More Risky or Less Risky asset groupings.
financial strategy service
includes
Consulting Services
Financial Strategy
the
The
development and periodic updating of a
A client should note that GWG’s categorization of
asset types into More Risky and Less Risky
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Away Assets and
they do not make any
recommendation as to whether a client should
buy, hold or sell any Held-Away Asset.
In certain instances when requested by a client,
GWG may provide a review of past performance
of Held-Away Assets Such performance reviews
and reporting show the historical performance of
a client’s assets and compares various aspects of
such performance to one or more benchmark
indices.
groupings is based on GWG’s view of the
historical performance of asset types and their
relative risks under normal economic and market
conditions. GWG’s use of the terms “More Risky”
and “Less Risky” should not be interpreted to
mean that the asset types included in the More
Risky asset grouping has
relatively higher
investment risk under every circumstance, or,
conversely, that the Less Risky asset grouping
has relatively lower investment risk under every
circumstance. A client should also note that the
particular asset grouping is subject to all of risks
associated with the asset classes and investments
included in the grouping and it is possible that the
Less Risky asset grouping could carry relatively
higher investment risk under certain economic or
market conditions. Please see ““Methods of
Analysis, Investment Strategies and Risk of
Loss—Principal Risks” below for more information.
report.
Inaccuracies
in
the
A client should note that the inclusion of Held-
Away Assets in a financial plan or performance
report is solely based on information provided by
the client or the client’s agent for the agreed-
upon period and that GWG and Baird do not
conduct a review of, or verify, such information,
and they do not guarantee the accuracy of the
information used to prepare the financial plan or
performance
the
information provided to GWG could impact the
client’s financial plan or performance report in a
materially negative manner.
strategy
and make
Investment Strategy
On an ongoing basis, GWG monitors the market
and the economy utilizing a variety of internal and
external resources to formulate an opinion as to
the current position of the market and economy
relative to the market and economic cycle. GWG
will provide a client a quarterly update either in-
person, or over a video or conference call. GWG
will also provide a client access to a quarterly
webinar and/replay in which GWG will provide an
update on its market and economic view.
GWG generally reviews a client’s then-current
target strategic
asset allocation versus
allocation and the target tactical allocation on a
quarterly basis. Accounts are generally re-
balanced automatically to the target tactical
allocation, generally quarterly if needed. As part
of this process, GWG will review a client’s current
investment
allocation
suggestions or recommendations to balance risk.
GWG believes the liquidity needs of a client are a
in any asset allocation
major consideration
suggestion or recommendation. Therefore, GWG
will review the expected liquidity within a client’s
balance sheet versus a client’s liquidity needs on
a quarterly basis. On an as need basis, GWG will
also review the liability side of a client’s balance
sheet, which includes loans and liabilities, and
provide a report on how those liabilities impact a
client’s cash flow, taxes, and risk.
to a client’s
Utilizing that
information along with GWG’s
analysis of market valuation and GWG’s
perception of how certain asset classes will
perform, GWG may suggest that a client make
adjustments
target strategic
allocations that were determined using the
financial strategy described above.
management
decisions
Investment strategy may involve the use of
different equity styles or strategies, such as: large
cap growth, large cap value, mid cap growth, mid
cap value, small cap growth, small cap value,
international and emerging market equities
strategies; different
income styles or
fixed
strategies, such as short or intermediate, taxable,
and tax-exempt bond, international and emerging
market bond, and high yield bond strategies. In
When requested by a client, GWG will include in
the client’s financial plan Held-Away Assets. A
client should note that Held-Away Assets are
included in a financial plan for the sole purpose of
assisting GWG with making overall asset
allocation recommendations to the client and
making
and
recommendations to the client as to client assets
held in Baird accounts. GWG’s role with respect to
Held-Away Assets included in a financial plan is
limited to performance monitoring and tracking
and periodically evaluating them in relation to the
clients’ investment policy/goals, potential risks
and returns, tax consequences and costs. Baird
and GWG do not provide any advice on Held-
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
information and assistance at
its GWG
many
instances, GWG provides
Investment Management Service
(described
below) to directly manage a core portfolio of
primarily passive and active mutual funds or
ETFs, across the different equity and fixed income
styles described above. This strategy will be
designed to be cost and tax efficient. GWG will
monitor the performance of each active or passive
mutual fund, or ETF investment manager, or
other “investment vehicle” that is part of a client’s
investment strategy on an ongoing basis relative
to the investment manager’s benchmark and peer
group. GWG will also regularly review the cost
and tax efficiency of each investment vehicle.
they are
titled
strategy
described
that
the characteristics of each
in
GWG’s
asset
and reduce estate tax impact. GWG may also
review the service offering of a client’s existing
estate attorney compared to alternative estate
attorneys identified by the client. As needed,
GWG will update a client’s estate attorney as to
relevant changes to the client’s Accounts and
financial or investment strategy. While trust
administration is the duty of a client’s trustee(s)
in trust
and custodian(s), GWG will assist
administration, as needed, by providing relevant
Account
the
direction of the trustee(s). As needed, GWG will
review beneficiary designations with a client
making sure any Accounts or investments held at
Baird that require such designation have the
designation intended by the client. Also as
needed, GWG will review all client Accounts
and/or trust Accounts held at Baird, and accounts
or investments held by the client or at other
firms, assuming the client has provided access to
information on accounts or investments not held
in
at Baird, making sure
accordance with the client’s instructions. As it
relates to estate planning, GWG will review, on an
annual basis, any client trust or partnership to
ensure
is
allocation
considered
recommendations made to a client.
Risk Management
When performing risk management services,
GWG seeks to analyze and review with a client
the risks identified in the financial planning
process described above. GWG seeks to minimize
investment risk through an asset allocation and
above.
investment
Additionally, as needed, GWG will work with
resources internal to Baird or third parties to
evaluate a client’s non-investment risks that can
be addressed by life, annuity, long-term care, and
umbrella insurance policies. GWG will rely on the
financial planning process and input from either
resources internal to Baird or third parties to
determine the appropriateness of a client’s
current life, annuity, long-term care, and umbrella
insurance coverage.
Philanthropic Planning
At the direction from a client, GWG will review the
client’s charitable giving plan and assist the client
with an efficient giving strategy, relying on both
internal resources and input from third parties. As
needed and requested by the client, GWG will also
assist a client in identifying a philanthropic
advisor as well as assist a client with an analysis
of the pros and cons of private foundations, donor
advised
funds, and direct giving strategies.
Additionally, on an as needed basis, GWG can
help a client identify appropriate assets for
charitable giving. This would typically include
identifying highly appreciated securities or
investments. GWG will also assist a client by
coordinating direct asset transfers to charitable
organizations as designated by the client.
tax efficiency across
Tax Planning
At a client’s direction, GWG will work directly with
a client’s existing tax advisors in an effort to
manage and reduce ordinary income and capital
gains tax impact. GWG may also review the
service offering of a client’s existing tax advisors
compared to alternative tax advisors identified by
the client. GWG will actively review accounts held
at Baird, and accounts or investments held by a
client or at other firms, assuming the client has
provided access to information on accounts or
investments not held at Baird, in an attempt to
increase
firms and
strategies. GWG will provide a client’s tax
preparer with the relevant data, to the extent
GWG is able to do so, required for a client’s yearly
tax preparation.
Family Education
At the direction of a client, GWG will assist the
client in organizing, planning the agenda for, and
facilitating a family meeting. From time to time,
or as needed, GWG will provide a client with
relevant financial literacy material. This material
may be produced by resources internal to Baird or
Estates and Trusts
At a client’s direction, GWG will work directly with
the client’s existing estate attorney to manage
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
third parties. At a client’s direction, GWG will work
with any other members of the client’s household
to help them develop their own financial plan.
Additionally, GWG will maintain any investment
documentation provided by a client as it relates to
investments that the client has made through
other firms or third parties. If requested by a
client, GWG will assist the client in tracking capital
calls related to private investments. A client will
also be able to set up check writing capability on
the client’s cash or money market Accounts held
at Baird to make capital call payments, or any
other payments they choose. Additionally, at a
client’s direction, GWG can have a check drawn
from the client’s Account and mailed to a recipient
designated by the client.
The foregoing list of Services described above is
intended to illustrate the types and levels of
service that GWG offers to clients. The actual
Services and levels of service to be provided to a
client will be set forth in the client’s agreement or
appended to the fee schedule to the agreement.
Discretionary Services
GWG Investment Management Service
Under the GWG Investment Management Service,
a client grants full discretionary authority and
management of the client’s Account to Baird and
the client’s GWG Consultant.
Sounding Board
Some clients may ask GWG to be a “sounding
board” and assist them in evaluating the general
investment or business
merits of certain
opportunities that are presented to the clients by
third parties (“Special Evaluations”). GWG team
members will work to use their experience,
expertise, and analytical capabilities to be a
resource as a client navigates financial issues and
evaluates investment opportunities presented to a
client by third parties as they arise. Typically, a
Special Evaluation involves GWG providing an
analysis of the financial aspects of the opportunity
presented that assesses the relative merits of the
opportunity in light of the client’s investment
policy/goals, potential risks and returns, tax
consequences, and costs. When additional
resources are needed to solve problems a client
faces, GWG may suggest third party experts be
brought to the table to provide relevant insight.
Upon request, GWG will also perform Special
Evaluations of purchases of substantial non-
investment-related assets being considered by
the client, such as a yacht, private plane, new
home, etc., focusing on the impact to the client’s
balance sheet and cash flow.
reviews
the client’s
is
Consultant makes
a
A client should note that this service solely
consists of GWG providing
information and
analysis to a client. In conducting Special
Evaluations, GWG does not recommend or provide
advice about the desirability of making the
investment or purchase and GWG makes no
recommendation as to whether a client should
buy, hold, or sell any such investment or other
limited to
property. Rather, GWG’s role
evaluating the investment or property in relation
to the clients’ investment policy/goals, potential
risks and returns, tax consequences and costs.
required
to prepare
the
In the GWG Investment Management Service, a
client’s GWG Consultant seeks to meet the client’s
particular investment needs by developing a
customized
investment strategy based upon
guidelines that are jointly established by the client
and
the
the client’s GWG Consultant. At
commencement of services, the client’s GWG
Consultant
investment
objectives and risk tolerance using the Consulting
Services described above. Based upon that review
and other information provided by the client, the
subsequent
GWG
recommendation to the client as to which
investment style the GWG Consultant believes is
best suited for the client. A client makes the final
decision as to which investment style is chosen
for the client’s Account. More specific information
as to how the client’s GWG Consultant will
manage the client’s Account is provided to the
client in connection with the opening of the
Account.
Data Aggregation
GWG will gather and organize the financial
paperwork, legal and tax documents for all client
assets, liabilities, trusts, foundations, and other
“financial
entities
roadmap” as described under “Financial Strategy”
above. GWG will administer all client Accounts
held at Baird providing monthly account
statements, in addition to the quarterly reports
described above under “Investment Strategy.”
A GWG Consultant typically recommends or
selects for client accounts investments in mutual
funds and ETFs that pursue the strategies
“Consulting
described under
the heading
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and
in various
authority to appoint investment managers to
manage the client’s Account with full discretionary
authority and to terminate or replace investment
managers for the client’s Account. The GWG
Recommended Managers Service is designed for a
client who wishes to have the client’s Account
managed by
investment managers that are
monitored by GWG and Baird on an ongoing
basis.
the
Service
Under the GWG Recommended Managers Service,
GWG and Baird determine
investment
managers (“GWG Recommended Managers”) and
their strategies (“GWG RM Strategies”) eligible to
participate in the Service through an initial and
ongoing evaluation process.
of
Services—Asset Allocation
Investment
Strategy Development” above. However, from
time to time, a GWG Consultant may make direct
types of securities,
investments
including, but not limited to, equity securities,
fixed income securities, Non-Traditional Assets
and certain Alternative Investment Products. All
or a portion of the assets in a client’s Account
may be held in cash or cash equivalents, including
securities issued by money market mutual funds,
or may be deposited in interest-bearing bank
accounts. Additional information about the types
of investments a GWG Consultant may use for
client accounts is contained under the heading
“Additional
Information—Permitted
Investments” below. For more information about
the GWG Investment Management Service, see
“Methods of Analysis, Investment Strategies and
Risk
Information—GWG
Loss—Service
Investment Management Service” below.
of
For more specific information about the managers
and SMA Strategies made available through the
GWG Recommended Managers Service and the
level of initial and ongoing research, evaluation,
monitoring and review performed by Baird on
those managers and SMA Strategies, see
“Methods of Analysis, Investment Strategies and
Risk
Information—GWG
Loss—Service
Recommended Managers Service” below.
Baird may remove any GWG Consultant or
strategy from the Service at any time and
transfer day-to-day management responsibility of
a client’s Account to another GWG Consultant or
Baird Financial Advisor at any time without
providing prior notice to, or obtaining the consent
of, a client.
involve
special,
GWG Recommended Managers have varying
investment objectives, styles and strategies, and
they may invest a client’s Account in various
types of securities, which will be chosen by the
GWG Recommended Manager and which may
include mutual funds, ETFs or other investment
products associated with the manager or Baird.
review
investing
in
Service
information
about
Important Information about GWG Investment
Management Service Accounts. GWG Consultants
may invest client accounts in illiquid securities
and Complex Investment Products. These types of
investments
sometimes
significant, risks and are not appropriate for all
clients. A client should understand those risks
those products. See
before
“Additional
Information—Complex
Strategies and Complex Investment Products”
and “Methods of Analysis, Investment Strategies
and Risk of Loss—Principal Risks” below for more
information.
the GWG
to
Clients are urged
Recommended Manager’s Form ADV Part 2A
contain additional
Brochure, which
should
important
GWG
the
Recommended Manager, including information
about
the GWG Recommended Manager’s
strategies, the types of investments the GWG
Recommended Manager may use for a client’s
Account, and the risks associated with investing in
a GWG RM Strategy. Such brochures are available
upon request.
Associated Investment Products are available to
clients under the GWG Investment Management
Service. This presents a conflict of interest. For
more information, see “Other Financial Industry
Activities and Affiliations” below.
initially selects
Some of the services provided under the GWG
Recommended Managers Service will be provided
to a client by a GWG Consultant assigned to the
client’s Account. A client, typically working with a
GWG Consultant,
the GWG
Recommended Manager and GWG RM Strategy
for the client’s Account. Thereafter, whenever
SMA Services
GWG Recommended Managers Service
The GWG Recommended Managers Service is a
program whereby a client provides Baird and the
client’s GWG Consultant with discretionary
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
faithfully
Baird or the client’s GWG Consultant deems it
necessary, Baird or the client’s GWG Consultant
will replace a GWG Recommended Manager or
another GWG
GWG RM Strategy with
Recommended Manager or GWG RM Strategy for
the client’s Account.
determines such action to be necessary and in the
client’s best interest. A client should note that
GWG and Baird do not monitor or ascertain
whether a third party Implementation Manager is
fully and
implementing the Model
Portfolio on a continuous basis. The client should
periodically discuss the Account’s performance
with the client’s GWG Consultant.
full discretionary authority
If a client participates in the GWG Recommended
Managers Service, the client authorizes and
directs GWG and Baird
to appoint GWG
Recommended Managers to serve as sub-adviser
to the client’s Account and to otherwise manage
the client’s Account in accordance with the terms
of the GWG Recommended Managers Service. The
client also authorizes and directs the GWG
Recommended Managers to manage the client’s
Account with
in
accordance with the GWG RM Strategy selected.
RM
Strategies
offered
below
Certain managers of Model-Traded Strategies
offered
through the Overlay Manager have
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a GWG client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of other
those Model
client accounts managed by
Providers. See “Additional Service Information—
Trading for Client Accounts—Trading Practices of
Investment Managers”
for more
information.
the client should understand
the discretionary
full discretionary authority
recommendation or
full discretionary authority
If a client’s Account is managed by an Other
Manager under the GWG Recommended Managers
that,
Service,
authority
notwithstanding
granted to Baird and the client’s GWG Consultant
under the Service: Baird and the client’s GWG
Consultant do not manage the Account and do not
otherwise have any influence over the Other
investment decisions or securities
Manager’s
selections, and therefore, Baird and the client’s
GWG Consultant are not responsible for the
decisions made by the Other Manager; and Baird
and the client’s GWG Consultant do not provide
any
investment advice
regarding the purchase or sale of investment
products made for the client’s Account.
Certain GWG RM Strategies are only made
available through Implementation Managers. The
through
GWG
Implementation Managers consist of Manager-
Traded Strategies and Model-Traded Strategies. If
a GWG RM Strategy offered
through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs GWG
and Baird to appoint the Implementation Manager
to serve as sub-adviser to the client’s Account. If
a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to manage the client’s
Account with
in
accordance with the selected GWG RM Strategy.
If a Manager-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to appoint the applicable
GWG Recommended Manager as sub-adviser, and
the client also authorizes and directs such GWG
Recommended Manager to manage the client’s
Account with
in
accordance with the selected GWG RM Strategy.
from
the
the
implement
the direction of
the
client’s Account,
the prior manager and
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Implementation Manager will
Account,
the Model Portfolio as
typically
proposed by the Model Provider. However, since
the Implementation Manager has discretionary
authority over
the
Implementation Manager may implement the
Model Portfolio differently than proposed by the
Model Provider if the Implementation Manager
From time to time, GWG or Baird may remove
investment managers
GWG
Recommended Managers Service, and GWG or
Baird may select a replacement manager to
manage the client’s Account. In such event, GWG
or Baird, at
the client’s
replacement manager, or the client’s replacement
manager may sell all or a portion of the securities
or other investments in the Account that were
the
managed by
replacement manager will reinvest the cash
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BGWG F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
proceeds of those sales. Sales of securities or
other investments could result in adverse tax
consequences for the client.
(“BSN
Strategies”)
eligible
in
Under the BSN Program, Baird determines the
investment managers (“BSN Managers”) and their
strategies
to
participate in the Program through a significantly
less rigorous evaluation process compared to the
GWG Recommended Managers Service. However,
a client should note that GWG and Baird do not
make any recommendation to clients regarding
representations
any BSN Strategy or any
regarding a BSN Manager’s qualifications as an
investment adviser or abilities to manage client
assets.
If GWG or Baird terminates an investment
manager from the GWG Recommended Managers
Service, a client authorizes GWG and Baird to
invest, with full discretionary authority, the assets
in the client’s Account previously managed by the
terminated
other
investment manager
securities, including, but not limited to, mutual
funds and ETPs. GWG’s and Baird’s discretionary
authority to make such other investments will
continue until a replacement investment manager
is selected or alternative arrangements are made
for the management of the client’s assets.
For more specific information about the managers
and SMA Strategies made available through the
BSN Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those managers and SMA
Strategies, if any, see “Methods of Analysis,
Investment Strategies and Risk of Loss—Service
Information—Baird SMA Network and Dual
Contract Programs” below.
the
A client who prefers to continue using an
investment manager that has been removed from
the GWG Recommended Managers Service, or
who directs or otherwise requests
that a
particular investment manager not recommended
by GWG be selected to manage the client’s
Account, will need to move to another Service,
such as the BSN Program. See “Baird SMA
Network Program” below for more information.
Clients who elect to do so will no longer receive
the same level of rigorous ongoing monitoring,
evaluation, or review of that investment manager
from GWG or Baird.
A client should only participate in the BSN
Program if the client wishes to take more
responsibility for monitoring the client’s Account,
the GWG Recommended Managers Program does
not contain an SMA Strategy that meets the
client’s particular needs, and
client
understands the risks of doing so.
have
varying
Industry
Activities
Important
Information about Affiliated
Managers. The GWG Recommended Managers
Service makes available to clients investment
services that are offered by Baird Advisors and
investment
Baird Equity Asset Management,
management departments of Baird. This presents
a conflict of interest. For more information, see
“Other
and
Financial
Affiliations” below.
BSN Managers
investment
objectives, styles and strategies, and they may
invest a client’s Account in various types of
securities, which will be chosen by the BSN
Manager and which may include mutual funds,
ETFs or other investment products associated with
the manager or Baird. Certain managers offer
strategies that exclusively invest in Funds (“Fund
Strategist Portfolios”).
a
is designed
client who wishes
Clients are urged to review the BSN Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the BSN
Manager, including information about the BSN
Manager’s strategies, the types of investments
the BSN Manager may use for a client’s Account,
and the risks associated with investing in a BSN
Strategy. Such brochures are available upon
request.
Baird SMA Network Program
The BSN Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
to
client. The BSN Program
accommodate
to
independently select an investment manager not
available in the GWG Recommended Managers
Program to manage the assets in the client’s
Account.
Some of the services provided under the BSN
Program may be provided to a client by a GWG
Consultant assigned to the client’s Account, and
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the client’s GWG Consultant may provide his or
her own advice and recommendations about BSN
Managers.
If a client participates in the BSN Program, the
client authorizes and directs GWG and Baird to
appoint the BSN Manager selected by the client to
serve as sub-adviser to the client’s Account. The
client also authorizes and directs the BSN
Manager to manage client’s Account with full
discretionary authority in accordance with the
BSN Strategy selected by the client.
Information—Trading
Certain managers of Model-Traded Strategies
offered
through the Overlay Manager have
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a GWG client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by those Model Providers. See
“Additional Service
for
Client Accounts—Trading Practices of Investment
Managers” below for more information.
influence over
reviewing
the
Certain BSN Strategies are only made available
through the Overlay Manager. The BSN Strategies
offered through the Overlay Manager consist of
Manager-Traded Strategies and Model-Traded
Strategies. If a client selects a BSN Strategy
offered through the Overlay Manager for the
client’s Account, the client authorizes and directs
GWG and Baird to appoint the Overlay Manager to
serve as sub-adviser to the client’s Account. If a
client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to manage the client’s Account
with full discretionary authority in accordance
with the BSN Strategy selected by the client. If a
client selects a Manager-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to appoint the applicable BSN
Manager as sub-adviser, and the client also
authorizes and directs such BSN Manager to
manage the client’s Account with full discretionary
authority in accordance with the BSN Strategy
selected by the client.
If a client’s Account is managed by an Other
Manager under the BSN Program, the client
should understand that: GWG and Baird do not
manage the Account and do not otherwise have
the Other Manager’s
any
investment decisions or securities selections, and
therefore, GWG and Baird are not responsible for
the decisions made by the Other Manager; GWG
and Baird do not provide any recommendation or
investment advice regarding the purchase or sale
of investment products made for the client’s
Account; and GWG and Baird only provide the
client with certain consulting services, which may
include the client’s GWG Consultant’s assistance
with determining the client’s financial needs,
investment goals and investment restrictions and
periodically
manager’s
performance. GWG and Baird do not undertake to
investment
provide any other consulting or
advisory services under the BSN Program unless
GWG and Baird agree to do so in writing.
the Account and
its
regarding
A client that participates in the BSN Program is
strongly encouraged to contact the client’s GWG
Consultant or BSN Manager on a periodic basis to
discuss:
investment
performance; the BSN Manager’s investment
philosophy and style (to determine if the BSN
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information
the BSN Manager,
described on the manager’s Form ADV, which is
available on the SEC's website at www.adviser
info.sec.gov.
If a client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the Overlay Manager will typically
implement the Model Portfolio as proposed by the
Model Provider. However, since the Overlay
Manager has discretionary authority over the
client’s Account, the Overlay Manager may
implement the Model Portfolio differently than
proposed by the Model Provider if the Overlay
Manager determines such action to be necessary
and in the client’s best interest. A client should
note that GWG and Baird do not monitor or
ascertain whether the Overlay Manager is fully
and faithfully implementing the Model Portfolio on
a continuous basis. The client should periodically
discuss the Account’s performance with the
client’s GWG Consultant.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Recommended Managers Service, may be more
appropriate for the client.
a
is designed
client who wishes
The BSN Strategies and BSN Managers made
available under the BSN Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the BSN Program,
GWG and Baird cannot appoint a replacement
manager or otherwise manage a client’s Account
assets. Given the terms of the BSN Program,
upon the withdrawal or removal of an investment
manager from the BSN Program, a client’s BSN
Program Account will be automatically removed
from the BSN Program and the Account will
become an unmanaged brokerage account, unless
the client provides contrary instructions to GWG.
See “Methods of Analysis, Investment Strategies
and Risk of Loss—Service Information—Baird SMA
Network and Dual Contract Programs” below for
further information.
Dual Contract Program
The DC Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
to
client. The DC Program
accommodate
to
independently select an investment manager not
available in the GWG Recommended Managers
Service or BSN Program to manage the assets in
the client’s Account. The Program is also designed
for a client that wants to independently select a
manager and negotiate the manager’s Portfolio
Fee rate directly with the manager.
Important Information about
the BSN
Program. Portfolios managed by 55I, LLC (d/b/a
55ip, “55ip”) are made available under the BSN
Program. 55ip uses research and other services
from Riverfront, an affiliate of Baird, in the
development of certain of those portfolios, and
Riverfront receives compensation from 55ip with
respect to those portfolios. This presents a conflict
of interest. For more information, see “Other
Financial Industry Activities and Affiliations”
below.
Under the DC Program, Baird determines the
investment managers (“DC Managers”) and their
strategies (“DC Strategies”) eligible to participate
in the Program through a significantly less
rigorous evaluation process compared to the GWG
Recommended Managers Service. However, a
client should note that GWG and Baird do not
make any recommendation to clients regarding
any DC Strategy or any representations regarding
a DC Manager’s qualifications as an investment
adviser or abilities to manage client assets.
appointment
For more specific information about the managers
and SMA Strategies made available through the
DC Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those managers and SMA
Strategies, if any, see “Methods of Analysis,
Investment Strategies and Risk of Loss—Service
Information—Baird SMA Network and Dual
Contract Programs” below.
in managing
the client’s Account
A client should only participate in the DC Program
if the client wishes to take more responsibility for
monitoring
the GWG
the client’s Account,
Recommended Managers Program does not
contain an SMA Strategy that meets the client’s
particular needs, and the client understands the
risks of doing so.
the
foregoing when deciding
DC Managers have varying investment objectives,
styles and strategies, and they may invest a
client’s Account in various types of securities,
which will be chosen by the DC Manager and
which may include mutual funds, ETFs or other
The BSN Program is designed to accommodate a
client who wishes to independently select an
investment manager that is not available in the
GWG Recommended Managers Service to manage
the client’s Account. The client assumes ultimate
responsibility for monitoring the client’s BSN
the BSN Manager’s
Program Account and
performance. A
and
client’s
continued retention of a BSN Manager to manage
the client’s Account are based ultimately upon the
client’s independent review of the BSN Manager
and the BSN Manager’s services. The client
ultimately determines that the BSN Strategy to be
used
is
consistent with the client’s stated investment
objectives and financial needs and risk tolerance.
Once retained by the client, a BSN Manager will
only be removed from managing the client’s BSN
Program Account upon the manager’s withdrawal,
removal from the BSN Program, or the client’s
direction to do so. A client should carefully
consider
to
participate in the BSN Program and also consider
whether another Service, such as the GWG
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment products associated with the manager
or Baird.
advisory services under the DC Program unless
GWG and Baird agree to do so in writing.
the Account and
its
the DC Manager’s
Clients are urged to review the DC Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the DC
Manager, including information about the DC
Manager’s strategies, the types of investments
the DC Manager may use for a client’s Account,
and the risks associated with investing in a DC
Strategy. Such brochures are available upon
request.
A client that participates in the DC Program is
strongly encouraged to contact the client’s GWG
Consultant or DC Manager on a periodic basis to
investment
discuss:
investment
performance;
philosophy and style (to determine if the DC
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information regarding the DC Manager, described
on the manager’s Form ADV, which is available on
the SEC's website at www.adviserinfo.sec.gov.
Some of the services provided under the DC
Program may be provided to a client by a GWG
Consultant assigned to the client’s Account, and
the client’s GWG Consultant may provide his or
her own advice and recommendations about DC
Managers.
Under the DC Program, DC Managers are offered
to clients through a dual contract arrangement,
and a client will need to enter into a separate
agreement with the DC Manager in addition to the
advisory agreement the client enters into with
GWG and Baird. A client participating in the DC
Program is solely responsible for negotiating the
client’s agreement with the client’s DC Manager,
and neither GWG nor Baird will participate or
advise a client regarding the terms of such an
agreement, the advisability of entering into such
an agreement, or the retention of the client’s DC
Manager unless GWG and Baird agree to do so in
writing.
The DC Strategies and DC Managers made
available under the DC Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the DC Program,
GWG and Baird cannot appoint a replacement
manager or otherwise manage a client’s Account
assets. Given the terms of the DC Program, upon
the withdrawal or removal of an investment
manager from the DC Program, a client’s DC
Program Account will be automatically removed
from the DC Program and the Account will
become an unmanaged brokerage account, unless
the client provides contrary instructions to GWG.
See “Methods of Analysis, Investment Strategies
and Risk of Loss—Service Information—Baird SMA
Network and Dual Contract Programs” below for
more information.
Information about
“Other Financial
the DC
Important
Program. Other
investment management
departments of Baird and Associated Managers
are available to clients under the DC Program.
This presents a conflict of interest. For more
information,
Industry
see
Activities and Affiliations” below.
appointment
reviewing
the
If a client’s Account is managed by an Other
Manager under the DC Program, the client should
understand that: GWG and Baird do not manage
the Account and do not otherwise have any
influence over the Other Manager’s investment
decisions or securities selections, and therefore,
GWG and Baird are not responsible for the
decisions made by the Other Manager; GWG and
Baird do not provide any recommendation or
investment advice regarding the purchase or sale
of investment products made for the client’s
Account; and GWG and Baird only provide the
client with certain consulting services, which may
include the client’s GWG Consultant’s assistance
with determining the client’s financial needs,
investment goals and investment restrictions and
periodically
manager’s
performance. GWG and Baird do not undertake to
investment
provide any other consulting or
The DC Program is designed to accommodate a
client who wishes to independently select an
investment manager. The client assumes ultimate
for monitoring the client’s DC
responsibility
the DC Manager’s
Program Account and
performance. A
and
client’s
continued retention of a DC Manager to manage
the client’s Account are based ultimately upon the
client’s independent review of the DC Manager
and the DC Manager’s services. The client
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
fund. See
in managing
the client’s Account
same
“Investment Discretion—
Conversion, Exchange or Sale of Certain
Investments” below for more information.
or
the
foregoing when deciding
including by
investing
ultimately determines that the DC Strategy to be
used
is
consistent with the client’s stated investment
objectives and financial needs and risk tolerance.
Once retained by the client, a DC Manager will
only be removed from managing the client’s DC
Program Account upon the manager’s withdrawal,
removal from the DC Program, or the client’s
direction to do so. A client should carefully
consider
to
participate in the DC Program and also consider
whether another Service, such as the GWG
Recommended Managers Service, may be more
appropriate for the client.
and
venture
capital
and
to
such
as
options,
is contained under
“Methods of Analysis,
Other SMA Strategy Information
Certain SMA Strategies are available through
multiple Services. The overall cost of an SMA
Strategy and the types and levels of service
provided to a client in connection with an SMA
Strategy will vary depending upon the particular
Service selected by the client. Certain managers
offer lower Portfolio Fee rates to clients through
the DC Program compared
the GWG
Recommended Managers or BSN Programs. A
client considering an SMA Strategy should discuss
with client’s GWG Consultant SMA Strategy
availability and the different Portfolio Fee rates,
costs, and the types and levels of service
provided in connection with the different Services.
A client is solely responsible for selecting the SMA
Strategy and the Service in which the client’s
Account will participate.
and Risk
of
invested
in concentrated and
Complex Strategies and Complex Investment
Products
Some Services offer clients the ability to pursue
other Complex
Alternative Strategies
Strategies that involve special risks not apparent
in more traditional investments like stocks and
bonds. Complex Strategies may be pursued in
multiple ways,
in
alternative mutual funds, ETFs, hedge funds,
managed futures, private equity funds and SMAs
third party managers. Some
managed by
Complex Strategies
in Non-Traditional
invest
Assets, such as real estate, commodities (which
may
include metals, mining, energy and
agricultural products), currencies, movements in
securities indices, credit spreads and interest
rates,
buyout
investments in private companies. Some Complex
Strategies engage in the use of margin or
leverage or selling securities short (“short sales”).
Some Complex Strategies invest in derivative
instruments
convertible
securities, futures, swaps, or forward contracts.
Complex Investment Products generally engage in
one or more Complex Strategies. Additional
information about Alternative Strategies and
the
Complex Strategies
heading
Investment
Strategies
Loss—Investment
Strategies—Alternative Strategies and Complex
Strategies” below. Additional information about
Complex Strategies and Complex Investment
Products, generally, is provided below.
Non-Traditional Assets
information about
currencies,
securities
A client should note that certain SMA Strategies
less
may be
diversified portfolios of securities and may involve
the use of leverage, margin, and options. A client
should discuss with the client’s GWG Consultant
the specific strategies and investments used by a
manager. Additional
the
strategies and investments used by a manager
are available in a manager’s Form ADV Part 2A
Brochure.
tokens
investment
Non-Traditional Assets, such as investments in
commodities,
indices,
interest rates, credit spreads, private companies,
and digital assets, such as cryptocurrencies, non-
stablecoins, and
(“NFTs”),
fungible
tokenized
products (collectively,
“Digital Assets”) may be used for diversification
purposes. They may also be used to try to reduce
market and inflation risk. The performance of
Non-Traditional Assets may not correspond to the
performance of the stock markets generally, and
investments
in Non-Traditional Assets will
generally impact an account’s returns differently
than more traditional investments like stocks or
bonds. Non-Traditional Assets are subject to risks
Additional Service Information
Conversion, Exchange or Sale of Certain
Investments
By participating in a Service, a client authorizes
GWG and Baird to convert or exchange any
shares of Funds, such as mutual funds, ETFs,
closed-end funds, UITs, Complex Investment
Products, and other similar investment pools, held
in the client’s Account to a class of shares of the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
that are different from, and in some instances,
greater than, other assets like stocks and bonds.
Non-Traditional Assets are generally more difficult
to value, less liquid, and subject to greater
volatility compared to stocks and bonds.
of the securities sold short does not decline below
the price at which they were originally sold. This
risk of loss is theoretically unlimited, as there is
no cap on the amount that the price of a security
may appreciate.
Margin and Leverage
Margin
Clients should note that investment managers
investment
managing a client’s Account or
products in the client’s Account may also engage
in short sales. Thus, a client’s Account will be
subject to short sales risks if the investment
manager managing the client’s Account or an
the client’s Account
in
investment product
engages in short sales.
Options and Other Derivative Instruments
Derivative Instruments
instruments,
securities,
futures,
Margin involves borrowing money from a firm,
such as Baird, to buy securities or other property.
If a client wishes to pay for securities by
borrowing part of the purchase price from Baird, a
client must open a margin account with Baird, and
Baird may provide the client with a margin loan.
Securities held in a client’s margin account are
used as Baird’s collateral for the margin loan. The
value of the collateral in the margin account must
be maintained at a certain level relative to the
margin loan for the duration of the loan. If the
securities in the margin account decline in value,
so does the value of the collateral supporting the
margin loan, and as a result, Baird may take
action, such as issue a margin call and sell
securities in the account.
Leverage
than,
the
instruments. While
returns,
traditional
investments.
Investing
involves
Leverage generally attempts to obtain investment
exposure in excess of available assets through the
use of borrowings, short sales and other
leverage can
derivative
potentially enhance
can also
it
exacerbate losses if changes in the markets, or
the values of the investments subject to the
leverage, are adverse to the strategy being
pursued. The use of leverage may also increase
an Account’s volatility.
such as options,
Derivatives
convertible
swaps, and
forward contracts are financial contracts that
derive value based upon the value of an
underlying asset, such as a security, commodity,
currency, or index. Derivative instruments may be
used as a substitute for taking a position in the
underlying asset. Derivative instruments may also
be used to try to hedge or reduce exposure to
other risks. They may also be used to make
speculative investments on the movement of the
value of an underlying asset. The use of
derivative instruments involves risks different
risks
from, or possibly greater
associated with investing directly in securities and
other
in
derivatives also generally
leverage.
Derivatives are also generally less liquid, and
subject to greater volatility compared to stocks
and bonds.
Short Sales
Options
to benefit
Options transactions may involve the buying or
writing of puts or calls on securities. In some
cases, Baird may require clients to open a margin
account to engage in options trading.
security or
from an
Short selling attempts
anticipated decline in the market value of a
security. To affect a short sale, a client sells a
security the client does not own. When a client
sells a security short, Baird borrows the security
from a lender and makes delivery to the buyer on
the client’s behalf. Because short sales involve an
extension of credit from Baird to the client, a
client must use a margin account. A client must
also eventually purchase the same shares sold
short and return them back to the lender. It is
possible that the prices of securities that a client
sells short may increase in value, in which case
the client may lose money on the short position.
Short selling thus runs the risk of loss if the price
With a call option, the purchaser has the right to
buy, and the seller (writer) the obligation to sell,
the underlying
index at a
predetermined price (i.e., the exercise or strike
price) prior to expiration of the option. The
premium paid to the seller (writer) for the option
is in consideration for the underlying obligations
imposed on the seller should the option be
exercised. With a put option, the purchaser has
the right to sell, and the seller has the obligation
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
to buy, the underlying security or index at the
exercise price prior to expiration of the option.
Clients should note that investment managers
managing a client’s Account or
investment
products in the client’s Account may also engage
in options transactions. Thus, a client’s Account
will be subject to options risks if the investment
manager managing the client’s Account or an
investment product
the client’s Account
in
engages in options transactions.
Complex Investment Products
Products
include
futures, but also
In buying a call option, the purchaser expects
that the market value of the underlying security
or index will appreciate, which would enable the
purchaser of a call to buy the underlying security
or index at a strike price lower than the prevailing
market price. The purchaser of the call option
makes a profit if the prevailing market price is
greater than the sum of the strike price plus the
premium paid for the option. The seller of a call
option earns income in the form of the premium
received from the purchaser for the option and
expects that the market value of the underlying
security or index will depreciate such that the
option will expire without being exercised. The
seller of a call option makes a profit if the
prevailing market price of the underlying security
or index is less than the sum of the strike price
plus the premium received.
ETNs,
business
Complex Investment Products typically invest
primarily in Non-Traditional Assets or engage in
one or more Complex Strategies. Complex
Investment
Alternative
Investment Products, such as hedge funds, funds
of hedge funds, private equity funds, funds of
private equity funds, private debt funds, and
managed
include other
investments
pursuing Complex Strategies,
including but not limited to, exchange or swap
funds, leveraged funds, inverse funds, and other
special situation funds, structured certificates of
(“structured
deposit and
structured notes
products”),
development
companies (“BDCs”), real estate investment trusts
limited partnerships
(“REITs”), and master
(“MLPs”).
thereby making
website
In addition, a client should be aware that more
traditional investments, such as mutual funds,
ETFs, UITs and variable annuities may also pursue
Complex Strategies,
them
Complex Investment Products. A client should
carefully review the prospectus or other offering
document for each investment and understand
the strategy being pursued before deciding to
invest. More detailed information about mutual
funds, ETFs, UITs and variable annuities is
available
at
Baird’s
on
bairdwealth.com/retailinvestor.
In buying a put option, the purchaser expects that
the market value of the underlying security or
index will depreciate, which would enable the
purchaser of a put to sell the underlying security
or index at a strike price higher than the
prevailing market price. The purchaser of the put
option makes a profit if the prevailing market
price is less than the sum of the strike price and
the premium paid for the option. The seller of a
put option earns income in the form of the
premium received from the purchaser for the
option and expects that the market value of the
underlying security or index will appreciate such
the option will expire without being
that
exercised. The seller of a put option makes a
profit if the prevailing market price of the
underlying security or index is greater than the
difference between the strike price and the
premium.
Additional Important Information
losses
in
In purchasing a put or call option, the purchaser
faces the risk of loss of the premium paid for the
option if the market price moves in a direction
opposite to what the purchaser had expected. In
selling or writing an option, the seller faces
significantly more risk. A seller of a call option
faces the risk of significant loss if the prevailing
market price of the underlying security or index
increases above the strike price, and a seller of a
put option faces the risk of significant loss if the
prevailing market price of the underlying security
or index decreased below the strike price.
The use of Complex Strategies or Complex
Investment Products is not appropriate for some
clients because they involve special risks. A client
should not engage in those strategies or invest in
those products unless the client is prepared to
experience significant
the client’s
Account. This is especially true for short selling,
which can result in unlimited losses as there is no
limit to the amount borrowed securities can rise in
value. See “Methods of Analysis, Investment
Strategies and Risk of Loss—Principal Risks”
below for more information. Before using those
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and
any
Investments”).
“Methods
of Analysis,
for investment (“Permitted Investments”) and
those that are not permitted in Program Accounts
(“Unpermitted
Permitted
Investments vary by Service. Although Baird
determines the Permitted Investments under
those Services, the level of initial and ongoing
evaluation, monitoring and review that GWG and
Baird perform on Permitted Investments varies.
For more information, see the descriptions of each
Service under “Advisory Business” above and
under
Investment
Strategies and Risk of Loss—Service Information”
below.
types of strategies or products, a client is strongly
urged to discuss them with the client’s GWG
Consultant
investment manager
managing the client’s Account. A client should
also carefully review the client’s agreements with
Baird and related disclosure documents, which the
client should have received when opening the
Account. Additional information about Complex
Strategies and Complex Investment Products is
provided under the heading “Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment Strategies—Alternative Strategies and
Complex Strategies” below and on Baird’s website
at bairdwealth.com/retailinvestor.
GWG or Baird may add Permitted Investments or
restrict client access to a Permitted Investment at
any time in their sole discretion.
for notifying
and
any
Service
Some Permitted Investments contain restrictions
that limit their use, and clients will not be
permitted to purchase or hold such investments
outside of an Account. See “Advisory Business—
Additional
Information—Account
Requirements” below for more information.
failure or delay
A client assumes responsibility for engaging in
Complex Strategies and investing in Complex
Investment Products. If a client determines that
the client no longer wants to engage in those
strategies or invest in those products, the client is
responsible
the client’s GWG
investment manager
Consultant
managing the client’s Account. GWG and Baird
are not responsible for any losses resulting from
any Other Manager’s
in
implementing any such instructions.
In certain limited instances, Baird may allow a
client to hold an investment in an Account that is
an Unpermitted Investment.
GWG
Investment Management Service.
Permitted Investments for the GWG Investment
Management Service generally include, but are
not limited to, the following types of investments:
Complex
Strategies
or
• equity securities, including, but not limited to,
common stocks, American Depositary Receipts
(“ADRs”), and ordinary shares,
including
whether exchange-traded, or over-the-counter
traded;
The use of Complex Strategies or Complex
Investment Products has a unique impact upon
the calculation of a client’s asset-based Advisory
Fee. See “Fees and Compensation—Calculation
and Payment of Advisory Fees” below for more
information. A client should also understand that
Baird and the client’s GWG Consultant have a
financial incentive to use, select or recommend
Complex
certain
Investment Products, including margin and short
sales. See “Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
stocks,
As a creditor, Baird may have interests that are
adverse to a client. Neither GWG nor Baird will act
as investment adviser to a client with respect to
the liquidation of securities held in an Account to
meet a call on a margin loan. Any such sale of
assets will be executed in Baird’s capacity as
broker-dealer and creditor and may, as permitted
by law, result in executions on a principal basis.
Permitted Investments
Under the Discretionary and Non-Discretionary
Services, Baird determines the asset categories
and investment products that clients may access
• fixed income securities, including but not limited
to, debt securities issued by domestic and
corporations and other entities;
foreign
securities
asset-backed
preferred
(including mortgage-backed securities and
collateralized mortgage obligations (“CMOs”));
convertible debt securities; obligations issued
by U.S., state, or foreign governments or their
agencies, instrumentalities, or authorities, such
as securities issued by the U.S. Treasury,
federal
federal government agencies or
government-sponsored enterprises
(“Agency
securities”), or foreign governments; municipal
funds;
securities; money market mutual
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
certificates of deposit (“CDs”) (primary or
secondary); commercial paper;
The types of investments that are not permitted
for the GWG Investment Management Service
generally include, but are not limited to:
• rights or warrants on equity securities and
written covered call equity options;
• Class B or Class C shares offered by mutual
funds or any other class of mutual fund shares
that impose a contingent deferred or level sales
charge (back-end or level load);
• inverse funds;
load-waived, or
for purchase; shares
• UITs that impose an initial or deferred sales
charge (load);
• put options;
• all annuities and insurance products;
or
options
on
• commodities,
futures
commodities, and commodity pools; and
investment
funds
• private
• open-end mutual funds shares that Baird has
selected for use in the Service, which generally
includes only those funds with which Baird has a
selling agreement and only those funds that are
institutional are
no-load,
allowed
that were
in a Baird brokerage
originally purchased
account and not sold when transitioned to an
advisory account will held in the account as
non-billable assets when the original purchase
front-end sales charge
was subject to a
(typically 36 months) or until the Contingent
Deferred Sales Charge (CDSC) expires (typically
13 months) if subject to a back-end sales
charge after which time they will be converted
to the appropriate advisory share class and
become billable assets;
and Complex
Investment Products that Baird has not selected
for use in the Services.
for use
in
• closed-end funds, ETFs, and UITs that have cost
fee-based
structures designed
investment advisory programs; UITs originally
purchased in a brokerage account and not sold
when transitioned to an advisory account will be
held as non-billable assets until the UIT
termination date at which time they will be
liquidated and the proceeds are billable;
SMA Services. Investment products under the
SMA Services are selected solely by
the
investment manager providing services to the
client. The investment products used by an
investment manager may include products that
Baird does not permit to be used in connection
with the GWG Investment Management Service
described above. A client should review the
investment manager’s Form ADV Part 2A
Brochure for more information.
• BDCs, publicly-traded REITs, certain non
publicly-traded (or private) REITs, and MLPs
(which may be organized as limited liability
companies (“LLCs”));
leveraged
• ETNs,
funds, and other special
situation mutual funds, and exchange or swap
funds;
Consulting Services. From time to time, GWG
may advise clients with respect to, or may
manage, certain Held-Away Assets such as
investments, and
private REITs, real estate
insurance products held by custodians other than
Baird even though those assets may not be
eligible for Accounts held at Baird. Any such
arrangement will be set forth in the client’s
advisory agreement.
infrastructure
• certain hedge funds, funds of hedge funds,
private equity funds, funds of private equity
funds, funds of real estate, structured products,
private debt funds, private real estate funds,
private
funds, and managed
futures that Baird has selected for use in the
Services; and
• cash and cash equivalents.
or
supervised
by
them
Unsupervised Assets
Under certain circumstances, Baird, in its sole
discretion, may accept a client request to hold an
asset in an Account that is not included in the
investment advisory services provided by Baird or
a GWG Consultant or otherwise monitored,
(an
overseen
“Unsupervised Asset”). For example, if Baird
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
service
If
a
client
holds
or
for
Goal Management
GWG and Baird make available to clients an
optional goal management
(“Goal
Management”). Goal Management provides clients
the ability to set a single, overall investment
objective for all or a portion of assets selected by
the client with the flexibility of using multiple,
eligible Advisory Accounts that may have different
investment strategies or objectives. If a client
elects to have Baird implement a plan of Goal
Management (a “Goal Management Plan”) using
two or more eligible Advisory Accounts (“Goal
Management Accounts”), the Goal Management
Accounts, taken together, will be managed or
advised by Baird and client’s GWG Consultant in
such a way so as to seek to achieve a single,
investment objective (“Goal
overall goal or
Management Objective”) chosen by the client.
Each individual Account included in a Goal
Management Plan will also be managed or advised
by Baird and client’s GWG Consultant
in
accordance with the terms of the applicable
Advisory Program or Service and any investment
strategy or objective applicable to the Account.
However, to the extent consistent with the terms
applicable to an Account included in a Goal
individual Account
Management Plan, each
included in the Goal Management Plan may be
managed or advised in any manner believed by
Baird or the client’s GWG Consultant to be
the Goal
appropriate
necessary
Management Accounts, taken together, to seek to
achieve the Goal Management Objective.
permits a client
to hold an Unpermitted
Investment in an Account, the asset is typically
also considered an Unsupervised Asset. Baird, in
its sole discretion, may also designate an asset
that is otherwise a Permitted Investment as an
Unsupervised Asset under certain circumstances,
such as when a client acquires the asset in an
unsolicited transaction, transfers the asset from
firm or Baird
an account held at another
brokerage account, or continues to hold the asset
against Baird’s or the client’s GWG Consultant’s
recommendation.
an
Unsupervised Asset in an Account, the client
should understand that the Unsupervised Asset
may not be included in performance reports
provided to the client and that Baird and GWG
Consultants do not manage, provide investment
advice, or otherwise act as an investment adviser
with respect to the Unsupervised Asset, even if
the Unsupervised Asset is included in account
statements or performance reports provided to
the client. Because Baird and GWG Consultants do
not manage or provide investment advisory
services regarding Unsupervised Assets, no asset-
based Advisory Fee is charged on Unsupervised
Assets. While Unsupervised Assets are not subject
to the asset-based Advisory Fee, Baird may
impose additional fees upon Accounts holding
Unsupervised Assets. See “Other Fees and
Expenses” below for more information. A client
that holding an
should also understand
Unsupervised Asset in an Account may increase
the risk of trade errors, overinvestment, and
negative Account performance. A client should
consult the client’s GWG Consultant for further
information.
Special Considerations for the Services
Third Party Information
is contained under
The Goal Management Objectives that Baird
makes available to clients as part of Goal
Management include: (1) All Growth; (2) Capital
Growth; (3) Growth with Income; (4) Income
with Growth; (5) Conservative Income; and (6)
Capital Preservation. A description of those
objectives
the heading
“Methods of Analysis, Investment Strategies and
Risk of
Loss—Investment Strategies—Asset
Allocation Strategies” below.
When providing services to a client, GWG and
Baird rely on information provided by third parties
and other external sources believed to be reliable,
including, but not limited to, information provided
by investment managers. GWG and Baird assume
that all such information is accurate, complete
and current. GWG and Baird do not conduct an in-
depth review of, or verify, such information, and
they do not guarantee the accuracy of the
information used. See “Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis” below for more information.
In certain circumstances, clients that are part of
the same household may include their eligible
Advisory Accounts in the same Goal Management
Plan (a “Household Goal Management Plan”). It is
the client’s sole responsibility to notify GWG that
the client is part of a household so that GWG is
aware of the client’s eligibility for a Household
Goal Management Plan. It is also the client’s sole
responsibility to notify GWG whenever the client
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
ceases to be part of a household if an Account is
part of a Household Goal Management Plan.
Failure to do so could have a materially negative
impact on applicable Accounts.
Tax Management Services
Many Services and managers make available tax
management strategies and services that are
intended to reduce the negative impact of U.S.
federal income taxes on an Account and enhance
Account performance by selectively
trading
investments in the Account to recognize or avoid
investment gains and losses.
An Account will be removed
from a Goal
Management Plan: (1) upon request or consent of
the client, (2) if the Account ceases to be an
eligible Advisory Account, (3) in the event the
Account is part of a Household Goal Management
Plan, if the client notifies GWG that the client
ceases to be a member of the applicable
household, or (4) upon written notice from Baird
that it is no longer able to manage the Account
according to the Goal Management Plan.
Certain Services and managers
include tax
management services as a default feature of the
Services or the manager’s services. A client that
wishes to opt an Account out of participation in a
tax management service should contact the
client’s GWG Consultant.
Tax management services are provided solely
based upon
information
the direction and
provided by a
client. The offering and
performance of tax management services to a
client’s Account does not constitute tax advice. A
client is ultimately responsible for all tax-related
consequences resulting from the client’s decision
to enroll in a Service or select a manager that
utilizes tax management services.
risks,
and
Given the nature of Goal Management, a client
enrolling Accounts in a Goal Management Plan
should understand that each Account enrolled in a
Goal Management Plan may not be invested in a
manner such that the individual Account alone
would be able to achieve the Goal Management
Objective. It is likely that one or more Accounts
included in a Goal Management Plan, taken alone,
will be managed or advised differently and will be
subject to greater or enhanced risks than would
be the case if the Account alone had the same
objective as the Goal Management Objective.
Such enhanced risks include, without limitation,
market risks, investment objective and asset
allocation risks, capitalization risks, investment
style risks, illiquid securities and liquidity risks,
concentration risks, frequent trading and portfolio
risks, Non-Traditional Assets and
turnover
Complex
Complex
Strategies
Investment Product risks.
for
tax
purposes
in
Information—Legal
and
Tax management strategies are not intended to,
and likely will not, eliminate a client’s U.S. federal
income tax obligations relating to investments in
an Account. Like all investment strategies, there
is no guarantee that the implementation of a tax
management strategy will be successful. A client’s
use of a tax management strategy may not
actually
lower a client’s tax obligations or
otherwise achieve a client’s tax goals. The
effectiveness of tax managed strategies and
services may be negatively
impacted by
applicable tax rules, such as the IRS wash sales
rules and straddle rules, which will disallow, limit
or defer a client’s ability to recognize losses in an
Account
specified
circumstances. Tax management strategies and
services also involve special risks. See “Additional
Service
Tax
“Methods of Analysis,
Considerations” and
Investment Strategies and Risk of Loss—
Investment
Management
Strategies—Tax
Strategies” below for more information.
included
in
A client should understand the terms of the tax
management services that will be implemented,
including the associated limitations, risks and
additional costs, if any, before enrolling an
Account in a Service or selecting a manager for
A client should note, particularly if the client
elects to include eligible Advisory Accounts in a
Household Goal Management Plan, that: if an
Account is removed from a Goal Management
Plan for any reason, including if the client ceases
to be a member of the same household, the
Service and strategy for the Account removed
from the Goal Management Plan will remain
unchanged unless a change is requested by the
client; further, the Account removed from the
Goal Management Plan will not be allocated assets
the Goal
from other Accounts
Management Plan unless the client and all other
applicable clients, if any, consent and direct Baird
to do so and then only to the extent permitted by
applicable law; and GWG and Baird will have no
liability for implementing a Goal Management Plan
as requested by the client.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
that Account. A client is strongly urged to consult
with the client’s tax advisor about potential tax
implications before enrolling an Account in a
Service or selecting a manager for that Account. A
client is also encouraged to discuss the client’s tax
management needs with
the client’s GWG
Consultant.
the
IRS wash
sales
GWG Tax Management Strategies
as part of the assessment process. The Baird
PWM Home Office or the GWG Consultant will
then reinvest (or recommend the reinvestment
of) the proceeds of such sale in one or more
replacement securities that the GWG Consultant
believes are not “substantially identical” for
purposes of
rules.
Replacement securities may
include, without
limitation, ETFs, cash, cash equivalents or other
securities. Unless the client instructs otherwise,
investment in replacement securities will be made
on a temporary basis and generally only for the
duration of any applicable IRS wash sale rule
period, currently 30 days after the sale, and
within a reasonable time thereafter, the proceeds
will be reinvested in a manner consistent with the
way the Account was invested prior to the
employment of the tax harvesting strategy.
the
implementation of
the
implementation of
Certain GWG Consultants offer tax management
investment strategies (“GWG TM Strategies”),
described below, to non-Retirement Accounts
enrolled in GWG Consultant-directed Services,
including the GWG Investment Management
Service. A client is encouraged to ask the client’s
GWG Consultant if GWG TM Strategies will be
used if the Account is enrolled in a Service. GWG
Consultants who offer GWG TM Strategies will
generally implement such strategies for Accounts
they manage on a discretionary basis unless a
client opts out by contacting the client’s GWG
Consultant. The Baird PWM Home Office will assist
with
the GWG TM
the
Strategies.
Generally,
tax
harvesting strategy is limited to open end mutual
fund and ETF positions with unrealized capital
losses over $1,000 for U.S. federal income tax
purposes, unless Baird and the client otherwise
agree.
Capital Gains Avoidance Strategy
investment strategies
Each GWG TM Strategy is a secondary investment
strategy designed
to achieve a secondary
objective of an Account to reduce the negative
impact of U.S. federal income taxes and each
such strategy is implemented together with the
for the
other primary
Account that are designed to achieve the client’s
primary investment objectives or goals.
The GWG TM Strategies features are not available
to Retirement Accounts.
for
capital
gains
Tax Harvesting Strategy
the GWG Consultant,
as
A capital gains avoidance strategy seeks to avoid
capital gains attributable to an investment in the
Account for U.S. federal income tax purposes by
selling the investment before the capital gain is
distributed by the issuer. When implementing a
capital gains avoidance strategy, the Baird PWM
Home Office or
the GWG Consultant, as
applicable, periodically, but at least annually,
monitors the issuers of investments held in the
Account
distributions
announcements and capital gains avoidance
opportunities. When an opportunity is identified,
the Baird PWM Home Office or the GWG
Consultant, as applicable, sells (or recommends
the sale of) such securities in the client’s Account
identified as part of the monitoring process in
order for the Account to avoid a capital gain
distribution made by the issuer. The Baird PWM
Home Office or the GWG Consultant will then
reinvest (or recommend the reinvestment of) the
proceeds of such sale in cash until the capital gain
distribution has been paid by the issuer, and then
the securities will be purchased again. If the
securities are sold at a loss, then Baird PWM or
the GWG Consultant may employ (or recommend
the employment of) the tax harvesting strategy
described above.
A tax harvesting strategy seeks to improve the
value of an Account, on a post U.S. federal
income tax basis, by offsetting capital losses in
the Account with capital gains. This strategy is
oftentimes referred to a “tax harvesting” or “tax
implementing a tax
loss harvesting”. When
harvesting strategy, the Baird PWM Home Office
or
applicable,
periodically, but at least annually, conducts an
assessment of the Account to identify capital
losses for tax harvesting opportunities. When an
opportunity is identified, the Baird PWM Home
Office or the GWG Consultant, as applicable, sells
(or recommends the sale of) certain securities in
the client’s Account in order for the Account to
recognize the unrealized capital losses identified
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
A client should also note that when normal
trading activity
for the client’s
is resumed
Account, such activity could generate taxable
gains or losses.
Third Party Manager Tax Management
Services
the
Generally, the capital gains avoidance strategy is
limited to open end mutual fund positions in a
client Account, and a mutual fund position will be
included in the implementation of the strategy
only if the potential net U.S. federal income tax
benefit to the Account related to such position is
estimated by Baird to be $1,000 or more. For
purposes of calculating the $1,000 threshold, the
Account’s current unrealized gain or loss in each
mutual fund position is analyzed in light of the
applicable amount of capital gains distribution
announced by the mutual fund company.
Some investment managers participating in the
SMA Services offer tax management services and
others do not. A client should consult the client’s
GWG Consultant or review
investment
manager’s Form ADV Part 2A Brochure for specific
information.
Additional Important Information about GWG’s
Tax Management Strategies.
Client-Directed Tax Management Strategies
implementation of a
responsibility
for
A client may direct GWG and Baird, and GWG and
Baird may agree, to implement an investment
strategy designed by the client or client’s tax
advisors for the client’s specific tax purposes (a
“client-designed strategy”). GWG and Baird do
the
not undertake any
development, evaluation or efficacy of any client-
designed strategy.
The
tax management
strategy is based upon Baird’s or the GWG
Consultant’s, as applicable, estimates of capital
gains and losses associated with investments in
client’s Account and information provided to them
by third parties, such as issuers of securities.
Capital losses will remain in an Account following
the implementation of a tax harvesting strategy,
and the Account will realize capital gains following
the implementation of a capital gains avoidance
the extent such estimates or
to
strategy,
information are incorrect.
responsible
for
selecting
for
Investment Objectives
Generally, every Account will have one of the
investment objectives described below. Although
a GWG Consultant may
recommend an
investment objective for an Account based upon
the information provided by a client, the client is
ultimately
the
investment objective
the Account. The
investment objective will determine, in part, and
limit the Services, investment products and
services that will be made available to the
Account.
in Baird’s or
judgment,
negatively
The implementation of the tax harvesting strategy
and capital gains avoidance strategy (or the
recommendation to implement a strategy) is done
in the sole discretion of the Baird PWM Home
Office or GWG Consultant, as applicable, and
securities may be excluded from implementation
of such strategies for a number of reasons,
including without limitation, the length of time the
security has been in the Account, the lack of a
replacement security acceptable to Baird or the
GWG Consultant, withdrawal and deposit activity
the Account, market conditions deemed
in
unfavorable by Baird or the GWG Consultant, or if
the GWG
doing so would,
Consultant’s
impact
management of the Account.
All Growth. An All Growth investment objective
typically seeks to provide growth of capital.
Typically, an Account pursuing an All Growth
investment objective will experience high
fluctuations in annual returns and overall market
value. Under normal market conditions, such an
Account generally invests nearly all of its assets in
equity securities. Such an Account may also hold
other types of investments.
The tax harvesting and capital gains avoidance
strategies are provided by Baird and GWG
Consultants on an Account-by-Account basis.
When employing such strategies for a client
Account, Baird does not monitor or consider the
trading activity in any other client account,
including any Account held at Baird or another
firm.
Capital Growth. A Capital Growth investment
objective typically seeks to provide growth of
capital. Typically, an Account pursuing a Capital
Growth
investment objective will experience
moderately high fluctuations in annual returns
and overall market value. Generally, under
normal market conditions, such an Account will
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
cash. Such an Account may also hold other types
of investments.
primarily invest in a mix of equity securities and
fixed income securities, with a significantly higher
allocation to equity securities. Such an Account
may also hold other types of investments.
for
a
client’s
specific
Growth with Income. A Growth with Income
investment objective typically seeks to provide
moderate growth of capital and some current
income. Typically, an Account pursuing a Growth
with Income investment objective will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of equity securities and fixed
income securities, with a bias towards equity
securities. Such an Account may also hold other
types of investments.
investment
objective
investment
Opportunistic. An Opportunistic
objective typically seeks to provide long term
growth
through capital appreciation and/or
income by utilizing an active management style
that shifts the percentage of assets held in
various investment categories to take advantage
of the manager’s perception of market pricing
anomalies, market sectors deemed favorable for
investment by the manager, the current interest
rate environment or other macro-economic trends
identified by the manager to achieve growth while
accounting
short,
intermediate and long term investment and/or
cash flow needs. Depending upon the investment
strategy used, an Account pursuing an
Opportunistic
could
experience high fluctuations in annual returns and
overall market value. The types of investments in
which such an Account may invest will also vary
widely, depending upon the particular investment
strategy used.
long-term growth by
investments based upon
Income with Growth. An Income with Growth
investment objective typically seeks to provide
current income and some growth of capital.
Typically, an Account pursuing an Income with
Growth
investment objective will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of fixed income securities and
equity securities, with a bias towards fixed income
securities. Such an Account may also hold other
types of investments.
in
to
implement a
typically
objective
and
overweighting
index or
Conservative Income. A Conservative Income
investment objective typically seeks to provide
current income. Typically, an Account pursuing a
Conservative Income investment objective will
experience relatively small fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, such an Account
will primarily invest in a mix of fixed income
securities, cash and equity securities, with a
significantly higher allocation to fixed income
securities. Such an Account may also hold other
types of investments.
Tactical. A tactical investment objective seeks to
tactically and
provide
actively adjusting account allocations to different
categories of
the
manager’s perception of how those investment
the short-term.
categories will perform
tactical
Strategies used
involve
investment
underweighting
account
allocations to certain asset classes, geographic
locations or market sectors relative to an
applicable long-term strategic asset allocation,
benchmark
the market generally.
Accounts with a tactical investment objective may
have investments focused or concentrated in
certain asset classes, geographic locations or
market sectors and they often experience higher
levels of trading and portfolio turnover relative to
accounts with other investment objectives.
A
Tax-Managed
indicates
that
the
account
Capital Preservation. A Capital Preservation
investment objective typically seeks to preserve
capital while generating current income. Typically,
an Account pursuing a Capital Preservation
investment objective will experience relatively
small fluctuations in annual returns and overall
market value. Under normal market conditions,
such an Account generally invests nearly all of its
assets in a mix of fixed income securities and
investment
Tax-Managed.
objective
is
transitioning from one investment strategy to
another using one or more tax management
strategies or tax management considerations. The
primary investment strategy or consideration for
Accounts with a Tax-Managed
investment
objective will involve tax management, and such
accounts may not be successful in pursuing any
other investment strategies, objectives or goals.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Goal. A Goal investment objective indicates that
the Account is a Goal Management Account that is
part of a Goal Management Plan and the Account
will be managed or advised in accordance with
the applicable Goal Management Objective.
Investment Objectives
For information about the risks associated with
the investment objectives described above, see
the section of the Brochure entitled “Methods of
Analysis, Investment Strategies and Risk of
Loss—Principal Risks—Risks Associated with
Certain
and Asset
Allocation Strategies” below.
rebate the distribution (12b-1) fees to a client if
the client is paying an asset-based Advisory Fee
on such investment; or (2) exclude such fund
shares from the calculation of the client’s asset-
based Advisory Fee (sometimes referred to as
“unbillable assets”) for such period of time that
Baird collects and retains the distribution (12b-1)
fee as further described under the heading “Code
of Ethics, Participation or Interest in Client
Transactions and Personal Trading—Participation
or Interest in Client Transactions—Investment
Product Selling or Servicing—Mutual Funds”
below. Clients should note that the Approved
Share Class for a mutual fund family is based
upon the average expense ratio for the class
across all mutual funds in the fund family and not
on a fund-by-fund basis. Further, the expenses of
every mutual fund can and will vary over time.
Therefore, while Baird has endeavored to select
the lowest cost share classes as described above,
in some instances, the Approved Share Class is
not the least expensive share class for a particular
mutual fund. Clients may be able to obtain a less
expensive share class in other Programs or at
another firm.
payments,
revenue
sharing
the applicable mutual
Interest
Baird receives certain compensation from mutual
fund families in the form of distribution (12b-1)
fees, shareholder servicing fees, transfer agency
fees, networking fees, accounting fees, marketing
and
support
administration fees. The amount of compensation
paid to Baird generally varies based upon the
share class of
fund
purchased by clients. Because the compensation
that Baird receives from certain mutual funds is
based upon share class purchased by clients,
Baird has a financial incentive to make available
to clients those share classes that provide Baird
greater compensation, which, in many instances,
would cause clients investing in those share
classes to incur higher ongoing costs relative to
other share classes made available by the fund
families. This presents a conflict of interest. Baird
addresses this conflict through the Share Class
Policy described above and through disclosure in
this Brochure. For more information about the
compensation that Baird receives from mutual
funds, see “Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading—Participation or
in Client
Transactions—Investment Product Selling and
Servicing—Mutual Funds” below.
Mutual Fund Share Class Policy
Most mutual funds offer different share classes.
While each share class of a given mutual fund has
the same underlying investments, those share
classes have different fees, costs and investment
minimums, and they provide different levels of
compensation to Baird. In an effort to provide
clients with appropriate low cost mutual fund
investment options for their fee-based investment
advisory accounts, Baird has established a mutual
fund share class policy (“Share Class Policy”) for
certain GWG-directed Services, including GWG
Investment Management (the “Share Class Policy
Services”). Typically, only one share class of a
given mutual fund family will be made available
for purchase by clients in the Share Class Policy
Services pursuant to the Share Class Policy (the
“Approved Share Class”). When selecting the
Approved Share Class for a mutual fund family,
Baird endeavors to select the share class with the
lowest expense ratio, based upon the average
expense ratio of the class across all mutual funds
in the mutual fund family, that are widely
available for trading on the mutual fund trading
platform of Charles Schwab & Co.,
Inc.
(“Schwab”). In selecting the share class for a
mutual fund family to be made available for
purchase by clients in the Share Class Policy
Services, Baird considers a number of factors,
including the number of funds within the fund
family that offer the share class, client positions
in and demand
funds, and the
for those
availability of the share classes and funds for
purchase on the Schwab mutual fund trading
platform. Generally, share classes designed for
retirement plans and those that pay a distribution
(12b-1) fee to Baird will not be permitted in those
Services, or, if such share classes are permitted
and the client’s Account is subject to an asset-
based fee arrangement, Baird will either: (1)
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a bank constitutes a direct obligation of the bank
and is not directly or indirectly Baird’s obligation.
Shares of mutual funds held in client Accounts
that do not meet the requirements of the Share
Class Policy will generally be converted to the
applicable Approved Share Class subject to
certain restrictions. The Share Class Policy is
subject to change at Baird’s discretion without
notice to clients. Additional information about the
Share Class Policy is available on Baird’s website
at bairdwealth.com/retailinvestor.
The Share Class Policy does not apply to the
portion of a UAS Account managed by third party
managers. Third party managers are responsible
for establishing their own criteria for selecting
investments, including mutual funds, if any.
Custody Services
Baird may provide custody services in connection
with the Services. See “Custody” below for more
specific information.
Any aggregate cash balances held by a client in
excess of the applicable aggregate deposit limit
are automatically invested in shares of a money
market mutual fund that Baird makes available in
the Money Market Fund feature of the program.
Cash held in employee benefit plan accounts,
employee health and welfare plan accounts, donor
advised fund accounts, and SEP and SIMPLE IRAs
will be automatically invested or swept into a
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the program. In addition, clients with aggregate
cash balances of $5 million or more across all of
their accounts with Baird within the same
household may opt out of the Bank Sweep
Feature and instead have all of their cash
balances automatically swept into an institutional
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the program. More information about the Money
Market Fund Feature of Baird’s Cash Sweep
Program is available at rwbaird.com/cashsweeps.
to provide FDIC
The Bank Sweep Feature seeks to provide FDIC
insurance protection for a client’s cash balances
up to an aggregate deposit limit determined
under the program. Any deposits, including CDs,
that a client maintains, directly or indirectly
through an intermediary (such as us or another
broker), with a bank participating in the Cash
Sweep Program in the same capacity with the
bank will be aggregated with the client’s cash
balances deposited with the bank under the Cash
Sweep Program for purposes of calculating the
$250,000 FDIC insurance limit. Total deposits
exceeding $250,000 at a bank may not be fully
insured by the FDIC. A client is responsible for
monitoring the total amount of other deposits that
the client has with a bank outside the Cash Sweep
Program in order to determine the extent of
deposit insurance coverage available. Baird is not
responsible for any insured or uninsured portion
of a client’s deposits at a bank. Cash invested in a
money market mutual fund under the Money
Market Fund Feature is not FDIC insured, but is
Investor Protection
protected by Securities
Corporation (“SIPC”) coverage up to applicable
limits.
is
available
receives
compensation
for
Cash Sweep Program
Baird maintains a Cash Sweep Program that is
intended for clients who want to earn interest and
receive FDIC insurance protection on their cash
time while awaiting
over short periods of
investment. If a client participates in Baird’s Cash
Sweep Program, uninvested cash in the client’s
accounts will be automatically deposited or swept,
on a daily basis, into one or more FDIC-insured
deposit accounts at participating banks (the “Bank
Sweep Feature”) or, under certain conditions, will
be automatically invested in shares of a money
market mutual fund that Baird makes available in
the program (the “Money Market Fund Feature”),
subject to the terms and conditions of the
program. By using multiple participating banks as
opposed to a single bank, the Bank Sweep
Feature seeks
insurance
protection for a client’s cash balances of up to an
aggregate deposit limit determined under the
program (currently, $2,500,000 for most account
types and $5,000,000 for joint accounts). A client
receives interest on cash balances in deposit
accounts under the Bank Sweep Feature at tiered
rates that are based on the aggregate value of
the accounts within the client’s household. The
applicable client household tier values are: less
than $1 million; at least $1 million but less than
$2 million; at least $2 million but less than $5
million; and $5 million are more. Current rate
at
information
rwbaird.com/cashsweeps. Each deposit account at
Baird
the
administrative, accounting and other services that
Baird provides under the program, which is paid
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
account
values
of
a client may invest, often at a higher yield,
although these investments do not have an
automatic sweep feature. In addition, instead of
maintaining cash balances in an advisory Account,
a client has the option to maintain such cash
balances in a brokerage account that is not
subject to an asset-based Advisory Fee.
in connection with
less. For
A client should understand that the Cash Sweep
Program is an ancillary account service and it is
not nor is it part of any advisory program or
investment advisory service. GWG and Baird do
not act as investment adviser or a fiduciary to a
client
the Cash Sweep
Program. However, a client should note that the
amount of the client’s advisory Account dedicated
to cash and cash equivalents is part of the overall
investment allocation advice provided to the client
and thus the amount of such cash and cash
equivalents included in the calculation of the
Advisory Fee for the client’s advisory Account.
on
website
More detailed information about the Cash Sweep
Program and the compensation Baird receives is
available
at
Baird’s
www.rwbaird.com/cashsweeps. A
client also
receives information about the compensation
Baird receives from the Cash Sweep Program
through a client’s account statements.
trust administration
trust administration, custody,
its
related
to
those assets, and
out of the aggregate interest that is paid by the
participating banks on the aggregate client
balances in the deposit accounts participating in
the Bank Sweep Feature. Baird’s annual rate of
compensation may be up to 3.60% of the
for clients with
aggregate client balances
household
than
less
$1,000,000, 2.45% for clients with household
account values of $1,000,000 but less than
$2,000,000, 2.00% for clients with household
account values of $2,000,000 but less than
$5,000,000, and 1.75% for clients with household
account values of $5,000,000 or more. In a lower
interest rate environment Baird’s annual rate of
compensation will be
fee-based
investment advisory IRA accounts participating in
the Bank Sweep Feature, Baird’s compensation is
a monthly per account fee (which is the same
regardless of client balances in bank deposit
accounts). The per account fee for these advisory
IRA accounts is generally paid out of the interest
that the banks pay on aggregate client balances
in the deposit accounts, and the per account fee
varies based on the applicable Fed Funds Target
Rate but in no event will it exceed $19.00 per
month. Baird also receives an annual rate of
compensation of up to 0.50% of the aggregate
client balances automatically invested into money
market mutual funds under the Money Market
Fund Feature. A client should note that the client
will be charged the asset-based Advisory Fee on
the value of all of the assets in the client’s
Accounts, including cash that is swept into a bank
deposit account or invested into a money market
mutual fund under the Cash Sweep Program. As a
result, Baird receives two layers of fees on a
client’s assets swept or invested in the Cash
Sweep Program:
the Advisory Fee, which
compensates Baird for the investment advice,
trading and custody services provided to the
client
the
compensation paid by the banks or money market
funds related to those assets, which compensates
Baird for the services Baird provides to the banks
and funds and for Baird’s efforts in maintaining
the Cash Sweep Program. The compensation that
Baird receives from the Cash Sweep Program
gives Baird a financial incentive to recommend
that a client participate in the Cash Sweep
Program and maintain high levels of uninvested
cash balances in the client’s accounts.
any
trust
Trust Services Arrangements
Baird maintains an alliance with
certain
institutions, both non-affiliated and affiliated,
including Baird Trust Company (“Baird Trust”),
services,
that provide
including
tax
reporting and recordkeeping. GWG Consultants at
times refer clients seeking trust services to
institutions that are members of the alliance.
fiduciary duties, the trustee
Subject to
oftentimes retains Baird to provide investment
advisory services to the client trust. A client
should understand that any such referral for trust
services under the Trust Alliance Program made
by Baird and its GWG Consultants is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
oversee
services
such
arrangement. Baird has a financial incentive to
recommend that clients use Baird Trust, an
affiliate, over other non-affiliated trust companies.
As an alternative to the Cash Sweep Program,
Baird makes available other money market
mutual funds and other cash alternatives in which
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
contact
loan, Baird has an
incentive
financial
incentive
trust administration
As a result of this affiliation, Baird Trust also has
a financial incentive to retain Baird to provide
investment advisory or other services on behalf of
In addition, Baird and GWG
the client.
Consultants have a
to
recommend arrangements that involve Baird and
the GWG Consultant providing
investment
advisory services to the client and the trust
company only providing trust administration
services compared to an arrangement whereby a
trust company would provide both investment
advisory and
services
because it is more profitable to Baird and the
GWG Consultant.
that any margin balance
(i.e.,
ongoing
Baird
Trust
generally
paid
to Baird
rwbaird.com/loanrates or
a GWG
Consultant. Because a client will pay interest to
Baird on the outstanding balance of the client’s
to
margin
recommend to the client investment products and
services that involve the use of margin. Baird and
GWG Consultants also have an incentive to
recommend investment products and services
that involve the use of margin, because a margin
loan allows a client to make larger securities
purchases and retain assets
in the client’s
Accounts
that pay an ongoing asset-based
Advisory Fee instead of liquidating them to fund a
cash need, which increases the asset-based fees
Baird earns on a client’s Accounts. A client should
note
the
outstanding amounts of the margin loan the client
owes to Baird) in the client’s advisory Accounts
will not be applied to reduce the client’s billable
account value in calculating the client’s asset-
based Advisory Fee, which gives Baird and GWG
Consultants further incentive to recommend client
use of margin instead of liquidating assets to fund
a cash need. Because the interest Baird receives
and fees Baird earns on a client’s Accounts
increase as the amount of the client’s margin loan
increases, Baird and GWG Consultants also have
an
incentive to recommend that the client
continue to maintain a margin loan balance with
Baird at high levels. Baird has the right to lend
the securities a client pledges as collateral for the
client’s margin loan, and Baird receives additional
compensation for lending those securities, which
provides Baird a further incentive to recommend
margin to a client.
In addition, outside of the Trust Alliance Program,
GWG Consultants may refer a client to Baird Trust
to provide investment management and trust
administration services to the client. If a client
enters into such a relationship with Baird Trust,
Baird and the client’s GWG Consultant typically
relationship management
provide
services.
provides
compensation to Baird and the client’s GWG
Consultant for the referral and providing ongoing
services, which may be up to 50% of the ongoing
fees that a client pays to Baird Trust, and which is
credited to the client’s GWG Consultant for
purposes of determining the GWG Consultant’s
compensation. The compensation paid to Baird
and a client’s GWG Consultant does not increase
the fees that the client pays to Baird Trust. Due to
Baird’s affiliation with Baird Trust and the
compensation
and GWG
Consultants, Baird and GWG Consultants have a
financial incentive to favor Baird Trust over other
trust companies.
A client should note that Baird’s margin loan
program is generally intended to be used to fund
additional purchases of securities. or short-term
liquidity needs. If a client wishes to obtain a loan
for some other purpose, a client should instead
consider whether the client is eligible for Baird’s
Securities-Based Lending Program, which involves
clients obtaining loans from third-party lenders for
general use purposes. Baird and GWG Consultants
have a conflict to the extent they would
recommend that a client use the Baird margin
loan program instead of the Securities-Based
Lending Program because a client pays interest
and other fees to Baird instead of a third-party
lender.
Additional important information about margin,
including the risks and margin interest rates that
Margin Loans
Margin involves borrowing money from Baird
using eligible securities as collateral, including for
the purpose of buying securities. If a client uses
margin, the client will pay Baird interest on the
amount the client borrows. The rate of interest
that a client pays on a margin loan will be at a
base rate determined by Baird plus or minus a
specified percentage that varies based on the
outstanding debit balance of the margin loan and
the client’s household account value. Interest
rates are lower for larger debit balances and
those with higher household account balances. As
a result, rates will vary. To determine the actual
interest rate that may apply to a client’s margin
at
Baird’s
loan,
visit
website
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
apply, is set forth in the “Margin” section of
Baird’s website at bairdwealth.com/retailinvestor.
of
website
of liquidating assets in the client’s accounts with
Baird because a decline in the amounts the client
has in the client’s accounts will result in lower
revenues to Baird and compensation paid to the
client’s GWG Consultant. Additional important
information about securities-based lending is set
forth in the “Securities-Based Lending Program”
section
at
Baird’s
bairdwealth.com/retailinvestor.
the
loan or
A client should understand that any referral made
by Baird and GWG Consultants under the
Securities-Based Lending Program is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
oversee any such lending arrangement.
Other Non-Advisory Services
Certain Baird associates from time to time may
provide clients with tax return preparation, bill
pay or related services. In some instances, the
fee for those services may be bundled with the
Advisory Fee. A client should understand that the
provision of such services is separate from, and
not related to, the Services offered under this
Brochure and will be governed by an agreement
separate from the client’s advisory agreement
with Baird. A client should understand that Baird
and its associates do not act as investment
advisor or fiduciary to the client when providing
tax return preparation, bill pay or related non-
advisory services to the client.
informing
the
financial
incentive
Client Responsibilities
A client is responsible for providing information to
Baird and the client’s GWG Consultant reasonably
requested by them in order to provide the
services selected by the client. Baird, the client’s
GWG Consultant and investment managers, if
any, will rely on this information when providing
services to the client. A client is also responsible
for promptly
client’s GWG
Consultant of any significant life changes (e.g.,
change in marital status, significant health issue,
or change in employment) or if there is any
change to the client’s investment objectives, risk
tolerance,
investment
financial circumstances,
needs, or other circumstances that may affect the
manner in which the client’s assets are invested.
None of Baird, the client’s GWG Consultant or any
investment manager managing a client’s Account
Securities-Based Lending Program
Baird offers clients an opportunity to borrow
money from a third party lender under Baird’s
Securities-Based Lending Program. These loans, if
made, can be used for any personal or business
purpose other than to purchase, carry or trade
securities, or to repay margin debt. These loans
are secured by the investments and other assets
in the client’s accounts with Baird. A client will
pay interest on the outstanding balance of the
client’s loan. The rates of interest charged by the
bank depends on many factors, such as the
prevailing interest rate environment, the amount
line of credit, a client’s
of
creditworthiness, and the aggregate assets in a
client’s Baird accounts in the client’s household
(“relationship size”). The interest rates are based
on a benchmark
rate, plus an applicable
percentage that varies based on the approved
loan amount and the relationship size. Rates are
generally higher for smaller loans and relationship
sizes and lower for larger loans and relationship
sizes. The interest rate that will apply to a client’s
loan will be set forth in the loan agreement the
client enters into with the bank. Baird receives an
ongoing administrative fee from the bank, at an
annual rate of up to 2.50% of the outstanding
balance under a client’s loan, which is paid by the
bank out of the interest the client pays to the
bank. A client’s GWG Consultant typically receives
an ongoing referral fee at an annual rate of up to
0.25% of the outstanding balance of the client’s
loan, which is paid out of Baird’s administrative
fee. A client should note that Baird and GWG
Consultants will continue to receive compensation
on assets held in the client’s accounts that serve
as collateral for the client’s loans, including
Advisory Fees. Because Baird
receives an
administrative fee and GWG Consultants receive a
referral fee if a client obtains a loan from a third
party
lender under Baird’s Securities-Based
Lending Program, Baird and GWG Consultants
have an incentive to recommend that a client
obtain loans under that program. Baird and GWG
Consultants will continue to receive compensation
on assets held in a client’s accounts that are
collateral for such loans, including Advisory Fees
on such assets if those assets are in the client’s
advisory Account. As a result, Baird and GWG
Consultants have a
to
recommend that a client obtain a loan under the
program to provide for the client’s needs instead
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
be required to pay tax on the UBTI produced by
the tax-exempt Accounts.
is responsible
for any adverse consequence
arising out of the client’s failure to promptly
inform the client’s GWG Consultant of any such
changes. Since investment goals and financial
circumstances change over time, a client should
review the client’s participation in a Service with
the client’s GWG Consultant at least annually.
A client’s ability to recognize losses in an Account
for tax purposes may be disallowed, limited or
deferred by applicable tax rules. For example, IRS
wash sales rules will disallow a client’s tax
deductions for a loss in an Account related to the
sale of an investment if the client purchases
(whether through Baird or another firm) a
“substantially identical” investment within the
wash sale period (currently 30 days before or 30
days after the date of the sale). Similarly, IRS
straddle rules limit and defer a client’s ability to
claim tax deductions related to the loss on a sale
of an investment in an Account if the client holds
an offsetting position in any account held at Baird
or another firm.
the Services,
Retirement Accounts
Additional laws, regulations and other conditions
apply to Retirement Accounts. Each owner,
trustee, plan
sponsor, adopting employer,
responsible plan fiduciary, named fiduciary, or
other fiduciary acting on behalf of a Retirement
Account (“Retirement Account Fiduciary”) should
understand that GWG and Baird do not provide
legal advice regarding Retirement Accounts. A
Retirement Account Fiduciary is urged to consult
with his or her own legal advisor about the laws
and regulations that may apply to Retirement
Accounts. ERISA and the IRC prohibit GWG and
Baird from offering certain types of investment
products and services to Retirement Accounts.
the
tax
implications of
Legal and Tax Considerations
A client’s investment activities may have legal
and tax consequences to the client.
purchases,
sales,
The investment strategies used for a client’s
Account and transactions in a client’s Account,
liquidations,
including
redemptions, and rebalancing transactions, may
cause the client to realize gains or losses for
income
tax purposes. Funds often make
distributions of income and capital gains to
investors, which may cause the client to realize
income for tax purposes.
GWG and Baird do not offer legal or tax advice to
clients. The information, recommendations, and
services provided by GWG and Baird to clients
through
including, without
limitation, tax management strategies, do not
constitute tax advice. A client is responsible for
understanding
the
investment activities in the client’s accounts
(whether held at Baird or another firm) and
complying with applicable tax rules. A client is
strongly urged to consult with the client’s tax
advisor about potential tax implications before
making investment or trading decisions. GWG and
Baird do not undertake any responsibility to
monitor or verify a client’s compliance with
applicable tax rules, and they are not responsible
for any tax‑related effects or obligations resulting
from the investments or transactions in a client’s
Account.
Account Requirements
Opening an Account
Certain investment products, such as Alternative
Investments and Complex Investments, are
classified as partnerships. Clients invested in such
investment products will be treated as partners
for U.S. federal income tax purposes, which has
tax implications different from other types of
investments, including Schedule K-1 reporting.
A client that wishes to engage GWG will enter into
an advisory agreement with GWG and Baird. The
client’s advisory agreement will contain the
specific terms applicable to the services selected
by the client, Advisory Fees payable by the client,
and other terms applicable to the client’s advisory
relationship with GWG and Baird.
taxable
Clients with tax-exempt Accounts, such as certain
Retirement Accounts or charitable or religious
organization Accounts, should be aware that some
investments, such as some Non-Traditional
Assets, Alternative Investments and Complex
Investments, may produce
income,
referred to as unrelated business taxable income
(“UBTI”). In such circumstances, such clients will
In addition to the investment advisory services
that GWG and Baird provide in connection with
each Service, Baird, in its capacity as broker-
dealer, may provide clients with trade execution,
custody and other standard brokerage services.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
a client changes services or establishes other
Accounts with GWG.
is a brokerage agreement
Certain Account Requirements
Minimum Account Size
For this reason, a client may also enter into a
client account agreement with Baird if the client
has not already done so. The client account
that
agreement
authorizes Baird to execute trades for, and
perform related brokerage and custody services
to, the client’s Account.
Baird generally requires that assets in a client’s
Account be held in a Baird account, for which
Baird acts as custodian. However, in certain
limited circumstances when requested by a client,
Baird may permit a client to include Held-Away
Assets in the client’s Account.
Each Service has a minimum account size and
may have a minimum Advisory Fee, which are
described in the section entitled “Fees and
Compensation—Advisory Fees” below. GWG or
Baird may remove an Account from a Service and
immediately terminate the advisory agreement
with respect to an Account upon written notice to
the client if the client fails to maintain the
required minimum asset levels in an Account or if
the client fails to otherwise abide by the terms of
a Service as determined by GWG or Baird in their
sole discretion.
Account Contributions and Withdrawals
in
to
investment manager until
A client may fund an Account with cash and with
securities that GWG, Baird and the client’s
investment manager,
to be
if any, deem
acceptable
their sole discretion. Funds
deposited or transferred to a client’s SMAs from
another Baird account and funds deposited or
transferred to a client’s SMAs from outside of
Baird will not be available for investment by the
client’s
the next
business day and therefore the investment of
such funds, at the discretion of the manager, will
occur no earlier than the next business day.
After a client has signed and delivered an
advisory agreement to Baird, the agreement is
subject to review and acceptance by the client’s
GWG Consultant, his or her Market Director or
PWM Supervision department supervisor (or his or
her respective designee), and Baird PWM’s Home
Office. The agreement and Baird’s advisory
relationship with a client will become effective
when the client’s paperwork is accepted by Baird
PWM’s Home Office and following such acceptance
Baird has delivered
the client written
confirmation of the Account’s enrollment in the
applicable Service. A client should understand
that the advisory agreement will not become
effective, and Baird will not provide any advisory
services to the client, until such time that Baird
has accepted the advisory agreement. Baird may
delay acceptance of the advisory agreement and
the provision of advisory services to the client for
various reasons, including deficiencies in the
client’s paperwork. Once it has become effective,
the agreement shall continue until it is terminated
in accordance with the terms described in the
advisory agreement.
certain
retain
those documents
for
The terms of a client’s agreements and this
Brochure apply to all Accounts that a client
establishes with GWG, including any Accounts
that a client may open with Baird in the future.
Some of the information in those documents may
not apply to a client now, but may apply in the
future if a client changes services or establishes
other Accounts with GWG. GWG will generally not
provide a client another copy of the agreements
or this Brochure when a client changes services or
establishes new Accounts unless
the client
requests a copy from GWG. Therefore, a client
should
future
reference as they contain important information if
Some GWG Consultants will invest, or recommend
investing, cash contributions made to an Account
over a period of time. This method of investment
is sometimes referred to dollar cost averaging
(“DCA”). The goal of this method of investment is
to reduce the risk of making large purchases of
securities at an inopportune time or price. The
Overlay Manager
investment
and
managers also offer an optional DCA service for
Accounts they manage. Additional information will
be provided to a client if the client enrolls in a
DCA service. A client should note that, if dollar
cost averaging is used to invest cash in the
client’s Account, the returns for the Account
could, depending upon market and other
conditions, be lower than the returns that could
have been obtained had all the cash in the
Account been fully invested upon contribution to
the Account. In addition, a client should note that,
when dollar cost averaging is used, the amount of
cash in the client’s Account will be included in the
value of the Account for fee calculation purposes.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Business—Additional
Service
“Advisory
Information—Unsupervised Assets” above.
Whenever assets are contributed to an Account, a
client should discuss with the client’s GWG
Consultant the timing of when the assets will be
invested. If DCA will be used to invest the assets,
a client should ask for more specific information
about how the assets will be invested and the
associated timing for investing.
that
A client is responsible for notifying GWG and any
investment manager managing
the client’s
Account of any contributions made into the
Account and instructing GWG and any investment
manager to liquidate positions in the event the
client wishes to withdraw assets
from the
Account. GWG and Baird have no responsibility to
invest cash deposits (other than complying with a
client’s cash sweep instructions) or liquidate
positions with respect to an Account managed by
an Other Manager, and they are not responsible
for any losses that may result from a client’s
failure to notify GWG and any
investment
manager managing the client’s Account regarding
deposits or withdrawals.
A client may also incur additional expenses and
liabilities, including tax related liabilities, when
transferring assets out of an Account or Baird’s
custody. See “Termination of Accounts” below.
Liens and Use of Account Assets as Collateral
sale
could
in adverse
As security for the full and complete payment
when due of any debts and other obligations that
a client owes to GWG and Baird, and to the extent
permitted by applicable law or regulation, all
assets in a client’s Account held at Baird will be
subject to a first priority security interest, lien and
right of setoff in favor of Baird. Baird may sell
assets in an Account to satisfy the lien. As a
secured party, Baird may have interests that are
adverse to a client. Neither GWG nor Baird will act
as investment adviser to a client with respect to
such sale of assets held in an Account. Any such
sale of assets will be executed in Baird’s capacity
as broker-dealer and creditor and may, as
permitted by law, result in executions on a
principal basis. Such sales could have adverse tax
consequences, disrupt a client’s
investment
strategy, and have an adverse impact on the
Account’s performance. A client should review the
client’s agreements for more information.
When a client funds an Account with securities,
including when a client changes Services for an
Account or changes investment managers for an
Account within the same Service, the client should
understand that GWG’s, Baird’s or the client’s
investment manager’s review of securities used to
fund the Account may delay
investing. In
addition, GWG, Baird or the client’s investment
manager,
the
if any, may determine
securities contributed to the Account may not be
appropriate for the client’s strategy, and GWG,
Baird or the investment manager, if any, may
sell, or recommend the sale of, such securities.
Further, an investment manager may be removed
from the management of a client’s Account and a
replacement
investment manager may be
appointed. In such event, Baird, at the direction
of the client’s replacement manager, or the
client’s replacement manager may sell all or a
portion of the securities or other investments in
the Account that were managed by the prior
manager and the replacement manager will
reinvest the cash proceeds of those sales. Any
such
tax
result
consequences for the client. A client should note
that securities transferred into an Account may be
subject to the Advisory Fee immediately upon its
transfer into the Account, even if the client paid a
commission or front-end sales charge on the
security prior to its transfer into the Account. In
addition, if the securities are subject to deferred
sales charges or redemption fees, the client will
be responsible for paying those charges and fees.
To the extent permitted by applicable law, certain
funding transactions may be handled by Baird on
a principal basis, and such transactions are not
considered investment advisory services of GWG,
Baird or the client’s investment manager.
If an asset transferred to an Account is an
Unpermitted Investment under the terms of the
applicable Service, GWG, Baird or the client’s
investment manager may sell the asset or
transfer it into a separate brokerage account.
Alternatively, they may designate such asset as
an Unsupervised Asset as further described under
All of the assets in a client’s Account must be free
and clear from any security interest, lien, charge
or other encumbrance (other than a security
interest, lien, charge or other encumbrance in
favor of Baird) and must remain so for the
duration of the client’s relationship with Baird,
unless Baird otherwise specifically agrees in
writing.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
that GWG or Baird may deliver to the client. The
term of the consent to electronic delivery is
indefinite but a client may revoke the consent at
any time by notifying GWG.
Termination of Accounts
If a client wishes to obtain loans secured by
assets in the client’s Account (commonly referred
to as “securities-based lending”) and GWG and
Baird agree to the arrangement, the client should
understand that the lender may exercise certain
rights and powers over the assets in the Account,
including the disposition and sale of any and all
assets pledged as collateral for the loan to meet a
collateral call, which may occur without prior
notice to the client. A collateral call could have
adverse tax consequences, disrupt a client’s
investment strategy, and have an adverse impact
on the Account’s performance. A client should be
aware of these and other potential adverse effects
of securities-based lending and collateralizing
Accounts before deciding to do so.
A client is required to disclose the terms of the
client’s agreements with Baird to any lender
seeking to use Account assets as collateral. A
client must promptly notify GWG and Baird of any
default or similar event under the client’s
collateral arrangements.
The client’s advisory agreement will survive any
event that causes the client’s GWG Consultant to
be unable to provide services to the client (either
on a temporary or permanent basis), including if
the client’s GWG Consultant ceases
to be
employed by Baird. In any such event, Baird will
endeavor to continue to provide services to the
client and will as promptly as practicable assign
another GWG Consultant or Baird Financial
Advisor to the client’s Accounts (either on a
temporary or permanent basis) and the client will
be notified of any such change or, if Baird
determines that it is unable to continue to provide
advisory services to the client, Baird may remove
the applicable Account from a Service or Program
and convert the Account to a brokerage account
upon notice to the client.
GWG or Baird may remove an Account from a
Service and immediately close an Account upon
written notice to a client if the client fails to abide
by the terms of the Service. GWG or Baird may
also remove an Account from a Service at any
time upon written notice to a client if the client
fails to maintain the required minimum asset
levels in such Account.
A client should understand that neither GWG nor
Baird will provide advice on or oversee a
securities-based lending or collateral arrangement
and they will not act as investment adviser or a
fiduciary to the client with respect to the
liquidation of securities held in the client’s
Account to meet a collateral call. Any such
liquidation will be executed in Baird’s capacity as
broker-dealer and may, as permitted by law,
result in executions on a principal basis.
See
“Additional
In some instances, Baird and GWG Consultants
may refer a client to a third party lender under
Baird’s Securities-Based Lending Program that
pays Baird and GWG Consultants certain
Service
compensation.
Information—Securities-Based Lending Program”
above for more information.
Business—Additional
exclusive
responsibility
to
in
writing,
Upon the termination of an Account’s enrollment
in a Service, GWG, Baird and, if relevant, any
other
investment manager managing such
Account, shall have no obligation to act as
investment adviser to such Account. If such
Account is custodied at Baird, the Account shall
be converted to and designated as a brokerage
account. GWG, Baird, and, if relevant, any other
investment manager managing such Account,
shall be under no obligation to recommend any
action with regard to, or to liquidate the securities
or other investments in, such Account. After an
Account is removed from a Service, it is the
issue
client’s
instructions,
the
regarding
management of any assets in such Account.
Securities purchased on margin are used as
Baird’s collateral for the margin loan. Clients that
have a margin account should review the section
“Advisory
Service
Information—Complex Strategies and Complex
for additional
Investment Products” above
information.
Electronic Delivery of Documents
If a client directs Baird to liquidate assets in
connection with a closure of an Account, the client
should understand that Baird acts as broker-
investment adviser, when
dealer, and not
By signing an advisory agreement, a client
consents to the electronic delivery of documents
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Asset-Based Fee Arrangement
fee
GWG generally offers one asset-based
arrangement: a tiered fee schedule.
processing such a liquidation request and that the
client will generally be charged commissions,
sales charges, sales “loads”, or other applicable
transaction-based fees in accordance with the
applicable Baird fee schedule or other third-party
transaction-based fee schedule for the particular
investment then in effect. Additional information
about the compensation that a client pays to
Baird for effecting brokerage transactions is
contained in Baird’s Client Relationship Details
document, available on Baird’s website at
bairdwealth.com/retailinvestor.
Under a tiered fee schedule, the asset-based fee
will vary for different segments of client assets,
gradually decreasing as the Account balance
increases. For example, a client with an Account
value of $75 million may pay one rate on the first
$25 million of assets in the Account, a lower rate
on the next $25 million of assets in the Account
and a still lower rate on the remaining $25 million
of assets. Use of a tiered fee schedule will result
in a blended asset-based fee rate.
A client may incur significant expenses and
liabilities, including tax-related liabilities for which
the client will be solely liable, if the client closes
an Account, terminates an advisory agreement, or
transfers assets out of Baird’s custody. GWG and
Baird will not be liable to a client in any way with
respect to the termination, closure, transfer or
liquidation of the client’s Accounts.
The typical asset-based fee varies depending
upon the Service and the fee option selected by
the client. Fee options and rates may also differ
among different Accounts held by the same client,
depending on the services selected
for an
Account.
All new client Accounts paying an asset-based fee
are generally subject to a unified advice fee
arrangement (“Unified Advice Fee Arrangement”),
which is described below.
Unified Advice Fee Arrangement
Some of the investments offered in connection
with the Services contain restrictions that limit
their use, and such
investments may be
unavailable for purchase or holding outside of an
Account. For example, certain mutual funds, ETFs
or other Funds held in an Account may only be
available to a client through a GWG Service or
may not be held at another firm. If such
restrictions apply and the client terminates a
Service or closes an Account, the Client will be
required to sell or redeem such Funds or
exchange them for other Funds that may be more
costly to the client or have poorer performance. A
client should consider restrictions applicable to
investments carefully before participating in a
Service. A client should contact the client’s GWG
Consultant for specific information as to how
Account closure, termination of an agreement, or
asset transfers might impact the assets in the
client’s Accounts.
Under a Unified Advice Fee Arrangement, the
asset-based Advisory Fee is comprised of an
advice fee (“Advice Fee”) and, for some Services,
an additional portfolio fee (“Portfolio Fee”). The
Advice Fee covers certain investment advisory
and custody services provided by GWG and Baird.
The Portfolio Fee covers portfolio management
and other services provided by Baird and the
manager to the client’s Account, which may
include departments or affiliates of Baird. If a
client has a Unified Advice Fee Arrangement, the
client’s Advisory Fee rate will be equal to the sum
of the applicable Advice Fee rate and the
applicable Portfolio Fee rate, if any.
Clients with a Unified Advice Fee Arrangement
generally choose a tiered fee schedule for the
Advice Fee portion of the Advisory Fee.
Tiered Advice Fee Schedule
following
fee schedule sets
tiered Advice Fee rates
forth
for
the
the
The
maximum
Services.
Fees and Compensation
Advisory Fees
Fee Options and Fee Schedule
A client’s advisory agreement will set forth the
actual compensation the client will pay to Baird.
In most instances, a client pays an ongoing
Advisory Fee based upon the value of assets in
the client’s Account (an “asset-based
fee”),
although other options, such as a flat fee, are
available.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Tiered Advice Fee Schedule
Annual Fee
Rate
Value of Assets
On first $25 million ($0 - $25 million)
0.80%
The Portfolio Fee rates are current as of the date
of this Brochure. A client’s actual Portfolio Fees
could be higher or lower than the amounts shown
above if Baird adds new investment managers to
the Services with higher or lower fees or if Baird
and a manager renegotiate the amount of the
subadvisory fee.
On next $25 million ($25 - $50 million)
0.60%
On next $50 million ($50 - $100 million)
0.40%
Over $100 million
0.20%
Portfolio Fee Schedule
The Advice Fee and Portfolio Fee rates do not
reflect the internal fees and expenses of any
Funds or other investment products used in
connection with a strategy, the costs of which are
borne by a client in addition to the Advisory Fee.
See “Other Fees and Expenses” below.
following
fee schedule sets
forth
The Portfolio Fee
rate varies by Service,
investment vehicle, and the type of investment
strategy or style being pursued by the Account.
The
the
maximum Portfolio Fee rates or range of rates for
the Services.
Portfolio Fee Schedule
Service
Annual Fee Rate
or Range of Rates
titled
“Administrative
GWG Investment Management
0.00%
GWG Recommended Managers
In some instances, Baird provides operational and
administrative services to third party managers in
connection with their management of client
Accounts. As compensation for those services,
Baird receives a portion of the Portfolio Fee at an
annual rate of up to 0.02% of the value of the
Account. Additional information is contained in the
document
Servicing,
Revenue Sharing, and Other Third Party
Payments” available on Baird’s website at
bairdwealth.com/retailinvestor.
0.20% - 0.75%
Equity SMA Strategies
0.20% - 0.52%
Balanced SMA Strategies
0.25% - 0.40%
Fixed Income SMA Strategies
0.25% - 0.52%
Global and International SMA
Strategies
0.35% - 0.60%
Alternative SMA Strategies
0.10%
Tax Managed Strategies
Baird SMA Network (BSN)
0.22% - 0.77%
Equity SMA Strategies
0.22% - 0.52%
Balanced SMA Strategies
0.10% - 0.27%
Fixed Income SMA Strategies
0.27% - 0.52%
Global and International SMA
Strategies
Certain managers offer lower Portfolio Fee rates
for SMA Strategies to clients through the DC
Program compared to the GWG Recommended
Managers or BSN Programs. If a client has
decided to participate in the DC Program, upon
the client’s request, the client’s GWG Consultant
may assist the client with the client’s negotiation
with the manager of the Portfolio Fee rate for the
applicable SMA Strategy. The Portfolio Fee
negotiated by the client could be higher or lower
than the Portfolio Fee that applies to the same
SMA Strategy that is available through other
Services. The client is ultimately responsible for
understanding the differences between the SMA
Programs, deciding to participate in the DC
Program, selecting
the SMA Strategy, and
negotiating and agreeing to the Portfolio Fee rate.
0.37% - 0.77%
Alternative SMA Strategies
—1
Dual Contract (DC)
Flat or Hourly Fee Arrangement
1 Fees charged by managers under the DC Program are
negotiated by each client pursuant to a separate
agreement that does not include Baird. Baird, therefore,
does not have the necessary information to provide a
definitive range of fees paid to managers under the DC
Program.
Under a flat fee or hourly fee arrangement, the
applicable fee may be determined according to a
fixed asset-based or hourly fee rate or may be a
fixed dollar amount. Specific services may each
have their own, separately-stated, flat fee, or
several services may be grouped together under a
single flat fee. Some services may entail a flat fee
per usage. Flat fees are negotiable and vary by
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
client. The details of flat fee arrangements,
including fee amounts, the billing schedule, and
the services covered, will be included in the
client’s advisory agreement.
Service Account Minimums
The minimum asset value to open an Account in a
Service is set forth in the table below.
short sale positions and open options positions
with a negative market value will be excluded
from the calculation of a client's Advisory Fee. The
value of cash balances held in a client’s Account
will be excluded from the calculation of a client's
Advisory Fees in an amount equal to the value of
any open short sale positions and options
positions with a negative market value held in the
margin account.
Account Minimum
Service
Asset Level
Consulting Services
Negotiable
Baird SMA Network
$100,000(1)
Dual Contract
$100,000(1)
GWG Investment Management
$50,000
GWG Recommended Managers
$100,000(1)
If requested by a client and approved by Baird, a
client’s Advisory Fee may be determined by also
including the aggregate value of assets in certain
other Advisory accounts held by a client and
certain members of the client’s household or
family (a “household fee arrangement”). A client
should note that Retirement Accounts may not be
included in a household fee arrangement to the
extent a prohibited transaction under ERISA or
the IRC may result. The terms of any such
household fee arrangement will be set forth in the
client’s advisory agreement.
(1) BSN Fund Strategist Portfolios have a minimum
account requirement of $10,000. Other SMA
Strategies typically have an account minimum of
$100,000. However, each investment manager sets
its own minimum account size requirements, which
can range from $25,000 to more than $1,000,000.
As a result, some investment managers may not be
available to clients with smaller accounts.
A client’s Account may also be subject to a
minimum quarterly Advisory Fee that will be set
forth in the client’s advisory agreement regardless
of the value of the assets in the client’s Account.
In addition, if a third party custodian has custody
of the client’s Account assets, Baird may impose
Account requirements different than those set
forth above, including but not limited to higher
minimums, and it may impose additional fees due
to the increase in resources needed to administer
the Account.
While GWG and Baird may perform an analysis as
to whether any client Accounts may be eligible for
a household fee arrangement, a client should note
that it is client’s sole responsibility to inform the
client’s GWG Consultant that client’s household or
family has two or more Advisory accounts that
are eligible for a household fee arrangement.
GWG and Baird do not undertake any obligation
to ensure client Accounts are eligible for a
household fee arrangement. By agreeing to a
household fee arrangement, each client subject to
such household fee arrangement consents to
GWG and Baird providing to each other client
subject to such household fee arrangement, in
GWG’s or Baird’s sole discretion, information
about the aggregate level, or range, of household
assets used for fee calculation purposes. As a
result, each such client should understand that
the other clients included in the household fee
arrangement may be able to ascertain the amount
of the client’s assets at Baird.
A client is encouraged to periodically review with
the client’s GWG Consultant the client’s Advisory
Fee and the services provided to determine if the
services and fees continue to meet the client’s
needs.
Calculation and Payment of Advisory Fees
Baird will calculate a client’s Advisory Fee by
applying the applicable fee rate to the value of all
of the assets in the client’s Accounts, including
cash and its equivalent and including all Held-
Away Assets, unless otherwise agreed to in
writing. Liabilities held in a client's Accounts,
including the value of margin debit balances, open
For purposes of calculating a client’s asset-based
Advisory Fee, the value of a client’s assets is
generally determined by Baird. Baird generally
relies upon third party sources, such as third
party pricing services when valuing Account
assets. In some instances, such as when Baird is
unable to obtain a price for an asset from a
pricing service, Baird may obtain a price from its
trading desk or it may elect to not price the asset.
Obtaining a price from its trading desk may
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
present a conflict of interest. In some cases, Baird
obtains prices from the issuers or sponsors of
investment products in the client’s Account when
prices are not otherwise readily available. This
frequently occurs with respect to the valuation of
annuities and Complex Investment Products. If
the assets in the client’s Account are held by a
custodian other than Baird, Baird may also use
valuation information provided by the client’s
third party custodian in determining the value of
the assets in the client’s Account.
As mentioned above, Baird will include cash and
cash equivalent balances in a client’s Account
when calculating a client’s asset-based Advisory
Fee. Baird has adopted internal policies that
monitor the percentage of an Account swept into
cash under the Cash Sweep Program. These
internal policies are designed to inform GWG
Consultants and their clients who hold large cash
sweep balances in their Accounts for sustained
periods that those Accounts are holding large
cash sweep balances and that there may be other
investment or account options for their cash and
in
that Baird receives direct compensation
addition to the Advisory Fee from client balances
in the Cash Sweep Program.
is unreliable. Valuation data
If a client maintains a debit balance in the client’s
margin account with Baird, such balance has no
bearing on the asset-based Advisory Fees charged
on client’s Account. In other words, the margin
balance (i.e., the outstanding amounts of the
margin loan a client owes to Baird) in client’s
Account will not be applied to reduce the client’s
billable Account value in calculating the Advisory
Fee.
third party pricing services,
Neither GWG nor Baird conducts a review of
valuation information provided by third party
pricing services, issuers, sponsors, or custodians,
and they do not verify or guarantee the accuracy
of such information. GWG and Baird do not accept
responsibility for valuations provided by third
parties that are inaccurate unless they have a
reason to believe that the source of such
valuations
for
investments, particularly annuities and Complex
Investment Products, may not be provided to
Baird in a timely manner, resulting in valuations
that are not current. The prices obtained by Baird
from
issuers,
sponsors and custodians may differ from prices
that could be obtained from other sources.
The Account value used for the Advisory Fee
calculation may differ from that shown on a
client’s Account statement or performance report
due to a variety of factors, including the client’s
use of margin, options, short sales, and other
considerations. If a client has assets held by a
third party custodian, the prices shown on a
client’s Account statements provided by the
custodian could be different from the prices
shown on statements and reports provided by
Baird. See “Custody” below for more information.
the
When determining the value of Held-Away Assets,
prices provided by a client or the client’s agent
will frequently be used and the initial amount
invested by the client will typically be used as the
value of the Held-Away Asset unless the client or
the client’s agent provides updated information.
Neither GWG nor Baird conducts a review of
valuation information provided by a client or the
client’s agent and they do not verify or guarantee
the accuracy of such information. GWG and Baird
for valuations
responsibility
do not accept
provided by a client or the client’s agent.
Valuation data may not be current. The prices
provided by a client or the client’s agent may
differ from prices that could be obtained from
other sources.
Values used for fee-calculation purposes may vary
from prices received in actual transactions and
are not firm bids, offers or guarantees of any type
with respect to the value of assets in an Account,
and the Advisory Fee for some securities may be
calculated based on values that are greater than
the amount a client would receive if the securities
were actually sold from the client’s Account.
A client’s Advisory Fees are payable in accordance
with the terms of the client’s advisory agreement.
Typically, Advisory Fees are payable on a calendar
quarterly basis, in advance. The initial billing
period begins when
client’s advisory
agreement is accepted by Baird and the Account
is opened by Baird (the “Opening Date”). The
initial Advisory Fee payment will be adjusted for
the number of days remaining in the then current
quarter. The initial Advisory Fee will be based on
the value of assets in the client’s Account on the
Opening Date. The period which such payment
covers shall run from the Opening Date through
the last business day of the then current calendar
quarterly billing period. Thereafter, the quarterly
Advisory Fees shall be calculated based upon the
Account’s asset value on the last business day of
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the prior calendar quarter and shall become
payable on the first business day of the then
current calendar quarter.
the Account move into a new tier or cross a
breakpoint during such period, no rebate or fee
adjustment will be made. However, GWG and
Baird, in their sole discretion, may make fee
adjustments in response to asset fluctuations in a
client’s Account occurring during a billing period
that result from contributions to, or withdrawals
from, the client’s Account.
The minimum asset value in order to retain the
services of GWG is $25 million, and a minimum
annual Advisory Fee of $150,000 may be
assessed to a client regardless of the level of
assets advised by GWG. GWG may waive the
minimum asset value or minimum Advisory Fee at
its discretion. The minimum Advisory Fee is
subject to change upon notice to the client.
the
client’s Account may
A client’s Advisory Fees and other charges will be
automatically deducted from the client’s Account,
unless the client requests, and GWG and Baird
agree, to an alternate arrangement, such as
having Baird issue the client an invoice for the
Advisory Fees (“direct billing”). A client should
understand that the client’s Advisory Fees and
other charges relating to the client’s Account may
be satisfied from free credit balances and other
assets in the client’s Account. If free credit
balances in a client’s Account are insufficient to
pay the Advisory Fees or other charges when due,
GWG, Baird and any
investment manager
sell
managing
investments from the client’s Account to the
extent they deem necessary and appropriate, in
their sole discretion, to pay the client’s Advisory
Fees and other charges.
The Advisory Fee and minimum account value are
negotiable in certain instances and may vary
based upon a number of factors, including but not
limited to the size and nature of the assets in the
client’s Account, the client’s particular investment
strategy or objective, and any particular services
requested by the client. In some instances, clients
may pay a higher fee than indicated in the fee
schedule above. The fees paid by a client may
differ from the fees paid by other clients based on
a number of factors, including but not limited to
the factors identified above.
If a client’s Account is subject to direct billing, the
client is required to pay each bill within 30 days of
the date of the invoice. GWG and Baird may
automatically deduct a client’s Advisory Fees and
other charges from the client’s Account as
described above in the event that Baird does not
receive payment from the client within 30 days of
the date of the invoice. GWG or Baird may rescind
a direct billing arrangement with a client at any
time. Direct billing may not be available for
Retirement Accounts.
To the extent permitted by applicable law, GWG
or Baird may modify a client’s existing fees and
other charges or add additional fees or charges by
providing the client with 30 days’ prior written
notice.
The fee schedule set forth above is the current
fee schedule for the Services. Each Service has
had other fee schedules in effect, which may
reflect fees that are lower or higher, as the case
may be, than those shown above. As new fee
schedules are put into effect, they are made
applicable only to new clients, and fee schedules
applicable to existing clients may not be affected.
Therefore, some clients may pay different fees
than those shown above.
If GWG, Baird or the client terminates the client’s
advisory agreement or the client’s participation in
a Service, a pro-rated refund from the date of
termination through the end of the applicable
billing period will generally be made to the client
in the client’s affected Accounts. GWG and Baird
will not implement a decrease in the client’s fee
rate during a billing period or otherwise reimburse
or adjust Advisory Fees during any such period for
asset value appreciation or depreciation in a
client’s Account during such period. For example,
if a client’s Account is subject to a tiered or
breakpoint fee schedule and the asset levels of
Obtaining Services Separately: Brokerage or
Advisory? Factors to Consider
Baird offers brokerage accounts and other
services to clients, and certain services provided
to a client in connection with a particular Service
may be available to a client outside of the Service
separately. Thus, a client’s participation in a
Service could cost the client more or less than if
the client purchased each service separately. A
number of factors bear upon the relative cost of
each Service. In comparing the Services to
brokerage accounts or other services, a client
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
should consider a number of factors, including,
but not limited to:
Relationship Details document, which should have
been delivered to the client and is available on
Baird’s website at bairdwealth.com/retailinvestor.
• whether a client prefers to have ongoing
monitoring, investment advice or professional
management of the client’s investments, which
are provided to Service Accounts, or whether
the client does not want or need such services;
A client should review other account types and
programs with the client’s GWG Consultant to
determine whether they are more appropriate or
should be used in addition to a Service.
• whether the types of investment strategies,
products and solutions the client seeks are
available;
Advisory Fee Payments to Baird, GWG
Consultants and Investment Managers
GWG and Baird and Associated Managers benefit
from the Advisory Fees and charges that clients
pay for the services described in this Brochure.
• whether there are limitations on the types of
securities and other investments available for
purchase and whether those limitations are
significant to the client;
• whether the nature and level of transaction
services, account performance reporting, or
other ancillary services the client wants are
available;
Fee or
subadvisory
Baird retains the entire Advisory Fee paid by
clients, except as further described below. With
respect to SMA Strategies available under the
SMA Programs managed by Other Managers,
Baird pays Other Managers (including Associated
Managers and Implementation Managers, if any)
fee as
a Portfolio
compensation for the manager’s services as
further described below.
• whether the client prefers to pay an ongoing
Advisory Fee for continuous advice or pay
commissions and other fees on a transaction-
by-transaction basis;
• the relative costs and expenses of a Service
Account and a brokerage account, which will
vary depending upon:
fee or commission rate
the client
o the
negotiates;
o the size of the client’s account;
o the level of trading activity and size of trade
orders;
Client Accounts are generally subject to a Unified
Advice Fee Arrangement in which the Advisory
Fee consists of an Advice Fee and a separate
Portfolio Fee. Baird pays the manager out of the
Portfolio Fee paid by the client. The Portfolio Fee
rates are set forth under “Fee Options and Fee
Schedules—Unified Advice Fee Arrangement—
Portfolio Fee” above. However, Baird, in many
instances, retains a portion of the Portfolio Fee
when a client’s Account is managed by an Other
Manager. The maximum portion of the Portfolio
Fee retained by Baird in those instances is equal
to an annual rate of 0.10% of the value of a
client’s Account. Such amounts are retained by
Baird for the services it provides.
o applicable account fees and charges;
o the client’s use of third party managers who
charge their own fees for managing accounts
in addition to GWG’s Advice Fee; and
As the portion of the Advisory Fee or Portfolio Fee
paid to an Other Manager increases, the portion
of the Advisory Fee or Portfolio Fee that is
retained by Baird decreases. Thus, Baird (but not
GWG) has an incentive to recommend or favor
investment managers that are paid less, because
Baird will receive a higher portion of the Advisory
Fee or Portfolio Fee.
o the amount of the client’s account invested in
investment products that have additional
internal ongoing operating fees and expenses
(e.g., Funds).
In addition, Baird has an incentive to favor
Associated SMA Strategies over other SMA
Strategies because the entire Advisory Fee is
retained by Baird and Associated Managers and
Additional important information about brokerage
accounts and facts to consider when making
account type decisions is contained in the Client
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
because Baird benefits from its receipt of Advisory
Fees and the overall success of Associated
Managers. For more information, see “Other
Financial Industry Activities and Affiliations”
below.
include
invitations
affiliated managers and products and for referrals
to a limited number of other firms. More specific
information is provided under the headings “Other
Financial Industry Activities and Affiliations” and
“Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading—Participation
or Interest in Client Transactions” below. They
also generally receive non-cash compensation and
other benefits from Baird and from sponsors of
investment products with which Baird does
business. Such non-cash compensation and other
benefits may
to attend
conferences or educational seminars, payment of
related travel,
lodging and meal expenses,
reimbursement for branch and client events, and
receipt of gifts and entertainment. Receipt of such
compensation and benefits provides GWG
Consultants an incentive to favor investment
products and their sponsors that provide the
greatest levels of compensation and benefits.
their
total production
are
for
reimbursements,
awards
of
professional
fees
A GWG Consultant is primarily compensated on a
monthly basis based upon a percentage of the
GWG Consultant’s total production each month,
which primarily consists of the total advisory fees
and transaction-based fees paid to Baird by the
GWG Consultant’s clients and any other fees Baird
earns on advisory and brokerage accounts held by
those clients, including trail fees paid by third
parties. The percentage of the GWG Consultant’s
total production actually paid to the GWG
Consultant will increase as the total amount of the
GWG Consultant’s production increases, meaning
that, as the total amount of the GWG Consultant’s
production increases, the rate and amount of
compensation that Baird pays to the GWG
increase. GWG Consultants
Consultant also
generally also receive deferred compensation or
bonuses based on various criteria, including net
new assets they gather, performing certain wealth
management activities, such as financial planning,
levels. GWG
and
Consultants who achieve certain production
thresholds
professional
eligible
development conferences, business development
and
coaching,
recognition trips to attractive destinations. GWG
Consultants are also eligible for bonuses for
designations
achievement
depending on a GWG Consultant’s
total
production level. Thus, GWG Consultants have a
general incentive to generate financial and other
plans and charge higher
for advisory
accounts and recommend larger investments in
advisory accounts.
GWG Consultants generally receive recruitment
bonuses and/or special compensation from Baird
when they join Baird from another firm. The
amount of such special compensation is typically
based on the GWG Consultant’s production at the
prior firm for the 1-year period prior to joining
Baird or on the level of the GWG Consultant’s
client assets at the prior firm. All or a substantial
portion of the special compensation is paid in the
form of an upfront bonus when the GWG
Consultant joins Baird, and the remaining portion,
if any, is paid in the form of back end bonuses
generally in equal installments on an annual basis
thereafter
for a certain number of years
(generally from one to three years). Installment
payments are generally contingent upon the GWG
Consultant achieving annual production or client
asset levels that exceed a significant percentage
of the GWG Consultant’s annual production for
the 1-year period prior to joining Baird or the
client assets that the GWG Consultant had prior to
joining Baird. The special compensation
is
intended to compensate GWG Consultants for the
significant effort involved in transitioning their
business from the prior firm. This compensation
provides GWG Consultants who have left another
firm additional incentive to recommend that
clients of the prior firm become Baird clients and
to recommend investment products and services
that increase their production, and thus presents
a conflict of interest. The special compensation is
generally structured in the form of a forgivable
loan from Baird to the GWG Consultant. Under the
terms of the forgivable loan, Baird makes the
Given the structure of their compensation, they
also have an incentive to recommend that a client
transfer the client’s accounts to Baird, establish
new accounts with Baird (including IRA rollovers)
and add more money into the client’s accounts. In
addition, most GWG Consultants are shareholders
of Baird Financial Group, Inc. (“BFG”), Baird’s
ultimate parent company, and thus benefit
financially from the overall success of Baird and
its Associated Parties. The number of shares of
BFG stock that a GWG Consultant may purchase
is based in part on the GWG Consultant’s total
level. GWG Consultants generally
production
receive compensation for referrals to certain
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in
the
important
to GWG Consultants
value or return of the client’s investment in the
product. These fees and expenses may include
investment management fees, distribution (12b-
1) fees, shareholder servicing fees, transfer
agency fees, networking fees, accounting fees,
marketing support payments, administration fees,
custody
fees, expense reimbursements, and
expenses associated with executing securities
transactions for the investment product’s portfolio
(“ongoing operating expenses”). These ongoing
operating expenses are separate from, and in
addition to, the Advisory Fees. As a result of
making investments in these types of products, a
client should be aware that the client is paying
multiple layers of fees and expenses on the
amount of the client’s assets so invested—the
ongoing operating expenses and the Advisory
information about
Fee. Additional
ongoing fees and expenses that apply to those
types of investments is provided in Baird’s Client
Relationship Details document and Baird’s website
at bairdwealth.com/retailinvestor. A client can
find the actual ongoing fees and expenses of an
investment product that the client will pay or bear
in the product’s prospectus or offering document.
upfront or installment payment to the GWG
Consultant in the form of a loan, and Baird
forgives a portion of the loan made to the GWG
Consultant each month for so long as the GWG
Consultant remains Baird’s employee. Should the
GWG Consultant cease to be Baird’s employee
prior to the maturity date of the loan, the GWG
Consultant is required to repay Baird the amount
of the loan outstanding and not forgiven by Baird.
In other words, upon leaving Baird, the GWG
Consultant would be required to repay to Baird a
portion of the special compensation that the GWG
Consultant had received and that had not been
forgiven. The amount of such repayment declines
over time in proportion to the time the GWG
Consultant remains Baird’s employee. Structuring
this special compensation
form of
forgivable loans provides the GWG Consultant
added incentive to remain Baird’s employee and
to recommend that persons become and remain a
Baird client. Additional information about referral
and non-cash compensation and other financial
incentives provided
is
provided under the heading “Code of Ethics,
Participation or Interest in Client Transactions and
Personal Trading—Participation or Interest
in
Client Transactions” below.
In
those
instances,
website
From time to time, Baird GWG Consultants
outside of GWG may refer their clients to GWG
the GWG
Consultants.
Consultant generally shares a portion of his or her
compensation with the referring Baird Financial
Advisor.
Additional Account Fees and Charges
If the client’s Account is custodied at Baird, the
client is also responsible for all applicable account
fees and service charges Baird may impose in
connection with the client’s agreements with
Baird. A schedule of fees and service charges is
available
at
Baird’s
on
bairdwealth.com/retailinvestor.
Baird addresses the conflicts described above
through disclosure in this Brochure and by
adopting internal policies and procedures for GWG
and Baird and their associates that require them
to provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients).
Other Fees and Charges
In addition to the Advisory Fee described above, a
client of GWG will incur other fees and expenses.
The asset-based fee only covers investment
advice provided by GWG, and a client will pay for
other services, such as custody and trade
execution, separately in addition to the Advisory
Fee. Please see the section “Brokerage Practices”
below for more information about GWG’s trading
practices.
A client is responsible for bearing or paying, in
addition to the Advisory Fee, the costs of all:
front-end or deferred sales
• commissions,
charges, redemption fees, or other charges;
• markups, markdowns, and spreads charged by
Baird in a principal transaction with a client or
Other Fees and Expenses
Cost and Expense Information for Certain
Investment Products
A client should be aware that certain investment
products in which the client invests, such as
mutual funds and other Funds, annuities and
their own ongoing
other products, have
management and other operating
fees and
expenses that are deducted from the assets of the
product (or income or gains generated by the
product on its investments) and thus reduce the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
charged by other broker-dealers that buy
securities from, or sell securities to, the client’s
Account (such costs are inherently reflected in
the price the client pays or receives for such
securities);
• redemption fees, surrender charges or similar
fees that an investment product or its sponsor
may impose;
In addition to the Advisory Fee, a client will also
be responsible for paying the fees charged by
each investment manager selected by the client
under the Dual Contract Program. If a client
directs GWG or Baird to pay the client’s DC
Manager’s fee out of the client’s Account, and
GWG or Baird agree to do so, GWG and Baird will
not be responsible for verifying the calculation or
accuracy of such fee.
• underwriting discounts, dealer concessions or
similar fees related to the public offering of
investment products;
• extra or special fees or expenses that may
result from the execution of odd lot trade orders
(i.e., “odd-lot differential”);
• electronic fund fees, wire transfer fees, fees for
transferring an investment between firms, and
similar fees or expenses related to account
transfers (including any such fees imposed by
Baird);
• currency conversions and transactions;
conversions,
• securities
including, without
limitation, the conversion of ADRs to or from
foreign ordinary shares;
• interest, fees and other costs related to margin
accounts, short sales and options trades;
If a client holds an Unsupervised Asset in the
client’s Account, the client may be charged a
commission, markup or markdown in connection
with its purchase or sale. The cash proceeds from
the sale of an Unsupervised Asset that remain in
a client’s Account are considered Permitted
Investments subject to the asset-based Advisory
Fee. If an asset becomes an Unsupervised Asset
during a quarterly billing period, that asset will be
excluded for purposes of determining the asset-
based Advisory Fee beginning at the start of the
next quarterly billing period, and no portion of the
asset-based Advisory Fee paid by a client in
advance for the quarter will be refunded or
rebated to the client. Additionally, Unsupervised
Assets in an Account are subject to any applicable
fees
set-up, maintenance and administrative
established by Baird. Baird may waive such fees
in its discretion.
related
to
the
• fees
establishment,
administration or termination of Retirement
Accounts, retirement or profit sharing plans,
trusts or any other legal entity, including,
without limitation, the calculation and payment
of unrelated business income tax (“UBIT”);
Clients who have Accounts managed by GWG may
also have other accounts with Baird that are not
managed by GWG. Those accounts may be
subject to fees, commissions or other expenses
that are entirely separate from the payment of
fees and expenses for the services provided by
GWG.
• fees imposed by the SEC or securities markets,
including transaction fees imposed by electronic
trading platforms, which fees may be imbedded
in the price the client receives for the security;
and
imposed upon or
resulting
• taxes
from
transactions effected for a client’s Account, such
as income, transfer or transaction taxes, foreign
stamp duties, or any other costs or fees
mandated by law or regulation.
Other Compensation Received by GWG and
Baird
Baird is registered as a broker-dealer under the
Securities Exchange Act, and GWG Consultants
are registered broker-dealer representatives of
Baird. In such capacities, Baird and GWG
Consultants provide brokerage and
related
services to clients, including the purchase and
sale of individual stocks, bonds, mutual funds,
private investment funds, and other securities,
and sales of annuities. At times, Baird and GWG
Consultants provide such brokerage and related
services to clients in connection with the Services
described in this Brochure. Baird and GWG
Consultants receive compensation based upon the
sale of such securities and other investment
Clients who use a custodian other than, or in
addition to, Baird will pay the other custodian’s
fees and expenses in addition to the Advisory Fee.
In addition, if a third party custodian has custody
of the client’s Account assets, the Account is
subject to any applicable set-up, maintenance and
administrative fees established by Baird. Baird
may waive such fees in its discretion.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
based fees over client accounts that are not
subject to performance-based fees.
interest
of
fee
the
arrangements
holdings
inequitable
In addition to complying with its fiduciary duties
by disclosing this conflict of interest to clients
through this Brochure, Baird generally addresses
posed by
potential
conflicts
by
performance-based
periodically monitoring
and
performance of performance-based fee accounts
and comparing them to accounts not subject to a
performance fee that are also managed using a
similar strategy in an attempt to detect any
possible
treatment. Baird also
attempts to minimize potential conflicts of interest
posed by performance-based fee arrangements
through internal trade allocation procedures that
are designed to make securities allocations to
discretionary client accounts in a manner such
that all such clients receive fair and equitable
treatment over time.
Interest
products, including asset-based sales charges and
service fees on the sale of mutual funds. This
practice presents a conflict of interest because it
gives Baird and GWG Consultants an incentive to
use, select or recommend investment products
based upon the compensation received rather
than on a client’s needs. However, when
providing investment advisory services to clients,
Baird and GWG Consultants are fiduciaries and
are required to act solely in the best interest of
clients. Baird addresses this conflict through
disclosure in this Brochure and by adopting
internal policies and procedures for GWG and
Baird and their associates that require them to
provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients). For more specific
information about Baird’s compensation and other
benefit arrangements and how Baird addresses
the potential conflicts of interest, please see the
sections “Advisory Business” and “Fees and
Compensation” above, and “Other Financial
Industry Activities and Affiliations” and “Code of
Ethics, Participation or
in Client
Transactions and Personal Trading” below.
individuals and
their
requirements
for
opening
GWG will purchase for client accounts, or will
recommend the purchase of, various investment
products, including “no load” mutual funds or
mutual funds with waived sales loads. A client has
the option to purchase investment products
through other brokers or agents that are not
affiliated with Baird.
Types of Clients
GWG offers the Services primarily to: high net
worth
families and
businesses. GWG also provides services to other
types of current or prospective clients, including,
but not limited to: pension and profit sharing
plans; trusts; estates; charitable organizations;
and corporations or other business entities.
or
Applicable
maintaining an Account, such as minimum
account size, are discussed in the section entitled
“Fees and Compensation—Advisory Fees” above.
Performance-Based Fees and Side-By-
Side Management
GWG does not advise any client accounts that are
subject to performance-based fee arrangements.
Methods of Analysis, Investment
Strategies and Risk of Loss
Investment Strategies
The investment styles, philosophies, strategies,
techniques and methods of analysis that GWG,
investment
Baird, Baird PWM’s home office
professionals, and Other Managers use
in
formulating investment advice for clients vary
widely by Service and the person providing the
advice. A brief description of commonly used
strategies is provided below.
Act.
Performance-based
Equity Strategies
Equity strategies generally have an objective to
provide growth of capital and primarily invest in
equity securities, such as common stocks.
However, these strategies may also invest in
other types of investments, such as fixed income
Baird advises client accounts not participating in
services described in this Brochure that are
subject to performance-based fee arrangements.
Performance-based fee arrangements involve the
payment of fees based upon the capital gains or
capital appreciation of a client’s account. Any such
fee arrangements are made in compliance with
applicable provisions of Rule 205-3 under the
Advisers
fee
arrangements present a potential conflict of
interest for Baird (but not GWG) with respect to
other client accounts that are not subject to
performance-based fee arrangements because
such arrangements give Baird an incentive to
favor client accounts subject to performance-
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
those that the investment manager believes are
out of favor with investors, appear underpriced by
the market relative to their earnings or intrinsic
value, or have high dividend yields. This strategy
is subject to investment style risks.
focused,
securities and cash. Equity strategies may invest
in companies of all market capitalization ranges or
may
focus on any combination of specific
capitalization ranges, such as large cap, mid cap
or small cap companies. Equity strategies may be
combined with other strategies described below,
such as growth, value, income, economic industry
or sector
international, global, or
geographic region or country focused strategies.
Growth Strategies
A growth strategy typically invests primarily in
equity securities of growth companies, which are
those that the investment manager believes
exhibit signs of above-average growth relative to
peers or the market, even if the share price is
high relative to earnings or intrinsic value. This
strategy is subject to investment style risks.
fixed
invest
Income Strategies
An income strategy typically invests primarily in
income-producing securities, such as dividend-
income
paying equity securities and
securities. This strategy may
in a
combination of investment grade and high yield
bonds. This type of strategy may also invest in
yield- or
income-producing, Non-Traditional
Assets.
technology,
region or
country
Fixed Income or Bond Strategies
Fixed income or bond strategies generally have
one or more of the following objectives: (1)
provide current income; or (2) preservation of
capital. These strategies primarily invest in fixed
income securities, such as corporate bonds,
municipal securities, mortgage-backed or asset-
backed securities, or government or agency debt
obligations. However, these strategies may also
invest in other types of investments, such as
equity securities or cash. Fixed income strategies
may invest in debt obligations having any credit
rating, maturity or duration, or they may focus on
specific credit ratings, maturities or durations,
such as investment grade, non-rated, or high
yield (“junk”) bonds, or bonds having short-term,
intermediate-term or long-term maturities. Fixed
income strategies may be combined with other
strategies described below, such as economic
industry or sector focused, international, global,
focused
or geographic
strategies.
Economic Industry or Sector Focused Strategies
Economic industry or sector focused strategies
primarily invest in companies in one or more
economic industries or sectors, such as the
telecommunications,
industrial,
materials, or financial sectors. These strategies
alone generally are not intended to satisfy a
client’s entire portfolio diversification needs.
These strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
include companies
ranges,
regions, credit
International Strategies
Generally, international strategies primarily invest
in securities issued by foreign companies, which
may
in developed and
emerging markets. International strategies may
invest in companies of all market capitalization
ranges and in investments having any credit
rating, maturity or duration, or they may focus on
industries or
specific capitalization
sectors, geographic
ratings,
maturities or durations.
region or market
Balanced Strategies
Balanced strategies generally have one or more of
the following objectives: (1) provide current
income; (2) growth of capital/principal or income;
or (3) preservation of capital. These strategies
primarily invest in a mix of equity, fixed income
securities and cash. Balanced strategies may
invest in companies of all market capitalization
ranges and in investments having any credit
rating, maturity or duration, or they may focus on
specific capitalization ranges, credit ratings,
maturities or durations as described above.
Balanced strategies may be combined with other
strategies described below, such as economic
industry or sector focused, international, global,
focused
or geographic
strategies.
Global Strategies
Generally, global strategies invest in a mix of
securities issued by U.S. and foreign companies,
which may include companies in developed and
Value Strategies
A value strategy typically invests primarily in
equity securities of value companies, which are
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
ranges,
regions, credit
emerging markets. Global strategies may invest
in companies of all market capitalization ranges
and in investments having any credit rating,
maturity or duration, or they may focus on
industries or
specific capitalization
sectors, geographic
ratings,
maturities or durations.
Geographic Region or Country Focused Strategies
Geographic region or country focused strategies
primarily invest in companies located a particular
part of the world, such as Latin America, Europe
or Asia, in a group of similarly-situated countries,
such as developed or emerging markets, or one
or more specific countries. These strategies alone
generally are not intended to satisfy a client’s
entire portfolio diversification needs. These
strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
than other strategies. The
to
Opportunity or Opportunistic Strategies
Opportunity strategies will generally be invested
in a manner that seeks to provide long term
through capital appreciation and/or
growth
income by utilizing an active management style
that shifts the amount of investment made in
different asset classes and market sectors to take
advantage of the manager’s perception of market
pricing anomalies, those market or industry
sectors deemed favorable for investment by the
manager, the current interest rate environment
and/or other macro-economic trends identified by
the manager. Opportunity strategies often involve
the use of other strategies, particularly tactical or
rotation strategies, and will have the risks
associated with those strategies. Opportunity
Strategies may also involve investment in a more-
limited number of companies compared to other
strategies. As a result, a decline in value of one or
a few investments will more adversely impact
performance than if assets were more evenly
invested in a larger number of companies.
Opportunity strategies often experience higher
fluctuations in annual returns and overall market
value
types of
investments used
implement opportunity
strategies vary widely by manager and could
include equity securities, fixed income securities,
Non-Traditional Assets, Alternative Investment
Products and cash.
underweighting
and
taxable
Tax Management Strategies
Tax management strategies involve buying and
selling investments in a manner intended to
reduce the negative impact of U.S. federal income
taxes. They often involve buying or selling
investments to limit taxable investment gains or
to offset
investment gains with
investment losses or selling investments to avoid
recognition of taxable investment gains.
tax management strategy
is
strategies are often
subject
these
strategies
Tactical and Rotation Strategies
Tactical strategies typically tactically and actively
adjust account allocations to different categories
of investments, such as asset classes, geographic
locations or market sectors, based upon the
manager’s perception of how those investments
will perform in the short-term. Similarly, rotation
strategies
typically actively adjust account
allocations to different market sectors based upon
the manager’s perception of how those market
sectors will perform in the short-term. Tactical
and rotation strategies are often driven by
technical analysis or methodologies and typically
overweighting
involve
account allocations to certain asset classes,
geographic locations or market sectors relative to
an applicable long-term strategic asset allocation,
benchmark index or the market generally. These
strategies often will be focused or concentrated in
one or more asset classes, geographic locations or
market sectors from time to time, and it is likely
that they will have limited or no exposure to one
or more asset classes, geographic locations or
market sectors. For that reason, tactical and
rotation
to
concentration risk. Because the decision-making
for tactical and rotation strategies is based upon
the manager’s short-term market outlook,
accounts pursuing
often
experience higher levels of trading and portfolio
turnover relative to other strategies.
A
typically a
secondary strategy used to achieve a secondary
tax management objective and it is typically
together with other primary
implemented
investment
to achieve
strategies designed
primary investment objectives or goals. However,
managers in certain situations may use a tax
management strategy as the primary investment
strategy or tax management may be their primary
consideration when managing client Accounts,
such as when the manager is transitioning an
Account from one investment strategy to another.
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the
strategy, particularly
utilizes
strategy
because there is a higher chance of uncoordinated
or conflicting trading activity in those accounts.
Automatic purchases in client accounts, such as
reinvestment programs, may also
dividend
inadvertently violate wash sales rules. A client’s
investments held in other accounts at Baird or
another firm may be deemed to be offsetting
positions for purposes of the IRS straddle rules,
which will also negatively impact the client’s
ability to deduct losses and will reduce the
intended benefit of the tax management strategy.
Accounts pursuing a tax management strategy in
some instances will be subject to additional or
different risks of loss, which may be material. The
holdings of Accounts pursuing tax management
strategies will often differ from the holdings of
similarly-managed accounts that do not utilize
if
such a
tax
management
replacement
the performance of
securities. Therefore,
Accounts utilizing a tax management strategy will
vary from similarly-managed accounts that do not
utilize such a strategy, possibly in a materially
negative manner, and such Accounts may not be
successful in pursuing any other investment
strategies, objectives or goals.
investment strategies, there
resulting
from
Tax management strategies are not intended to,
and likely will not, eliminate a client’s tax
obligations relating to investments in an Account.
Like all
is no
guarantee that the implementation of a tax
management strategy will be successful. A client’s
use of a tax management strategy may not
actually
lower a client’s tax obligations or
otherwise achieve a client’s tax goals.
Managers do not consider the holdings or
transactions in other client accounts (whether
held at Baird or another firm) when implementing
tax management strategies. Managers do not
undertake any responsibility to monitor or verify a
client’s compliance with applicable tax rules, and
they are not responsible for any tax‑related
effects or obligations
the
investments or transactions in a client’s Account.
A client is responsible for ensuring that the
holdings and transactions in the client’s other
accounts at Baird or another firm do not violate
appliable tax rules and bears the risk of such
violations. A client is strongly urged to consult the
client’s tax advisor prior to pursuing a tax
management strategy.
that
involve
the
The effectiveness of tax management strategies
will be reduced if a client’s ability to recognize
losses for tax purposes is disallowed, limited or
deferred under applicable tax rules, such as the
IRS wash sales rules, which disallow losses if
substantially identical securities are purchased by
a client (whether through Baird or another firm)
within 30 days before or after a sale, and IRS
straddle rules, which limit and defer a client’s
ability to claim tax deductions related to the loss
on a sale of an investment in an Account if the
client holds an offsetting position in any account
firm. Some tax
held at Baird or another
the sale of
management strategies
securities at a loss and the reinvestment of the
proceeds into a replacement security that the
manager believes
to not be “substantially
identical” for purposes of the IRS wash sales rule.
A manager’s belief may be incorrect, resulting in
a disallowance of the loss and reducing the
intended benefits of
tax management
strategy.
limitations of
Direct Indexing Strategies
Direct indexing strategies involve investing in a
basket of individual securities, such as stocks,
that seeks to track a selected benchmark index.
Direct indexing strategies may be more costly
than other
track
investment options
benchmark indices, such as mutual funds and
ETFs. Direct indexing strategies also generally
include the use of tax management strategies in
an attempt to enhance Account performance. The
use of tax management strategies will cause an
Account to deviate from the benchmark index,
which will cause the Account’s returns to vary
from that of the benchmark index. The use of tax
management strategies may not be successful
and the performance of Accounts pursuing a
direct index strategy could be materially lower
than the benchmark index. See “Tax Management
Strategies” above for more information about the
tax management
risks and
strategies.
the wash sales
resulting
losses. The
rules,
risk of
Alternative Strategies and Complex Strategies
Alternative Strategies and other Complex
in a wide range of
Strategies may
invest
Trading activity in a client’s accounts (whether at
Baird or another firm) may also inadvertently
violate
in
disallowed
inadvertent
violations increases as the number of client
increases
accounts and managers
involved
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
common stock. This strategy may involve the
use of a wide range of derivative instruments.
• Fixed
Income Arbitrage Strategies. Fixed
income arbitrage strategies generally seek to
profit from interest rate, credit spread and other
arbitrage opportunities by investing in fixed
income securities, interest rate instruments and
derivative instruments.
investments, which may include equity securities,
fixed income securities, Non-Traditional Assets,
Alternative
Investment Products and cash.
Alternative Strategies and other Complex
Strategies generally involve the use of margin,
leverage, short sales and derivative instruments.
Many Alternative Strategies and other Complex
Strategies have no substantive restrictions on the
types of investments that may be used. Examples
of Alternative Strategies and other Complex
Strategies include the following.
• Relative Value Strategies. Relative value
strategies generally involve the purchase of
traditional assets, such as stocks and bonds,
and Non-Traditional Assets and the use of short
sales and derivative instruments in an attempt
to exploit price differences among securities
that share similar economic or
financial
characteristics.
• Capital Structure Arbitrage Strategies. Capital
structure arbitrage generally involves investing
in multiple levels of a single company’s capital
structure, often taking long and short positions
in a company’s debt or equity in order to
capitalize on perceived mispricings resulting
from market inefficiencies or different pricing
assumptions. This type of strategy typically
involves the use of derivatives and structured
products.
• Long/Short Strategies. Long/short strategies
generally involve the purchase of securities
believed to be undervalued and selling short
securities believed to be overvalued. They may
also involve the use of Non-Traditional Assets,
leverage and derivative instruments.
• Absolute Return, Total Return and Real Return
Strategies. Absolute return, total return and
real return strategies generally involve the
purchase of traditional assets, such as stocks
and bonds, and Non-Traditional Assets in an
attempt to generate performance that has low
correlation to the major equity markets over a
complete market cycle. They may also involve
the use of derivative instruments.
• Event-Driven
• Market Neutral Strategies. Market neutral
strategies generally involve the purchase of
securities and selling securities short in similar
dollar amounts in an attempt to produce returns
that are
independent of general market
performance. They may also involve the use of
Non-Traditional Assets, leverage and derivative
instruments.
events
(such
and
liquidations).
Event-driven
Strategies.
strategies generally involve the use of Non-
Traditional Assets, short sales and derivative
instruments in an attempt to seek arbitrage
opportunities, particularly those triggered by
as mergers,
corporate
restructurings,
These
strategies typically involve the assessment of if,
how and when an announced transaction will be
completed.
• Statistical Arbitrage Strategies. Statistical
Arbitrage is based on the theory that stocks
have a tendency to return to a short-term trend
line. This type of strategy typically involves the
“systematic” or automated trading of securities
based upon where a security is relative to its
trend line.
arbitrage
strategies
involve
in corporate
is
buy-outs,
restructurings
short
securities believed
• Merger Arbitrage/Special Situations Strategies.
Merger
the
purchase and sale of securities of companies
involved
reorganizations and
business combinations, such as mergers,
exchange offers, cash tender offers, spin-offs,
and
leveraged
liquidations. These strategies often
involve
short selling, options trading, and the use of
other derivative instruments.
• Convertible Arbitrage Strategies. Convertible
arbitrage involves the purchase and short sale
of multiple securities of the same company. The
implemented by purchasing
strategy
securities believed to be undervalued and
selling
to be
overvalued. Often, the strategy involves the
purchase of a convertible bond issued by a
company and selling short that company’s
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
typically unrated or
• Distressed Strategies. Distressed strategies
generally involve the purchase of securities in
companies that are in financial distress, or
companies that are entering into or are already
in bankruptcy. They may also involve the use of
short sales and derivative instruments.
types of
referred
to as
floating
in
smaller
private debt funds. The investments involved
are
rated below
investment grade and are illiquid. Oftentimes,
the interest rate paid by the companies is
determined by a reference interest rate, such
as the federal funds rate, which is periodically
investments are
reset. These
sometimes
rate
corporate debt, floating rate loans or floating
rate bank loans. Private debt strategies often
involve the use of leverage and may involve
investment
capitalization,
distressed or bankrupt companies.
• Macro Strategies. Macro strategies generally
involve the purchase of traditional assets, such
as stocks and bonds, and Non-Traditional Assets
and the use of short sales and derivative
instruments in an attempt to profit from
in securities markets,
anticipated changes
commodities markets, currency values, and/or
interest rates.
and
Systematic
• Discretionary
industrial
typically made
strategies
generally
rely
Trading
Strategies. Discretionary
trading strategies
generally attempt to identify and capitalize on
patterns or trends in the markets. Systematic
trading
on
computerized trading systems or models to
identify and capitalize on those patterns or
trends. These strategies often involve the use of
Non-Traditional Assets, short sales, derivative
instruments and significant leverage.
risks
related
• Private Investment Strategies.
o Private Real Estate Strategies. Private real
estate strategies invest in physical properties,
such as office buildings, apartments, retail
facilities. These
centers, and
investments are
through
participation in private REITs. Private real
focus on specific
estate strategies may
types, or
regions, property
geographic
economic sectors. Investments in private real
estate can be illiquid, meaning they may take
time to sell or refinance. Property values can
fluctuate due to market conditions, supply
and demand, and other factors. There are
also
tenant vacancies,
to
property damage, or environmental hazards.
Leverage is often used in private real estate
investments, which can increase potential
returns but also amplifies potential losses.
generally
in
companies
involve
in
o Private
invest
types. Examples of
include,
These
among
utilities,
investments
o Private Equity Strategies. Private equity
equity
strategies
investments
private
transactions. These investments are typically
made through participation in private equity
funds or funds of private equity funds. Private
equity strategies may invest in companies of
all market capitalization ranges or may focus
on any combination of specific capitalization
ranges. They may also focus on companies in
one or more economic industries or sectors or
geographic regions. Some private equity
strategies focus on companies that are newly
formed, in financial distress or already in
bankruptcy. The securities purchased are
typically unregistered and illiquid. Private
equity strategies may also involve the use of
leverage.
Infrastructure Strategies. Private
infrastructure
in
strategies
infrastructure projects and assets and may
involve exposure to a range of economic or
market sectors, geographic locations and
infrastructure
asset
others,
investments
and
telecommunication,
transportation.
are
typically made through participation in private
infrastructure funds. Investments in private
infrastructure strategies are often illiquid.
They may focus on certain sectors, industries,
geographic regions, size ranges or stages of
development or operations, or on certain
types and sizes of investments and may,
therefore, also lack diversification.
o Private Debt or Private Credit Strategies.
Private debt (also known as private credit)
strategies invest in loans or debt instruments
issued by companies in private transactions.
These investments are typically made through
participation in private debt funds or funds of
• Leveraged Strategies. Leveraged strategies
generally involve the use of Non-Traditional
Assets, leverage, short sales and derivative
instruments in an attempt to amplify returns or
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
produce returns that are a multiple of a
benchmark index.
instruments; and currencies and currency-
linked instruments, and Digital Assets;
• the Alternative Investment Products category
which is comprised of certain asset classes,
such as: hedge funds, private equity funds and
managed futures; and
• Inverse Strategies. Inverse strategies generally
involve the use of Non-Traditional Assets,
leverage, short sales and derivative instruments
in an attempt to produce returns that are the
opposite of a benchmark index.
• cash.
allocation
strategies
have
Business—Additional
also
have
varying
Alternative Strategies and other Complex
Strategies are not appropriate for some clients
because they are subject to special risks. See
Service
“Advisory
Information—Complex Strategies and Complex
Investment Products” above and “Methods of
Analysis, Investment Strategies and Risk of
Loss—Principal Risks—Non-Traditional Assets and
Complex Strategies Risks” below
for more
information.
investing, which
and
actively
typically
adjusting
tactical
Asset Allocation Strategies
Certain Services, including the GWG Investment
Management Service, make available asset
allocation strategies. Asset allocation strategies
involve investing in one or more of the following
categories of assets:
Asset
varying
investment objectives, ranging from growth of
capital to preservation of capital. Asset allocation
strategies
investment
strategies. Some asset allocation strategies use
strategic investment strategies, which involve
in accordance with a
investing accounts
predetermined target allocation to different asset
classes. Some asset allocation strategies use
involves
tactical
tactically
account
allocations to different asset classes based upon
the manager’s perception of how those asset
classes will perform in the short-term. Some asset
allocation strategies involve the use of both
investment strategies,
strategic and
sometimes referred to as dynamic strategies.
Asset allocation strategies may be implemented
using a variety of investment types, such as
individual securities, mutual funds and ETPs. The
amount allocated to an asset class or investment
type varies by strategy, and some strategies may
have little or no allocation to one or more asset
classes or types of investments described above.
companies; U.S.
cap
located
• the equity securities asset category, which is
comprised of certain asset classes, such as,
equity securities issued by: U.S. large cap
large cap value
growth companies; U.S.
companies; U.S. large cap core companies; U.S.
mid cap growth companies; U.S. mid cap value
companies; U.S. mid cap core companies; U.S.
small cap growth companies; U.S. small cap
core
small
value
companies;
in
foreign companies
developed markets; foreign companies located
in emerging markets; U.S. REITs; and foreign
REITs;
involves
as:
short-term
taxable
that are based upon
Baird’s
projections
• the fixed income securities asset category,
which is comprised of certain asset classes,
bonds;
such
intermediate term taxable bonds; long-term
taxable bonds; short-term tax-exempt bonds;
intermediate term tax-exempt bonds; long-term
tax-exempt bonds; high yield fixed income
securities; foreign fixed income securities; and
broad fixed income securities;
Baird uses its Capital Market Assumptions in
developing its proprietary model asset allocation
strategies, including those used by some GWG
Consultants. In determining its Capital Market
Assumptions, Baird conducts an analysis of
different asset classes and the different levels of
risk associated with those investments. That
analysis
the consideration of past
performance and the use of forward-looking
projections
certain
assumptions made by Baird about how markets
will perform in the future. There is no assurance
that asset classes or markets will perform in
accordance with
or
assumptions. For more information about Baird’s
Capital Market Assumptions, a client should
contact the client’s GWG Consultant.
• the Non-Traditional Assets category, which is
comprised of certain asset classes, such as:
commodity-linked
commodities
and
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird’s most common asset allocation strategies
are described below. A client should note that the
specific investments in an Account following a
particular asset allocation strategy could vary
from the description below for a number of
reasons, including market conditions.
Income with Growth Portfolio. An Income with
Growth Portfolio typically seeks to provide current
income and some growth of capital. Typically, an
Income with Growth Portfolio will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, this strategy will primarily
invest in a mix of fixed income securities and
equity securities, with a bias towards fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
fixed income securities than equity securities.
invest
All Growth Portfolio. An All Growth Portfolio
typically seeks to provide growth of capital.
Typically, an All Growth Portfolio will experience
high fluctuations in annual returns and overall
market value. Under normal market conditions,
this strategy generally invests nearly all of its
assets in equity securities. This strategy may also
invest in other asset classes, such as fixed income
securities, Non-Traditional Assets and cash. This
strategy may also
in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
experience
relatively
Conservative Income Portfolio. A Conservative
Income Portfolio typically seeks to provide current
Income
income. Typically, a Conservative
small
Portfolio will
fluctuations in annual returns and overall market
value. Generally, under normal market conditions,
this strategy will primarily invest in a mix of fixed
income securities, cash and equity securities, with
a significantly higher allocation to fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets.
Generally, under normal market conditions, this
strategy will have a significantly higher allocation
to fixed income securities and cash than equity
securities.
Preservation
A
Portfolio.
Capital Growth Portfolio. A Capital Growth
Portfolio typically seeks to provide growth of
capital. Typically, a Capital Growth Portfolio will
experience moderately high fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, this strategy will
primarily invest in a mix of equity securities and
fixed income securities, with a significantly higher
allocation to equity securities. This strategy may
also invest in other asset classes, such as Non-
Traditional Assets and cash. This strategy may
also invest in Alternative Investment Products or
may involve the use of leverage, short sales and
derivative instruments. Generally, under normal
market conditions, this strategy will have a
significantly higher allocation to equity securities
than fixed income securities.
typically seeks
Capital
Capital
Preservation Portfolio typically seeks to preserve
capital while generating current income. Typically,
a Capital Preservation Portfolio will experience
relatively small fluctuations in annual returns and
overall market value. Under normal market
conditions, this strategy generally invests nearly
all of its assets in a mix of fixed income securities
and cash. This strategy may also invest in other
asset classes, such as equity securities and Non-
Traditional Assets.
and
targets only. There
Growth with Income Portfolio. A Growth with
to provide
Income Portfolio
moderate growth of capital and some current
income. Typically, a Growth with Income Portfolio
will experience moderate fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, this strategy will
primarily invest in a mix of equity securities and
fixed income securities, with a bias towards equity
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
equity securities than fixed income securities.
Some GWG Consultants
investment
managers use asset allocation strategies that
include target asset allocation percentages for
equity and/or fixed income investments in the
names or descriptions of the strategies (e.g., 80-
20, 60-40, 40-60, 20-80, etc.). A client should
note that those percentages are intended to be
is no
asset allocation
guarantee that Accounts following asset allocation
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment
restrictions,
Strategies”
below
strategies will be invested strictly in accordance
with target asset allocations. It is likely that the
actual investments in Accounts following those
strategies will vary, sometimes significantly, from
the target asset allocations and may include other
asset classes due to market conditions and the
GWG Consultant’s or
investment manager’s
assessment of how to best invest a client’s
Accounts. See “Important Information about
Implementation of Investment Objectives and
Investment
for more
information.
For information about the risks associated with
the asset allocation strategies described above,
see the section of the Brochure entitled “Principal
Risks—Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies” below.
invested in a manner inconsistent with the
investment strategy or
investment objective
selected by the client for the Account in certain
other circumstances, such as when the client’s
Account
is transitioning to a new Service,
investment objective or investment strategy, or
due to other factors, such as market appreciation
or depreciation of the assets in the client’s
Account, deposits and withdrawals made by the
client, and
if any,
imposed by the client. A client’s Account may not
be able to achieve its investment objectives
during any such period of time and the Account
may be subject to different or enhanced risks
than would be the case had the Account been
invested in a manner wholly consistent with the
investment objective or
investment strategy
selected by the client. Clients are encouraged to
discuss with their GWG Consultant on a regular
basis how the Account is being managed or
advised and whether any such conditions exist.
Methods of Analysis
Baird, its home office investment professionals,
and GWG Consultants may use various forms of
investment analyses, including the following:
Important Information about Implementation of
Investment Objectives and Investment Strategies
A client should note that, to implement an
investment strategy, a client’s GWG Consultant or
investment manager may use or recommend
mutual funds, ETPs or other Funds that primarily
invest in particular types of securities instead of
direct investment in those types of securities. A
client should also note that the client’s GWG
Consultant or investment manager may use a
strategy not described above or they may use a
strategy with the same or similar name that is
implemented differently. A client should ask the
client’s GWG Consultant or investment manager
for more specific information about the strategy
being used for the client’s Account.
• Fundamental Analysis. Fundamental analysis
involves an approach to investing through a
detailed analysis of specific companies, such as
their financial statements and financial ratios,
management, competitive advantages and
markets, in an attempt to determine the value
of an investment. Fundamental analysis may
include qualitative and quantitative analyses.
Analysis. Qualitative
• Qualitative
A client’s Account
is subject to the risks
associated with the Account’s particular strategies
and investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
analysis
involves the use of subjective judgment to
analyze factors that may be difficult to quantify
or measure objectively. As it pertains to
managers and investment products, qualitative
analysis may include review of the background
and experience of a manager or a mutual fund
company.
in an attempt
From time to time, the client’s GWG Consultant or
investment manager will
invest the client’s
Account, or recommend that the client invest the
Account, in a manner that is inconsistent with the
investment strategy or
investment objective
selected by the client for the Account when the
client’s GWG Consultant or investment manager
determines that it is appropriate to do so, such as
using defensive strategies in response to adverse
market or other conditions or engaging in tax
management. Similarly, a client’s Account may be
• Quantitative Analysis. Quantitative analysis is a
method of evaluating securities by analyzing a
large amount of data through the use of
to
algorithms or models
understand behavior, predict market events,
market prices, etc., and generate an investment
decision. As it pertains to managers and
investment products, quantitative analysis may
review of manager performance,
include
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment style, style consistency, risk, and
risk-adjusted performance.
(“AI”)
• Technical Analysis. Technical analysis is a
method of analyzing past price and volume
patterns and trends in the trading markets to
attempt to predict the direction of both the
overall market and specific investments.
in
formulating
• Top-Down Analysis. Top-down analysis involves
a consideration of certain macroeconomic
trends, such as general economic conditions,
geographic or market sector performance, fiscal
and monetary policy, taxes, or interest rates, to
make investment decisions.
Analysis. Bottom-up
• Bottom-Up
investment,
Baird PWM home office investment professionals
and GWG Consultants may use artificial
intelligence
tools, such as machine
learning, predictive analytics and probabilistic
modeling tools, data processing and automation
tools, generative AI tools, visual, speech and
audio tools, specialized domain tools, and other
similar technologies and tools (collectively, “AI
investment advice.
Tools”),
Generally, the use of AI Tools is limited to certain
aspects of Baird’s investment-advice process,
such as assisting with drafting of materials,
automation of workflow processes, and the
compilation,
organization,
reproduction,
summarization, analysis and interpretation of
information. The use of AI Tools is only supportive
of Baird’s investment-advice process and does not
replace the professional judgment of Baird PWM
home office investment professionals or GWG
Consultants. All AI Tool-assisted outputs used in
formulating investment advice are subject to
inform
review before such outputs
human
recommendations or investment decisions.
analysis
involves consideration of factors particular to a
particular
such as business
financials (e.g., balance sheet strength and
cash flows), financial ratios (e.g., price-to-
earnings ratio), and business fundamentals
(e.g., management and product or services
performance) to make investment decisions.
could negatively
influence
When providing investment advice to clients,
GWG Consultants utilize research reports and
other research material created by Baird PWM
Research Groups, such as PWM Equity Research,
PWM Fixed Income Research, and Asset Manager
Research. GWG Consultants may also utilize
research reports created by Baird’s Institutional
Equities & Research Department. It should be
noted that GWG Consultants are not obligated to
act in a manner consistent with those research
reports and they may act in a manner that is
contrary to those reports if they deem it to be in
the client’s best interest.
PWM Research Groups
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations,
deceptive behaviors and other flaws due to the
construction of their underlying models and the
composition of their training data, which can
result in outputs that seem plausible but are in
fact inaccurate, incomplete, or misleading. The
use of AI Tools creates a risk that erroneous
information
the
investment-advice process. Baird has established
policies and procedures designed to address the
include
risks posed by AI Tools, which
requirements that AI Tools pass a firm-level due
diligence process and that Baird associates obtain
training and independently verify AI Tool outputs.
However, such measures cannot eliminate the
risks posed by AI Tools.
and GWG
Baird
Consultants use various third party information
and tools when formulating investment advice.
The sources of information and tools may include,
among others, information provided or created by
issuers and their sponsors (which may include
information that is reported publicly, provided
directly to Baird, or reported through third party
platforms) and information and tools provided by
third party research firms, which may include
firms affiliated with Baird. Although Baird has
deemed the information and tools provided by
third party research firms to be generally reliable,
Baird does not independently verify or guarantee
the accuracy of the information or tools used.
When providing investment advice to clients,
GWG Consultants may also use the model
portfolios or recommended or eligible product lists
(described below) made available by Baird’s PWM
Research Groups, or they may use investment
products that Baird has generally deemed to be
“available” for use in its advisory programs
(“Available Investment Products”). The level of
initial and ongoing evaluation, monitoring and
review that GWG and Baird perform on managers
and on investment products varies. Available
Investment Products generally do not receive the
same level of initial or ongoing evaluation,
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monitoring or review by Baird as those managers
or products that are included in a model portfolio
or on a recommended or eligible product list. As a
result, Available Investment Products are subject
to certain risks. See “Methods of Analysis,
Investment Strategies and Risk of Loss—Principal
Risks—Available Investment Product Risks” below
for more information.
Individual stocks are selected with an emphasis
on higher quality companies that the team
believes have strong fundamental characteristics
teams, attractive growth
and management
prospects, and
reasonable price-appreciation
expectations. Each stock selected is assigned a
weighting as a percentage of the portfolio. No
single company stock will comprise more than the
greater of 5% of the portfolio or 1.5 times the
stock’s market weight in the S&P 500 index;
provided that a stock will not be removed due to
capital appreciation. Stocks can be sold or
positions reduced for a variety of reasons such as
valuation, a change in company or industry
fundamentals, or a change in industry sector
weighting. The Portfolio is intended as a long-
term investment strategy.
Baird Rising Dividend Portfolio
More specific information about Baird PWM model
portfolios, recommended lists and eligible product
lists is provided below. A client should note that
investment products recommended to the client
or selected for the client’s Account, including
investment managers or products included on a
Baird PWM recommended or eligible product list,
are those which, in Baird’s professional judgment,
may be appropriate to help the client pursue the
client’s financial goals. GWG and Baird do not
represent or guarantee that such investment
managers or products are or will be the best
investment managers or products available.
Under certain circumstances when requested by a
client, GWG and Baird may allow a client to
transfer from another firm or select an investment
product that is not on a Baird recommended or
eligible product list or that does not qualify as an
Available Investment Product. A client should note
that, unless GWG and Baird otherwise agree in
writing, GWG and Baird do not provide any initial
or ongoing evaluation, monitoring or review of
any such investment product and that the client’s
decision to transfer or select such investment
product is based solely upon the client’s review of
the investment product.
Certain PWM-Managed Portfolios
Baird Recommended Portfolio
The Baird Rising Dividend Portfolio, which is
managed by Baird’s PWM Equity Research team,
seeks to provide a core equity strategy with a
portfolio yield above that of the S&P 500 Index.
The team’s top–down investment approach begins
with macroeconomic and market outlooks from
Baird’s Investment Strategy team. The 30–50
stocks in the portfolio are primarily large cap
stocks—as defined by a market capitalization of
$10 billion or greater at the time of investment—
and all are above $5 billion at the time of
investment. The team looks for quality companies
with strong
fundamental characteristics and
management, attractive dividend yields, and the
ability to increase their dividends. Companies are
screened for dividend history and consistency,
earnings growth expectations, and balance sheet
quality. Each stock selected
is assigned a
weighting as a percentage of the portfolio. No
single company stock will comprise more than the
greater of 5% of the portfolio or 1.5 times the
stock’s market weight in the S&P 500 index;
provided that a stock will not be removed due to
capital appreciation. A position can be reduced or
removed due to changes in valuation, company
fundamentals or the perceived ability to continue
to raise its dividend in the future—among a
variety of other potential reasons for portfolio
changes including a change in industry sector
weighting. The Portfolio is intended as a long-
term investment strategy.
investment
approach
AQA Portfolios
to
clients
Baird makes available
Automated Quantitative
Analysis
certain
(“AQA”)
is
The Baird Recommended Portfolio, which
managed by Baird’s PWM Equity Research team,
seeks to outperform the S&P 500 Index by
investing in a diversified core portfolio of 35–50
stocks. The portfolio invests primarily in stocks
with market capitalization greater than or equal to
$10 billion (large cap). The portfolio may also
contain stocks with market caps below $10 billion
but these stocks generally will not represent more
than 35% of the total portfolio. The team’s top–
down
begins with
macroeconomic and market outlooks from Baird’s
Investment Strategy team. This information is
used to underweight or overweight particular
industry sectors compared to the S&P 500 Index.
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investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird
also considers other qualitative and quantitative
factors.
performance.
The
analysis
Baird’s Asset Manager Research Department is
primarily responsible for selecting and evaluating
included on Baird’s
investment managers
Recommended Managers List.
selecting
In
investment managers, Baird’s Asset Manager
Research Department utilizes quantitative and
qualitative measures to evaluate managers based
on the:
• quality and stability of their organization
• soundness and clarity of their investment
philosophy
• reliability and consistency of their investment
process
• competitiveness of their investment
performance
Baird’s Asset Manager Research Department may
also employ the use of computers and third party
software to more readily display information and
assist with the evaluation and analysis.
Portfolios, which are managed by Baird’s PWM
Equity Research team. AQA is an analytical tool
that seeks to identify stocks of companies that
are undervalued by calculating the intrinsic values
for the stocks and comparing the calculated
values to current market prices. Focusing on a
company’s past
financial performance, AQA
analyzes fundamental ratios and trends of the
most recent eight-year history of a company and
each company in its peer group, excluding
estimates of future balance sheet and income
statement
is
ignores certain qualitative
quantitative and
information such as company-specific material
news and events. Stocks are ranked from the
most undervalued to the most overvalued based
on the difference between the values calculated
by AQA and current market prices. The stocks
identified by AQA as being the most undervalued
are then selected for investment. Baird offers the
following four (4) AQA Portfolio strategies, each of
which invest in undervalued stocks identified
using AQA, excluding securities issued by banks,
REITS and insurance companies: (1) the AQA All
Cap Strategy, which primarily invests in stocks
across market capitalizations, generally those
included in the S&P 500®, S&P MidCap 400® or
S&P SmallCap 600® Indices; (2) the AQA Large
Cap Strategy, which primarily invests in large cap
stocks, generally those included in the S&P 500®
Index; (3) the AQA Mid Cap Strategy, which
primarily invests in mid cap stocks, generally
those included in the S&P MidCap 400® Index;
and (4) the AQA Small Cap Strategy, which
primarily invests in small cap stocks, generally
those included in the S&P SmallCap 600® Index.
Certain Recommended Lists
Baird’s Recommended Managers List
Baird’s initial screening process begins with a
proprietary, multi-factor model that evaluates
managers on different factors including risk-
adjusted performance, consistency of returns and
downside protection. These factors are scored
over various time periods and relative to a
specific peer group universe, narrowing the pool
of managers for further evaluation. Baird’s Asset
Manager Research Department then performs a
more in-depth evaluation of managers that are
identified through the initial screening process,
which generally includes a review of the following
factors: stability of the firm/team, the robustness
and repeatability of the investment process, the
portfolio’s past returns pattern and tax-efficiency,
and how the manager adds value. The final
determination of Baird’s Recommended Managers
List
is subject to the approval of Baird’s
Investment Committee.
conference
calls,
Ongoing manager evaluation generally includes
quarterly
performance
attribution and periodic onsite visits. Material
adverse changes affecting a manager may result
in the manager being placed on “watch” status.
Managers on “watch” status are scrutinized to see
When selecting managers and BRM Strategies for
Baird’s Recommended Managers List, Baird often
seeks registered investment advisory firms having
portfolio managers with academic credentials
such as a master’s degree or participation or
completion of the Chartered Financial Analyst
(“CFA”) program. Baird also typically looks for a
portfolio manager with greater than three (3)
years of investment experience focusing on the
particular investment style that is offered by the
portfolio manager. Baird generally looks for
portfolio managers
that have demonstrated
success, that have performance histories showing
sufficient ability to achieve returns in excess of
their respective benchmarks, and that have
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for
removal
that
to
the
change
if improvement or degradation is taking place.
Potential causes
from Baird’s
Recommended Managers List include fundamental
changes in the operations of the manager,
turnover in key personnel, substantial changes in
management or ownership, a
in
investment philosophy or style, significant drift
from stated objectives, major legal, regulatory or
compliance difficulties, impairment of financial
condition, sustained underperformance in relation
to its peers, or other adverse changes affecting
the manager that in Baird’s opinion warrants the
manager’s removal.
Baird’s
Asset Manager
Investment Committee
its discretion, decides
inclusion
If a Model-Traded BRM Strategy is selected for a
client’s Account, it is important to note that
Baird’s selection and ongoing evaluation of a BRM
Strategy is based upon an assumption that the
Recommended Manager’s Model Portfolio will be
fully and faithfully implemented by the Overlay
Manager or Implementation Manager on a
continuous basis. A client should understand that
the Overlay Manager or Implementation Manager
has discretion over the client’s Account and may
invest the client’s Account in a manner that differs
from the Model Portfolio. Baird does not monitor
the Account’s performance nor does it ascertain
whether the Overlay Manager or Implementation
Manager is implementing the Model Portfolio as
provided by the Recommended Manager. If the
Overlay Manager or Implementation Manager, in
the exercise of
to
implement the Model Portfolio differently, the
performance of a client’s Account could be
negatively impacted. Baird is not monitoring,
evaluating or reviewing the Overlay Manager or
Implementation Manager or the performance of a
client’s Account under those circumstances.
least three (3) years and have underlying
investments
fund’s
adhere
market capitalization policy and are consistent
with the manager’s stated investment process
and philosophy. Baird generally looks for funds
that are among the top-performing funds in a
style category in terms of risk-adjusted returns or
that are managed by individuals or firms that
have demonstrated success in other, related asset
classes; that have performance histories showing
sufficient ability to achieve returns in excess of
their respective style index; and that have
investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird’s
Asset Manager Research Department is primarily
responsible
for assisting with selecting and
evaluating funds included on the List. In selecting
Research
funds,
Department utilizes a quantitative and qualitative
evaluation process of the investment managers of
such funds. The process Baird uses for selecting
and removing funds for the Baird Recommended
Fund List is similar to the process Baird uses to
select and remove BRM Strategies described
under “Baird’s Recommended Managers List”
above. Baird’s
is
ultimately responsible for selecting funds included
on the List. The Baird Ultra Short Bond Fund,
Baird Short-Term Bond Fund, Baird Aggregate
Bond Fund, Baird Quality Intermediate Municipal
Bond Fund, Baird Core Intermediate Municipal
Bond Fund, and Baird Mid Cap Growth Fund,
mutual funds affiliated with Baird, have been
selected by Baird
in Baird’s
for
Recommended Mutual Fund List. This presents a
conflict of interest. However, the criteria used by
Baird in deciding to select Associated Funds for
Baird’s Recommended Mutual Fund List are the
same as those used for unassociated funds.
Baird’s Recommended Funds of Hedge Fund List
SMA
Strategies
for
Certain SMA Strategies offered by Baird Equity
Asset Management have been selected by Baird
for inclusion on Baird’s Recommended Managers
List. This presents a conflict of interest. However,
the criteria used by Baird in deciding to select
Baird’s
Associated
Recommended Managers List are the same as
those used for unassociated SMA Strategies.
Baird’s Recommended Mutual Fund List
Baird’s Recommended Funds of Hedge Fund List
may contain several types of funds of hedge
funds (“FOHFs”) that pursue various Alternative
Strategies or other Complex Strategies. Some
FOHFs primarily use credit-oriented investment
strategies, which Baird classifies as fixed income
diversifiers. Some FOHFs primarily use equity-
oriented investment strategies and are classified
as equity diversifiers. Other FOHFs use a
combination of credit- and equity-oriented
strategies, which Baird views as balanced
diversifiers. In certain circumstances, FOHFs may
be an appropriate substitute for part of a client’s
Baird’s Recommended Mutual Fund List
is
designed to include mutual funds and ETFs across
numerous asset classes. When selecting funds for
inclusion on the List, Baird generally seeks funds
that have investment managers with tenure of at
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allocation to traditional high yield fixed income or
equity investments.
changes
monitoring, Baird evaluates a FOHF’s assets under
(subscriptions and
management and
flows
redemptions), organizational
(e.g.,
personnel changes or new offerings), recent
changes made to the FOHF portfolio (e.g., hedge
funds added or removed), and reasons for
performance differences between the FOHF and
its benchmark. Subsequent onsite reviews are
similar in nature and scope to the initial on-site
review.
for
the
fund; and
To be added to Baird’s Recommended FOHF List,
a FOHF must generally meet the
following
requirements: the investment advisor to the FOHF
is registered as an Investment Adviser under the
Advisers Act; the fund has stable to growing
assets under management as determined by
Baird, principals of the fund have an appropriate
level of hedge fund management experience and
a sufficient network of contacts in the industry as
determined by to Baird; in Baird’s opinion, the
fund has adequate diversification by number of
hedge funds and type of hedge fund strategy;
effective risk management programs have been
established
the service
providers to the fund (e.g., auditor, administrator,
and legal counsel) are deemed to be reputable in
the judgment of Baird. Baird also seeks FOHFs
that it believes possess one or more unique
attributes that may lead to favorable performance
relative to their peers going forward.
legal documents
Baird may place a FOHF on “watch” status if it has
experienced a material event that, in Baird’s
opinion, may negatively affect
the FOHF’s
performance going forward or possibly lead to the
departure of an important member(s) of the
FOHF. Examples include a large decline in assets
under management, high rate of redemptions,
notable change in the investment or compliance
teams, weakening performance, or regulatory
problems. Any firm that is placed on “watch”
status is evaluated more closely to determine if
the problem is likely to be temporary or long-
term, and whether it can be remedied. Baird will
remove a FOHF from “watch” status and return it
to active status if, in Baird’s opinion, the problem
has been or is in process of being adequately
addressed. However, Baird will terminate a FOHF
from the List if it believes the issue is likely to be
long-term and adversely affect the FOHF’s future
performance.
offering memorandum,
Baird’s Recommended Private Funds Lists
Baird maintains lists of recommended private
Funds (“Recommended Private Funds”), including
a Recommended Funds of Private Equity Funds
List, a Recommended Private Debt Fund List, and
a Recommended Private Real Assets Fund List.
In making
that determination,
funds,
funds
or
Before adding a prospective FOHF to the List,
Baird’s Asset Manager Research Department
conducts an in-depth due diligence process. The
process begins with a review of the FOHF’s
responses to a due diligence questionnaire and of
marketing and
(such as,
subscription documentation, investor agreements,
and
organizational
documents, and the investment advisor’s Form
ADV Part 2A Brochures). This is followed by an
onsite review, where Baird meets with one or
more principals and analysts to assess how the
FOHF identifies, hires, monitors, and terminates
individual hedge funds. Baird also evaluates how
the FOHF constructs its hedge fund portfolio and
manages risk. At the conclusion of the onsite
review, an investment thesis is presented to and
discussed with a Baird Investment Committee.
The Committee votes on whether to add the FOHF
to Baird’s Recommended Funds of Hedge Fund
the
List.
Committee considers the information presented,
taking into account the merits of the individual
FOHF, how that FOHF compares to other FOHFs
that Baird offers, and the level of expected
demand for the particular FOHF.
client’s allocation
to
and
onsite
Baird’s Recommended Funds of Private Equity
Funds List contains funds of private equity funds
that pursue certain Alternative Strategies or other
Complex Strategies. These strategies can include
buyout, growth equity, venture capital, special
situations or distressed
investments. The
investments are typically structured in the form of
primary
co-
secondary
investments. Most will be to “middle market”
companies, many of which have above average to
high levels of leverage, or debt relative to equity.
In certain circumstances, funds of private equity
funds may be an appropriate substitute for part of
a
traditional equity
investments.
After a FOHF is added to Baird’s Recommended
Funds of Hedge Fund List, it is monitored each
reviews
subsequent
quarter,
periodically take place. As part of its quarterly
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that pursue
or
Baird’s Recommended Private Debt Fund List
contains private debt funds (also known as
private
certain
funds)
credit
other Complex
Alternative Strategies
Strategies. The private debt funds on Baird’s
Private Debt Funds List generally make first lien,
second lien and unsecured loans, primarily to
middle market companies sponsored by private
equity firms. In certain circumstances, private
debt funds may be an appropriate substitute for
part of a client’s allocation to traditional high yield
fixed income or equity investments.
funds
that
or
the
diligence questionnaire (known as a DDQ or RFI)
and of marketing and legal documents (such as,
subscription documentation, investor agreements,
offering memorandum, organizational documents,
and the investment advisor’s Form ADV Part 2A
Brochures). This is followed by an onsite review,
where Baird meets with one or more principals
and analysts to assess how the fund makes
investment decisions. Baird also evaluates how
the fund constructs its portfolio and manages risk.
In addition, Baird may undertake a brief review of
the fund’s third-party service providers. At the
conclusion of the onsite review, an investment
thesis is presented to and discussed with a Baird
Investment Committee. The Committee votes on
whether to add the fund to a Baird Recommended
Private Fund List. In making that determination,
information
considers
the Committee
presented, taking into account the merits of the
individual fund, how that fund compares to other
similar funds that Baird offers, and the level of
expected demand for that particular fund.
utilities,
telecommunication,
The
investments may
with
companies
that
Baird’s Recommended Private Real Assets Fund
List contains private real estate and private
pursue
infrastructure
certain
Alternative Strategies
other Complex
Strategies. These strategies invest in different
real assets and may involve exposure to a range
of economic or market sectors, geographic
locations and asset
types. Examples of
investments may include, among others, real
and
estate,
transportation.
be
structured in the form of asset ownership or
leasing or include direct investment in or joint
control
ventures
infrastructure assets. In certain circumstances,
private real assets funds may be an appropriate
substitute for part of a client’s allocation to
traditional fixed income or equity investments.
After a fund is added to a Baird Recommended
Private Fund List, it is monitored each quarter,
and subsequent onsite reviews periodically take
place. As part of its quarterly monitoring, Baird
evaluates a fund’s assets under management and
fund
flows (subscriptions and redemptions),
organizational changes (e.g., personnel changes
or new offerings), recent changes made to the
portfolio, and reasons for performance differences
between the fund and its benchmark. Subsequent
onsite reviews are similar in nature and scope to
the initial on-site review.
To be added to a Baird Recommended Private
Fund List, a fund must generally meet the
following requirements: the investment advisor to
the fund is registered under the Advisers Act ; the
fund has stable
to growing assets under
management as determined by Baird; principals
of the fund have an appropriate level of applicable
experience and a sufficient network of contacts in
the industry as determined by Baird; effective risk
management programs have been established for
the fund; and the service providers to the fund
(e.g., auditor, administrator, and legal counsel)
are deemed to be reputable in the judgment of
Baird. Baird also seeks funds that it believes
possess one or more unique attributes that may
lead to favorable performance relative to their
peers going forward.
fund
Baird may place a Recommended Private Fund on
“watch” status if it has experienced a material
event that, in Baird’s opinion, may negatively
affect the fund’s performance going forward or
possibly lead to the departure of an important
member(s) of the
investment team.
fund’s
Examples include a large decline in assets under
management, high rate of redemptions, notable
change in the investment or compliance teams,
weakening performance, or regulatory problems.
Any fund that is placed on “watch” status is
evaluated more closely to determine if the
problem is likely to be temporary or long-term,
and whether it can be remedied. Baird will
remove a fund from “watch” status and return it
to active status if, in Baird’s opinion, the problem
has been or is in process of being adequately
addressed. However, Baird will remove a fund
from a Recommended Private Fund List if it
Before adding a prospective
to a
Recommended Private Fund List, Baird’s Asset
Manager Research Department conducts an in-
depth due diligence process. The process begins
with a review of the fund’s responses to a due
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
believes the issue is likely to be long-term and
adversely affect the fund’s future performance.
managed futures fund is based solely upon the
client’s own review and evaluation of the fund.
Certain Eligible Product Lists
Structured Products
Annuities
is calculated,
the
When determining whether to make a structured
product available to Baird clients, Baird reviews
the offering documents for the structured product
and considers: the size of the issuer and issuer’s
credit rating, the maturity of the product, how
interest
the underlying asset
category (e.g., a basket of securities or currencies
or a market index), applicable caps, barriers, and
participation rate, and whether the structured
product has principal protection.
strength
ratings
When determining whether to make an annuity
product available to Baird clients, Baird reviews
the offering documents for the product and
considers: the size of the insurer and the insurer’s
credit rating,
insurer’s distribution and
support model, and product specifications and
features of the product. Baird favors highly-rated
insurers and evaluates them by using credit rating
agencies
and
financial
independent third-party research.
Baird’s ETF Focus List
indices,
Baird tends to favor larger-sized issuers of
structured products over smaller-sized issuers
and also tends to favor structured products that
have shorter maturities, less complex payout
structures, underlying assets that are more liquid
or transparent, and offer full or partial principal
protection. If a product does not offer full
principal protection, Baird also considers how
much principal is exposed to loss, whether, in
Baird’s judgment, there is reasonable risk/reward
trade-off for that exposure, as well as the events
that could trigger loss of principal and Baird’s
belief as to the likelihood of the occurrence of
such events.
Investment Solutions Department
Baird’s ETF Focus List is designed to encompass
numerous asset classes and varied investment
objectives. Baird generally seeks to include ETPs,
primarily ETFs, with transparent, experienced
sponsors that have stable or growing assets under
management and have demonstrated consistent
strategy performance over time. Baird tends to
favor ETPs that have well-known, diversified
fees and tracking
lower
benchmark
errors, and higher trading liquidity relative to
other ETPs. Inclusion on or exclusion from the
Baird ETF Focus List is not meant to be a buy or
is a
sell recommendation. Rather, the List
collection of ETPs that may be appropriate to
meet particular client investment goals.
the
Programs.
Baird’s
PWM Stock Opportunities List
Compliance,
Legal,
and
is
Baird’s
primarily responsible for selecting and evaluating
structured products made available to clients
under
Alternative
Investment Committee, which includes members
of Baird’s Investment Solutions, Asset Manager
Research,
Risk
Management Departments, ultimately determines
whether to make a structured product available to
Baird clients.
Available Hedge Funds
yield,
The PWM Stock Opportunities List is comprised of
stocks that Baird’s PWM Equity Research team
believes offer timely investment opportunities
based on market, sector, and
fundamental
analysis. Stocks on the list must be covered by
Baird, Evercore ISI, or Morningstar and are
screened to curb near-term fundamental risk. The
List focuses on large cap and mid/small cap
companies,
and
investments with
speculative investment opportunities.
Managed Futures
Effective March 1, 2018, Baird ceased maintaining
an official list of managed futures funds that are
structured as limited partnerships. Therefore,
Baird does not, and will not in the future, provide
any evaluation, monitoring or review of those
funds or their sponsors. A client’s decision to
invest in, or to maintain an investment in, a
Baird makes hedge funds available to clients in
certain Programs sponsored by, affiliated with or
offered by Capital Integration Systems LLC or
CAIS Capital LLC (“CAIS”). An independent third-
party research firm provides research and due
diligence materials to Baird on the hedge funds
available on the CAIS platform (“Available Hedge
Funds”). Clients interested in an Available Hedge
Fund or invested in an Available Hedge Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely
relies upon the independent third-party research
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firm to provide an independent analysis of each
Available Hedge Fund, Baird does not conduct its
own research or due diligence on any Available
Hedge Fund, and Baird does not verify the
accuracy of the information contained in the
research and due diligence materials.
are not on a Baird recommended or available
Fund list or offered through CAIS. Baird does not
provide any research or due diligence on such
in
Funds, but they are reviewed by GWG
accordance with its investment process described
below.
Available Private Funds
Baird Trust Strategies
Baird makes available to clients five (5) portfolio
strategies developed and maintained by Baird
Trust (“Baird Trust Strategies”) described below.
The Baird Trust Strategies invest in a mix of
equity securities and ETFs.
third-party
research
firm
(1)
The Baird Trust Large Cap Equity strategy
invests in a fairly concentrated portfolio of large
cap equity securities. This strategy is intended for
clients seeking investment in large cap companies
as one part of their overall asset allocation. This
strategy is generally not intended to be a
complete investment program.
In addition to Recommended Private Funds, Baird
makes available to clients in certain Programs
other private funds sponsored by, affiliated with,
or offered by CAIS (“Available Private Funds”),
including Available Private Equity Funds, Available
Private Debt Funds, Available Private REITs and
Available Private Infrastructure Funds. When
determining whether to make a fund an Available
Private Fund, Baird utilizes the services of an
independent
that
provides research and due diligence materials to
Baird on the private funds available on the CAIS
platform. Clients interested in an Available Private
Fund or invested in an Available Private Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely
relies upon the independent third-party research
firm to provide an independent analysis of each
Available Private Fund, Baird does not conduct its
own research or due diligence on any Available
Private Fund, and Baird does not verify the
accuracy of the information contained in the
research and due diligence materials.
(2)
The Baird Trust Core + Satellite 100
strategy is a diversified portfolio with a 100%
target equity allocation. The strategy uses the
Baird Trust Large Cap Equity strategy as the core
allocation of
the portfolio while providing
exposure to satellite asset classes (such as mid
cap and small cap companies) through the use of
ETFs that principally invest in equity securities.
This model does not include fixed income.
Affiliated Private Equity Funds
(3)
The Baird Trust Core + Satellite 70/30
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation of the portfolio
while providing exposure to satellite asset classes
(such as mid cap and small cap companies) and
fixed income securities through the use of ETFs
that principally invest in equity securities and
fixed income securities. This strategy has a target
allocation of 70% of its assets to equity securities
and 30% of its assets to fixed income securities.
In addition to Recommended Funds of Private
Equity Funds and Available Private Equity Funds,
Baird makes available to clients private equity
funds that are affiliated with Baird (“Affiliated
Private Equity Funds”). Baird does not subject
Affiliated Private Equity Funds to the criteria
imposed upon Recommended Funds of Private
Equity Funds or Available Private Equity Funds
described above when making them available to
clients, and Baird does not perform any
evaluation, monitoring or review of Affiliated
Private Equity Funds. This presents a potential
conflict of interest. See “Other Financial Industry
Activities and Affiliations—Certain Relationships
and Arrangements—Baird and Associated Parties”
below.
fixed
Other Funds
The Baird Trust Core + Satellite 50/50
(4)
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation portion of the
portfolio while providing exposure to satellite
asset classes (such as mid cap and small cap
companies) and fixed income securities through
the use of ETFs that principally invest in equity
securities and
income securities. This
strategy has a target allocation of 50% of its
assets to equity securities and 50% of its assets
to fixed income securities.
In certain instances when GWG believes it to be
consistent with a client’s investment goals, GWG
may recommend to the client certain Funds that
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GWG typically recommends or selects mutual
funds and ETFs for GWG Investment Management
Accounts. However, other types of securities may
be recommended or selected for those Accounts.
(5)
The Baird Trust Equity Income strategy
primarily invests in dividend paying companies
that Baird Trust believes have the ability to
consistently grow their dividend at attractive rates
over the long‑term.
More specific information about the particular
investment strategies and methods of analysis
that Baird uses in connection with each Program
is further described below.
for
the client. Once
The GWG Investment Process
When recommending or selecting a particular
mutual fund or ETF for client Accounts, GWG
begins by reviewing a client’s asset allocation and
investment strategy needs and identifying the
characteristics of the types of mutual funds or
ETFs appropriate
the
characteristic types of mutual funds or ETFs are
identified, GWG looks for investments that meet
those requirements. GWG tends to look for
passively managed funds when selecting funds
that invest primarily in equity securities and
actively managed funds when selecting funds that
invest primarily in fixed income securities. GWG
also looks for funds that have higher trading
volumes and lower expense ratios. Once GWG has
identified a potential fund for a client, GWG
conducts a quantitative and qualitative analysis of
the investment manager for the fund similar to
the analysis it performs on investment managers
described under “GWG Recommended Managers
Service” below.
In order to implement the overall client portfolio
strategy, GWG may utilize one or more of the
Services and a
combination of different
investment vehicles, such as SMAs, mutual funds
and ETFs.
More specific information about the particular
investment strategies and methods of analysis
that GWG and Baird use in connection with each
Service is further described below.
Service Information
GWG Investment Management Service
When providing advice to clients, GWG starts with
the “financial
framework” and risk analysis
developed for a client in connection with the
financial planning process described above. Using
a variety of tools, GWG then develops and
recommends a
strategic asset
long-term,
allocation and investment strategy for the client’s
portfolio that is appropriate for the client’s risk
and
return objectives. GWG develops a
customized asset allocation strategy by dividing
client assets into what GWG views as “Less Risky”
and “More Risky” asset classes. GWG then
develops an investment strategy by diversifying
the client’s portfolio among different investments
in each asset class with the goal to manage risk.
Investment strategies may involve the use of
different equity styles or strategies, such as: large
cap growth, large cap value, mid cap growth, mid
cap value, small cap growth, small cap value,
international and emerging market equities
strategies; different
income styles or
fixed
strategies, such as short or intermediate, taxable
and tax-exempt bond, international and emerging
market bond, and high yield bond strategies. In
certain instances when appropriate for a client,
Investment strategies may involve different Non-
Traditional Asset strategies, such as real estate
and real estate fund and commodity strategies;
and Alternative Strategies, which may include the
use of hedge funds, funds of hedge funds, private
equity funds, funds of private equity funds, and
managed
futures. See “Advisory Business—
Consulting Services” above for more specific
information.
Under the GWG Investment Management Service,
GWG may use various investment strategies. A
client’s particular investment strategy is typically
determined by GWG in consultation with the client
using the investment process described in the
section “The GWG Investment Process” above.
time
to
From
time, and depending on
macroeconomic conditions, GWG may also
recommend or implement a slight, short-term
tactical tilt to the client’s chosen asset allocation
that is above or below the long-term strategic
asset allocation.
GWG Consultants, as a group, utilize a variety of
investment styles and strategies, including the
investment strategies described in the sections
“Methods of Analysis, Investment Strategies and
Risk of Loss—Investment Strategies” and “The
GWG Investment Process” above. They may also
use the model portfolios or recommended or
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organizational
and
lists,
see
eligible product lists made available by Baird’s
PWM Research Groups, or they may use lists of
investment products that Baird has generally
deemed to be “available” for use in its advisory
programs. For more information about Baird
model portfolios, recommended lists and eligible
product
“Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis” above.
performance such as the investment process and
personnel,
investment
structure. GWG also focuses on the risk and
investment style relative to other investment
strategies already in a client’s portfolio. GWG
generally relies upon Baird’s Advisory Research
group to provide periodic review and evaluation of
managers on Baird’s Recommended Managers
List. To the extent a manager is not on Baird’s
Recommended Managers List, GWG will perform
periodic review and evaluation of the manager
using its own quantitative and qualitative analysis
described above. GWG will remove a manager
from management of a client’s Account when the
manager is removed from Baird’s Recommended
Managers List or if GWG determines that removal
is in the client’s best interest.
Service
Clients should note that an investment manager
managing the client’s Account under the GWG
Recommended Managers Service may not be on
Baird’s Recommended Managers List. A client
should understand that GWG and Baird do not
perform any due diligence or ongoing monitoring,
evaluation or reviews of investment managers
except to the extent GWG otherwise specifically
agrees to do so in writing.
GWG manages client assets using investment
strategies and investment products based upon a
investment objectives and
client’s particular
financial goals. GWG may use a wide variety of
investment products to implement the client’s
investment strategy, which
investments are
further described under “Advisory Business—
Information—Permitted
Additional
Investments” above. GWG may also use certain
investment strategies, such as concentrated
investment strategies and margin, and certain
types of investments, such as illiquid securities
and Complex Investment Products,
including
REITs, private equity funds, funds of private
equity funds, leveraged or inverse funds and
structured products. These investment strategies
and products involve special risks and may not be
appropriate for all clients. Please see “Principal
Risks” below for more information.
GWG Recommended Managers Service
or
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, a client should note that GWG and Baird
do not monitor or ascertain whether a third party
Implementation Manager is fully and faithfully
implementing the Model Portfolio on a continuous
basis.
the heading
other
selecting
When
recommending
investment managers
to manage a client’s
Account in the GWG Recommended Managers
Service, GWG typically utilizes managers included
on Baird’s Recommended Managers List described
under
“Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis—Certain Recommended Lists—Baird’s
Recommended Managers List” above. Although in
some circumstances, GWG may select a manager
to manage a client’s Account that is not included
on Baird’s Recommended Managers List.
A client assumes ultimate responsibility
for
client’s selection of an Other Manager under the
GWG Recommended Managers Program (including
any third party Implementation Manager). GWG
and Baird assume no responsibility for the client’s
termination of an Other Manager (including any
third party Implementation Manager), the Other
Manager’s investment decisions, performance,
compliance with applicable laws or regulations, or
for any other matters involving or affecting the
Other Manager.
Baird SMA Network and Dual Contract
Programs
GWG will select or replace, or recommend the
selection or replacement of, a particular manager
based upon the client’s particular goals and
circumstances and the client’s selected asset
investment strategy. Before
allocation and
selecting or recommending a manager to a client,
GWG performs
its own quantitative and
qualitative analysis of the manager, focusing on
the manager’s performance and factors GWG
believes will help a manager repeat historical
Clients participating in the BSN Program or the
DC Program should note that the level of initial
and ongoing review performed by GWG and Baird
on the managers and their SMA Strategies made
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the
not contain an SMA Strategy that meets the
client’s particular needs, and
client
understands the risks of doing so.
available under those Programs, including any
Associated SMA Strategies, is significantly less
than that performed by GWG and Baird with
respect to managers and their strategies eligible
for the GWG Recommended Managers Service.
retention of an
A client should note that the client’s appointment
and continued
investment
manager to manage the client’s Account in
connection with the BSN and DC Programs are
based ultimately upon the client’s independent
review of the investment manager and the
investment manager’s services. Once retained by
the client, an investment manager will only be
removed from managing the client’s Account upon
the investment manager’s withdrawal, removal
from the Program, or the client’s direction to do
so.
BSN and DC Managers are subject to an initial
review by Baird that considers the manager’s
assets under management,
regulatory and
compliance history, and certain other limited
qualitative and quantitative
factors deemed
relevant by Baird. The ongoing review is generally
performed on an annual basis and is generally
limited to significant changes in the managers’
assets under management in the SMA Strategy
and a review of the SMA strategy in comparison
to a relevant peer group or benchmark.
a
client who wishes
(including any
responsibility
for
the
(including
any
third
The BSN and DC Programs are designed to
accommodate
to
independently select an investment manager not
available in the GWG Recommended Managers
Service to manage the assets in the client’s
Account. A client should note that GWG and Baird
do not make any recommendation to clients
regarding any BSN Strategy or DC Strategy or
any representations regarding a BSN Manager’s or
DC Manager’s qualifications as an investment
adviser or abilities to manage client assets.
A client assumes ultimate responsibility
for
client’s selection of a manager under the BSN or
DC Programs
third party
Implementation Manager). GWG and Baird
client’s
assume no
termination of a manager under the BSN or DC
Programs
party
Implementation Manager). GWG and Baird also
assume no responsibility for any Other Manager’s
investment decisions, performance, compliance
with applicable laws or regulations, or for any
other matters involving or affecting the Other
Manager.
The Overlay Manager may provide review and
ongoing evaluations of certain BSN Managers that
it makes available through the BSN Program.
Clients should review Overlay Manager’s Form
ADV Part 2A Brochure for more information, which
is available upon request, or contact their GWG
Consultant for more information.
is
Portfolio management services under the DC
Program may be provided by an investment
management department of Baird if the client
selects such an SMA Strategy. In order to provide
portfolio management services under the DC
Program, Baird requires that Baird associates
meet all applicable requirements set forth by
applicable law and regulations of self-regulatory
organizations, such as the Financial Industry
Regulatory Authority,
Inc., exchanges, and
governmental agencies.
GWG and Baird do not monitor or ascertain
fully and
whether the Overlay Manager
faithfully implementing Model Portfolios under the
BSN Program on a continuous basis.
of
Loss—Principal
SMA Strategies offered under the BSN and DC
Programs are subject to certain risks. See
“Methods of Analysis, Investment Strategies and
Risks—Available
Risk
Investment Product Risks” below
for more
information.
and
Associated Managers.
A client should only participate in the BSN or DC
Programs if the client wishes to take more
responsibility for monitoring the client’s Account,
the GWG Recommended Managers Program does
Portfolio Management by GWG, Baird and
Associated Managers
Portfolio management services under the GWG
Investment Management, GWG Recommended
Managers and DC Programs may be provided by
Such
Baird
arrangements create a potential conflict of
interest because Baird and Associated Managers
may receive higher aggregate compensation if
clients retain Baird and Associated Managers
instead of retaining unassociated managers.
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Analysis, Investment Strategies and Risk of
Loss—Service Information” above.
departments,
reviewing
those portfolio managers
the heading
The following Services exclusively offer portfolio
management by Baird, its GWG Consultants, its
PWM home office investment professionals, its
or
investment management
investment managers that are affiliated with
Baird: GWG Investment Management Service.
The processes, if any, used by Baird for selecting
and
is
“Methods of
described under
Analysis, Investment Strategies and Risk of
Loss—Service Information” above.
When providing investment advisory services to
clients, GWG and Baird are fiduciaries and are
required to act solely in the best interest of
clients. Baird addresses the conflicts described
above through disclosure in this Brochure and by
adopting internal policies and procedures for GWG
and Baird and their associates that require them
to provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients). For more specific
information about these potential conflicts and
how Baird addresses them, please see the
sections “Other Financial Industry Activities and
Affiliations” and “Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
A client should note that the processes and
standards used by Baird in determining whether
to make affiliated investment options available
under the GWG Investment Management Service
differ from those processes and standards used
by Baird in determining whether to make non-
affiliated investment options available under other
Services. Baird approves, and continues to make
available, affiliated investment options under the
GWG Investment Management Service that would
not be approved for, or would have been removed
from, such other Services. This practice presents
a conflict of interest because Baird has a financial
incentive to maximize the number of affiliated
investment options it makes available under the
GWG Investment Management Service due to the
fact that, by increasing investment options, Baird
will likely attract more client assets and thereby
increase Baird’s revenues. A client participating in
the GWG Investment Management Service should
monitor the client’s Account performance and
periodically discuss the performance of such
Account with the client’s GWG Consultant.
conditions and other
professionals,
an
or
for
the associated
Principal Risks
Risk is inherent in any investment product and
GWG and Baird do not guarantee any level of
return on a client’s investments. There is no
assurance that a client’s investment objectives
will be achieved, and a client could lose all or a
portion of the amount invested. The management
of client accounts and recommendations made to
clients are based in part upon the use of forward-
looking projections, which in turn are based upon
certain assumptions about how markets will
perform in the future. There can be no guarantee
that markets will perform in the manner assumed
and the actual performance of markets and a
client’s Account could differ materially from those
assumptions. Also, a client’s Account value may
fluctuate, sometimes dramatically, depending
upon the nature of the client’s investments,
market
factors. By
participating in a Service, a client may be subject
to certain risks, including, but not limited to the
risks described below. The risks discussed below
vary by Service, investment style or strategy, and
the investments in the client’s Account, and each
risk may or may not apply to a client. Clients
should not pursue a strategy or invest in an
investment product unless they are prepared to
accept
risks. Clients are
encouraged to discuss with their GWG Consultant
the risks that apply to them. A client should also
review
the prospectus or other disclosure
document for any security or other investment
product in which the client invests, as it will
contain important information about the risks
Portfolio management services under the GWG
Recommended Managers Service or DC Program
could be provided by Baird PWM home office
investment
investment
management department of Baird or an
Associated Manager should a client select an
Associated SMA Strategy. When Baird selects SMA
Strategies, or otherwise determines manager
the Baird
eligibility,
availability
Recommended Managers List or the DC Program,
Associated SMA Strategies and Associated
Managers are subject to the same selection and
review processes, if any, that Baird applies to
unassociated SMA Strategies and investment
managers participating in each respective Service.
The processes, if any, used by Baird for selecting
and reviewing SMA Strategies and Associated
SMA Strategies for those Services are further
“Methods of
described under
the heading
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associated with investing in such security or other
investment product.
Investment Risk Information
The investment risks of the Services generally
include the following:
Conflicts of Interest Risks. Issuers, advisors or
other sponsors of investment products or their
affiliates may engage in business practices that
conflict with the interests of investors. Among
other things, these business practices can have a
negative impact on the market price of the
investment product. Clients are encouraged to
review
the prospectus or other disclosure
document for the investment product and also
discuss with their GWG Consultant the conflicts of
interest risks that may apply to them.
Stock Market Risks. Equity security prices vary
and may fall, thus reducing the value of a client’s
investments. Certain stocks selected for a client’s
Account may decline in value more than the
overall stock market.
Market Risks. A client’s Account may change in
value due to overall market fluctuations. General
economic conditions, political developments,
international events and other factors may cause
the overall market to decline, which in turn may
reduce the value of the client’s Account regardless
of the relative strength of the securities held in
the Account. Securities prices often vary for
reasons unrelated to matters directly affecting the
issuers of the securities.
fluctuate
client
accounts
about
Equity Securities Risks. Equity securities may
experience sudden, unpredictable drops in value
or long periods of decline in value. This may occur
because of factors that affect the securities
markets in general, such as adverse changes in
economic conditions, the general outlook for
corporate earnings, interest rates or investor
sentiment. Equity securities may also lose value
because of factors affecting an entire industry or
sector, such as increases in production costs, or
factors directly related to a specific company,
such as decisions made by its management.
Management and Securities Selection Risks.
A client’s Account may
in value
differently than, or in the opposite direction as,
the overall market or applicable benchmark
because of the selection of individual securities for
the Account. The judgments made by the persons
managing
the
attractiveness, value and potential appreciation of
particular securities may prove to be incorrect.
For example, while the stock markets may
experience increases in value, the client’s Account
may experience a decline in value due to the
underperformance of the stocks selected for
investment in the client’s Account.
Common Stock Risks. Common stocks are
susceptible to general stock market fluctuations
and to volatile increases and decreases in value
as market confidence in and perceptions of their
issuers change. These investor perceptions are
based on various and unpredictable
factors
including: expectations regarding government,
economic, monetary and fiscal policies; inflation
interest rates; economic expansion or
and
contraction; and global or regional political,
economic and banking crises. Holders of common
stocks are generally subject to greater risk than
holders of preferred stocks and debt obligations of
the same issuer because common stockholders
generally have inferior rights to receive payments
from issuers in comparison with the rights of
preferred stockholders, bondholders and other
creditors.
Investment Objective and Asset Allocation
Risks. A client’s investment objective and asset
allocation strategies involve the risk that certain
asset classes selected for the client’s Account may
not perform as well as other asset classes during
varying periods. In addition, clients who pursue
more aggressive investment objectives and asset
allocation strategies, while hoping to achieve high
returns, may face greater risk of loss than clients
with more conservative objectives and strategies.
In developing investment objectives and asset
allocation strategies, clients should carefully
consider their financial situation and needs,
investment goals, investment time horizon and
risk tolerance. A client should inform the client’s
GWG Consultant of these considerations so the
GWG Consultant can assist in determining the
client’s investment objectives and asset allocation
strategies.
Fixed Income Security Risks. Fixed income
securities are subject to certain risks, including
interest rate risk, credit risk and liquidity risk. In
addition, they are subject to maturity risk.
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larger companies. Therefore,
Generally, the longer a bond’s maturity, the
greater the interest rate risk and the higher its
yield. Conversely, the shorter a bond’s maturity,
the lower the interest rate risk and the lower its
yield. Non-rated, split-rated, below investment
grade, and asset-backed securities, including
mortgage-backed securities and CMOs, have
additional, special risks.
them more susceptible
companies may be substantially less than is
typical of
the
securities of such companies may be subject to
greater and more abrupt price fluctuations. In
addition, small- and mid-size companies may lack
the management experience, financial resources
and product diversification of larger companies,
making
to market
pressures and business failure.
foreign
Interest Rate Risk. The value of some
investment products, particularly fixed income
securities, is affected significantly by changes in
interest rates. Generally, when interest rates rise,
the product’s market value declines and when
interest rates decline, its market value rises. In
addition, a rise in interest rates may have a
negative impact on the issuer, which, in turn,
could have a negative impact on the market value
of the investment product.
Foreign Issuer and Investment Risks.
Securities of
issuers, ADRs, Global
Depositary Receipts (“GDRs”) and European
Depositary Receipts (“EDRs”), and investments in
foreign markets generally, are subject to certain
inherent risks, such as political or economic
instability of the country of issue, the difficulty of
predicting international trade patterns and the
possibility of imposition of exchange controls.
Such securities may also be subject to greater
fluctuations in price than securities of domestic
corporations. Investors in foreign markets may
face delayed settlements, currency controls and
adverse economic developments as well as higher
overall transaction costs. In addition, fluctuations
in the U.S. dollar’s value versus other currencies
may enhance, erode, reverse gains or widen
losses from investments denominated in foreign
currencies. For instance, foreign governments
may limit or prevent investors from transferring
their capital out of a country. This may affect the
value of a client’s investment in the country that
adopts such currency controls. Exchange rate
fluctuations also may impair an issuer’s ability to
repay U.S. dollar denominated debt, thereby
increasing the credit risk of such debt. In
addition, there may be less publicly available
information about a foreign company than about a
domestic company. Foreign companies generally
are not subject to uniform accounting, auditing
and financial reporting standards comparable to
those applicable to domestic companies. With
respect to certain foreign countries, there is a
possibility of expropriation or
confiscatory
taxation, or diplomatic developments, which could
affect investment in those countries.
Investments
Credit Risk. The value of some investment
products, particularly fixed income securities, is
affected by changes in the product’s credit quality
rating or the issuer’s financial condition. If the
credit quality rating or the issuer’s financial
condition declines, so may the value of the
investment product. Issuers may experience
unanticipated financial problems and may be
unable to meet its payment obligations. Municipal
obligations in particular may be adversely affected
by political and economic conditions and
developments (for example, legislation reducing
state aid to local governments.) Bonds receiving
the lowest investment grade rating or a non-
investment grade rating may have speculative
characteristics and, compared to higher grade
debt obligations, may have a weakened capacity
to make principal and interest payments due to
changes in economic conditions or other adverse
circumstances. Ratings agencies such as Moody’s,
Fitch and S&P provide ratings on bonds based on
their analyses of information they deem relevant.
Ratings are essentially opinions or judgments of
the credit quality of an issuer and may prove to
be inaccurate. In addition, there may be a delay
between events or circumstances adversely
affecting the ability of an issuer to pay interest
and/or repay principal and an agency’s decision to
downgrade a security.
market
depth,
less
liquid
Emerging Markets Risks.
in
emerging markets can involve risks in addition to
and greater than those generally associated with
investing in more developed foreign markets. The
extent of economic development, political
stability,
infrastructure,
capitalization, and regulatory oversight can be
less than in more developed markets. Emerging
Capitalization Size Risks. A client may be
invested in small and mid cap stocks, which are
often more volatile and
than
investments in larger companies. The frequency
and volume of trading in securities of such
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incidents,
market economies can be subject to greater
social, economic,
regulatory, and political
uncertainties. All of these factors can make
emerging market securities more volatile and
potentially less liquid than securities issued in
more developed markets.
and risk management programs designed to
prevent or mitigate such
these
measures are subject to inherent limitations,
including the possibility that certain risks may not
be identified or fully addressed. As a result, client
Accounts and investments may be negatively
affected.
Intelligence Risks.
increasingly use AI systems
the
that
could
compromise
technology
Such
incidents may
in
fact
inaccurate,
regulatory
scrutiny,
rely
on
third-party
AI
or
penalties,
reputational
investigate,
or
remediate
in
the
section
titled
their
own
information
related
incidents
Information Security, Cybersecurity and
Technology-Related Risks. As issuers and their
service providers increasingly rely on digital
technologies, such as
Internet, cloud
computing, and AI‑enabled systems, they face
heightened information security, cybersecurity,
including
and other technology‑related risks,
incidents
the
confidentiality, integrity, or availability of their
systems, data, or
infrastructure.
Technology-related incidents may result from
deliberate adversarial actions (such as cyber
attacks) or unintentional events (such as systems
or human error) and could have a materially
adverse impact on the issuer’s performance and
operations.
involve
unauthorized access, disclosure, use, corruption,
degradation, or destruction of systems or data
(such as
through hacking, malware, social
engineering or theft of digital devices); or the
disruption of systems access to authorized users
(such as through denial of service attacks). Such
events can impede critical functions, compromise
sensitive business and protected customer
information, and may result in financial losses,
business interruptions, impediments to the ability
to process transactions, breaches of applicable
privacy, data protection, or other laws, regulatory
harm,
fines
reimbursement or other remediation costs, and
increased compliance or operational expenses.
Substantial costs may be incurred to prevent,
future
detect,
technology related incidents. Issuers’ increasing
use of AI systems introduces additional risks
discussed
“Artificial
Intelligence Risks” below. Issuers may also rely
on third party or cloud based platforms that
present
security,
cybersecurity, and other technology‑related risks.
Similar adverse consequences may arise from
technology
affecting
regulatory bodies,
governmental authorities,
financial market systems, exchanges, brokers-
dealers, banks, insurance companies, custodians,
or other market participants. Although issuers and
their service providers may adopt business
continuity plans, information security controls,
Issuers of
Artificial
investments
in
various aspects of their business operations,
creating competitive market pressures to increase
the development and use of AI systems. Failure to
effectively develop or use AI systems may place
an issuer at a competitive disadvantage. At the
same time, AI systems present significant risks
that could materially affect an issuer’s business
and financial performance. AI Tools rely on
complex models, large datasets, and evolving
algorithms. AI Tools are highly-useful but
complex and fallible systems that can exhibit bias,
hallucinations, deceptive behaviors and other
flaws due to the construction of their underlying
models and the composition of their training data,
which can result in outputs that seem plausible
but are
incomplete, or
misleading. The use of erroneous outputs can
undermine customer trust and expose issuers to
litigation,
substantial
remediation costs, and reputational harm. AI tools
require timely access to high‑quality, compliant
data, and any disruption in data availability can
impair or disable AI Tool functionality. Issuers
often
systems,
infrastructure, and data, which can create vendor
dependency, limit visibility into and validation of
AI model performance, and increase the risk of
disruption in data availability. The regulatory
environment for AI is rapidly evolving and may
involve inconsistent or conflicting requirements
across
jurisdictions. Compliance may require
significant investment, changes to AI systems, or
the discontinuation of certain AI‑enabled features.
Non‑compliance may lead to fines, enforcement
actions, or operational constraints. AI systems are
vulnerable to cyberattacks or other adversarial
actions that can impair system performance and
integrity and compromise sensitive business and
protected customer information. The impairment
of AI systems or the unauthorized disclosure of
sensitive business or protected information can
result in material disruption and damage to
legal and
significant
business operations,
remediation
liabilities, substantial
regulatory
expenses, and reputational harm. AI systems may
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use
protected
on the opinion of bond counsel to the issuers at
the time of issuance. Thus, there is a risk that
interest may be taxable on a municipal security
that is otherwise expected to produce tax-exempt
interest.
inadvertently
information,
potentially giving rise to intellectual property
infringement claims and substantial damages.
Public concerns regarding fairness, transparency,
and responsible use of AI may reduce demand for
an issuer’s products or services. Failure to use AI
responsibly may harm an issuer’s reputation and
competitive position.
securities,
and/or
issued by
Government Obligation Risks. Client assets
may be invested in securities issued, sponsored or
guaranteed by the U.S. Government, its agencies
and instrumentalities. However, no assurance can
be given that the U.S. Government will provide
financial support to U.S. Government-sponsored
agencies or instrumentalities where it is not
obligated to do so by law. For instance, securities
issued by the Government National Mortgage
Association (“Ginnie Mae”) are supported by the
faith and credit of the United States.
full
Securities
the Federal National
Mortgage Association (“Fannie Mae”) and the
Federal Home Loan Mortgage Corporation
(“Freddie Mac”) have historically been supported
only by the discretionary authority of the U.S.
Government. While the U.S. Government provides
financial support to various U.S. Government-
sponsored agencies and instrumentalities, such as
those listed above, no assurance can be given
that it will always do so.
falling. Since
interest
federal
taxation,
in such
for purchases or withdrawals.
redemptions
in
Money Market Fund Risks. A money market
fund is a type of mutual fund that generally
invests in short-term debt instruments. Many
investors use money market funds to store cash.
There are three primary types of money market
funds: (1) government money market funds
(funds that invest nearly all assets in cash,
government
repurchase
agreements collateralized by cash or government
securities); (2) retail money market funds (funds
that have policies and procedures reasonably
designed to limit beneficial ownership to natural
persons); and (3) institutional money market
funds (funds that permit beneficial ownership by
institutions and natural persons). The rules
governing money market funds vary based on the
type of money market fund. Government and
retail money market funds generally try to keep
their net asset value (NAV) at a stable $1.00 per
share using special pricing and valuation
conventions. Institutional money market funds
are required to calculate their NAV in a manner
such that the NAV will vary based upon the
market value of assets and liabilities of the fund
(also known as a “floating NAV”). An investment
in a money market fund is not insured or
guaranteed by the FDIC or any other government
agency. Although some money market funds seek
to preserve the value of an investment at $1.00
per share, there can be no assurance that will
occur, and it is possible to lose money should the
fund value per share fall. In some circumstances,
money market funds may be forced to cease
operations when the value of a fund drops. In
that event, the fund's holdings may be liquidated
and distributed to the fund's shareholders. This
liquidation process could take time to complete.
During that time, the amounts a client has
invested in the money market fund would not be
available
In
addition, retail and institutional money market
funds are required to impose redemption fees
(also known as liquidity fees) and suspend
redemptions (also known as redemption gates) in
certain
circumstances. Government money
market funds may also impose redemption fees
and suspend
those same
circumstances. More specific information about
how a money market fund calculates its NAV and
Municipal Securities Risks. Repayment of
municipal securities depends on the ability of the
issuer or project backing such securities to
generate taxes or revenues. Municipal securities
may also decrease in value during times when tax
rates are
income on
municipal securities is normally not subject to
regular
the
income
attractiveness of municipal securities in relation to
other investment alternatives is affected by
changes in federal income tax rates applicable to,
or the continuing federal tax-exempt status of,
such interest income. Any proposed or actual
rates or exempt status,
changes
therefore, can significantly affect the liquidity,
marketability and supply and demand
for
municipal securities, which would in turn affect
Baird’s ability to acquire and dispose of municipal
securities at desirable yield and price levels.
Investment in tax-exempt debt obligations poses
additional risks. In many cases, the IRS has not
ruled on whether the interest received on a tax-
exempt obligation is tax-exempt, and accordingly,
purchases of these municipal securities are based
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the circumstances under which it will impose a
redemption fee or suspend redemptions is set
forth in the prospectus for that money market
fund.
to
lower
to make a market
for
Frequent Trading and Portfolio Turnover
Risks. Some of the investment strategies offered
to clients in this Brochure may involve frequent or
active trading for client accounts, which could
result in high portfolio turnover. Strategies that
involve frequent or active trading increase the
management and securities selection
risks
because the persons managing the accounts are
making more trading decisions, which may prove
to be incorrect. A portfolio with a high turnover
rate will also incur more transaction costs than
one with a lower rate. Higher transaction costs
may negatively impact the return of the portfolio.
High portfolio turnover may also cause a client to
experience adverse tax consequences due to the
fact that the client may have increased instances
of realized gains and losses and such gains and
losses may commonly be characterized as short
term gains and losses under applicable tax law.
Illiquid Securities and Liquidity Risks.
Liquidity risk is the risk that certain investments
may be difficult or impossible to sell at the time
and price that a client would like to sell. Clients
may have
the price, sell other
investments or forego an investment opportunity,
any of which may have a negative effect on the
management or performance of client accounts.
The liquidity of a particular investment depends
on the strength of demand for the investment,
which is generally related to the willingness of
broker-dealers
the
investment as well as the interest of other
investors to buy the investment. During periods of
economic uncertainty, significant economic and
market downturns and periods in which financial
services firms are unable to commit capital to
make a market in, or otherwise buy, certain
investments, a client may experience challenges
in selling such investments at optimal prices. In
addition, recent regulatory changes applicable to
financial intermediaries that make markets in
debt securities have restricted or made it less
desirable for those financial intermediaries to hold
large inventories of debt securities. Because
market makers provide stability to a market
through their intermediary services, a reduction in
dealer inventories may lead to decreased liquidity
and increased volatility in the fixed income
markets. In the event the client directs Baird to
liquidate an illiquid investment, the client should
understand that Baird may have difficulty finding
a buyer in the market for such investment and
such investment may be held in the Account for a
period of time while Baird attempts to satisfy the
client’s liquidation request.
Asset-Backed Securities Risks. Asset-backed
securities are securities secured or backed by
mortgage loans, student loans, automobile loans,
installment sale contracts, credit card receivables
or other assets and are issued by entities such as
commercial banks, trusts, financial companies,
industrial companies,
finance subsidiaries of
savings and loan associations, mortgage banks
and investment banks. These securities represent
interests in pools of assets in which periodic
payments of interest or principal on the securities
are made, thus, in effect passing through periodic
payments made by the individual borrowers on
the assets that underlie the securities, net of any
fees paid to the issuer or guarantor of the
securities. Asset-backed securities are issued in
multiple classes (or tranches) and their relative
payment rights may be structured in many ways.
Asset-backed securities may be subject to greater
risk of default during periods of economic
downturn than other instruments. Asset-backed
securities also can be more sensitive to interest
rate risk than other types of fixed income
securities. Modest movements in interest rates
(both increases and decreases) may quickly and
significantly reduce the value of certain types of
these securities. Asset-backed securities are
subject to a number of other risks, including, but
not limited to, market and valuation risks,
liquidity risk, and prepayment risk.
Split-Rated,
and
Concentration Risks. A client’s Account may
consist of a portfolio of securities that
is
concentrated in an issuer or group of issuers, an
industry or economic sector or group of related
industries or sectors, or concentrated in limited
asset classes. Client accounts with concentrated
positions are susceptible to greater volatility and
increased risk of loss than an Account that is
diversified across several issuers and industries or
sectors and asset classes. A client should not
engage in strategies using concentration unless
the client is prepared to experience significant
losses in the value of the client’s Account.
Non-Rated,
Below
Investment Grade Securities (High Yield or
“Junk” Bonds) Risks. Investing in securities or
other investment products that are not rated,
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securities
include market
selection
split-rated or are below investment grade (also
known as high yield or “junk” bonds) involve
significant, special risks. As a result, they may not
be suitable for some clients. The risks associated
with these investments include, but not limited to,
price volatility risk, credit risk, default risk, and
liquidity risk. Clients investing in securities or
other investment products that are not rated,
split-rated or are below investment grade should
have a high tolerance for risk, including the
willingness and ability to accept significant price
volatility, potential lack of liquidity and potential
loss of their investment.
credit
capitalization
risk,
foreign
including equity,
fixed
investment
style,
investment style, economic industry or sector, or
geographic region. Many ETFs seek to track the
performance of an index or other underlying
benchmark. Passively managed ETFs will not be
able to replicate exactly the performance of the
indices the ETFs track because the total return
generated by the securities will be reduced by
management fees, transaction costs and other
expenses incurred by the ETF. ETFs have other
risk,
risks, which may
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
rate
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk.
Certain ETFs pursue Complex Strategies, which
are subject to special risks. The degree of these
and other risks will vary depending on the type of
ETF selected.
securities
selection
credit
capitalization
risk,
foreign
that
Mutual Fund Risks. Mutual funds can have
investment objectives and
many different
strategies,
income,
balanced, international, and global strategies, and
strategies that focus on a particular market
capitalization,
economic
industry or sector, or geographic region. Mutual
funds have risks, which may include market risk,
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
risk,
risk,
rate
investment style
issuer and
investment risk, and emerging market risk.
Certain mutual funds pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of mutual fund selected. Also, investment
return and principal value will fluctuate, and
shares, when redeemed, may be worth more or
less than their original cost.
fund
that
for purposes of making
equity,
Closed-End Fund Risks. Unlike mutual funds
which continuously offer and redeem their shares
on a daily basis at net asset value, closed-end
funds typically raise money by selling a fixed
number of shares of common stock in a single,
one-time offering, much the way a company
issues stock in an initial public offering. Closed-
end funds can have many different investment
objectives and strategies, including equity, fixed
international, and global
income, balanced,
strategies, and strategies
focus on a
particular market capitalization, investment style,
industry or sector, or geographic
economic
shares are not
region. Closed-end
redeemable, meaning
investors cannot
require closed-end funds to buy back their shares,
although closed-end fund shares are listed and
traded on an exchange. For many reasons,
closed-end fund shares often trade at a discount
to their net asset value and the market prices of
closed end fund shares often fall below their
public offering prices. Clients are therefore
cautioned about buying shares of a closed-end
fund in its initial public offering. Closed-end funds
often engage in leverage to raise additional
capital
investments
through borrowings and issuances of senior
securities (such as preferred stock). Such
leverage may present the opportunity to enhance
potential returns but also involve the risk of
exacerbating losses and depreciation in the value
of the underlying securities. Closed-end funds
have other risks, which may include market risk,
Exchange Traded Fund Risks. An ETF is
different from a mutual fund in that an ETF does
not sell its shares directly to public investors and
does not redeem shares from public investors.
Rather, shares of an ETF are commonly purchased
or sold in the secondary market on a securities
exchange, like common stocks. An ETF maintains
a net asset value but, based on demand and
other factors, the market price of shares of an
ETF may vary from its net asset value. ETFs
invest in and hold securities and other assets,
such as stocks, bonds, commodities and
currencies, and have stated investment objectives
and principal strategies. ETFs can have many
different investment objectives and strategies,
including
income, balanced,
fixed
international, and global strategies, and strategies
that focus on a particular market capitalization,
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securities
selection
when redeemed, may be worth more or less than
their original cost.
credit
capitalization
risk,
foreign
closed-end
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate
risk,
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk.
Certain
funds pursue Complex
Strategies, which are subject to special risks.
Some closed-end funds are organized as interval
funds, which differ from traditional closed-end
funds in that their shares do not trade on the
secondary market, but instead their shares are
subject to repurchase offers from the fund.
Closed-end funds structured as an interval fund
will, therefore be relatively less liquid. Interval
funds also often impose a redemption fee when
shares are sold back to the fund. The degree of
these and other risks will vary depending on the
type of close-end fund selected.
is selected by
negative
tax
consequences.
Risks Common to All Funds; Purchase and
Redemption Risks. Funds are generally subject
to the same risks as the securities or other assets
in which they invest. In addition, from time to
time Baird, a GWG Consultant, or an investment
manager may decide to add or remove a Fund to
or from an investment strategy or Service. In
addition, they may decide to increase or decrease
their clients’ account allocations to a Fund. In
general, they will place transactions for all
affected Accounts at one time, which may cause
the Fund to experience relatively large purchases
or
redemptions. Significant purchases and
redemptions may adversely affect the Fund in
question and consequently, a client’s investment.
A Fund receiving large purchase orders may have
difficulty investing the cash, which may have a
negative impact on the Fund’s performance. A
Fund experiencing large redemption orders may
have to sell portfolio securities, which may
negatively impact performance and which may
have
Large
redemptions could also reduce liquidity as the
Fund may suspend or delay redemptions. These
risks are more pronounced with respect to newer
Funds and those with smaller asset sizes.
equity,
Risks Associated with Certain Investment
Strategies
Growth and Value Investment Style Risks.
Investment styles or strategies that focus on
growth stocks may perform better or worse than
styles or strategies that focus on value stocks or
that are broader or more diversified. Similarly,
investment styles or strategies that focus on
value stocks may perform better or worse than
styles or strategies that focus on growth stocks or
that are broader or more diversified. A particular
style of investing may go out of favor at times
and for extended periods. Growth stocks are often
characterized by high price-to-earnings ratios and
may be more volatile than stocks with lower
price-to-earnings ratios. Value stocks are subject
to the risk that the broader market may not agree
with the manager’s assessment of, or recognize,
the investments’ intrinsic value.
ESG Considerations Risk. Consideration of ESG
factors in the investment process may cause an
advisor or manager to forgo opportunities to
recommend or invest in certain companies or to
Unit Investment Trust Risks. A UIT is a pooled
in which a portfolio of
investment vehicle
securities
the sponsor and
deposited into the trust for a specified period of
time. The portfolio of a UIT is designed to follow
an investment objective over a specified time
period, although there is no guarantee that the
objective will be met. UITs can have many
different investment objectives and strategies,
income, balanced,
fixed
including
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. UITs are passively managed
and follow a “buy and hold” strategy, meaning
that UITs buy a fixed portfolio of securities and
hold on to that portfolio until their termination
date at which time the portfolio is liquidated with
the net proceeds paid to investors. UITs, thus,
generally have a relatively higher risk of loss than
other funds in the event of adverse changes in
market or economic conditions. UITs have other
risks, which may
include management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, and emerging market
risk. Certain UITs pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of UIT selected. Also, investment return and
principal value will fluctuate, and units, if and
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predictions can be made. A technical method may
fail to identify trends or be able to accurately
predict future prices if a market does not have
sufficient data or trends or if the market behaves
erratically.
gain exposure to certain industries or regions.
Therefore, there is a risk that, under certain
market conditions, an Account pursuing strategies
that consider ESG factors may underperform
accounts that do not consider such factors. There
are not universally accepted ESG factors and
advisors and managers typically consider them in
their discretion.
the heading
Other Strategy Risks. The risks associated with
other types of investment strategies are described
under
“Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment Strategies” above.
such as
commodities,
an
investment
traditional
Non-Traditional Assets and Complex
Strategies Risks
Non-Traditional Assets Risks. Non-Traditional
Assets,
currencies,
securities indices, interest rates, credit spreads,
private companies, and Digital Assets, are subject
to risks that are different from, and in some
instances, greater than, other assets like stocks
and bonds. Some Non-Traditional Assets are less
transparent and more sensitive to domestic and
foreign political and economic conditions than
more
investments. Non-Traditional
Assets are also generally more difficult to value,
less liquid, and subject to greater volatility
compared to stocks and bonds.
Risks.
Investments
by
the
investments
that were not predicted by
in
securities.
can be no assurance
that
Quantitative Strategy Risks. Some investment
managers may employ quantitative investment
methodologies or processes to make investment
the quantitative
decisions. The success of
investment methodologies and processes used by
investment managers depends on the analyses
and assessments that were used in developing
such methodologies and processes, as well as on
the accuracy and reliability of models and data
provided by third parties. Incorrect analyses and
assessments or inaccurate or incomplete models
and data would adversely affect performance.
manager’s
Additionally,
methodologies and processes are predictive in
nature, based on historical outcomes and trends.
Certain low-probability events or factors that are
assigned little weight may occur or prove to be
more likely or may have more relevance than
expected, for short or extended periods of time,
which may adversely affect
the portfolios
generated
investment manager’s
quantitative methodologies and processes. It is
also possible that prices of securities may move in
directions
the
investment manager’s quantitative methodologies
and processes or may fail to move as much as
predicted, for reasons that were not expected.
There
these
methodologies will enable a client to achieve the
client’s objective.
investment and
trading activities
or
consuming
Commodities
in
commodities markets or a particular sector of the
in
commodities markets, and
securities or other instruments denominated in or
indexed or linked to commodities, are subject to
certain risks. Those investments generally will
subject a client Account to greater volatility than
investments
The
traditional
commodities markets are impacted by a variety of
factors, including changes in overall market
movements, domestic and foreign political and
economic conditions, interest rates, inflation rates
and
in
commodities. Prices of commodities may also be
affected by factors such as drought, floods,
weather, livestock disease, embargoes, tariffs and
other regulatory developments. The prices of
commodities can also fluctuate widely due to
supply and demand disruptions
in major
producing
regions. Certain
commodities may be produced in a limited
number of countries and may be controlled by a
small number of producers or groups of
producers. As a result, political, economic and
supply related events in such countries could have
a disproportionate impact on the prices of such
Technical Strategy Risks. Some investment
managers and DDK Consultants may employ
technical analysis or investment methodologies to
make investment decisions or recommendations.
The primary risk of using technical analysis is that
past price and volume patterns and trends in the
trading markets cannot predict future prices,
volume patterns or trends. There is no guarantee
that technical investment methods used are
designed properly, are updated with new data as
it becomes available, or can accurately predict
future market or investment performance. In
order for technical investment methods to work,
there must be sufficient data about the markets
available so that trends can be identified and
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commodities. No active trading market may exist
for certain commodities investments, which may
impair the value of the investments.
instruments
in
that
such as a security, commodity, currency, or
index. Derivative instruments often have risks
similar to the underlying asset, however, in
certain cases, those risks are greater than the
risks presented by
the underlying asset.
Derivative instruments may experience dramatic
price changes and imperfect correlations between
the price of the derivative and the underlying
asset, which may increase volatility. Derivatives
generally create leverage, and as a result, a small
movement in the underlying asset's value can
result in large change in the value of the
derivative instrument. Derivatives are also subject
to liquidity risk, interest rate risk, market risk,
credit risk, management risk and counterparty
risk. The use of these
is not
appropriate for some clients because they involve
special risks. A client should not invest in these
instruments unless the client is prepared to
experience volatility and significant losses in the
client’s Account.
Currency Risks. Investments in currencies, and
investments in securities or other instruments
denominated in or indexed or linked to currencies,
are subject to certain risks. Those investments
are subject to all of the risks associated with
foreign investing generally. In addition, currency
markets generally are not as regulated as
securities markets. Also, changes in currency
impact the
exchange rates could adversely
investment. Devaluation of a currency by a
country will also have a significant negative
impact on
investment
the value of any
denominated
currency. Currency
investments may also be positively or negatively
affected by a country’s strategies intended to
make its currency stronger or weaker relative to
other currencies.
the
the underlying security or
Leverage and Margin Risks. Leveraging
strategies may amplify
impact of any
decrease in the value of underlying securities in
the client’s Account, thereby increasing a client’s
risk of loss. The use of leverage may also increase
an Account’s volatility. Strategies
involving
margin can cause a client to lose more money
than deposited in the client’s margin account. A
client should not engage in strategies involving
leverage or margin unless the client is prepared
to experience significant losses in the value of the
client’s Account.
Options Risks. In purchasing a put or call
option, the purchaser faces the risk of loss of the
premium paid for the option if the market price
moves in a direction opposite to what the
purchaser had expected. In selling or writing an
option, the seller faces significantly more risk. A
seller of a call option faces the risk of significant
loss
if the prevailing market price of the
underlying security or index increases above the
strike price, and a seller of a put option faces the
risk of significant loss if the prevailing market
price of
index
decreased below the strike price.
Hedging Risks. When a derivative instrument is
used as a hedge against an opposite position, any
loss on the derivative instrument should be
substantially offset by gains on the hedged
investment, and vice versa. Although hedging can
be an effective way to reduce the investment risk,
it may not always perfectly offset one position
with another. As a result, there is no assurance
that hedging transactions will be effective.
Short Sales Risks. Short selling runs the risk of
loss if the price of the securities sold short does
not decline below the price at which they were
originally sold. This risk of loss is theoretically
unlimited, as there is no cap on the amount that
the price of a security may appreciate. In
addition, a
lender may request, or market
conditions may dictate, that securities sold short
be returned to the lender on short notice, which
may result having to buy the securities sold short
at an unfavorable price. A client should not
engage in short sales unless the client is prepared
to experience significant losses in the client’s
Account.
in
the marketplace and
contracts
other
Derivative Instrument Risks. The values of
options, convertible securities, futures, swaps,
forward
derivative
and
instruments is derived from an underlying asset,
Digital Assets Risks. Digital Assets are not
appropriate for some clients because they involve
substantial risk of loss including special risks not
present in traditional financial markets. Digital
Assets derive value primarily from the demand for
such assets
their
association with decentralized networks and other
technology. Digital Assets may lack an intrinsic
for Digital Assets are
value and markets
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Assets
involve
technological
limited
short
sales,
risks may
securities
include: market
selection
trading,
settlement,
and
validators, miners,
or
credit
capitalization
risk,
foreign
limited number of
susceptible
to extreme and sudden price
movements and fragmented liquidity. Markets for
Digital Assets continue to evolve, but
lack
certainty regarding the status of regulation and
investor protections. The use and custody of
Digital
and
cybersecurity risks, including the potential for
system outages, protocol
flaws, operational
disruptions, hacking incidents, or failures of
third-party platforms and service providers that
support
storage
infrastructure. Many Digital Assets depend on
protocol
external
developers whose actions or inaction can impact
network stability or asset functionality and affect
value. Market structure risks—such as reliance on
a
trading venues or
counterparties—may impair the ability to transact
or liquidate positions during periods of market
stress. A client should not invest in these
instruments unless the client is prepared to
experience extreme volatility and significant
losses in the client’s Account.
funds and funds of hedge funds also have reduced
liquidity compared to other investments and are
generally subject to a higher risk of volatility.
Investing in hedge funds and funds of hedge
funds involves other special risks, including, but
to, risks associated with Non-
not
Traditional Assets,
leverage,
derivative instruments, and Complex Strategies.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
rate
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk. Hedge
funds and funds of hedge funds are complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in hedge funds or funds
of hedge funds should have a high tolerance for
risk, including the willingness and ability to accept
significant price volatility, potential
lack of
liquidity and potential loss of their investment.
funds have unique
in
certain
that may
sectors,
for those
fee
an
incentive
funds are subject to
to administrative service
Private Equity Funds and Funds of Private
Equity Funds Risks. Private equity funds are
pools of actively managed capital that invest
primarily in private companies with the intent of
creating value in the companies in which they
invest by improving operations, reducing costs,
selling non-core assets and maximizing cash flow.
Private equity funds usually have an investment
focus on
objective or strategy
companies
industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes of investments. Funds of private equity
funds typically invest substantially all of their
assets in other private equity funds. Private
equity funds and funds of private equity funds
have unique tax characteristics. A client should
consult with a tax advisor before investing in
those funds. Private equity funds and funds of
limited
private equity
regulation and offer
limited disclosure and
transparency. Also, the costs of private equity
funds and funds of private equity funds are
typically higher than other types of
funds.
Investment advisers or managers for those funds
often receive a management fee plus an incentive
fee or carried interest. Private equity funds and
funds of private equity fund are also generally
fees and
subject
portfolio company transaction fees. Because of
Complex Investment Product Risks
Hedge Funds and Funds of Hedge Fund
Risks. Hedge funds typically engage in one or
more Complex Strategies, including the use of
Non-Traditional Assets, short sales, leverage and
other derivative instruments. Funds of hedge
funds typically invest substantially all of their
assets in other hedge funds. Hedge funds and
funds of hedge
tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Some
hedge funds and funds of hedge funds are subject
to limited regulation and offer limited disclosure
and transparency. Also, the costs of hedge funds
and funds of hedge funds are typically higher than
other types of funds. Investment advisers or
funds often receive a
managers
management
or
plus
performance-based fee. Because of the existence
of a performance-based fee, fund managers may
be motivated to make riskier investments that
have the potential for significant growth in value.
Hedge funds and funds of hedge funds are also
subject to a higher risk of incorrect valuations.
Many hedge funds hold investments for which
market quotations are not readily available, which
necessitates the use of “fair value” pricing. Fair
value pricing is an inherently subjective process
and may not accurately reflect the prices that can
actually be obtained upon sale of the assets for
which fair values are used. Investments in hedge
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in certain sectors,
compared
other
expect
debt
funds
have
unique
receive a management
risk,
foreign
transaction
investments
should not
expect
to
the existence of a carried interest, fund managers
may be motivated to make riskier investments
that have the potential for significant growth in
value. Investments in private equity funds and
funds of private equity funds also have reduced
investments.
liquidity
to
Investors
receive
to
should not
distributions from a fund for a number of years.
Private equity investing is very risky. Many
investments made in portfolio companies are not
profitable. In addition, investments made by
private equity funds and funds of private equity
funds may be concentrated in one or more
economic
industries or sectors, geographic
regions, stages of development or operation, or
sizes of companies. Investing in private equity
funds and funds of private equity funds involves
other special risks, including, but not limited to,
dependence upon key personnel and conflicts of
interest risks. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, and emerging market risk.
Private equity funds and funds of private equity
that have
funds are complex
significant, special risks. As a result, they may not
be suitable for some clients. Clients investing in
private equity funds and funds of private equity
funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
funds
involves special
risk,
foreign
fund
risks, currency
investment objective or strategy that may focus
on companies
industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes, including focusing investments on
smaller capitalization, distressed or bankrupt
companies. Private debt funds commonly use
borrowings or leverage to make investments.
Funds of private debt funds typically invest
substantially all of their assets in other private
debt funds. Private debt funds and funds of
private
tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
debt funds and funds of private debt funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private debt funds and funds of private debt funds
are typically higher than other types of funds.
Investment advisers or managers for those funds
often
fee plus a
performance fee. Private debt funds and funds of
private debt fund are also generally subject to
operational expenses and
fees.
Because of the existence of a performance fee,
fund managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Investments in private debt
funds and funds of private debt funds also have
reduced liquidity compared to other investments.
receive
Investors
distributions from a fund for a number of years.
Private debt investing is very risky. Investments
made by private debt funds and funds of private
debt funds may be concentrated in one or more
industries or sectors, geographic
economic
regions, stages of development or operation, or
sizes. Investing in private debt funds and funds of
private debt
risks,
including, but not limited to, dependence upon
key personnel, conflicts of interest risks, market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
issuer and
investment style
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
investment
risks and
leveraging risks. Private debt funds and funds of
private debt funds are complex investments that
have significant, special risks. As a result, they
may not be suitable for some clients. Clients
investing in private debt funds and funds of
private debt funds should have a high tolerance
for risk, including the willingness and ability to
Private Debt Funds (or Private Credit Funds)
and Funds of Private Debt Funds Risks.
Private debt funds (also known as private credit
funds) are pools of actively managed capital that
invest primarily in loans or debt instruments
issued by companies in private transactions.
Sometimes, repayment of the loan is secured by
assets of the companies obtaining the loans.
However, the companies often have low or no
credit ratings. Thus, investments held by private
debt funds generally are subject the same risks as
below investment grade or “junk” bonds. Trading
markets for the investments held by those funds
are also limited and their investments may be
illiquid. Oftentimes, the interest rate paid by the
companies is determined by a reference interest
rate, such as the federal funds rate, which is
periodically reset. These types of investments are
sometimes referred to as floating rate corporate
debt, floating rate loans or floating rate bank
funds usually have an
loans. Private debt
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
accept lack of liquidity and potential loss of their
investment.
risk, credit
risk,
foreign
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, interest
issuer and
rate
investment risk, and emerging market risk. REITs
involve significant, special risks and may not be
suitable for some clients. Clients investing in
REITs should have a high tolerance for risk,
including the willingness and ability to accept
significant price volatility and volatility of regular
distribution amounts, potential lack of liquidity
and potential loss of their investment.
warehouses,
investments. Some may
in properties
industries,
involved
located
improved management
real estate
funds
typically
in which
they are
for those
risk, growth
Real Estate Investment Trusts (“REITs”) and
Private REIT Risks. A REIT is a corporation,
trust or association that owns and typically
operates income-producing real estate or real
estate-related assets. The income-producing real
estate assets owned by a REIT may include office
buildings, shopping malls, multi-family housing,
student housing, hotels, resorts, hospitals and
health care facilities, self-storage facilities, data
telecommunications
centers,
facilities, and mortgages or loans. Many REITs are
registered with the SEC and their common stock
and preferred stock are publicly traded on a stock
exchange. These are known as publicly-traded
REITs. Others may be registered with the SEC but
are not publicly traded. These are known as
private REITs (also known as non-traded or non-
exchange traded REITs). There is no public
trading market for private REITs and the sole
method for disposing of the shares may be limited
to a periodic offer to redeem the shares by the
issuer, if the issuer offers a redemption program.
Private REITs are generally subject to limited
limited disclosure and
regulation and offer
transparency. The shareholders of a REIT are
responsible for paying taxes on the dividends that
they receive and on any capital gains associated
with their investment in the REIT. Dividends paid
by REITs generally are treated as ordinary income
and are not entitled to the reduced tax rates on
other types of corporate dividends. Prices of REIT
securities and trading volumes may be more
volatile that other investments. Many REITs focus
on a particular sector of the real estate market,
such as apartments, student housing, hotels and
hospitality, health care, office buildings, shopping
malls, warehouses, self-storage facilities and the
like. Those REITs are subject to risks associated
with sectors
focused.
Additionally, many REITs may own properties that
are concentrated in a particular geographic region
or regions, which subject them to the risk of
deteriorating economic conditions in those areas.
Investing in REITs involves other special risks,
including, but not limited to, real estate portfolio
risk
(including development, environmental,
competition, occupancy and maintenance risk),
liquidity risk, leverage risk, distribution risk,
capital markets access
risk,
interest risk,
counterparty risk, conflicts of
risk, and
dependence upon key personnel
regulatory risk. Other risks may include: market
Private Real Estate Funds and Private Real
Estate Fund of Funds. Private real estate funds
are pools of actively managed capital that directly
invest primarily in investments in real estate and
investments. Private real
real estate-related
estate funds may invest in any number of types of
real estate, such as office, apartment, retail,
lodging, industrial and other real estate and real
focus
estate-related
in certain
investment
sectors or
certain
in
geographic regions or that have certain sizes of
operations or investment requirements. Some
may focus investment on properties the manager
or
sponsor believes are undervalued or
undercapitalized or that require repositioning,
redevelopment,
or
additional capital to reach their full value. Private
real estate funds commonly use borrowings or
leverage to make investments. Trading markets
for investments held by those funds are limited
and their investments may be illiquid. Funds of
invest
private
substantially all of their assets in other private
real estate funds. Private real estate funds and
funds of private real estate funds have unique tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
real estate funds and funds of private real estate
funds are subject to limited regulation and offer
limited disclosure and transparency. Also, the
costs of private real estate funds and funds of
private real estate funds are typically higher than
other types of funds. Investment advisers or
managers
funds often receive a
management fee plus a performance fee. Private
real estate funds and funds of private real estate
fund are also generally subject to operational
expenses and transaction fees. Because of the
existence of a performance fee, fund managers
may be motivated to make riskier investments
that have the potential for significant growth in
75
BGWG F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
fees and
should not
expect
to
investing
for
significant growth
reduced
liquidity compared
investments made
by
industries or
risks may
fund
risks, currency
securities
include: market
selection
risk,
foreign
infrastructure
funds
are
value. Investments in private real estate funds
and funds of private real estate funds also have
reduced liquidity compared to other investments.
receive
Investors
distributions from a fund for a number of years.
Private real estate
is very risky.
Investments made by private real estate funds
and funds of private real estate funds may be
concentrated in properties involved in one or
more economic industries or sectors, geographic
regions, stages of development or operation, or
sizes. Investing in private real estate funds and
funds of private real estate funds involves special
risks, including, but not limited to, dependence
upon key personnel, conflicts of interest risks,
market risk, management and securities selection
risk, investment objective and asset allocation
risk, interest rate risk, credit risk, capitalization
risk, investment style risk, foreign issuer and
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
risks and
investment
leveraging risks. Private real estate funds and
funds of private real estate funds are complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in private real estate
funds and funds of private real estate funds
should have a high tolerance for risk, including
the willingness and ability to accept lack of
liquidity and potential loss of their investment.
infrastructure funds are also generally subject to
administrative service
investment
transaction fees. Because of the existence of
incentive fees, fund managers may be motivated
investments that have the
to make riskier
potential
in value.
Investments in private infrastructure funds also
have
to other
investments. Investors should not expect to
receive distributions from a fund for a number of
years. Private infrastructure investing is very
risky. Many investments are not profitable. In
private
addition,
infrastructure funds may be concentrated in one
or more economic
sectors,
geographic regions, stages of development or
operation, or sizes of companies. Investing in
private infrastructure funds involves other special
risks, including, but not limited to, dependence
upon key personnel and conflicts of interest risks.
risk,
Other
risk,
management and
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, and emerging market risk.
complex
Private
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in private infrastructure
funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
telecommunication,
Private
utilities,
infrastructure
throughout
for those
Private Infrastructure Funds Risks. Private
infrastructure funds are pools of actively managed
capital that invest primarily in infrastructure
projects and assets and may involve exposure to
a
range of economic or market sectors,
geographic locations and asset types. Examples of
infrastructure investments may include, among
and
others,
transportation.
funds
usually have an investment objective or strategy
that may focus on certain sectors, industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes of investments. Private infrastructure
funds have unique tax characteristics. A client
should consult with a tax advisor before investing
in those funds. Private infrastructure funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private infrastructure funds are typically higher
than other types of funds. Investment advisers or
funds often receive a
managers
management fee plus an incentive fee. Private
Exchange Traded Notes Risks. An ETN is a
type of debt security that trades on an exchange
and provides a return linked to the performance
of an underlying benchmark. The underlying
benchmark can be a particular security, bond,
commodity, currency, or other Non-Traditional
Asset type, a group or basket of companies,
securities, commodities, currencies, derivative
instruments, Non-Traditional Asset investments or
other assets, or an index or other benchmark
linked to stocks, market volatility, bonds, interest
rates, Treasury yields, yield curves and spreads,
derivative instruments, strategies, commodities,
currencies or other assets. ETNs trade on
exchanges
the day at prices
determined by the market. Unlike ETFs, issuers of
ETNs do not buy or hold assets to replicate or
approximate the performance of the underlying
benchmark. Also in contrast to ETFs, ETNs also do
not calculate their net asset value, are generally
not redeemable on a daily basis, and are not
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
currencies,
Assets,
leverage,
and other Non-
commodities,
Traditional
derivative
instruments and Complex Strategies. Other risks
may include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
foreign issuer and investment risk, and emerging
market risk. Managed futures can be speculative
investments because of the types of investments
they make and they involve significant, special
risks. As a result, they may not be suitable for
some clients. Clients investing in these funds
should have a high tolerance for risk, including
the willingness and ability to accept significant
price volatility, potential lack of liquidity and
potential loss of their investment.
credit
capitalization
risk,
foreign
registered under the Investment Company Act of
1940. Issuers may also have the right and option
to redeem ETNs. Redemptions are made at the
ETN’s “indicative value” or “closing indicative
value”. An ETN's closing indicative value is
computed by the issuer and is distinct from an
ETN's market price, which is the price at which an
ETN trades in the secondary market. Issuers of
ETNs may also issue and redeem notes as a
means to keep the ETN’s market price in line with
its indicative value, which have caused significant
fluctuations in ETN prices. Investing in ETNs
involves special risks, including, but not limited
to, risks associated with Non-Traditional Assets
and derivative instruments and the risk that the
actual market price for an ETN may vary
significantly from the indicative value computed
by the issuer. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate
risk,
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk. ETNs
are complex investments and involve significant,
special risks. As a result, ETNs may not be
suitable for some clients.
inverse
pools
(typically
structured
in managed
Managed Futures Risks. Managed futures are
as
commodity
investment partnerships) managed by a futures
trading adviser that trade speculatively in various
derivative instruments and other investments.
There are significantly higher fees and expenses
associated with investments in managed futures
than other types of funds. Sponsors or managers
for these pools often receive a management fee
plus incentive or performance-based fee. Because
of the existence of a performance-based fee,
managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Managed futures may seek
exposure to different asset classes, such as equity
securities, fixed income securities, commodities
(such as metals, agricultural products, and energy
products), currencies, interest rates, and indices.
Managed futures often obtain this exposure
through derivative instruments, which may be
traded on U.S. or foreign exchanges or markets.
Managed futures often employ computerized,
systematic and often proprietary trading models
and systems. Investing
futures
involves special risks, including, but not limited
to, liquidity risks and risks associated with
Leveraged Fund and Inverse Fund Risks.
Leveraged funds and inverse funds may be
structured as ETNs, ETFs or open-end mutual
funds. Leveraged funds seek to deliver multiples
of the performance of the index or benchmark
they track. Inverse funds seek to deliver the
opposite of the performance of the index or
benchmark they track. Leveraged inverse funds
seek to achieve a return that is a multiple of the
inverse performance of the underlying index. Most
leveraged and
funds “reset” daily,
meaning that they are designed to achieve their
stated objectives on a daily basis. Because of the
effects of compounding, volatility and the fund
expenses, the returns of a leveraged or inverse
fund over longer periods of time can differ
significantly from the performance (or inverse of
the performance) of their underlying index or
benchmark during the same period of time. To
achieve their objectives, leveraged and inverse
funds typically employ aggressive investment
techniques, such as the use of leverage, short
sales, swap contracts, futures, options and other
derivative instruments. Investing in leveraged
funds and inverse funds involves special risks,
including, but not limited to, risks associated with
Non-Traditional Assets, short sales, leverage, and
derivative instruments. Other risks may include:
market risk, management and securities selection
risk, investment objective and asset allocation
risk, stock market risk, equity securities risk,
common stock risk, fixed income securities risk,
interest rate risk, credit risk, foreign issuer and
investment risk, and emerging market risk.
Leveraged funds and inverse funds are complex
investments that have an increased risk of loss
77
BGWG F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
funds and they
compared to other
involve
significant, special risks. As a result, they may not
be suitable for some clients. A client should not
invest in these securities unless the client is
prepared to experience significant losses in the
value of the client’s Account.
risk, capital markets access
Investing
risks may
securities
include: market
selection
investments may cause significant volatility in the
BDC’s net asset value and stock price. Due to the
nature of BDCs’ investments, securities issued by
BDCs are subject to greater liquidity risk than
other investments. A debt security or preferred
stock issued by a BDC, in many cases, is non-
rated or is rated below investment grade, which
can carry its own risks. Investing in BDCs involves
other special risks, including, but not limited to,
portfolio company credit and investment risk,
risk,
leverage
dependence upon key personnel
risk, and
regulatory risk. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, and
interest rate risk. BDCs can be speculative
investments because of the types of investments
they make and involve significant, special risks.
As a result, BDC investments may not be suitable
for some clients. Clients investing in BDCs should
have a high tolerance for risk, including the
willingness and ability to accept significant price
volatility, potential lack of liquidity and potential
loss of their investment.
risk, credit
risk,
risk,
foreign
emerging market
Structured Products Risks. Structured products
are a hybrid between two asset classes (typically
issued in the form of a CD or note) but instead of
having a pre-determined rate of interest, the
return is linked to the performance of an
underlying asset class, such as single security or
basket or index of securities; a commodity or
basket or index of commodities, including futures;
and a foreign currency or basket of foreign
currencies.
in structured products
involves special risks, including, but not limited
to, risks associated with derivative instruments.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
issuer and
rate
investment
risk,
commodities risk and currency risk. Structured
products are complex investments and involve
special risks. As a result, they may not be suitable
for some clients.
is
those
Master Limited Partnership Risks. An MLP is a
form of publicly-traded partnership that is taxed
as a partnership. MLPs have unique
tax
characteristics. A client should consult with a tax
advisor before investing in MLPs. An MLP must
generally earn at least 90% of its income from
certain qualifying sources, which includes income
and gains from certain activities involving natural
resources such as oil, natural gas, natural gas
liquids, refined petroleum products, coal, carbon
dioxide and biofuels. An MLP
is generally
structured as a limited partnership or limited
liability company and managed and operated by a
general partner or manager. Owners of an MLP
are called “limited partners” or “unit holders”.
Unit holders own interests or units in the MLP
(“units”) that are traded on a stock exchange.
MLPs make distributions to unit holders of their
available cash flows. Many MLPs focus on a
particular sector or industry. Those MLPs are
subject to risks associated with sectors or
industries in which they are focused. The value of
an investment in an MLP and the amount of
distributions it makes may depend on the prices
of the underlying commodity, such as oil or
natural gas. Many MLPs are sensitive to changes
in the prevailing level of commodity prices. MLPs
have also shown sensitivity to interest rate
Business Development Company Risks. A
BDC
closed-end
typically a domestic,
investment company that is operated for the
purpose of making equity and debt investments in
small and developing businesses, as well as
financially troubled businesses. As a result,
investments made by BDCs tend to be risky and
speculative. Investment advisers or managers for
BDCs often receive a management fee plus
incentive or performance-based fee. Because of
the existence of a performance-based
fee,
managers may be motivated to make riskier
investments that have the potential for significant
growth in value. BDCs commonly use borrowings
or leverage to make investments in portfolio
companies. Adverse interest rate movements can
negatively
impact a BDC’s ability to make
investments. Investments made by BDCs are
typically illiquid, and valuing such investments is
challenging. It is possible that valuations on
investments used are materially different from the
values that BDCs will ultimately receive upon
investments. Changing
disposition of
market and economic conditions affecting a BDC’s
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including, but not
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
movements. Investing in MLPs involves other
special risks,
limited to,
macroeconomic risk, interest rate risk, liquidity
risk, operating risk, capital markets access risk,
growth risk, distribution risk, conflicts of interest
risk, and regulatory risk. MLPs are complex
investments that have significant, special risks. As
a result, MLPs may not be suitable for some
clients. Clients investing in MLPs should have a
high tolerance for risk, including the willingness
and ability to accept potential lack of liquidity and
potential loss of their investment.
information
about
upon
Portfolio’s
Additional
certain
Complex Investment Products and other
investments pursuing Complex Strategies,
including the risks associated with those
investments, is available on Baird’s website
at bairdwealth.com/retailinvestor and on
FINRA’s website
at www.finra.org/
Investors. A client is encouraged to read the
included on those
disclosure documents
websites carefully before investing.
foreign
issuer and
investment
the headings
Capital Growth Portfolio. A Capital Growth
Portfolio will generally be invested in a manner
that seeks to provide growth of capital. Capital
Growth Portfolios have historically experienced
moderately high fluctuations in annual returns
and overall market value, typically as a result of
changes to market and economic conditions. The
Portfolio’s investments are subject to a risk of
price declines, especially during periods when
stock markets in general are declining. A Capital
Growth Portfolio’s primary risks generally include:
market risk, management and securities selection
risk, investment objective and asset allocation
risk, stock market risk, equity securities risk,
common stock risk, and capitalization risks.
Depending
specific
the
investments, the Portfolio may also be subject to
other primary risks, including investment style
risks,
risks,
emerging market risks, fixed income securities
risk, interest rate risk, credit risk, asset-backed
securities risks, below investment grade (high
yield or “junk” bonds) securities risks, and the
risks described under
“Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies
Each Account is subject to the risks associated
with the investments in the Account. Generally,
an Account will be subject to the risks associated
with the portfolio listed below that corresponds to
the investment objective of the Account or the
asset allocation strategy pursued by the Account.
risk,
common
stock
to other primary
risks,
risks,
foreign
to other primary
risks,
risks,
foreign
All Growth Portfolio. An All Growth Portfolio will
generally be invested in a manner that seeks to
provide growth of capital. All Growth Portfolios
have historically experienced high fluctuations in
annual returns and overall market value, typically
as a result of changes to market and economic
conditions. The Portfolio’s investments are subject
to a high risk of price declines, especially during
periods when stock markets in general are
declining. An All Growth Portfolio’s primary risks
generally include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities
risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
subject
including
investment style
issuer and
investment risks, emerging market risks, fixed
income security risks, below investment grade
(high yield or “junk” bonds) securities risks, and
Growth with Income Portfolio. A Growth with
Income Portfolio will generally be invested in a
manner that seeks to provide moderate growth of
capital and some current income. Growth with
Income Portfolios have historically experienced
moderate fluctuations in annual returns and
overall market value, typically as a result of
changes to market and economic conditions and
interest rates. The Portfolio’s investments are
subject to a risk of price declines, especially
during periods when stock markets in general are
declining or when interest rates are rising. A
Growth with Income Portfolio’s primary risks
generally include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
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risks,
foreign
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
investment style
issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
income. Relative
to
interest
rates are
fixed
risks,
foreign
Capital Preservation Portfolio. A Capital
Preservation Portfolio will generally be invested in
a manner that seeks to preserve capital while
generating current
the
portfolios described above, Capital Preservation
Portfolios have historically experienced smaller
fluctuations in annual returns and overall market
value as a result of changes in stock market
conditions, but have experienced fluctuations in
relation to changes in interest rates and economic
conditions. The Portfolio’s investments are subject
to risk of price declines, especially during periods
rising. A Capital
when
Preservation Portfolio’s primary risks generally
include: market risk, management and securities
selection risk, investment objective and asset
income securities risk,
allocation risk,
interest rate risk, credit risk, and money market
fund risk. Depending upon the Portfolio’s specific
investments, the Portfolio may also be subject to
other primary risks, including foreign issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
Income with Growth Portfolio. An Income with
Growth Portfolio will generally be invested in a
manner that seeks to provide current income and
some growth of capital. Income with Growth
Portfolios have historically experienced moderate
fluctuations in annual returns and overall market
value, typically as a result of changes to interest
rates and market and economic conditions. The
Portfolio’s investments are subject to a risk of
price declines, especially during periods when
interest rates are rising or when stock markets in
general are declining. An Income with Growth
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
fixed income securities risk, interest rate risk,
credit risk, money market fund risk, stock market
risk, equity securities risk, common stock risk,
and capitalization risks. Depending upon the
Portfolio’s specific investments, the Portfolio may
also be subject to other primary risks, including
issuer and
investment style
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
to
to
perception
take advantage of
of market
economic
The
the
Portfolios
have
the
investments made,
Conservative Income Portfolio. A Conservative
Income Portfolio will generally be invested in a
manner that seeks to provide current income.
Relative
the portfolios described above,
Conservative Income Portfolios have historically
experienced smaller fluctuations in annual returns
and overall market value as a result of changes in
stock market conditions, but have experienced
fluctuations in relation to changes in interest rates
and
Portfolio’s
conditions.
investments are subject to risk of price declines,
especially during periods when interest rates are
rising. A Conservative Income Portfolio’s primary
risks generally include: market risk, management
and securities selection risk, investment objective
and asset allocation risk, fixed income securities
risk, interest rate risk, credit risk, money market
fund risk, equity securities risk, and common
stock risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
to other primary
risks,
Opportunistic Portfolio. An Opportunistic
Portfolio will generally be invested in a manner
that seeks to provide long term growth through
capital appreciation and/or income by utilizing an
active management style that shifts the amount
of investment made in different asset classes and
market sectors
the
manager’s
pricing
anomalies, those market or industry sectors
deemed favorable for investment by the manager,
the current interest rate environment and/or
other macro-economic trends identified by the
manager to achieve growth while accounting for a
client’s specific short, intermediate and long term
investment and/or cash flow needs. Depending
investment strategy used, some
upon
Opportunistic
historically
experienced high fluctuations in annual returns
and overall market value, typically as a result of
changes to market and economic conditions.
Depending upon the investment strategy used
and
the Portfolio’s
investments may be subject to a high risk of price
declines, especially during periods when stock
markets in general are declining. An Opportunistic
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if an Available
Product
experiences
organizational,
is a higher risk
that
fixed
income
security
Product
that
experiences
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, and capitalization risks. Depending
upon the Portfolio’s specific investments, the
Portfolio may also be subject to other primary
risks, including investment style risks, foreign
issuer and investment risks, emerging market
risks,
risks, below
investment grade (high yield or “junk” bonds)
securities risks, and the risks described under the
headings “Non-Traditional Assets and Complex
Strategies Risks” and “Complex
Investment
Product Risks” above.
the
list of
Thus,
Investment Product
experiences significant performance problems or
if the manager or sponsor of an Available
significant
Investment
management,
operational,
compliance, legal, regulatory or other problems,
there
the Available
Investment Product will be made available (and
will continue to be made available) to clients by
Baird. An investment by a client in an Available
Investment
the
occurrence of any such event could negatively
impact the client’s Account. Available Investment
Products should only be used by a client if the
client wishes to take more responsibility for
monitoring and managing the assets in the
client’s Account,
recommended
products does not contain an investment product
that meets the client’s particular needs, and the
client understands the risks of doing so.
priorities,
changes
in
Recent Events
Global
financial markets have continued to
experience periods of elevated volatility, driven by
a combination of economic, political, and broader
macroeconomic developments. Conditions across
major economies have been influenced by shifting
policy
geopolitical
relationships, and evolving investor expectations.
Additional Considerations. A client should note
that an Account pursuing a particular investment
objective or asset allocation strategy will from
time to time be subject to actual risks that are
higher or lower than, or different from, the risks
described above under certain circumstances. See
“Investment Strategies—Important Information
about Implementation of Investment Objectives
and Investment Strategies” above for more
information. In addition to the specific risks
described above, a client’s Account may be
subject to additional risks, depending upon the
particular investments in the client’s Account. A
client should discuss the risks of particular
investments with the client’s GWG Consultant. A
client should also note that there is no guarantee
as to how an Account will perform in the future. It
is possible that an Account could experience more
dramatic return or market value fluctuations than
occurred in the past.
that Baird
establishes
for
Within the United States, the current U.S.
administration has demonstrated
intent on
implementing policy changes through executive
orders and legislation, contributing to a less
certain policy environment. Potential adjustments
to federal programs, regulatory initiatives, and
legislative priorities create additional factors for
markets to assess, which may cause meaningful
inflation reduction
market uncertainty. While
for policymakers,
focus
remains a central
achieving the U.S. Federal Reserve Board’s long
term inflation target of 2% continues to prove
challenging. Although annual price increases have
generally moderated, the price of many goods
and services remains elevated compared to levels
from a few years ago. Leadership changes at the
Federal Reserve and political divisions and discord
add further uncertainty to the economic outlook.
less
Available Investment Product Risks
The use of Available Investment Products,
including SMA Strategies made available under
the BSN and DC Programs, are subject to
additional risks compared to the use of Baird
recommended
investment products. Available
Investment Products are investment products that
generally do not meet the qualifications and
standards
its
recommended product lists. As a result, there is a
higher likelihood that some Available Investment
Products will have poor performance and will
significantly underperform compared
to an
applicable benchmark
index or peer group.
Available Investment Products are also subject to
significantly
review by Baird
rigorous
compared to recommended investment products.
Internationally, geopolitical risks have increased
as the U.S. and Israel are engaged in a military
conflict with Iran. The conflict has disrupted
global trade and caused an increase in the price
of oil. The continuation or escalation of military
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censured and required to pay restitution to
affected customers estimated to be approximately
$2.1 million including interest.
strikes could lead to a lengthy period of military
conflict, and Iran’s military attacks and other
hostile actions against other countries present a
risk of widening the conflict. In addition, the war
between Ukraine and Russia is now passing its
fourth anniversary, instability in parts of the
Middle East persist, and relations between the
U.S. and other countries are strained.
supervisor within
Rapid advancements in artificial intelligence (AI)
and automation are increasingly influencing global
economic trends, corporate decision making, and
financial market dynamics. Expanding investment
in these technologies is contributing to shifts in
how industries operate, compete, and allocate
resources. The fast pace of technological change,
potential disruptions to existing business models,
introduce
and evolving regulatory responses
additional uncertainty and may contribute to
market volatility.
In July 2016, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that the firm and a
its Private Wealth
firm
Management business did not
reasonably
supervise a former Financial Advisor who misused
a customer’s funds. The findings stated that the
supervisor did not reasonably follow-up on red
flags associated with a trade correction request
submitted by the Financial Advisor that should
have alerted him to the Financial Advisor's misuse
of a customer’s funds. The supervisor also did not
follow certain of Baird’s written supervisory
procedures (“WSPs”) relating to trade corrections.
After the supervisor realized that the Financial
Advisor misused the customer’s funds, Baird
reimbursed the customer for the loss. The
findings also included that Baird 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.
Baird was censured and fined $200,000.
Taken together, these developments may have a
significant negative impact upon global economic
conditions and contribute to a heightened risk
environment. As a result, fluctuations in asset
prices may increase, and such volatility could
adversely affect the value of a client’s Account .
certain of
the
its
Disciplinary Information
In April 2016, Baird, without admitting or denying
the findings, consented to the sanctions and
findings of the Financial Industry Regulatory
Authority, Inc. (“FINRA”) that it violated NASD
Conduct Rule 3010, FINRA Rule 3110, and FINRA
Rule 2010, by failing to establish and maintain a
supervisory system and procedures reasonably
designed to ensure that customers who purchased
mutual fund shares received the benefit of
applicable sales charge waivers. In May 2015,
Baird began a review to determine whether Baird
had provided available sales charge waivers to
eligible customers. Based on this review, in May
2015, Baird self-reported to FINRA that various
eligible customers had not received available
sales charge waivers. Baird was found to have
retirement plan and
disadvantaged certain
charitable organization customers
that were
eligible to purchase Class A shares in certain
mutual funds without a front-end sales charge.
The findings also stated that these customers
were instead sold Class A shares with a front-end
sales charge or Class B or C shares with higher
ongoing fees and the potential application of a
contingent deferred sales charge. Baird was
In September 2016, the SEC announced that
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
subadvisors
practices by
participating in Baird’s wrap fee programs offered
through
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
implement policies and
failed
to adopt or
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to
designed
provide
to Baird’s clients and
Initiative at https://www.sec.gov/news/press-
release/2019-28.
reports about an
reports was engaged
specific
procedures
information
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. Baird also was ordered to cease
and desist committing or causing any violations
and any future violations of Section 206(4) of the
Advisers Act and Rule 206(4)-7 thereunder and
pay a civil money penalty in the amount of
$250,000.
to disclose
In June 2019, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that between late
April 2013 and early July 2013 it published
issuer without
research
disclosing that the research analyst who authored
the
in employment
discussions with the issuer that constituted an
actual, material conflict of interest and that the
research analyst’s
the
failure
employment discussions with the issuer in the
research reports made those reports misleading.
Baird was censured and fined $150,000.
Initiative.” Under
brokerage
customers
an
it charged
supervisory
system
firms bought
fees and/or
the conflict of
In August 2022, Baird, without admitting or
denying the findings, consented to the entry of
findings of FINRA, which found that it charged
unfair
certain
its published
commission when
minimum commission amount of $100 on 7,277
retail equity trades and failed to establish and
maintain a
reasonably
designed to prevent charging a customer a
commission that is unreasonable or unfair in
violation of FINRA Rules 3110, 2121, and 2010.
Baird also consented to a censure, a fine in the
amount of $150,000, and the payment of
restitution of $266,481 plus interest. The findings
related to FINRA’s routine examination of Baird in
2020. During that examination, Baird modified its
minimum commission schedule and supervisory
procedures. Baird also took steps to make
payments to the affected customers, which on
average amounted 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. The brokerage customers identified by
FINRA did not include any GWG client and no
GWG client was alleged to have been charged an
unfair commission.
In March 2019, Baird, without admitting or
denying the findings, consented to an order of the
SEC, which found that it violated Sections 206(2)
and 207 of
for making
the Advisers Act
inadequate disclosures to advisory clients about
mutual fund share classes. The order was part of
a voluntary self-reporting program initiated by the
SEC called the “Share Class Selection Disclosure
(or SCSD)
the program,
firms were offered the
investment advisory
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 settlement terms imposed by the
including returning money to affected
SEC,
investment advisory clients. The central issue
identified by the SEC was that, in many cases,
investment advisory
for or
recommended to their investment advisory 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
advisory clients, and the investment advisory
firms did not adequately disclose their receipt of
12b-1
interest
associated with those 12b-1 paying share classes.
Baird and many other firms self-reported under
the program and entered
into substantially
identical orders. By self-reporting and consenting
to the order, Baird agreed to a censure and to
cease and desist from committing or causing any
violations and future violations of Sections 206(2)
and 207 of the Advisers Act. Baird also agreed to
establish a distribution fund and to deposit into
that fund the improperly disclosed 12b-1 fees
received by Baird plus prejudgment interest,
which will be paid to affected advisory clients.
More information about the order is contained in
Baird’s Form ADV, which is available on the SEC’s
Investment Advisory Public Disclosure website at
https://www.adviserinfo.sec.gov/IAPD/Default.as
px or in the SEC’s press release about the SCSD
In September 2023, Baird entered into an Offer of
Settlement with the SEC, 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
business-related
associates’
supervise
its
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procedures, and pay a $57,500 administrative
fine.
other
Additional information about Baird’s disciplinary
history is available on the SEC’s website at
www.adviserinfo.sec.gov.
including
the
Other Financial Industry Activities and
Affiliations
Baird’s Broker-Dealer Activities
Baird PWM offers brokerage accounts and related
services to its clients. Baird is also engaged in a
broad range of broker-dealer activities through
other business units,
its Global
Investment Banking, Fixed
Income Capital
Markets (including Baird Public Finance) and
Institutional Equities and Research Departments.
Certain GWG and Baird associates and certain
management persons of Baird are registered, or
have an application pending to register, as
registered representatives and associated persons
of Baird to the extent necessary or appropriate to
perform their job responsibilities.
communications. As part of
Certain Relationships and Arrangements
Baird and Associated Parties
including
for eligible
the
those
amount
the
training,
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
text and
properly retaining business-related
instant messages
off-channel
and
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.
While Baird had policies and procedures in place
prohibiting such off-channel communications, it
was discovered that certain Baird supervisors
communicated
off-channel using non-Baird
approved methods on their personal devices
investment
about Baird’s broker-dealer and
adviser businesses, and
findings were
reported to the SEC. Baird took steps prior to and
after the SEC’s review, including implementing a
for Baird
new communication tool designed
associates’ personal devices, conducting training,
and periodically requiring requisite associates to
provide an attestation relating to their business-
related
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
surveillance program,
procedures,
technology solutions and similar matters related
to off-channel communications.
timing
of
state
investment
Financial
Advisors
located
Baird PWM has relationships or arrangements with
other Baird businesses units and the Associated
Parties described below,
referral
programs that pay special compensation to GWG
referrals. Additional
Consultants
referral programs,
information about
including
referral
of
compensation, is disclosed on Baird’s website at
bairdwealth.com/retailinvestor.
These
relationships or arrangements present a conflict of
interest because they provide a financial incentive
to Baird and GWG Consultants to use, select or
recommend the investment products and services
of Baird and Associated Parties over those of
unassociated parties and those that pay the
greatest level of compensation. Baird addresses
this potential conflict through disclosure in this
Brochure. Further, when acting as fiduciaries,
Baird and GWG Consultants are required to select
or recommend investment products only when
they determine it to be in the client’s best interest
to do so.
Baird Asset Management
Baird’s Asset Management business, Baird
Advisors, Baird Equity Asset Management, and
Chautauqua Capital Management (“CCM”), part of
In March 2026, Baird entered into an Offer of
Settlement with the Massachusetts Securities
Division to settle a regulatory matter relating to
the
adviser
representative registration approvals for two of
in
Baird’s
Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals
provided investment advisory services before
their Massachusetts registrations were completed
as a form was missing from their application
materials. 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
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Baird has a financial incentive to the extent it
would recommend that a client invest in a
portfolio company owned by a Baird Capital
private equity fund. A list of the portfolio
companies held by Baird Capital private equity
funds is located on Baird Capital’s website located
at https://www.bairdcapital.com/portfolio/baird-
capital-portfolio.aspx.
Baird Equity Asset Management,
provide
investment management services to institutional
clients and Funds. GWG Consultants who refer
clients to Baird Asset Management are eligible for
referral compensation to be paid by Baird. GWG
Consultants, therefore, have a financial incentive
to favor the services provided by Baird Asset
Management over
those provided by other
managers.
Baird Funds
Baird Global Investment Banking
Baird Institutional Equities and Research
Baird Public Finance
its Global
municipal
advisory,
Investment Banking,
Through
Institutional Equities and Research, and Public
Finance Businesses, Baird provides investment
banking,
securities
underwriting, stock buyback and related services
to various corporate, municipal, and other issuers
of securities. Baird receives compensation from
such issuers in connection with the services it
provides, and the success of its services generally
depends upon Baird’s ability to sell the securities
of such issuers. Baird may, therefore, have an
incentive to favor the securities of issuers for
which Baird provides such services over the
securities of issuers for which Baird does not
provide such services.
of
referral
Baird is the investment adviser and principal
underwriter for Baird Funds, Inc. (the “Baird
Funds”). Baird Advisors provides
investment
management, administrative, and other services
to certain Baird Funds investing primarily in fixed
income securities (the “Baird Bond Funds”). Baird
Equity Asset Management and CCM provide
investment management and other services to
certain Baird Funds investing primarily in equity
securities (the “Baird Equity Funds”), and
Greenhouse Funds LLLP, a party related to Baird,
is the investment subadvisor to one of those
Funds, the Baird Equity Opportunity Fund. In
certain instances, GWG Consultants who refer
clients to the Baird Funds are eligible for referral
compensation to be paid by Baird. Due to the
amount
compensation, GWG
Consultants have a financial incentive to favor the
Baird Equity Funds over the Baird Bond Funds.
Baird Trust
engaging
Trust
for
Services
Baird is affiliated, and may be deemed to be
under common control, with Baird Trust, a
Kentucky-chartered trust company, because both
entities are indirectly wholly owned by BFG. Baird
and GWG Consultants receive compensation from
Baird Trust for referring clients and providing
ongoing relationship management services to
trust
Baird
clients
administration services as described under the
heading “Advisory Business—Additional Service
Information—Trust
Arrangements”
above.
Baird Capital
A GWG Consultant who refers a client to Baird
Investment Banking for a possible transaction in
which Baird Investment Banking earns a financial
advisory or underwriting fee receives a portion of
such fee. A GWG Consultant who refers a client to
Baird Public Finance for a municipal advisory or
underwriting opportunity receives a portion of the
compensation earned by Baird Public Finance on
that opportunity. Baird and GWG Consultants thus
have an incentive to recommend the securities
issued in those offerings. A GWG Consultant who
to Baird’s Institutional
refers a corporation
Equities business for a stock buy-back program
receives a portion of the commissions earned by
Baird’s Institutional Equities business. Baird and
its GWG Consultants may, therefore, have an
incentive to buy, and to recommend that clients
sell, the securities of issuers that are part of
Baird’s buyback services.
Sagard
Baird is engaged in a global private equity
business through Baird Capital (“Baird Capital”).
Baird and GWG Consultants may refer clients to
Baird Capital. GWG Consultants who assist in
obtaining a client’s investment in a private equity
fund offered through Baird Capital are eligible for
referral compensation.
Baird’s direct parent corporation, BFC, has a
minority ownership interest (about 5%) in Sagard
Holdings Management, Inc. (“Sagard”) and the
right to appoint a member to Sagard’s board of
is currently a management
directors, which
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such Associated Party that might present a
conflict of interest with clients.
additional
compensation
Sagard-affiliated
information
person of Baird. Baird has agreed to use best
efforts, to the extent consistent with its fiduciary
duties, best
interest obligations, and other
regulatory responsibilities, to offer to clients
investment products managed by affiliates of
Sagard. Baird has an incentive to do so because
not reaching minimum thresholds would give
Sagard a right to redeem BFC’s ownership
in Sagard and reaching significant
interest
thresholds would give BFC the right to increase its
ownership interest. GWG Consultants do not
for
receive
any
investment
recommending
products. Additional
identifying
Sagard-affiliated
investment products will be
provided to clients prior to investment.
55ip
An Associated Party receives fees or other
compensation for investment advisory or other
services that it provides to an Associated Fund.
The amount of fees and other compensation paid
by an Associated Fund to an Associated Party is
disclosed in the Associated Fund’s prospectus or
other offering document. An Associated Party also
receives fees from a client for services that it
provides related to the client’s Associated SMA
Strategy. Information about the amount of fees
paid to an Associated Party with respect to an
SMA Strategy is contained in the applicable Baird
Form ADV Part 2A Brochure, the applicable
Program Account Schedule, or in some instances,
the client’s contract with the Associated Party.
55I, LLC (d/b/a 55ip, “55ip”) uses research and
other services from Riverfront, an affiliate of
Baird, in the development of its portfolios under
receives
the BSN Program, and Riverfront
compensation from 55ip with respect to those
portfolios. Due to its affiliation with Riverfront,
Baird has a financial incentive to favor 55ip
portfolios that use Riverfront services.
incentive
to
favor
the
Associated Investment Products and
Services
Baird and GWG Consultants may select or
recommend Associated Investment Products and
Services, including the Associated Funds and
Associated SMA Strategies, listed in Appendix A to
this Brochure.
through disclosure
in
Baird and GWG Consultants have a financial
incentive to use, select or recommend Associated
Investment Products and Services because Baird
and BFG benefit financially if a client utilizes those
investment products and services rather than
unassociated investment products and services,
and GWG Consultants benefit financially from the
overall success of Baird and BFG. Similarly, Baird
and GWG Consultants also generally have a
financial
investment
products and services of Baird over Associated
Parties and to favor those of Associated Parties in
which BFG has a materially greater indirect
ownership interest over those of Associated
Parties in which BFG has a materially lesser
indirect ownership interest. Baird addresses this
this
potential conflict
Brochure. Further, when acting as fiduciaries,
Baird and its GWG Consultants are required to
select or recommend investment products only
when they determine it to be in the client’s best
interest to do so. The criteria used by them in
deciding to select or recommend Associated
Investment Products are generally the same as
those used for unassociated investment products.
However, a client should note that certain
Services and certain categories of investment
products only offer investment products and
services of Associated Parties. In those cases,
Baird and GWG Consultants do not impose the
same criteria or level of review.
Certain Associated Parties are associated with
Baird because BFC, Baird’s parent corporation,
owns some or all of the Associated Parties’ voting
securities. BFC’s parent corporation (and Baird’s
ultimate parent corporation), BFG, may be
deemed to indirectly own or control such voting
securities. Baird is deemed to be under common
control and “affiliated” with an Associated Party
when BFG indirectly owns or controls 25% or
more of such Associated Party’s voting securities
(or of an entity deemed
to control such
Associated Party). Baird considers itself “related”
to an Associated Party when BFG indirectly owns
or controls at least 10% but less than 25% of
such Associated Party’s voting securities (or of an
entity deemed to control such Associated Party).
Baird considers
itself “associated” with an
Associated Party when certain other relationships
or other arrangements exist between Baird and
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including
or
by
Baird’s
Persons from using knowledge about advisory
client account transactions to profit personally,
directly, or indirectly, by trading in his or her
personal accounts. The Code also generally
prohibits Access Persons
from executing a
security transaction for their personal accounts
during a blackout period one business day before
or after the date that a client transaction in that
same security is executed. The Code provides for
certain exceptions deemed appropriate by Baird
management
Compliance
Department. In addition, orders for the accounts
of Access Persons and other Baird associates that
are under discretionary management by Baird
may be aggregated with orders for other Baird
client accounts, so long as the order is executed
as part of a block transaction with client orders. A
copy of the Code is available to clients or
prospective clients upon request.
Relationships and Arrangements with
Investment Managers
Investment
those
managers,
participating in the Services, may select Baird, in
its capacity as a broker-dealer, to execute
portfolio trades for their clients, including for
Funds they advise and in which Baird clients
invest. Investment managers may also select
Baird to provide custody, research or other
services. Baird receives compensation for those
services. This may create an incentive for Baird to
favor the investment products and services of
such investment managers. However, Baird is a
fiduciary that is required to act in the best
interest of advisory clients when selecting or
recommending investment managers or their
investment products and services to such clients.
Baird addresses this potential conflict through
disclosure in this Brochure. Baird does not
consider the extent to which an investment
manager directs or is expected to direct trading,
custody or research services to Baird when
considering
investment
the eligibility of an
manager or its investment products or services
for the Services.
Baird has also implemented certain policies and
procedures relating to Baird’s and its associates’
trading activities that are designed to prevent
them from improperly benefiting from the trading
activities of Baird’s advisory clients. In addition,
Baird’s Compliance Department monitors the
personal trading activities of all of Baird’s
associates providing advisory-related services to
clients.
incentive
to recommend an
Code of Ethics, Participation or
Interest in Client Transactions and
Personal Trading
Code of Ethics
Subject to the restrictions described below, Baird
and its affiliates and associates may engage in
securities transactions for their own accounts,
including the same or related securities that are
recommended to or owned by Baird clients. These
transactions may include trading in securities in a
manner that differs from, or is inconsistent with,
the advice given to Baird clients, and the
transactions may occur at or about the same time
that such securities are recommended to or are
purchased or sold for client accounts. This creates
a potential for a conflict between the interest of
clients and the interests of Baird and its affiliates
and associates.
Participation or Interest in Client
Transactions
Investment Advisory Accounts
Asset-based Advisory Fee arrangements create an
incentive for Baird and GWG Consultants to set
the applicable fee rate at a high level and to
encourage clients to add more money into their
accounts. Baird and GWG Consultants also have
an
investment
advisory account to a client rather than a
brokerage account if the client has, or is expected
to have, lower levels of trading activity in the
client’s account. Select clients may pay a fixed
dollar fee, which presents a conflict in that such
fee does not give the GWG Consultant an
incentive to make recommendations that could
benefit the client’s account, or a performance or
incentive fee, which presents a conflict because it
incentive to
gives the GWG Consultant an
recommend riskier
in order to
investments
achieve the level of performance in the account
that would result in payment of the fee.
To address the potential for conflicts of interest,
Baird has adopted a Code of Ethics (the “Code”)
its associates that provide
that applies to
investment advisory services to clients, including
GWG Consultants, their supervisors, and certain
associates who have access
to non-public
information relating to advisory client accounts
(“Access Persons”). The Code prohibits Access
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fees increase. Thus, Baird and GWG Consultants
have an incentive to use, select or recommend
such products and to recommend such products
that pay the greatest ongoing fees.
Accounts and Investments Provide Different
Levels of Compensation
The types of accounts and investment products
to clients provide Baird and GWG
offered
Consultants different levels of compensation.
Baird and GWG Consultants have an incentive to
generate revenues
from client accounts by
selecting and recommending account types and
investment products that will provide them the
greatest level of compensation.
Certain mutual funds charge 12b-1 fees, which
are paid to Baird. Baird receives 12b-1 fees on an
ongoing basis as compensation for the services
Baird provides to the applicable mutual fund. The
12b-1 fees paid by a mutual fund are disclosed in
the mutual fund’s prospectus.
the
Relationships
and
website
Recommendations of Associated Investment
Products and Services
Baird and GWG Consultants have an incentive to
use, select or
investment
recommend
products and services of Associated Parties
because they will benefit financially. See “Other
Financial Industry Activities and Affiliations—
Certain
Arrangements—
Associated Investment Products and Services”
above and “Certain Parties Associated with Baird”
at
Baird’s
on
bairdwealth.com/retailinvestor.
Baird generally does not allow mutual funds with
12b-1 fees to be purchased for GWG Service
Accounts. If Baird receives 12b-1 fees from a fund
with respect to a client’s mutual fund investment
in the client’s Account and the client’s Account is
subject to an asset-based fee arrangement, Baird
either: (1) rebates such 12b-1 fees to the client’s
Account if the client is paying an asset-based
Advisory Fee on such investment; or (2) excludes
such fund shares from the calculation of the
client’s asset-based Advisory Fee (sometimes
referred to as “unbillable assets”) for such period
of time that Baird collects and retains the 12b-1
fee. 12b-1 fees rebated to a client’s Account are
estimated based on the average daily balance of
the mutual fund shares in the Account and the
annual rate of the 12b-1 fee paid by the
applicable fund. If any rebated fees remain in a
client’s Account at the time of billing, those
rebated amounts will be included in the Account
assets subject to the Advisory Fee.
Service
in
Referral Compensation Paid to GWG Consultants
GWG Consultants receive additional compensation
for referring clients to certain Associated Parties
described above. See “Other Financial Industry
Activities and Affiliations—Certain Relationships
and Arrangements—Baird and Associated Parties”
above. GWG Consultants also receive additional
compensation for referring clients to unaffiliated
banks that make loans to clients under Baird’s
Securities-Based Lending Program. See “Advisory
Information—
Business—Additional
Securities-Based Lending Program” above. Such
compensation gives GWG Consultants an
incentive to recommend or refer clients to those
Associated Parties and to recommend that a client
the Securities-Based Lending
participate
Program. For more information about referral
compensation paid to GWG Consultants and
related conflicts of interest, please see “Baird
Referral Programs” on Baird’s website at
bairdwealth.com/retailinvestor.
If Baird receives 12b-1 fees with respect to
mutual fund shares that are designated as
unbillable assets in a client’s Account, Baird will
retain such 12b-1 fees. This presents a conflict of
interest because it provides Baird and its GWG
incentive to use, select or
Consultants an
recommend mutual fund shares that pay greater
12b-1 fees. Baird addresses this conflict by
adopting a Mutual Fund Share Class Policy
described above and by adopting internal policies
that limit the circumstances under which mutual
fund investments in client accounts can be
designated as unbillable assets and 12b-1 fees
can be retained.
receives ongoing
fees
invested
Marketing Support and Revenue Sharing from
Mutual Fund and UIT Sponsors
Baird receives marketing support or revenue
sharing payments (“marketing support”) from the
sponsors and investment advisers of certain
Ongoing Product Fees
Baird
from certain
investment products that are purchased and held
in client Accounts. Those fees, such as distribution
(12b-1) and/or service fees (“12b-1 fees”) from
mutual funds, are based on the value of client
in those products. A GWG
assets
Consultant’s compensation increases as those
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that Schwab receives from the funds. Shareholder
servicing fees are not paid by Schwab on mutual
fund assets held in Retirement Accounts to the
extent prohibited by applicable law. The amount
of the shareholder servicing fees paid to Baird is
based on the value of the client assets invested in
those funds. However, the shareholder servicing
fee rate varies based on the type of fund (load or
no load), the value of client assets in those funds,
and the relationship that Schwab has with those
funds (whether or not Schwab receives payments
from those funds or their sponsors, and the rates
of such payments). As a result, Baird has an
incentive to use, select or recommend mutual
funds from which Baird would receive higher
payments from Schwab. However, Baird generally
does not compensate GWG Consultants based
upon the amounts Baird receives from Schwab
except with respect to amounts attributable to
sales loads and 12b-1 fees that Baird would
otherwise receive directly from a fund if it were
not for the existence of the clearing arrangement
with Schwab. If Baird receives 12b-1 fees from
Schwab with respect to a mutual fund investment
in a client’s Account, Baird rebates or retains such
fees as further described under the heading
“Ongoing Product Fees” above.
Trust
Portfolios
and
funds,
the opportunity
Please
see
seminars
supporting Baird
Please
see
mutual funds. These payments, which are based
on sales of, or client assets invested in, such
funds, are intended to compensate Baird for
providing marketing, distribution and other
services for the mutual funds. Marketing support
is not paid by sponsors or investment advisers of
mutual funds on mutual fund assets held in
investment advisory Retirement Accounts to the
law. Baird
extent prohibited by applicable
received marketing support payments over the
past two calendar years from the sponsors or
investment advisers of Alliance Bernstein Funds,
American Funds, Franklin Templeton Funds,
Goldman Sachs Funds, Hartford Funds, Invesco
Funds, John Hancock Funds, JPMorgan Funds,
Lord Abbett Funds, MFS Funds, PIMCO Funds and
Principal Funds. Baird also generally receives
marketing support related to the sale of units of
UITs. Sponsors of UITs typically make marketing
or concession payments to the firms that sell their
UITs,
including Baird. These payments are
typically calculated as a percentage of the total
volume of sales of the sponsor’s UITs made by
the
firm during a particular period. That
percentage typically increases as higher sales
volume levels are achieved. Descriptions of these
additional payments are provided in a UIT’s
prospectus. UIT sponsors that have paid volume
concessions to Baird over the past two calendar
years include Advisors Asset Management (AAM),
Guggenheim
First
Investments. Receipt of marketing support
payments from sponsors and investment advisers
of mutual funds and UITs provides Baird an
incentive to use, select and recommend such
mutual funds and UITs and to favor mutual funds
and UITs with sponsors or investment advisers
that make the greatest levels of such payments.
Baird does not share these payments with GWG
“Revenue
Consultants.
Sharing/Marketing Support and Other Third Party
Payments” at bairdwealth.com/retailinvestor for
more information.
Baird Conference Sponsorships
Baird hosts a number of seminars and
conferences for GWG Consultants in any given
year, including Baird’s PWM Symposium, which
gives sponsors of investment products, such as
mutual
to make
presentations at, and contribute money toward
the cost of, such seminars and conferences. This
presents a conflict of interest in that it gives Baird
an incentive to promote or market the sponsors’
investment products in order to persuade them to
and
continue
conferences.
“Revenue
Sharing/Marketing Support and Other Third Party
Payments” at bairdwealth.com/retailinvestor for
more information.
GWG Consultants Receive Benefits from Product
Providers
GWG Consultants generally receive non-cash
compensation and other benefits from Baird and
from sponsors of investment products with which
Baird does business. Such non-cash compensation
and other benefits may include invitations to
attend conferences or educational seminars,
payment of related travel, lodging and meal
Schwab Clearing Arrangement
Baird has a clearing arrangement with Charles
Schwab & Co., Inc. (“Schwab”) whereby Schwab
maintains an omnibus account with certain
mutual fund families for Baird on behalf of Baird
clients. Under the clearing arrangement, Schwab
provides clearing services for most “no load”
funds and “load” funds held by Baird clients.
Although Baird pays Schwab a fee for its clearing
and omnibus services, Schwab generally passes
through to Baird the shareholder servicing fees
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securities purchases. It also increases the value of
a client’s Account and thus the Advisory Fee
associated with that Account because the margin
loan is not deducted for purposes of calculating
the fee. Please see “Advisory Business—Additional
Service Information—Margin Loans” above for
more detailed information.
GWG
Consultants
receive
Party
Service
Payments”
for
expenses, and receipt of gifts and entertainment.
For example, GWG Consultants are invited to
educational conferences hosted by sponsors of
mutual funds, annuities and other investment
products, with the costs associated with such
conference (including travel and lodging) paid by
the sponsors. In addition, GWG Consultants hold
client events with some or all of the costs of such
events paid by sponsors of investment products.
Product sponsors may also provide gifts and
entertainment in connection with those or other
events. These benefits present a conflict of
interest in that they give GWG Consultants an
incentive to use, select or recommend investment
products and their sponsors that provide the
greatest levels of such benefits. Please see
“Revenue Sharing/Marketing Support and Other
at
Third
bairdwealth.com/retailinvestor
more
information.
Securities-Based Lending Program
Baird and GWG Consultants have an incentive to
recommend that a client participate in Baird’s
Securities-Based Lending Program because Baird
referral
and
compensation and such loans allow a client to
keep more assets in the client’s Accounts, which
result in more advisory fees for us and paid to the
client’s GWG Consultant. Please see “Advisory
Business—Additional
Information—
Securities-Based Lending Program” above for
more detailed information.
Program
Baird
to
clients
rather
Cash Sweep Program
Baird has an incentive to have clients participate
and maintain significant balances in Baird’s Cash
Sweep
receives
because
substantial compensation on client cash balances
that are automatically swept into bank deposit
accounts and invested in money market mutual
funds under the program. Please see “Advisory
Business—Additional Service Information—Cash
for more detailed
Sweep Program” above
information.
Consultant
receive
firm
and
to
incentive
to recommend an
for
it
them. Please see
Trust Services Arrangements
Baird and GWG Consultants have an incentive to
recommend that a client retain Baird Trust for the
client’s trust services needs rather than an
unassociated
recommend
arrangements that involve Baird and the GWG
Consultant providing investment advisory services
to the client and Baird Trust only providing trust
is more
administration services because
profitable
“Advisory
Business—Additional Service Information—Trust
Services Arrangements” above for more detailed
information.
Investment Advisory and Brokerage Account and
Service Recommendations
Baird and GWG Consultants generally have a
financial incentive to recommend investment
than
advisory Accounts
brokerage accounts because Advisory Fee
revenue
is recurring, more predictable and
typically greater than the revenues Baird earns,
and the compensation GWG Consultants receive,
from brokerage accounts. In addition, because
Advisory Fees are paid by a client regardless of
the trade activity in the client’s advisory Account,
Baird will receive greater revenue, and the client’s
greater
will
GWG
compensation, from a low trade-activity advisory
Account than from a low trade-activity brokerage
account. Baird and GWG Consultants thus have
an
investment
advisory Account to a client rather than a
brokerage account if the client has, or is expected
to have, lower levels of trading activity in the
client’s account. However, because Baird’s
revenues and the compensation paid to GWG
Consultants from brokerage accounts increase as
the level of trading increases, Baird and GWG
Consultants have an incentive to recommend a
brokerage account to a client rather than an
investment advisory Account if the client has, or
is expected to have, significant trading activity in
the client’s account. GWG Consultants also have a
financial incentive to recommend certain wealth
management services, such as financial planning.
Please see “Fees and Compensation—Advisory
Margin Loans
Baird has an incentive to recommend that a client
use margin because Baird receives interest on
client margin
loans, and Baird and GWG
Consultants also have an incentive to recommend
that a client use margin, because a margin loan
allows the client to make larger and more
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Fees—Advisory Fee Payments to Baird, GWG
Consultants and Investment Managers” above for
more detailed information.
select or
department and thus of BFG, which will serve to
grow the value of the BFG stock. For example,
ownership of BFG stock, the performance of which
is impacted by the success of Associated Parties,
provides a client’s GWG Consultant an incentive
to use,
recommend Associated
Investment Products and Services to a client even
though such recommendation does not increase
the client’s GWG Consultant’s production.
for
Account Transfers and New Accounts
Baird and a client’s GWG Consultant have an
incentive to recommend that the client transfer
the client’s accounts to Baird and establish new
accounts with Baird (including IRA rollovers)
because doing so will result in increased revenues
to Baird and compensation
the GWG
Consultant.
Other Client Relationships
Certain client accounts overseen by Baird and
GWG Consultants may have similar investment
objectives and strategies but may be subject to
different fee schedules or commission rates. Thus,
Baird and its GWG Consultants have an incentive
to favor client accounts that generate a higher
level of compensation.
in companies or
Recommendations to Open Different Types of
Accounts
Baird and GWG Consultants have an incentive to
recommend that a client open different types of
accounts with Baird, such as individual accounts,
IRA rollovers, joint accounts, 529 plan accounts
and UGMA/UTMA accounts, because if a client has
different types of accounts with Baird, the client
brings more of the client’s investable assets to
Baird, on which fees can be generated, thereby
increasing Baird’s revenues and the client’s GWG
Consultant’s compensation. Also, if a client has
more account types with Baird, the client is
statistically more likely to maintain the client’s
relationship with Baird and the client’s GWG
Consultant for longer periods of time.
Relationships with Issuers of Securities
From time to time, Baird may have proprietary
issuers whose
investments
securities are offered and sold to clients, a GWG
Consultant or another Baird associate may have
significant investments in companies or issuers
whose securities are offered and sold to clients, or
a GWG Consultant or another other Baird
associate (or their spouses, partners or family
members) may have a position as an officer or
director of a company or issuer whose securities
are offered and sold to clients. In such cases,
Baird and/or a client’s GWG Consultant will have
an incentive to recommend that the client invest
in those companies.
that
increase
Fees—Advisory
GWG Consultants Transferring to Baird
A GWG Consultant joining Baird from another firm
has an incentive to recommend that a client to
transfer the client’s accounts from such firm to
Baird because doing so will increase the GWG
Consultant’s compensation. Please see “Fees and
Compensation—Advisory
Fee
Payments
to Baird, GWG Consultants and
Investment Managers” above for more detailed
information.
compensation
with
Baird,
even
if
Baird Stock Ownership
Most GWG Consultants own common stock of
BFG, Baird’s ultimate parent, and when offered
the opportunity to buy BFG stock they usually do
so. The amount of BFG stock that a GWG
Consultant may purchase is based in part on the
GWG Consultant’s total production level. A client’s
GWG Consultant thus has an incentive to make
recommendations
the GWG
Consultant’s total production on the client’s
accounts with Baird. Moreover, revenues from
Baird’s PWM department,
in which GWG
Consultants operate, contribute substantially to
BFG’s overall revenues and profitability, and the
performance of BFG’s stock price is largely due to
the profitability of Baird’s PWM department. As a
result, a client’s GWG Consultant’s ownership of
BFG stock creates a financial incentive to make
recommendations to the client that increase the
amount of revenues generated from the client’s
accounts
those
recommendations will not increase the GWG
Consultant’s production, so as to increase the
revenues and profitability of Baird’s PWM
Principal Trading
Baird and GWG Consultants have an incentive to
execute a trade for a client on a principal basis.
The
that Baird and GWG
Consultants receive on principal trades, such as a
markup or markdown, is often higher than the
compensation they receive when executing trades
The
as
as
agent,
such
commissions.
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
have a conflict of interest that could affect the
content of its research reports.
sell
investments
compensation received by Baird and GWG
Consultants is in addition to the asset-based
Advisory Fee a client pays on the client’s advisory
Accounts. Thus, Baird and GWG Consultants have
an incentive to trade as principal rather than as
agent. Principal trades also allow Baird to sell
securities from Baird’s account that Baird deems
undesirable and to buy securities for Baird’s
account that Baird deems desirable. For more
information, please see “Advisory Business—
Additional Service Information—Trading for Client
Accounts—Trade Execution Services Performed by
Baird—Principal Trades” above.
recommended
Information—Trading
for
Baird and its Associated Parties and associates
may buy or
that are
recommended to or owned by a client for their
own accounts, or they may act as broker or agent
those
for other clients buying or selling
investments. Those transactions may include
buying or selling investments in a manner that
differs from, or is inconsistent with, the advice
given to a client, and those transactions may
occur at or about the same time that such
investments are
to or are
purchased or sold for a client’s account. Baird
may also engage in agency cross transactions and
principal transactions with clients as further
described under “Advisory Business—Additional
Service
Client
Accounts—Trade Execution Services Performed by
Baird” above.
Baird Underwritten Offerings
Baird and GWG Consultants have an incentive to
recommend that clients purchase securities in
offerings underwritten by Baird because the
underwriting compensation that Baird and GWG
Consultants will earn on those offerings tends to
be higher than the compensation they would
normally receive if clients were to buy them in the
secondary market, and because the profitability of
underwritten offerings to Baird depends upon
Baird’s ability to sell the securities allocated to
Baird in the offering.
to
Relationships
Baird and GWG Consultants have an incentive to
favor the securities of issuers for which Baird’s
Global Investment Banking, Fixed Income Capital
Markets (including Baird Public Finance) and
Institutional Equities and Research Departments
provide services due
the compensation
received by Baird and Baird Financial Advisors.
See “Other Financial Industry Activities and
and
Affiliations—Certain
Arrangements—Baird and Associated Parties”
above.
Allocations of IPOs and Other Public Offerings
GWG Consultants have the incentive to favor
some clients over other clients when allocating
shares issued in public offerings, particularly
those clients with larger accounts or accounts that
generate high fees and compensation, as a
reward for their past business or to generate
future business.
As a registered broker-dealer, Baird effects
transactions in securities on a national exchange
and may receive and retain compensation for
such services, subject to the limitations and
restrictions made applicable to such transactions
by Section 11(a) of the Exchange Act and Rule
11a2-2(T) thereunder.
Trade Error Correction
It is Baird’s policy that a client’s account will be
fully compensated for any losses incurred as a
result of a trade error for which Baird is
responsible. If the trade error results in a gain,
the gain may be retained by Baird. For more
information, please see “Advisory Business—
Additional Service Information—Trading for Client
Accounts—Baird’s Trading Practices—Trade Error
Correction” above.
A client may choose to hold cash balances in the
client’s eligible accounts as broker-dealer “free
credits.” To the extent a client elects to hold cash
balances as free credits, a client understands that
Baird does not pay interest on such balances and
Baird may benefit from the possession or use in
the ordinary course of its business of any free
credit balances in the client’s accounts, subject to
restrictions imposed by Rule 15c3-3 under the
Exchange Act.
Baird’s Other Broker-Dealer and Related Activities
The investment advice provided to a client may
be based on the research opinions of Baird’s
research departments. Baird does, and seeks to
do, business with companies covered by those
research departments and as a result, Baird may
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the size of
the order,
offered by Baird, clients should contact Baird or a
GWG Consultant.
automated
financial
interest or practices
Financial
Industry
Activities
non-institutional
participants
in
Other sections of this Brochure also describe
instances when Baird and its GWG Consultants
may recommend to clients, and may buy and sell
for client’s Account, securities in which Baird and
its Associated Parties and associates have a
material
that
present a conflict of
interest. For more
information, please see “Advisory Business—
Advisory Fees—Advisory Fee Payments to Baird,
GWG Consultants and Investment Managers” and
“Other
and
Affiliations” above, and “Client Referrals and
Other Compensation” below.
Baird selects securities trade execution venues
based on
trading
characteristics of the security, speed of execution,
likelihood of price improvement, availability of
efficient
transaction processing,
guaranteed automatic execution levels and other
qualitative factors. Baird receives payment or
liquidity rebates on certain options or equity
to some venues
routed
securities orders
(commonly known as “payment for order flow”).
The existence and amount of payments are
dependent upon the size and type of the routed
source and amount of any
order. The
compensation received by Baird in connection
with payment for order flow will be disclosed to
the
the
transaction upon request. This compensation
gives Baird an incentive to route client orders for
securities transactions to those venues that
provide Baird the greatest levels of compensation,
but Baird’s routing decision is always based upon
obtaining favorable executions for clients rather
than the availability of payment for order flow.
Information about Baird’s order routing practices
are
at:
available
http://www.rwbaird.com/help/account-
disclosures/routing-equity-orders.aspx.
for Baird and
Addressing Conflicts
The foregoing activities could create a conflict of
interest with clients. In addition to the measures
described above, Baird addresses conflicts posed
by those activities through disclosure in this
Brochure, the client’s agreements with Baird, the
Client Relationship Booklet and prospectuses,
offering documents or other disclosure documents
provided or made available to clients. Baird has
also adopted a Code of Ethics and other internal
policies and procedures
its
associates that:
from
time
• require them to provide investment advice that
is suitable for advisory clients (based upon the
information provided by such clients);
that
• are designed
securities
to ensure
allocations made to discretionary client accounts
are made in a manner such that all such clients
receive fair and equitable treatment over time;
Baird and its associates, by reason of Baird’s
investment banking or other
broker-dealer,
time acquire
to
activities, may
information deemed confidential, material and
non-public, about corporations or other entities
and their securities. Baird and its associates are
prohibited by applicable law or agreements from
disclosing such information to clients or acting
upon such information with respect to any client
Account. Baird’s other activities thus present a
potential conflict of
interest because such
activities may limit Baird’s ability to advise or
manage client Accounts.
• address Baird’s and its associates’ trading
activities and are designed to prevent them
from improperly benefiting from the trading
activities of Baird’s advisory clients; and
• address and limit cash and non-cash benefits
provided to GWG Consultants by third parties in
an attempt to avoid any question of propriety or
any conduct inconsistent with Baird’s high
standards of ethics.
Other Conflicts of Interest
Baird offers to clients other investment products
and services not described in this Brochure. These
investment products and
services provide
different levels of compensation to Baird and its
GWG Consultants. Baird and its GWG Consultants
have an incentive to favor those investment
products and services that generate a higher level
of compensation than those that generate a lower
level of compensation. For more information
about the other investment products and services
Duration Compensation Will Be Received
If a client holds any of the investment products
described above, Baird, its Associated Parties and
associates will receive the fees and payments
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
extend beyond
a
client’s
described above for the duration of the client’s
advisory
In some
relationship with Baird.
circumstances, the receipt of such compensation
advisory
may
relationship with Baird if the client continues to
hold those assets at Baird.
known as bunching trades or block transactions).
This practice may enable them to obtain more
favorable execution, including better pricing and
enhanced investment opportunities, than would
otherwise be available
if orders were not
aggregated. Using block transactions may also
assist them in potentially avoiding an adverse
effect on the price of a security that could result
from simultaneously placing a number of
separate, successive or competing, client orders.
under
their
direct
If Baird, or an Associated Party or associate of
Baird, receives any compensation or benefit
described in this Brochure from or related to a
client’s investment, they will generally retain the
compensation or benefit. Except as otherwise
described above, Baird generally does not rebate
these amounts to a client’s Account or credit the
amount against the Advisory Fees payable by a
client unless such compensation may not be
retained under applicable law or regulation.
to GWG
to
into
consideration
account
GWG and Baird generally aggregate buy and sell
orders when executing trades for client account
assets
discretionary
management when they have the opportunity to
do so. When utilizing block transactions, GWG and
Baird generally aggregate a client’s trade orders
with trade orders for clients who are participating
in the same Service and pursuing the same model
portfolio or strategy. In some cases, GWG or
Baird may aggregate a client’s trade orders with
trade orders for other advisory clients who are not
participants in the Services described in this
Brochure. However, GWG and Baird determine
whether or not to utilize block transactions for a
client in their sole discretion and GWG’s and
Baird’s decision is subject to their duty to seek
best execution. In determining the amount to be
allocated to an account, if any, GWG and Baird
take
specific
investment restrictions, undesirable position size,
account portfolio weightings, client tax status,
client cash positions and client preferences.
All advisory clients participating
in a block
transaction will receive the same execution price
for the security bought or sold. Average prices
may be used when allocating purchases and sales
to a client’s Account because such securities may
be purchased and sold at different prices in a
series of block transactions. As a result, the
average price received by a client may be higher
or lower than the price the client may have
received had the transaction been effected for the
client independently from the block transaction.
in
Brokerage Practices
GWG’s and Baird’s Trading Practices
Broker-Dealer Selection
GWG and Baird will select the broker-dealers,
which may include Baird, that will execute trade
orders for Non-Discretionary Accounts and with
respect to Accounts that are managed directly by
GWG or Baird unless the client has provided
instructions
the contrary. As
investment adviser, GWG and Baird have an
obligation to seek “best execution” of client trade
orders. “Best execution” means that they must
place client trade orders with those broker-
dealers that they believe are capable of providing
the best qualitative execution of client trade
orders under the circumstances, taking into
account the full range and quality of the services
offered by the broker-dealer, including the value
of the research provided (if any), the broker-
dealer’s execution capabilities, the cost of the
trade, the broker-dealer’s financial responsibility,
and its responsiveness to GWG and Baird. It is
important to note that GWG’s and Baird’s best
execution obligation does not require them to
solicit competitive bids for each transaction or to
seek the lowest available cost of trade orders, so
long as they reasonably believe that the broker-
dealer selected can be reasonably expected to
provide clients with the best qualitative execution
under the circumstances.
Trade Aggregation, Allocation and Rotation
Practices
GWG and Baird may aggregate contemporaneous
buy and sell orders for the accounts over which
they have discretionary authority (a practice also
The amount of securities available
the
marketplace, at a particular price at a particular
time, may not satisfy the needs of all clients
participating in a block transaction and may be
insufficient to provide full allocation across all
client accounts. To address this possibility, Baird
has adopted
trade allocation policies and
procedures that are designed to make securities
allocations to discretionary client accounts in a
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
treatment over
the client may buy or sell securities at prices that
are different from the prices obtained by other
clients who received the same or similar advice
from GWG or Baird.
manner such that all such clients receive fair and
equitable
time. If a block
transaction cannot be executed in full at the same
price or time, the securities actually purchased or
sold by the close of each business day will
generally be allocated pro rata among the clients
participating in the block transaction. However,
GWG may also make random allocations to client
accounts in certain circumstances, such as when
Baird deems a partial fill for the total block order
to be low. Adjustments may also be made to
avoid a nominal allocation to client accounts.
favorable net price
When GWG is not able to aggregate trades, GWG
generally uses a trade rotation process that is
designed to be fair and equitable to its advisory
clients over time. However, a client should be
aware that GWG’s trade rotation practices may at
times result in a transaction being effected for the
client’s Account that occurs near or at the end of
the rotation and, in such event, client’s trade
orders will significantly bear the market price
impact, if any, of those trades executed earlier in
the rotation, and, as a result, the client may
receive a
for the
less
applicable trade.
for
fixed
Notwithstanding the foregoing, if an aggregated
trade order involves fixed income securities, GWG
and Baird may allocate the securities based on
the needs of client accounts. In addition, GWG
and Baird will at times place aggregated trade
orders
income securities prior to
determining how the aggregated trade order will
be allocated to client accounts. In those instances
when an aggregated trade order for fixed income
securities is placed prior to determining client
allocations or when such trade order is only
partially filled, GWG or Baird will seek to allocate
trades in manner intended to be fair and equitable
to applicable clients over time. Furthermore,
when a trade order for fixed income securities is
only partially filled, GWG and Baird may place
orders for other fixed income securities that have
similar characteristics, such as issuer name,
structure, credit rating, or market sector.
Directed Brokerage Arrangements
In some cases, a client may direct GWG to use a
particular broker-dealer for execution of the
client’s trade orders (a “directed brokerage
arrangement”), and GWG may agree to the
arrangement. This may occur when a client’s
Account is held at another broker-dealer firm and
a client directs GWG to execute trades through
such firm, or when a client’s Retirement Account
or other account is maintained on a platform
operated and managed by a third party and
trades must be executed through that platform. A
client should understand that GWG and Baird
consider such arrangements to be directed
brokerage arrangements. A client should also
understand that if the client has a directed
brokerage arrangement, GWG and Baird may be
unable to achieve best execution for the client’s
transactions. A client should note that any costs
related to the directed brokerage arrangement
are not included in the Advisory Fee and that the
client will be solely responsible for monitoring,
evaluating and reviewing the arrangement with
the directed broker-dealer and paying any
commissions or markups or markdowns or other
costs imposed by the directed broker-dealer. A
client should also note that GWG generally will
not aggregate the client’s directed brokerage
trade orders with orders for other GWG clients. As
a result, a client’s transaction costs may be higher
because the client will not benefit from any
volume discounts or other reduced transaction
costs that GWG may obtain for its other clients. A
client should further note that GWG generally will
not include such client trade orders in its trade
rotation process and that GWG will generally
place the client’s trade orders with the directed
broker-dealer after GWG completes its trading for
other GWG client accounts. The client’s trade
orders will significantly bear the market price
impact, if any, of those trades executed earlier in
GWG’s rotation. As a result, the client may
receive a less favorable net price for the trade.
If a client directs GWG to use a particular broker-
dealer, and if the particular broker-dealer referred
the client to GWG or if the particular broker-
dealer refers other clients to GWG or Baird in the
future, GWG and Baird may benefit from the
Because GWG and Baird are unable to buy or sell
any security for a client’s Non-Discretionary
Accounts without the client’s authorization, GWG
and Baird generally do not aggregate or bunch
trades for those Accounts with the same or similar
trades for other client accounts. Because similar
orders for the client and GWG’s or Baird’s other
clients may be placed and filled at different times,
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
client’s directed brokerage arrangement. Because
of these potential benefits, GWG and Baird may
have an economic interest in having the client
continue the directed brokerage arrangement.
The benefits that GWG and Baird receive conflict
with the client’s interest in having GWG or Baird
recommend that the client utilize another broker-
dealer to execute some or all transactions for the
client’s Account.
Before directing GWG to use a particular broker-
dealer, a client should carefully consider the
possible costs or disadvantages of directed
brokerage arrangements.
client’s Account in the position that it would have
been in as if the error had not occurred, including
by adjusting or reversing the transaction, entering
an offsetting transaction, or other methods that
may be deemed appropriate by Baird. Errors
caused by GWG or Baird will be corrected at no
cost to client’s Account, with the client’s Account
not recognizing any loss from the error. GWG and
Baird may net gains and losses from a single error
event involving more than one transaction in a
security or transactions in multiple securities. The
client’s Account will be fully compensated for any
losses incurred as a result of an error event. If
the trade error results in a gain, the gain may be
retained by Baird but such gain is not given to or
shared with any GWG or Baird associate.
GWG and Baird offer many services and, from
time to time, may have other clients in other
programs trading in opposition to a client. To
avoid favoring one client over another client,
Baird attempts to use objective market data in
the correction of any trading errors.
If a client’s Account is managed by an Other
Manager, the client should review the Other
the Other
Manager’s Brochure and contact
Manager for information about how the Other
Manager corrects trade errors.
the purchase of
Cross Trading Involving Advisory Accounts
GWG generally does not in engage in cross
transactions, including agency cross transactions,
except in limited instances such as when clients
buy or sell variable rate demand obligations which
are also known as “put bonds”. When GWG
believes that the transaction is consistent with
each client’s best interest, GWG, acting as
investment manager, may cause (or in the case
of Non-Discretionary accounts, recommend) the
sale of securities from the account of an advisory
client while at or about the same time causing
(or, in the case of Non-Discretionary accounts,
recommending)
the same
securities
for the account of another GWG
advisory client. Such transactions may have the
benefit of reducing transaction and market impact
costs.
Soft Dollar Benefits
GWG and Baird receive no research or other
products from broker-dealers in connection with
GWG clients’ securities transactions.
Trading Practices of Investment Managers
If a client’s Account or a portion thereof is
managed by an investment manager, the client
should note that, like Baird, such investment
manager has a duty to seek best execution for
the client’s Account.
In such cases, because Baird is acting as
investment adviser for both buyer and seller,
Baird is subject to potentially conflicting interests
in causing (or recommending) the transactions.
Also, because Baird is acting as investment
adviser for both buyer and seller, transaction
prices may be determined more by reference to
market information or dealer indications for the
securities involved, and less through the type of
independent arms-length negotiation that might
otherwise occur. Baird has adopted internal
policies and procedures that require GWG and
Baird to obtain approval of Baird’s Compliance
Department before affecting a cross trade.
the
investment manager,
Trade Error Correction
It is Baird’s policy that if there is a trade error for
which GWG or Baird is responsible, GWG or Baird
facts and
will take actions, based on the
circumstances surrounding the error, to put the
Investment managers may participate in wrap fee
programs. In addition, investment managers may
manage institutional and other accounts not part
of a wrap
fee program. In the event an
investment manager purchases or sells a security
for all accounts using a particular SMA Strategy
the
offered by
investment manager may have to potentially
effect similar transactions through a number of
different broker-dealers. In some cases, to
address this situation, investment managers may
decide to aggregate all such client transactions
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
into a block trade that is executed through one
broker-dealer. This practice may enable the
investment manager to obtain more favorable
execution, including better pricing and enhanced
investment opportunities, than would otherwise
be available if orders were not aggregated. Using
block transactions may also assist the investment
manager in potentially avoiding an adverse effect
on the price of a security that could result from
simultaneously placing a number of separate,
successive or competing client orders.
in
in
the
the Model Provider’s
above, the performance of a Model Portfolio, as
reported by the Model Provider, will differ,
perhaps in a materially negative manner, from
the actual performance realized by GWG client
Accounts pursuing the Model Portfolio strategy.
GWG and Baird do not make or control any
investment manager’s trade rotation policies, and
they do not monitor, evaluate or review any
the
investment manager’s compliance with
manager’s trade rotation policies or whether such
trade rotation policies result
inequitable
performance of client Accounts. A client selecting
a Model Portfolio offered by such a Model Provider
is urged to obtain a copy of the Model Provider’s
Form ADV Part 2A Brochure and review the
description of the Model Provider’s trade rotation
policy contained in that document. A copy of a
Model Provider’s Brochure can be obtained by
contacting a GWG Consultant. A client should also
monitor the performance of an Account pursuing
such a Model Portfolio strategy and compare that
performance with the performance reported for
the Model Portfolio by the Model Provider. A client
about Account
should
questions
discuss
performance or
trade
rotation policy with the client’s GWG Consultant.
information
Alternatively, an investment manager may utilize
a trade rotation process where one group of
clients may have a transaction effected before or
after another group of the investment manager’s
clients. A client should be aware that an
investment manager’s trade rotation practices
may at times result in a transaction being effected
for the client’s Account that occurs near or at the
end of the investment manager’s rotation and, in
such event, client’s trade orders will significantly
bear the market price impact, if any, of those
trades executed earlier
investment
manager’s rotation, and, as a result, the client
may receive a less favorable net price for the
regarding an
trade. Additional
investment manager’s trade rotation policies, if
any, is available in the investment manager’s
Form ADV Part 2A Brochure.
A client should note that each
investment
manager is solely responsible for ensuring that it
complies with its best execution obligations to the
client. A client should review the manager’s
trading for the client’s Account because GWG and
Baird do not monitor, review or evaluate whether
the manager is complying with its best execution
obligations to the client. A client should review
the manager’s Form ADV Part 2A Brochure,
inquire about the manager’s trading practices,
and consider that information carefully, before
selecting a manager.
on
website
A client should note that the client’s advisory
agreement permits GWG and Baird to trade as
principal on orders received from Other Managers.
See “Trade Execution Services Performed by
Baird—Principal Transactions” below for more
information.
Trade Execution Services Performed by
Baird
If Baird provides trade execution services for a
client’s Account, Baird will generally act as agent
when routing client trade orders for execution.
However, Baird may cross trades between client
accounts or may act as principal for its own
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after
they have
implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. The Overlay Manager has
provided to Baird a list of Model Providers that
have such trade rotation policies, which list is
available
at
Baird’s
bairdwealth.com/retailinvestor. A GWG client
should understand that an Account pursuing a
Model Portfolio strategy offered by those Model
Providers will have trades executed for the client’s
Account at the end of the Model Provider’s trade
rotation on a regular and consistent basis. As a
result, trade orders for such an Account will
significantly bear the market price impact, if any,
of those trades executed earlier in the Model
Provider’s rotation and the performance of the
Account will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by the Model Provider. In
addition and for the same reasons described
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account in certain circumstances to the extent
permitted by applicable law as is more fully
described below.
transactions.
Riskless
A client should understand that certain securities,
such as securities traded over-the-counter and
fixed income securities, are primarily traded in
dealer markets. When Baird purchases or sells
these types of securities for client accounts, it
generally does so through broker-dealer firms
acting as a dealer or principal. Dealers executing
principal trades typically
include a markup,
markdown or spread in the net price at which
transactions are executed. A client bears such
costs in addition to the Advisory Fee.
Principal Transactions
Subject to the requirements of applicable law,
Baird and GWG Consultants may execute
transactions for a client’s Account while acting as
principal for Baird’s own account. Baird and GWG
Consultants act as principal when they sell a
security from Baird’s inventory to a client or they
purchase a security from a client for Baird’s
inventory. Baird and GWG Consultants also act as
principal when they sell new issue securities to
clients in securities offerings underwritten by
Baird. Baird also acts as principal in riskless
principal
principal
transactions refer to transactions in which Baird,
after having received a client’s order, executes an
identical order in the marketplace to fill the
client’s order while acting as principal.
realize profits
interests of
incentive
to
Agency Cross Transactions
GWG generally does not in engage in agency
cross transactions, except in limited instances.
However, in certain circumstances and to the
extent permitted by applicable law and regulation,
Baird and GWG Consultants may effect “agency
cross” transactions with respect to a client’s
Account. An “agency cross” transaction is a
transaction in which Baird or its affiliates act as
broker for the party or parties on both sides of
the transaction. As compensation for brokerage
services, Baird may receive compensation from
parties on both sides of an agency cross
transaction, the amount of which may vary. GWG
Consultants may receive compensation from Baird
related to agency cross transactions. Therefore,
Baird and GWG Consultants may have a
conflicting division of loyalties and responsibilities.
However, in all cases, Baird and GWG Consultants
will seek to obtain the best execution for each
respective advisory client and will effect agency
cross transactions only in accordance with the
requirements of Rule 206(3)-2 under the Advisers
Act. Furthermore, Baird will comply with
additional regulations applicable to Retirement
Accounts.
agency
transactions
“agency
Baird may
from principal
transactions with a client based on the difference
between the price Baird paid for the security and
the price at which Baird sold the security, which
may include a markup, markdown or spread from
the prevailing market price, an underwriting fee,
selling dealer concession, or other incentive to
execute the transaction. GWG Consultants may
from Baird related to
receive compensation
principal trades of securities underwritten by
Baird. Any compensation received by Baird or a
GWG Consultant in a principal transaction is in
addition to the Advisory Fee paid by the client.
Principal trades also allow Baird to sell securities
from its account that it deems undesirable and to
buy securities for its account that it deem
desirable. Thus, in trading as principal with a
client, Baird and GWG Consultants will have
potentially conflicting division of loyalties and
responsibilities regarding their own interests and
the
the client. This potential
compensation may give Baird and GWG
Consultants an
recommend a
transaction in which Baird and GWG Consultants
act as principal over other
transactions.
Nonetheless, Baird and GWG Consultants have a
fiduciary duty to act in the client’s best interest
and to seek best execution for advisory clients.
Baird addresses this conflict through disclosure in
this Brochure. Furthermore, Baird has adopted
internal procedures that require Baird and GWG
Consultants, when acting in a principal capacity,
to disclose all material information regarding
Baird’s interest in the transaction, and obtain the
client’s approval of the transaction prior to
settlement.
Where applicable, a client’s advisory agreement
and
cross
discusses
authorizes Baird and GWG Consultants to effect
agency cross transactions for a client’s Account. A
client’s authorization to Baird and GWG
cross”
Consultants
to effect
transactions
is given pursuant to Rule
206(3)-2 under the Advisers Act and may be
revoked at any time by the client in client’s
sole discretion by notifying the client’s GWG
Consultant in writing.
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A client’s advisory agreement discloses, where
applicable, the possibility of Baird’s role in
potential principal
transactions, and each
transaction confirmation sent to GWG clients
discloses the capacity in which Baird served in the
transaction and whether Baird is a market maker
in each security the client bought or sold.
Account Statements and Performance
Reports
If Baird provides transaction execution services to
a client, Baird will generally provide the client
with a monthly brokerage account statement
when activity occurs during
that month.
Otherwise, Baird will provide the client with a
quarterly statement if there has not been any
intervening monthly transaction activity.
or
if
other
the Account
A client’s GWG Consultant will provide the client
with a written report on the client’s Account’s
performance as often as the client and the GWG
Consultant may from time to time mutually agree.
Performance reporting may not be available for
Account assets that are not custodied at Baird.
For more information about performance reports
provided by GWG, see “Advisory Business—
Description of Advisory Services” above. GWG or
Baird may change or discontinue performance
reporting to a client at any time for any reason
upon notice.
To the extent permitted by applicable law and
regulation, if a client’s Account participates in a
non-
Non-Discretionary Service
discretionary service, or
is
managed by an Other Manager, the client’s
advisory agreement provides Baird and GWG
Consultants with a blanket authorization to act as
principal for Baird’s own account in selling any
security to, or purchasing any security from, the
client’s Account. With this authorization, Baird
and GWG Consultants may effect any and all
principal transactions with the client’s Account
without having
to provide specific written
disclosures or obtain written client consent prior
to completion of each proposed principal trade,
subject to the requirements of an exemptive
order issued by the SEC to Baird (Rel. No. IA-
4596) and other applicable law and regulation.
This authorization to enable Baird and GWG
Consultants to trade as principal with a
client’s Account may be revoked at any time
by the client in client’s sole discretion by
notifying the client’s GWG Consultant in
writing.
Client performance reports usually contain a
portfolio valuation and typically show the asset
allocation of the client’s portfolio, changes in a
client’s portfolio, and account performance
compared to a benchmark market index or indices
(such as the S&P 500® Index or the Bloomberg
U.S.
Intermediate Government/Credit Bond
Index). The benchmark may be a blended
benchmark that combines the returns for two or
more indices.
A client should note that past performance does
not indicate or guarantee future results. None of
GWG, Baird, or investment managers managing
the client’s Account promise or guarantee any
level of investment returns or that the client’s
investment objective will be achieved.
Review of Accounts
Client Account Review
Client accounts are monitored on a periodic basis
by the client’s GWG Consultant and are subject to
review by the Baird Market Director or PWM
Supervision department supervisor (or his or her
respective designee) responsible for supervising
the client’s GWG Consultant. A client’s GWG
Consultant generally reviews the performance of
the client’s Account at least annually. However,
the client’s GWG Consultant may not review the
performance of a client’s SMAs managed by Other
Managers under the Baird SMA Network Program
or Dual Contract Program. Baird has designated
individuals who are responsible for monitoring a
client’s GWG Consultant with respect to the client
account’s trading activity and attempting to
ascertain whether client accounts within each
composite are being treated equitably.
Benchmarks shown in performance reports are for
informational purposes only. GWG’s selection and
use of benchmarks is not a promise or guarantee
that the performance of a client’s Account will
meet or exceed the stated benchmark. When the
client compares Account performance to the
performance of a market index, the client should
recognize that a market index merely reflects the
performance of a list of unmanaged securities
included in the index and the index performance
does not take into account management fees,
execution costs, and other expenses related to
investing for a client’s Account. The securities
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
included in a client’s Account generally do not
exactly mirror the securities included in the index.
performance
comparisons
The benchmarks used by Baird with respect to a
client’s SMA may differ from the benchmarks used
by the manager of the client’s SMA. As a result,
the
in Baird’s
performance reports may differ from reports
provided to clients directly by the investment
manager for the client’s SMA.
When preparing a client’s Account statements and
performance reports, GWG and Baird generally
rely upon third party sources, such as third party
pricing services. In some instances, such as when
Baird is unable to obtain a price for an asset from
a pricing service, Baird may obtain a price from
its trading desk or it may elect to not price the
asset. Obtaining a price from its trading desk may
present a conflict of interest. In some cases, Baird
obtains prices from the issuers or sponsors of
investment products in the client’s Account when
prices are not otherwise readily available. This
frequently occurs with respect to the valuation of
annuities and Complex Investment Products. If
the assets in the client’s Account are held by a
custodian other than Baird, Baird may also use
valuation information provided by the client’s
third party custodian.
is unreliable. Valuation data
calculation of
The performance of investment managers may,
under certain circumstances, be presented to
clients on a “gross” or “gross of fees” basis, which
means the performance results being presented
does not reflect the deduction of Advisory Fees
and other costs that clients have incurred and will
incur when retaining the manager. Had applicable
Advisory Fees and other costs been included in
the performance calculation,
the manager’s
performance results would have been lower than
the performance results presented. Documents
presenting a manager’s performance results on a
gross of
fees basis should contain certain
disclosures about the performance results being
presented. Clients are urged to review carefully
those disclosures because they contain important
information about
the
the
performance results. If a client is presented
performance information for a manager’s strategy
on a gross of fees basis and the client has an
Account managed by that manager pursuant to
that strategy,
the client should obtain a
performance report for the Account and review
that performance information carefully because
the performance report for the Account will reflect
the deduction of applicable Advisory Fees and
other costs.
GWG and Baird do not conduct a review of
valuation information provided by third party
pricing services, issuers, sponsors, or custodians,
and they do not verify or guarantee the accuracy
of such information. GWG and Baird do not accept
responsibility for valuations provided by third
parties that are inaccurate unless they have a
reason to believe that the source of such
valuations
for
investments, particularly annuities and Complex
Investment Products, may not be provided to
GWG or Baird in a timely manner, resulting in
valuations that are not current. The prices
obtained by GWG and Baird from the third party
pricing services, issuers, sponsors and custodians
may differ from prices that could be obtained
from other sources. Values used in account
statements and performance reports may vary
from prices received in actual transactions and
are not firm bids, offers or guarantees of any type
with respect to the value of assets in an Account,
and the values may be greater than the amount a
client would receive if the securities were actually
sold from the client’s Account.
If a client has assets held by a third party
custodian, the prices shown on a client’s Account
statements provided by the custodian could be
different from the prices shown on statements
and reports provided by GWG or Baird. See
“Custody” below for more information.
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after
they have
implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. As a result, the performance of a
Model Portfolio, as reported by the Model
Provider, will differ, perhaps in a materially
negative manner, from the actual performance
realized by Baird client Accounts pursuing the
Model Portfolio strategy. See “Additional Service
Information—Trading for Client Accounts—Trading
Practices of Investment Managers” above for
more information.
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
subcustodians to maintain custody of certain
client assets participating in the Cash Sweep
Program (described below) and securities that are
traded on foreign exchanges.
including, but not
limited
to,
role
in developing
the
these
fees
to
Client Referrals and Other
Compensation
GWG or Baird may provide compensation to
individuals who refer clients in some instances.
When applicable, the compensation paid is a
percentage of the client’s fee payments or the
value of the client’s Account. The amount of
compensation will vary, with the specific level
determined based upon consideration of various
the
factors
individual’s
client
relationship and the assets under management.
registered
Baird may pay
representatives of Baird and its Associated Parties
as well as to unassociated solicitors that have
entered into a written agreement with Baird.
to client Accounts on
and
Personal
Trading”
GWG and Baird and Baird’s Associated Parties and
associates may receive certain economic benefits
in connection with providing advisory services to
clients, which are described in the sections
entitled “Advisory Business—Additional Service
Information”, “Fees and Compensation”, “Other
Financial Industry Activities and Affiliations”,
“Code of Ethics, Participation or Interest in Client
and
Transactions
“Brokerage Practices” above.
from
Custody
Certain Services may require clients to custody
their Account assets at Baird. If Baird is the
custodian of a client’s assets, Baird will provide
certain custody services, including holding the
client’s Account assets, crediting contributions
and interest and dividends received on securities
held in a client’s Account, and making or
“debiting” distributions
the Account.
Information about account statements and
performance reports, if any, that GWG and Baird
provide to clients is contained under the heading
“Advisory Business–Consulting Services” and
“Review of Accounts” above.
GWG and Baird in their sole discretion may accept
into a client’s Account,
Held-Away Assets
that are held by another
including assets
custodian (a “third party custodian”). A client who
uses a third party custodian to hold Account
assets does so at the client’s risk. A client should
understand that GWG and Baird do not monitor,
evaluate or review any third party custodian
unless they otherwise agree to do so in writing.
The client should also understand that the client
will pay a custody fee to the third party custodian
in addition to the Advisory Fee. Baird may also
impose additional fees on Accounts with assets
held by a third party custodian due to the
increase in resources needed to administer those
Accounts. Further, such third party custody
limit the Services made
arrangements may
available to the client. In addition, a client should
understand that: (a) each third party custodian
has exclusive control over the investment options
made available
the
custodian’s platform; (b) GWG and Baird have no
authority or ability to add to, or remove from, a
custodian’s platform any investment option; (c)
any advice given by GWG or Baird with respect to
the Account is inherently limited by the options
available through a custodian’s platform; (d) GWG
or Baird may have provided different investment
advice with respect to the Account had they not
been limited to the investment options made
available through the custodian’s platform; and
(e) certain investments, such as mutual fund
shares, could be more or less expensive than if
the investment was obtained from Baird or
another firm. A client should further note that
GWG and Baird may not provide performance
review or reporting for Held-Away Assets. In
addition, a client who uses a third party custodian
is not eligible for cash sweep services offered by
Baird. Clients using a third party custodian are
encouraged to establish appropriate cash sweep
arrangements.
As custodian, Baird may hold a client’s Account
assets in nominee or “street” name, a practice
that refers
to securities and assets being
registered in Baird’s name or in a name that Baird
designates, rather than in a client’s name directly.
Baird will be the holder of record in those
instances.
A client who uses a third party custodian
authorizes GWG and Baird to give instructions to
the client’s custodian for all actions necessary or
incidental to the purchase, sale, exchange, and
delivery of securities held in the client’s Account.
Also, the client will receive account statements
directly from the client’s selected custodian. A
Baird may utilize one or more subcustodians to
provide for the custody of a client’s assets in
certain circumstances. For instance, Baird utilizes
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accordance with the terms of the SMA Service
selected by the client.
(e.g.,
client should carefully review those account
statements and
them with any
compare
statements provided by GWG or Baird. A client
should note that the prices shown on a client’s
Account statements provided by the custodian
could be different from the prices shown on
statements and reports provided by GWG or Baird
due to a variety of factors, including the use of
different valuation sources and accounting
methods
settlement date
trade or
accounting) by the custodian and Baird.
for
buying,
holding,
Investment Discretion
Investment Selection and Trading
Authorizations
A client
retains complete discretion over
investment selection and trading decisions with
respect to assets in a client’s Non-Discretionary
Service Accounts, and GWG and Baird will only
execute transactions for such Accounts pursuant
to the client’s instruction or authorization.
the client. Pursuant
If a client’s Account participates in a Discretionary
Service, the client’s advisory agreement provides
Baird and the client’s GWG Consultant, as
applicable, discretionary authority to manage the
assets in the client’s Account in accordance with
the terms of the Service selected by the client.
a
If a client grants discretionary authority over the
client’s Account to GWG, Baird, the client’s GWG
Consultant or the client’s investment manager,
the client’s advisory agreement authorizes GWG,
Baird, the client’s GWG Consultant and the client’s
investment manager, as applicable, to manage
the client’s Account and to make investment
decisions for the client’s Account, with the
authority to determine the amount, type and
exchanging,
timing
converting and selling securities and other assets
for the client’s Account, subject to the terms of
the Service selected by the client. The client’s
advisory agreement also grants to GWG, Baird,
the client’s GWG Consultant and the client’s
investment manager, as applicable, complete and
unlimited trading authorization and appoints them
as the client’s agents and attorneys-in-fact to
manage the assets in the client’s Account on the
client’s behalf, subject to the terms of the Service
selected by
to such
authorization and powers of attorney, GWG,
Baird, the client’s GWG Consultant and the client’s
investment manager may, in their sole discretion
and at the client’s risk, purchase, sell, exchange,
convert and otherwise trade the securities and
other assets in the client’s Account, as well as
arrange for delivery and payment in connection
with the above, and act on the client’s behalf in
all matters necessary or incidental to the handling
of the client’s Account without prior notice to the
client. Such trading authorizations and powers of
attorney, whether granted to GWG, Baird, the
client’s GWG Consultant or the client’s investment
manager, shall remain in full force and effect until
terminated by the client, the client’s investment
manager, GWG or Baird.
If a client’s Account participates in the GWG
Recommended Managers Service, the client’s
advisory agreement provides Baird and the
client’s GWG Consultant discretionary authority to
appoint investment managers to manage the
client’s Account and to terminate or replace
investment managers for the client’s Account for
any reason without prior notice to the client. If
GWG or Baird terminates an investment manager
from management
client’s GWG
of
Recommended Managers Service Account, the
client’s advisory agreement provides GWG and
Baird discretionary authority to manage the
assets in the client’s Account until a replacement
investment manager is selected or alternative
arrangements are made for the management of
the client’s assets.
include
If a client’s Account participates in an SMA
Service, the client’s advisory agreement provides
the investment manager selected to manage the
client’s Account, which may
an
Implementation Manager, discretionary authority
to manage the assets in the client’s Account in
Orders for the purchase and sale of securities in a
client’s Discretionary Service Accounts will
generally be executed by Baird, in its capacity as
broker-dealer, as further described under the
heading “Brokerage Practices” above, unless
Baird’s duty to seek to obtain best execution
otherwise requires or unless the client has
provided other instructions to Baird in writing.
GWG and Baird do not have discretionary
authority over the assets in a client’s SMAs that
are managed by an Other Manager and cannot
purchase or sell such assets without the consent
of the client or such Other Manager. The
investment manager for a client’s SMAs may
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
initiate securities transactions through Baird, in its
capacity as broker-dealer, as further described
under the heading “Brokerage Practices” above,
subject to the manager’s duty to seek to obtain
best execution, or unless a client has provided
other instructions in writing. Baird, as broker-
dealer, will rely upon any such instructions of any
investment managers selected to manage the
client’s Account.
Account, a client’s investment restrictions may
force GWG, Baird or the client’s investment
manager to sell such security at an inopportune
impacting Account
time, possibly negatively
performance and causing the client’s Account to
realize taxable gains or losses, which could be
significant. A client should also be aware that, if
the client’s Account holds any investment vehicle
(such as a mutual fund or ETF), any investment
restrictions the client places on the client’s
Account may not flow through to the securities
owned by that investment vehicle.
Should a client wish to impose or modify existing
restrictions, or the client’s financial condition or
investment objectives have changed, the client
should contact the client’s GWG Consultant.
If a client participates in an SMA Service, the
client authorizes GWG and Baird to share client’s
information with the Overlay Manager and any
Other Manager or
Implementation Manager
managing the client’s Account. The client also
authorizes and directs GWG and Baird to transmit
to the Overlay Manager and any such Other
Implementation Manager any
Manager or
instructions that the client may provide to GWG or
Baird to the extent necessary to carry out the
client’s instructions.
other
from
the services
Associated Investment Products
The Services allow GWG and Baird to use the
discretionary authority granted to them by a
client to invest the client’s Account in Associated
Investment Products. Baird and Associated Parties
receive investment management or advisory fees
Associated
compensation
or
they
for
Investment Products
provide, the amount of which generally increases
when clients invest in such products. The amount
of fees or other compensation received by Baird
and Associated Parties is generally described in
the prospectus or other offering or disclosure
documents for the investment product. Additional
information is also available on Baird’s website at
bairdwealth.com/retailinvestor.
Client Investment Restrictions
The Discretionary and the SMA Services offer a
client the ability to impose reasonable investment
restrictions on the management of an Account,
including the designation of particular securities
or types of securities that should not be
purchased for the client’s Account, but a client
may not require that particular funds or securities
(or types) be purchased for the client’s Account.
Reasonable investment restrictions requested by
a client will apply only to those assets over which
GWG, Baird or a client’s investment manager has
discretion.
investments
to
those
in Associated
GWG may also offer clients a socially responsible
investing (“SRI”) service, which assists a client in
restricting
that are
consistent with the client’s social investment
guidelines or objectives. Clients electing the SRI
service generally bear the cost of the SRI service
as it is generally included in the Advisory Fee.
accounts without
restrictions
By signing an advisory agreement with Baird or
participating in a Service, a client consents to
GWG and Baird investing all or a portion of the
Investment
client’s Account
their
Products. GWG and Baird will use
discretionary authority to invest the client’s
Account in Associated Investment Products when
they determine it to be in the client’s best interest
to do so. Generally, the criteria used by them in
deciding to invest in Associated Investment
Products are the same as those used in deciding
to invest a client’s assets in investment products
unassociated with Baird. For more information
about the criteria used by GWG and Baird, clients
should review the section of the Brochure entitled
“Methods of Analysis, Investment Strategies and
Risk of Loss” above. A client’s consent may be
revoked at any time.
In the event that a client’s Account is restricted
from investing in certain securities, GWG, Baird or
the client’s investment manager, as applicable,
will select such other replacement securities, if
any, as they deem appropriate. Accounts with
investment restrictions may perform differently
from
and
performance may be poorer. In addition, in the
event there is a change in the classification or
credit rating of a security held in the client’s
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limitation the Mutual Fund Share Class Policy that
is described above.
The Services allow Other Managers, including
Associated Managers, to use the discretionary
authority granted to them by a client to invest the
client’s Account in investment products managed
or sponsored by the Other Manager or any of its
associated firms, which may include Baird. The
Other Manager or its associated firms receive
investment management or advisory fees or other
compensation from such products for the services
they provide, the amount of which generally
increases when clients invest in such products.
A client should understand that, the client may
not hold Advisory Class Shares in a non-Advisory
Account and that the client may not be able to
hold certain Advisory Class Shares in an account
held at another firm. Upon the termination of a
Service for an Account or the closure of an
Account for any reason, GWG and Baird may
convert or exchange the Advisory Class Shares
held in the Account to an appropriate non-
Advisory Class Shares issued by the same fund,
or, if an appropriate non-Advisory Class Shares is
not available, GWG and Baird may redeem or sell
such Advisory Class Shares.
By signing an advisory agreement with Baird or
participating in a Service, a client consents to
each Other Manager, including each Associated
Manager, managing client’s Account investing all
or a portion of the client’s Account in investment
products managed or sponsored by the Other
Manager or any of its associated firms, which may
include Baird. Each Other Manager is responsible
for providing to the client information about the
amount of fees received by the Other Manager
and its associated firms and the criteria used by
the Other Manager in deciding to invest in
products managed or sponsored by the Other
Manager or any of its associated firms. A client
should contact the Other Manager and review the
Other Manager’s Form ADV Part 2A Brochure for
more information. A client’s consent may be
revoked at any time.
Voting Client Securities
Non-Discretionary Accounts
With respect to any Accounts over which the
client retains discretionary investment authority,
a client retains the right to vote proxies with
respect to the securities held in such Accounts.
Accordingly, the client is responsible for voting
proxies and otherwise addressing all matters
submitted for consideration by security holders,
and GWG and Baird are under no obligation to
take any action or render any advice regarding
such matters. The client’s GWG Consultant may,
upon the client’s request, provide advice on proxy
voting or what other action the client could take.
Investment Policy Statements
GWG and Baird will not review, monitor, accept or
adhere to an investment policy statement or
similar document that was not prepared by GWG
or Baird, unless they otherwise specifically agree
to do so in writing. Adherence to any such
investment policy statement or similar document
is solely a client’s responsibility.
for use
instances. For
Separately Managed Accounts
Under the GWG Recommended Managers Service,
Baird SMA Network Program and Dual Contract
Program, a client may retain the right to vote
proxies with respect to the securities held in the
client’s Account, or, in most instances, the client
may delegate such right to the investment
manager selected to manage the client’s Account
(which may include Baird, the Overlay Manager or
an Implementation Manager). A client may select
either option by making the appropriate election
in the client’s advisory agreement (and in the
case of a dual contract arrangement under the
Dual Contract Program, by providing proper
instructions to the manager directly). Some
managers do not offer proxy voting services in
connection with certain strategies, such as option
strategies. Clients pursuing those strategies will
automatically retain the right to vote proxies in
those
information about a
manager’s voting policies and procedures, clients
Conversion, Exchange or Sale of Certain
Investments
By participating in a Service, a client authorizes
GWG and Baird to convert or exchange any
shares of mutual funds and other Funds held in
the client’s Account to a class of shares of the
same
fund, such as advisory class shares,
institutional class shares, financial intermediary
class shares, or another class of shares primarily
designed
advisory programs
in
(collectively, “Advisory Class Shares”), to the
extent made available by the mutual fund or
other Fund in accordance with policies established
by Baird from time to time, including, without
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
should review the manager’s Form ADV Part 2A
Brochure.
Discretionary Services
Under the GWG Investment Management Service,
a client may retain the right to vote proxies with
respect to the securities held in the client’s
Account, or a client may delegate such right to
Baird.
If a client retains proxy voting authority, Baird will
forward proxy materials that Baird actually
receives to the client. The client will then be
solely responsible for analyzing the materials and
casting the vote.
If a client delegates voting authority to Baird,
Baird will vote proxies solicited by, or with respect
to, securities held in the client’s Account for the
exclusive benefit of the client and in accordance
with policies and procedures adopted by Baird.
necessarily correspond with the opinions of GWG
Consultants. In the event the client’s GWG
Consultant believes the ISS recommendation is
not in the best interest of the client, the GWG
Consultant will bring the issue to Baird’s Proxy
Voting Sub-Committee through a proxy challenge
process. The Sub-Committee will
then be
responsible for determining how the vote will be
cast. The decision made by the Proxy Voting Sub-
Committee on the proxy challenge applies to all
advisory accounts managed by
the GWG
Consultant (or team of GWG Consultants), unless
the client has directed Baird to utilize specific
voting guidelines (e.g., Taft-Hartley guidelines).
For those matters for which the independent
proxy voting service does not provide a specific
voting recommendation, each GWG Consultant
will cast the vote in a manner he or she believes
is in the best interest of clients. The votes cast for
a client’s Account may differ from those votes
cast for other Baird clients based on differing
views of GWG Consultants and other Baird
portfolio managers.
contacting
Baird has adopted written policies and procedures
that are reasonably designed to ensure that it
votes client securities in the best interests of
clients. Those procedures address material
conflicts of interest that may arise between
Baird’s interests and those of its clients. Although
a description of Baird’s proxy voting policies and
procedures is provided below, Baird will furnish a
copy of its proxy voting policies and procedures to
clients upon their request. Additionally, clients
may obtain information on how Baird actually
voted proxies with respect to the securities held in
their GWG
their accounts by
Consultant or by calling (414) 765-3500.
Baird uses ISS’s electronic vote management
system to cast votes on behalf of clients. In
connection with Baird’s use of that system, ISS
pre-populates how client votes should be cast
based upon ISS’s voting recommendations. The
system allows Baird to change the pre-populated
vote (to the extent permitted by Baird’s proxy
voting policies) up until a certain time prior to the
applicable meeting (the “voting cut-off time”).
Baird’s proxy voting policies are designed to
address situations when additional information
becomes available after the votes are pre-
populated in the system and before the voting
cut-off time. However, there is no guarantee that
all information that could affect Baird’s proxy
voting decision will be received or considered by
Baird prior to a vote being cast.
interests. Baird utilizes
governance
services,
(or
voting
recommendations.
In situations in which a client has delegated to
Baird voting authority with respect to securities in
the client’s Account, Baird will vote proxies in a
manner that Baird believes is consistent with the
client’s best
an
independent provider of proxy voting and
currently
corporate
Institutional Shareholder Services (“ISS”), to
analyze proxy materials and votes and make
independent
ISS
provides proxy voting guidelines regarding its
position on various matters presented by
companies to their shareholders for consideration.
Baird will typically vote shares in accordance with
the recommendations made by ISS. However,
ISS’s guidelines are not exhaustive, do not
address all potential voting issues, and do not
The proxy voting policies and procedures also
address instances in which Baird’s interests may
appear to conflict with client interests, such as
when Baird or an affiliate of Baird is managing or
administering
to manage or
seeking
administer) a corporate retirement, pension or
employee benefit plan or providing (or seeking to
provide) advisory or other services to a company
whose management is soliciting proxies. In such
instances, there may be a concern that Baird
would be inclined to vote in favor of management
because of Baird’s relationship or pursuit of a
relationship with the company. In situations
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
authority, direct or implicit, and accept no
responsibility for taking any action or rendering
any advice with respect to the voting of proxies
related to securities held in a client’s Accounts.
interests of
Providing Baird Voting Instructions
As mentioned above, Baird may be the holder of
record for certain securities in a client’s Account.
If the client retains voting authority over such
securities (or delegates such authority to party
other than Baird), and a proxy is solicited with
respect to any such securities, the client (or other
authorized party) will need to provide voting
instructions to Baird. To the extent the client (or
other authorized party) does not provide timely
voting instructions, Baird will vote such securities
to the extent permitted by law and in compliance
with the rules of the New York Stock Exchange
and the SEC relating to such matters.
where there is a potential conflict of interest,
Baird’s
Proxy Voting Sub-Committee will
determine the nature and materiality of the
conflict. If the conflict is determined to not be
material, the Sub-Committee will vote the proxy
in a manner the Sub-Committee believes is in the
best
the client and without
consideration of any benefit to Baird or its
affiliates. If the potential conflict is determined to
be material, Baird’s Proxy Voting Sub-Committee
will take one of the following steps to address the
potential conflict: (1) cast the vote in accordance
with the recommendations of ISS or other
independent third party; (2) refer the proxy to
the client or to a fiduciary of the client for voting
purposes; (3) suggest that the client engage
another party to determine how the proxy should
be voted; (4) if the matter is not addressed by
ISS, vote in accordance with management’s
recommendation; or (5) abstain from voting.
Legal Proceedings and Corporate Actions
Generally, none of GWG, Baird or any Other
Manager responsible for managing all or a portion
of the assets in a client’s Account will render
advice or take action on a client’s behalf with
respect to securities that are or were held in the
client’s Account, or the issuers thereof, which go
into default or become the subject of legal
proceedings, such as class action claims, defaults
or bankruptcies. Also, they may or may not vote
or advise clients on other corporate actions, like
tender offers, that are not solicited by a proxy
statement. At a client’s request, Baird will forward
information that Baird actually receives to the
client.
While Baird uses its best efforts to vote proxies,
there are instances when voting is not practical or
is not, in Baird’s or GWG Consultants’ view, in the
best interest of clients. For example, casting a
vote on a foreign security may involve additional
costs or may prevent, for a period of time, sales
of shares that have been voted. Also, when a
client has entered into a securities lending
program, Baird generally will not seek to recall
the securities on loan for the purpose of voting
the securities; however, Baird reserves the right
to recall the shares on loan on a best efforts basis
if the client’s GWG Consultant becomes aware of
a proxy proposal where the proxy vote is
materially important to the client’s Account.
In addition to the services described above, Baird
has engaged ISS for vote execution and record-
keeping services.
Financial Information
GWG does not require or solicit prepayment of
more than $1,200 in fees per client six months or
more in advance and, thus, has not included a
balance sheet of Baird’s most recent fiscal year.
Neither Baird nor GWG is aware of any financial
condition that is reasonably likely to impair their
ability to meet their contractual commitments to
clients, nor has either been the subject of a
bankruptcy petition at any time during the past
ten years.
Other Proxy Voting Information
Clients wishing to direct particular votes once
they have granted Baird discretionary voting
authority may do so by contacting their GWG
Consultant. However, if Baird has been granted
discretionary voting authority, neither GWG nor
Baird will provide a client with notice that Baird
has received a proxy solicitation, nor will they
consult with the client before casting a vote,
unless the client otherwise directs them to do so.
Except to the extent a client has delegated proxy
voting authority to Baird, GWG and Baird have no
Special Considerations for Retirement
Accounts
Each Retirement Account Fiduciary of a client
should understand that GWG or Baird may invest
for the client, recommend that the client invest in,
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment
other
compensation
related
to
to
the applicable
or make available
to plan
for
participants, Associated Investment Products, that
Baird and its Associated Parties will receive fees
such
or
investments, and that they will retain such
compensation
the extent permitted by
applicable law, rule or regulation, including,
without limitation, Department of Labor (“DOL”)
Prohibited Transaction Exemption (“PTE”) 77-4,
DOL PTE 2020-02 or other advisory opinions
issued by the DOL.
investment advisory services they provide to the
client and, if applicable, the investment advisory
and other similar fees paid by the Associated
Investment Product to Baird or its Associated
Parties with respect to the services Baird or any of
its Associated Parties provides to the Associated
Investment Product is the difference between the
Advisory Fee disclosed in the client’s advisory
investment
agreement and
management, investment advisory and other
similar fees detailed in the applicable prospectus
or other offering or disclosure documents for the
Associated Investment Product.
that
directed
the
fiduciary
Fiduciary
such Fiduciary
is
that
for complying with all
Parties
from
transactions, and
the duty
broker-dealer,
for
the Associated
and
terminating
monitoring
a
If the client’s Account is a Retirement Account
and if GWG is directed to implement a directed
brokerage arrangement for the Account, each
Retirement Account Fiduciary of the client should
understand:
brokerage
the
arrangement must be for the exclusive benefit of
participants and beneficiaries of the Retirement
Account; and
responsibilities
discussed in ERISA Technical Bulletin 86-1. Each
should also
Retirement Account
solely
understand
responsible
fiduciary
in ERISA Technical
responsibilities discussed
Bulletin 86-1, including, without limitation, the
duty to make an initial determination that the
directed broker-dealer is capable of providing best
execution for the client’s brokerage transactions,
the duty to monitor the services provided by the
directed broker-dealer so as to assure that the
client has received best execution of the client’s
brokerage
to
determine that the commissions paid by the client
and any other fees or costs incurred by the client
are reasonable in relation to the value of the
brokerage and other services received by the
client. The client and each Retirement Account
Fiduciary of the client should also understand that
the client and the client’s Retirement Account
Fiduciaries are solely responsible for engaging a
directed
its
performance
directed
brokerage arrangement, and that GWG and Baird
are not responsible for determining whether a
directed broker-dealer is capable of providing best
execution.
To the extent Baird and its Associated Parties rely
upon PTE 77-4, each Retirement Account
Fiduciary should also understand that when GWG
or Baird invests the assets of a Retirement
Account in an Associated Investment Product that
pays investment advisory fees to Baird or any of
its Associated Parties, Baird and its Associated
Parties will receive such investment advisory fees
in accordance with the terms of DOL PTE 77-4,
and, as required thereby, GWG and Baird will
waive the asset-based Advisory Fees on that
portion of the assets invested in the Associated
Investment Product for such period of time so
invested or Baird will offset the investment
advisory fees received by Baird or any of its
the
Associated
Associated
Investment Product against
the asset-based
Advisory Fee that GWG and Baird charge to the
client. For the purpose of complying with the
terms of DOL PTE 77-4, the client and each
Retirement Account Fiduciary of
the client
acknowledge in the client’s advisory agreement
that: (i) the investment in Associated Investment
Products for the client’s Account is appropriate
because of, among other things, the investment
goals, redeemability, liquidity, and diversification
of those products; (ii) subject to the terms of the
applicable Service, all assets of the client’s
Account may be invested in one or more of the
Associated Investment Products; (iii) the client
and such Retirement Account Fiduciary received
prospectuses or other offering or disclosure
documents
Investment
Products that may be used in connection with the
Account, each of which include a summary of all
fees that may be paid by the Associated
Investment Products to Baird or its Associated
Parties; and (iv) the client received information
concerning
the nature and extent of any
differential between the rate of such Associated
Investment Product fees and the Advisory Fees
payable by the client. The differential between the
fees to be charged by GWG and Baird for the
If the client’s Account is a Retirement Account,
the client and each Retirement Account Fiduciary
of the client should note that the advisory
agreement authorizes Baird, in its capacity as
broker-dealer, to effect or execute securities
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
than
the
client
transactions for the client’s Account and to
receive commissions for such services, subject to
DOL PTE 86-128. In order to assist the client and
each Retirement Account Fiduciary of the client
with the determination as to whether such
authorization should be made, GWG will provide
the client with a copy of DOL PTE 86-128 and the
form to be used to terminate such authorization,
as well as the description of Baird’s brokerage
placement practices, which is set forth below.
GWG also will provide such other reasonably
available information that the client may request
for such purpose.
client’s GWG Consultant.
compensation
selected
if
investment managers, funds or other products
not associated with Baird and thus Baird may
have an incentive to offer Associated Investment
Products and Services; (b) Baird makes available
to the client investment managers, funds and
products not associated with Baird and the client
may obtain additional information about such
unassociated investment managers, funds or
products at any time by contacting the client’s
GWG Consultant; and (c) the client is free to
choose another investment option or participate
in another Baird advisory program that does not
use investment managers, funds or products
associated with Baird at any time by contacting
the
For more
information about Associated Investment Products
and Services, please see “Other Financial Industry
Activities and Affiliations” above.
likelihood of price
in certain
funds. Baird may place orders
When placing orders for securities transactions for
clients as a broker-dealer pursuant to DOL PTE
86-128, Baird has an obligation to use reasonable
diligence to ascertain the best market for the
subject security and to buy or sell in such market
so that the resultant price to the client is as
favorable as possible under prevailing market
conditions. Baird routes or places client orders to
various market makers, exchanges and other
execution venues based on their quality of
execution and execution capabilities in order to
obtain the best possible price and speed of
for clients. Baird selects market
execution
makers, exchanges and other execution venues
based on the size of the order, the trading
characteristics of the particular security, speed of
improvement,
execution,
availability of efficient automated transaction
processing, guaranteed automatic execution level
and other qualitative
factors. Order routing
decisions are not based on the availability of
payment for order flow or other remuneration,
although Baird receives payments for order flow
or other remuneration
instances.
Additional information about Baird’s routing of
equity orders is available on Baird’s website at
bairdwealth.com/retailinvestor. Baird does not
place orders with market makers or other third
parties for the purpose of compensating such
firms for their efforts in marketing Baird-affiliated
for
mutual
securities transactions with third party broker-
dealers and other firms that provide research
products and services to Baird.
If a client’s Account is a Retirement Account and if
the client is selecting Associated Investment
Products and Services, each Retirement Account
Fiduciary of the client understands and agrees
that in making such selection: (a) Baird and its
Associated Parties may receive higher aggregate
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Appendix A
Associated Investment Products and Services
Entity Type
Name
Relationship
Baird Advisors1
Baird Department
Baird Equity Asset Management1
Baird Department
Chautauqua Capital Management1
Baird Department
55I, LLC (d/b/a 55ip, “55ip”)
Associated
Investment Advisor
GAMMA Investing, LLC
Affiliated
Greenhouse Fund GP LLC
Related
Greenhouse Funds LLLP
Related
LoCorr Fund Management, LLC
Related
Reinhart Partners, LLC
Affiliated
Riverfront Investment Group, LLC
Affiliated
Dual Registrant2
Strategas Securities, LLC
Affiliated
Trust Company
Baird Trust Company1
Affiliated
Baird Funds, Inc.1
Affiliated
Bridge Builder Trust (Baird series)
Affiliated
Mutual Fund
Financial Investors Trust (Riverfront series)
Affiliated
LoCorr Investment Trust
Related
Managed Portfolio Series Trust (Reinhart series)
Affiliated
Pace® Select Advisors Trust (Baird Series)
Affiliated
Advisors’ Inner Circle Fund III (Strategas series)
Affiliated
ETF
ALPS ETF Trust (Riverfront Series)
Affiliated
First Trust Exchange-Traded Fund III (Riverfront series)
Affiliated
Automated Quantitative Analysis (AQA®) Portfolio Series
Affiliated
UIT
Dividend Income Trust (DIT) Series
Affiliated
Strategas Trust, Series 1-1
Affiliated
CIT
Reliance Trust Institutional Retirement Trust (Baird/Chautauqua series)
Affiliated
Greenhouse Master Fund LP
Related
Hedge Fund
Greenhouse Onshore Fund LP
Related
Greenhouse Overseas Fund Ltd.
Related
Chautauqua Global Growth Equity QP Fund, LP
Affiliated
Private Fund
Chautauqua International Growth Equity QP Fund, LP
Affiliated
Chautauqua Series Fund, LLC
Affiliated
Appendix A - 1
BGWG F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Venture Partners Management Company III, LLC
Baird Venture Partners III Limited Partnership
Affiliated
BVP III Affiliates Fund Limited Partnership
BVP III Special Affiliates Limited Partnership
Baird Venture Partners Management Company IV, LLC
Baird Venture Partners IV Limited Partnership
Affiliated
BVP IV Affiliates Fund Limited Partnership
BVP IV Special Affiliates Limited Partnership
Baird Venture Partners Management Company V, LLC
Baird Venture Partners V Limited Partnership
Affiliated
BVP V Affiliates Fund Limited Partnership
BVP V Special Affiliates Fund Limited Partnership
Baird Capital Partners Management Company V, LLC
Baird Capital1,3
Baird Capital Partners V Limited Partnership
Affiliated
Investment Advisor
BCP V Affiliates Fund Limited Partnership
Private Equity Fund
BCP V Special Affiliates Limited Partnership
Baird Capital Management Company, LLC
Baird Venture Partners GP VI, LLC
Baird Venture Partners VI LP
Affiliated
BVP VI Affiliates Fund LP
BVP VI Special Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management I LP
Baird Capital Global Fund I LP
Affiliated
Baird Capital Global Fund I-DE LP
BCGF I Special Affiliates LP
BCGF I Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management II LLC
Baird Capital Global Fund II Limited Partnership
Affiliated
BCGF II Affiliates Fund Limited Partnership
BCGF II Special Affiliates Limited Partnership
Appendix A - 2
BGWG F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Capital Management Company, LLC
Baird Capital Global GP III LLC
Baird Capital Global Fund III LP
Affiliated
Baird Capital1,3
BCGF III Affiliates Fund LP
Investment Advisor
BCGF III Special Affiliates LP
Private Equity Fund
Baird Capital Partners Europe Limited4
Baird Capital Partners Europe II LP
Affiliated
Baird Capital Partners Europe II Special Affiliates LP
The Growth Fund
Baird Principal Group Management Company I, LLC
Baird Principal Group5
Baird Principal Group Partners Fund I Limited Partnership
Investment Advisor
Baird Principal Group Management Company II, LLC
Affiliated
Private Equity Fund
Baird Principal Group Partners Fund II Limited Partnership
Baird Principal Group Management Company, LLC
Baird Principal Group Partners Fund III, LP
Holding Company
Sagard Holdings Management, Inc.6
Associated
1. Participates in a Baird PWM Referral Program that pays compensation to GWG Consultants for eligible referrals.
2. Registered with the SEC as a broker-dealer and investment advisor.
3. Baird Capital, Baird’s private equity business.
4. Baird Capital Partners Europe Limited, an English limited company, is regulated and authorized by the Financial
Conduct Authority.
5. Baird Principal Group, a group within Baird that has private equity funds only available to Baird employees.
6. Baird has a contractual relationship with and a small minority investment in Sagard Holdings Management, Inc., a
holding company for various financial services businesses whose investment products are made available to clients under
the Services. See “Other Financial Industry Activities and Affiliations—Certain Relationships and Arrangements—Baird and
Associated Parties” above for more information.
Appendix A - 3
BGWG F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Additional Brochure: BAIRD GENERATIONAL WEALTH GROUP - WRAP (2026-03-27)
View Document Text
Baird Generational Wealth Group
Wrap Fee Program Brochure
March 27, 2026
Baird Generational Wealth Group
777 East Wisconsin Avenue
Milwaukee, Wisconsin 53202
Toll Free: 800-792-2473
www.bairdfamilywealthgroup.com
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue
Milwaukee, WI 53202
1-800-792-2473
rwbaird.com
Member FINRA & SIPC
SEC File No. 801-7571
This wrap fee program brochure (“Brochure”) provides information about the qualifications and
business practices of Robert W. Baird & Co. Incorporated (“Baird”) and Baird Generational Wealth
Group (“GWG”), a team within Baird’s Private Wealth Management department. Clients should
carefully consider this information before becoming a client of GWG. If you have any questions about
the contents of this Brochure, please contact GWG at the toll-free phone number listed above. The
information contained in this Brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority. Additional information
about Baird is available on the SEC’s website at www.adviserinfo.sec.gov.
Material Changes
Baird Generational Wealth Group (“GWG”), a team within the Private Wealth Management department of
Robert W. Baird & Co. Incorporated (“Baird”), updated its Form ADV Part 2A wrap fee program brochure
(the “Brochure”) on March 27, 2026. The following summary discusses the material changes that GWG has
made to the Brochure since March 21, 2025, the date of the last annual update to the Brochure.
• In January 2026, Baird’s direct parent corporation, Baird Financial Corporation (“BFC”), made a
significant minority investment in Reinhart Partners, LLC (“Reinhart”), an investment advisor that offers
investment products and services through the Programs. As a result of the investment transaction, Baird
and Reinhart are affiliated, providing Baird a financial incentive to use, select or recommend Reinhart
investment products and services.
“Additional
Information—Other Financial
• In September 2025, Baird entered into a strategic partnership with Sagard Holdings Management, Inc.
(“Sagard”). Baird’s direct parent corporation, BFC, acquired a minority ownership interest in Sagard and
the right to appoint a member to Sagard’s board of directors. Baird agreed to use best efforts,
consistent with its fiduciary duties and other regulatory responsibilities, to offer investment products
managed or sponsored by affiliates of Sagard deemed suitable by Baird for its PWM clients, providing
Baird a financial incentive to recommend such investment products. See the Section of the Brochure
entitled
Industry Activities and Affiliations—Certain
Relationships and Arrangements—Baird and Associated Parties” for more information.
• Baird updated its description of the DC Program. The DC Program is designed to accommodate a client
who wishes to independently select an investment manager not available in the GWG Recommended
Managers Service or BSN Program to manage the assets in the client’s Account. The Program is also
designed for a client that wants to independently select a manager and negotiate the manager’s
Portfolio Fee rate directly with the manager. Certain managers offer lower Portfolio Fee rates to clients
through the DC Program compared to the BAM, GWG Recommended Managers, or BSN Programs. A
client considering an SMA Strategy should discuss with client’s GWG Consultant SMA Strategy
availability and the different Portfolio Fee rates, costs, and the types and levels of service provided in
connection with the different Programs. If a client has decided to participate in the DC Program, upon
the client’s request, the client’s GWG Consultant may assist the client with the client’s negotiation with
the manager of the Portfolio Fee rate for the applicable SMA Strategy. The Portfolio Fee negotiated by
the client could be higher or lower than the Portfolio Fee that applies to the same SMA Strategy that is
available through other Programs. The client is ultimately responsible for understanding the differences
between the SMA Programs, deciding to participate in the DC Program, selecting the SMA Strategy, and
negotiating and agreeing to the Portfolio Fee rate.
• Baird updated information about tax management and direct indexing strategies, including the
associated limitations and risks. See the Sections of the Brochure entitled “Services, Fees and
Compensation—Additional Service Information—Tax Management Services” and “Portfolio Manager
Selection and Evaluation—Methods of Analysis, Investment Strategies and Risk of Loss—Investment
Strategies” for more information.
• Baird provided additional information about possible tax consequences of a client’s investment activities.
See the Section of the Brochure entitled “Services, Fees and Compensation—Additional Service
Information—Legal and Tax Considerations” for more information.
• Baird updated the rates of Portfolio Fees charged by managers under the Services. See the Section of
the Brochure entitled “Services, Fees and Compensation—Advisory Fees” for more information.
• Baird updated information about Baird’s regulatory assets under management. See the Section of the
Brochure entitled “Portfolio Manager Selection and Evaluation—Selection and Evaluation—Advisory
Business” for more information.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• Baird updated its disclosures about the research, information and tools used by Baird PWM home office
investment professionals and GWG Consultants when formulating investment advice, which may include
the use of artificial intelligence (“AI”) tools, and the related risks. See the Section of the Brochure
entitled “Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and
Risk of Loss—Methods of Analysis” for more information.
• Baird included a description of the PWM Stock Opportunities List. See the Section of the Brochure
entitled “Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and
Risk of Loss—Methods of Analysis—Certain Eligible Product Lists” for more information.
• Baird updated investment risk information related to information security, cybersecurity, and other
technology‑related events, issuers’ use of AI, investments in digital assets, such as cryptocurrencies,
and those associated with recent events, such as those associated with the U.S. administration’s policy
initiatives, inflation, conflicts in Iran and the Middle East, the war between Ukraine and Russia, and the
strain in relationships between the U.S. and other countries. See the Section of the Brochure entitled
“Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and Risk of
Loss—Principal Risks” for more specific information.
• In March 2026, Baird entered into an Offer of Settlement with the Massachusetts Securities Division to
settle a regulatory matter relating to the timing of state investment adviser representative registration
approvals for two of Baird’s Financial Advisors located in Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals provided investment advisory services before their
Massachusetts registrations were completed as a form was missing from their application materials. 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.
• Baird updated information about firms affiliated with, related to, or otherwise associated with Baird. See
the Section of the Brochure entitled “Additional Information—Other Financial Industry Activities and
Affiliations” and Appendix A to the Brochure for more information.
A client should note that the foregoing summary only discusses material changes made to the Brochure
since March 21, 2025. The updated Brochure contains changes that are not listed above.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Table of Contents
Services, Fees and Compensation ................................................................... 1
The Client-Baird Fiduciary Relationship ............................................................ 1
Summary of GWG’s Services .......................................................................... 1
Consulting Services ...................................................................................... 5
Financial Strategy ................................................................................... 5
Investment Strategy ............................................................................... 6
Risk Management ................................................................................... 6
Tax Planning .......................................................................................... 6
Estates and Trusts .................................................................................. 7
Philanthropic Planning ............................................................................. 7
Family Education .................................................................................... 7
Sounding Board ...................................................................................... 7
Data Aggregation .................................................................................... 7
Discretionary Services ................................................................................... 8
GWG Investment Management Service ...................................................... 8
SMA Services ............................................................................................... 9
GWG Recommended Managers Service ...................................................... 9
Baird SMA Network Program .................................................................. 11
Dual Contract Program .......................................................................... 13
Other SMA Strategy Information ............................................................. 14
Additional Service Information ..................................................................... 15
Investment Discretion ........................................................................... 15
Trading for Client Accounts .................................................................... 17
Complex Strategies and Complex Investment Products .............................. 23
Permitted Investments .......................................................................... 26
Unsupervised Assets ............................................................................. 28
Special Considerations for the Services .................................................... 28
Goal Management ................................................................................. 28
Tax Management Services ..................................................................... 29
Investment Objectives ........................................................................... 32
Mutual Fund Share Class Policy ............................................................... 33
Custody Services .................................................................................. 34
Cash Sweep Program ............................................................................ 35
Trust Services Arrangements .................................................................. 36
Margin Loans ........................................................................................ 37
Securities-Based Lending Program .......................................................... 38
Other Non-Advisory Services .................................................................. 38
Client Responsibilities ............................................................................ 38
Retirement Accounts ............................................................................. 39
Legal and Tax Considerations ................................................................. 39
Advisory Fees ............................................................................................ 40
Fee Options and Fee Schedule ................................................................ 40
Service Account Minimums ..................................................................... 41
Calculation and Payment of Advisory Fees ................................................ 42
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Obtaining Services Separately: Brokerage or Advisory? Factors
to Consider ...................................................................................... 44
Advisory Fee Payments to Baird, GWG Consultants and
Investment Managers ........................................................................ 45
Other Fees and Expenses ............................................................................ 47
Cost and Expense Information for Certain Investment Products .................. 47
Additional Account Fees and Charges ...................................................... 47
Other Fees and Charges ........................................................................ 47
Compensation Received by GWG and Baird .................................................... 48
Account Requirements and Types of Clients .................................................. 49
Opening an Account .................................................................................... 49
Certain Account Requirements ..................................................................... 49
Minimum Account Size ........................................................................... 49
Account Contributions and Withdrawals ................................................... 49
Liens and Use of Account Assets as Collateral ........................................... 50
Electronic Delivery of Documents ............................................................ 51
Termination of Accounts .............................................................................. 51
Types of Clients.......................................................................................... 52
Portfolio Manager Selection and Evaluation .................................................. 52
Selection and Evaluation ............................................................................. 52
GWG Recommended Managers Service .................................................... 52
Baird SMA Network and Dual Contract Programs ....................................... 53
GWG Investment Management Service .................................................... 54
Oversight of the Services ....................................................................... 54
Performance Calculation .............................................................................. 54
Portfolio Management by GWG, Baird and Associated Managers ....................... 55
Advisory Business ....................................................................................... 56
Performance-Based Fees and Side-By-Side Management ................................. 57
Methods of Analysis, Investment Strategies and Risk of Loss ........................... 57
Investment Strategies ........................................................................... 57
Methods of Analysis .............................................................................. 65
Program Portfolio Strategies ................................................................... 74
Principal Risks ...................................................................................... 74
Voting Client Securities ............................................................................... 93
Non-Discretionary Accounts ................................................................... 93
Separately Managed Accounts ................................................................ 93
Discretionary Services ........................................................................... 93
Other Proxy Voting Information .............................................................. 95
Providing Baird Voting Instructions.......................................................... 95
Legal Proceedings and Corporate Actions ................................................. 95
Client Information Provided to Portfolio Managers ....................................... 95
Client Contact with Portfolio Managers ......................................................... 95
Additional Information .................................................................................. 96
Disciplinary Information .............................................................................. 96
Other Financial Industry Activities and Affiliations ........................................... 98
Baird’s Broker-Dealer Activities ............................................................... 98
Certain Relationships and Arrangements .................................................. 98
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Relationships and Arrangements with Investment Managers ...................... 100
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading ................................................................................... 101
Code of Ethics ..................................................................................... 101
Participation or Interest in Client Transactions ......................................... 101
Review of Accounts .................................................................................... 108
Client Account Review .......................................................................... 108
Account Statements and Performance Reports ......................................... 108
Client Referrals and Other Compensation ..................................................... 109
Financial Information ................................................................................. 109
Special Considerations for Retirement Accounts ............................................ 110
Associated Investment Products and Services ............................. Appendix A-1
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
contain
information about
and
retirement
accounts, which
adviser under the Investment Advisers Act of
1940, as amended (the “Advisers Act”). GWG and
Baird are deemed to have a fiduciary relationship
with a client when providing the investment
advisory services that are described in this
Brochure. That means that GWG and Baird are
required to act in the best interest of the client
when providing investment advisory services.
From time to time GWG and Baird may engage in
certain business practices or may
receive
compensation or other benefits that create a
potential for conflict between the interests of
clients and the interests of GWG and Baird. GWG
and Baird generally address potential conflicts of
interest by disclosing them to clients through
documents provided to clients, including, without
limitation, this Brochure, Brochure supplements
individuals
that
providing investment advice to clients and the
services they provide, and the agreements clients
enter into with GWG and Baird. In addition, Baird
has adopted internal policies and procedures for
GWG and Baird that require them to: provide
investment advice that is suitable for advisory
clients (based upon the information provided by
such clients); make full disclosure of all potential,
material conflicts of interest; act with utmost care
and good faith in dealings with advisory clients;
and seek to obtain “best execution” of advisory
client transactions. The specific business practices
that create potential conflicts of interest with
clients and additional measures used by GWG and
Baird to address them are discussed in other
sections of this Brochure.
(“IRC”)
(collectively,
A client should note that registration as an
investment adviser does not imply a certain level
of skill or training.
including
Services, Fees and Compensation
This Brochure describes some of the investment
advisory services that Robert W. Baird & Co.
Incorporated (“Baird”) offers to its clients through
Baird Generational Wealth Group (“GWG”), a
team of Baird Financial Advisors
(“GWG
Consultants”) within Baird’s Private Wealth
Management (“PWM”) department. Baird and
GWG offer other investment advisory services not
described in this Brochure. Separate brochures
describe those other investment advisory services
and discuss the terms and conditions, fees and
costs and potential conflicts of interest associated
with those services. This Brochure also references
other documents that contain additional important
information about Baird. Those documents
describe the types of investment products and
services that Baird makes available to clients,
including the terms, conditions, fees, costs, risks,
and conflicts of interest applicable to those
investment products
services. Those
documents are available on Baird’s website at
bairdwealth.com/retailinvestor. Included on that
website is Baird’s Client Relationship Booklet,
contains Baird’s Form CRS Client
which
and Baird’s Client
Relationship Summary
Relationship Details document. The Client
Relationship Booklet also contains an important
disclosure document for retirement investors that
have
include
employee pension benefit plan accounts that are
subject to the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”) and
individual retirement accounts (“IRAs”) that are
subject to the Internal Revenue Code of 1986, as
“Retirement
amended
Accounts”). A client of Baird should have already
received a copy of the Client Relationship Booklet.
A client or prospective client who wishes to obtain
a brochure for another investment advisory
service provided by Baird, or a paper copy of any
of the other documents referenced
in this
Brochure,
the Client Relationship
Booklet, should contact a GWG Consultant or call
Baird toll-free at 1-800-792-2473.
The information contained in this Brochure is
current as of the date above and is subject to
change at Baird’s discretion. Please retain this
Brochure for your records.
Summary of GWG’s Services
This Brochure describes certain
investment
advisory programs and services that GWG and
Baird offer to clients (“Services”) and applies to
each advisory account advised by GWG
(“Account”). The investment advisory services
offered under the Services generally include
investment advice and consulting services, which
are provided by Baird PWM’s home office
investment professionals or GWG, and, depending
upon the Service that a client selects, the Service
may include portfolio management. The Services
consist of:
The Client-Baird Fiduciary Relationship
is registered with the Securities and
Baird
Exchange Commission (“SEC”) as an investment
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
consulting
services
(“Consulting
• certain
Services”);
strategies may be affiliated with external
custodians. GWG will assist clients in evaluating
custodians and negotiating custodial fees, trading
commissions, as well as, investment management
fees.
• discretionary services, whereby a client gives
GWG or Baird (including Baird PWM’s home
office investment professionals or the client’s
GWG Consultant) full discretionary authority to
manage the client’s Account (“Discretionary
Services”);
provide
investment
advice
client’s
Account
• non-discretionary services, whereby GWG or
Baird
and
recommendations but the client retains full
authority with respect to the management of
the
(“Non-Discretionary
Services”); and
the client has
The SMA Services are generally offered under a
“single contract” arrangement. Under a single
contract arrangement, a client enters into an
advisory agreement with GWG and Baird, and
Baird, in turn, enters into a subadvisory or similar
agreement with the investment manager on the
client’s behalf. This type of arrangement is
frequently referred to as a single contract
arrangement because there is only one contract
between the client and GWG and Baird; the client
does not have an agreement directly with the
client’s investment manager. Under the Dual
Contract Program, a client has a “dual contract”
arrangement, meaning
two
contracts; one contract with GWG and Baird and
another contract with the client’s investment
manager.
• separately managed account (“SMA”) programs
and services, whereby an investment manager
manages the client’s Account according to a
strategy (each, an “SMA Strategy”) with full
discretionary authority, and GWG and Baird
provide additional consulting services to the
client (collectively, “SMA Services”).
Depending on their particular needs or objectives,
clients may use one or more of these Services.
Certain Programs may allow a client to invest in
groups of mutual funds and ETFs (referred to as
“sleeves”) and other model portfolios of securities
managed by Baird PWM (such sleeves and model
portfolios collectively, “PWM-Managed Portfolios”).
Aggregation
described
below.
The SMA Programs allow a client to select among
a variety of SMA Strategies offered by third party
investment managers (“Other Managers”), which
may include Other Managers affiliated with,
related to, or otherwise associated with Baird
(“Associated Managers”), or Baird to manage the
client’s Account.
The Consulting Services
include: Financial
Strategy, Investment Strategy, Risk Management,
Tax Planning, Estates and Trusts, Philanthropic
Planning, Family Education, Sounding Board, and
Data
The
Discretionary Services include: GWG Investment
Management. The SMA Services include: GWG
Recommended Managers; Baird SMA Network
(“BSN”); and Dual Contract (“DC”). The Additional
Consultant Services are only provided to certain
clients upon request by a client and agreement to
do so by GWG. GWG primarily provides
Consulting Services and recommends the GWG
Investment Management Service and GWG
Recommended Managers Service to clients when
appropriate. GWG will infrequently recommend
the other Services when GWG believes it is
appropriate for a particular client.
funds and exchange
traded
Baird has engaged an overlay management firm,
Envestnet Asset Management, Inc. (the “Overlay
Manager”) to provide certain subadvisory services
to clients that participate in certain SMA Services.
The SMA Services make available two types of
SMA Strategies: (1) manager-traded strategies,
whereby the manager itself manages a client’s
Account and conducts the trading to implement
the SMA Strategy selected by the client (a
“Manager-Traded Strategy”); and (2) model-
traded strategies, whereby the manager does not
manage a client’s Account (a “Model Provider”)
but instead provides a model portfolio (“Model
Portfolio”) to an overlay management firm, which
may include the Overlay Manager, Baird or other
firm (each, an “Implementation
third party
Generally, GWG provides clients with analysis and
recommendations on investment managers and
strategies. Investment strategies typically may
include either public or private securities, private
institutional
placements,
limited partnerships,
mutual
funds
(“ETFs”). Often these investment managers or
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Manager,
and
investment products
Manager”), that in turn manages a client’s
Account and conducts the trading to implement
the SMA Strategy selected by the client (a
“Model-Traded Strategy”). If a client selects a
Model-Traded Strategy, the Model Provider will
provide the Model Portfolio and updates to the
Implementation
the
Implementation Manager will manage the client’s
Account with full discretionary authority according
to the strategy selected by the client. Otherwise,
if the client selects a Manager-Traded Strategy,
the investment manager will directly manage the
client’s Account with full discretionary authority as
more fully described below.
Strategies”). Similarly, some Programs offer
clients the ability to invest in non-traditional or
real assets (“Non-Traditional Assets”). Some
Programs also offer the ability to invest in
investment products
that pursue Alternative
Strategies (“Alternative Investment Products”) or
other Complex Strategies (collectively, “Complex
Investment Products”). The use of
these
involves
strategies and
special risks, and a client should not engage in a
strategy or purchase an investment product
unless the client understands the related risks.
See “Additional Service Information—Complex
Strategies and Complex Investment Products”
and “Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks” below for more
information.
allocation
strategies
have
Fee.
See
“Additional
Baird is also registered with the SEC as a broker-
dealer under Securities Exchange Act of 1934, as
amended (the “Exchange Act”). GWG and Baird
provide the Services described in this Brochure
under a “wrap fee” arrangement. This means that
in addition to the investment advisory services
that GWG and Baird provide in connection with
each Service, Baird, in its capacity as broker-
dealer, also provides clients with trade execution,
custody and other standard brokerage services for
a single fee (“Advisory Fee”). A client should note
that the client may incur costs in addition to the
Advisory
Service
Information—Trading for Client Accounts” and
“Other Fees and Expenses” below for more
information.
to execute
transactions without
referred
intend
Each Service is designed to address different
investment needs of clients. All of the Services
discussed in this Brochure may not be appropriate
for every client. For example, the Services may
not be appropriate for clients who have low or no
trading activity, who desire to pay transaction-
based fees, who maintain their accounts invested
in high levels of cash or other concentrated
positions, who do not want ongoing professional
investment advice or account monitoring, who
tend
the
recommendation or advice of an advisor, which
to as “unsolicited”
are commonly
transactions, or who
to utilize an
investment strategy, product or solution that is
not available in a Service.
Certain Services make available asset allocation
investment strategies. Asset allocation strategies
involve investing in one or more categories of
assets, such as equity securities, fixed income
securities, Non-Traditional Assets, Alternative
Investment Products and cash, and one or more
subcategories of assets, called asset classes.
varying
Asset
investment objectives and investment strategies.
Some asset allocation strategies use strategic
investment strategies, which involve investing
accounts in accordance with a predetermined
target allocation to different asset classes. Some
asset allocation strategies use tactical investing,
which typically involves tactically and actively
adjusting account allocations to different asset
classes based upon the manager’s perception of
how those asset classes will perform in the short-
term. Some asset allocation strategies involve the
use of both strategic and tactical investment
strategies, sometimes referred to as dynamic
strategies. Asset allocation strategies may be
implemented using a variety of investment types,
such as individual securities, mutual funds and
exchange traded products (“ETPs”), including
ETFs and exchange traded notes (“ETNs”). The
amount allocated to an asset class or investment
type varies by strategy, and some strategies may
have little or no allocation to one or more asset
classes or types of investments described above.
See “Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of
Loss—Investment Strategies—Asset
Allocation Strategies” below for more information.
Some Services offer clients the ability to pursue
alternative investment strategies (“Alternative
Strategies”) or other non-traditional or complex
investment strategies that involve special risks
not apparent in more traditional investments like
“Complex
stocks
and bonds
(collectively,
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
funds, ETFs, unit
A client that wishes to participate in a Service will
enter into a client relationship agreement or other
investment advisory agreement with GWG and
client’s
(“advisory agreement”). The
Baird
advisory agreement will contain the specific terms
applicable to the services selected by the client,
fees payable by the client, and other terms
applicable to the client’s advisory relationship with
GWG and Baird. A client should note that the
client’s advisory relationship with GWG and Baird
does not begin until they enter into the applicable
advisory agreement with the client, which occurs
when Baird PWM’s Home Office has accepted the
client’s advisory agreement and determined that
all of the client’s paperwork is in order. See
“Account Requirements and Types of Clients”
below for more information.
“Additional
The Services make available many different
investment products and services offered by third
parties that are not associated with Baird, such as
investment trusts
mutual
(“UITs”), collective investment trusts (“CITs”),
private equity funds, hedge funds, private funds
and other investment pools (collectively “Funds”).
However, certain
investment products and
services managed, advised or sponsored by Baird
or other parties affiliated with, related to, or
otherwise associated with Baird,
including
Associated Managers (“Associated Parties”), have
been selected for inclusion in certain Services or
are made available to clients through Service
Accounts (“Associated Investment Products and
Services”). Associated Investment Products and
Services generally consist Funds managed,
advised or sponsored by Baird or Associated
Parties (“Associated Funds”) and other investment
products managed, advised or sponsored by Baird
or Associated Parties (collectively, “Associated
Investment Products”), and SMA Strategies
managed or advised by Baird or Associated
Managers (“Associated SMA Strategies”). Baird
and GWG Consultants may use, select or
recommend Associated Investment Products and
Services. This may present a conflict of interest. A
client is free at any time to select investment
products and services that are not associated with
Baird. For specific information about Associated
Parties and Associated Investment Products and
Services, see
Information—Other
Financial Industry Activities and Affiliations”
below.
As mentioned above, Baird, in its capacity as
broker-dealer, also provides GWG clients with
trade execution, custody and other standard
brokerage services. For this reason, a client will
also enter into a client relationship agreement or
other account agreement with GWG and Baird
(“account agreement”) if the client has not
already done so. The client’s account agreement
authorizes GWG and Baird to execute trades for,
and perform related brokerage and custody
services to, the client’s Account. Baird generally
does not permit a client to include assets in the
client’s Account that are held by a third party
custodian or that are otherwise held outside of a
Baird account (“Held-Away Assets”), although
GWG will provide Consulting Services on Held-
Away Assets when requested by a client and
agreed to by GWG.
Service
has
different
include
a
client’s
age,
Each
structures,
administration, types and levels of service, and
fees and expenses. In particular, a client should
note that the
investment advisory services
provided by GWG and Baird, including the depth
of
initial and ongoing research, evaluation,
monitoring and review of the investments in a
client’s Account, varies by Service and the
investments selected for the Account.
the
that GWG and Baird provide
A client’s GWG Consultant will offer or
recommend appropriate Services,
investment
strategies, and investment products and services
based upon a client’s investment profile and an
Account’s investment objective, which establishes
an Account’s investment return objective and risk
investment profile will
tolerance. A client’s
generally
other
investments, financial situation and needs, tax
status, investment goals, investment experience,
investment time horizon, liquidity needs, risk
tolerance and other relevant information provided
by a client and updated from time to time.
Although a GWG Consultant may offer or
recommend appropriate options, a client will
ultimately select
investment objective,
Services, investment strategies, and investment
products and services for an Account.
The foregoing discussion of the Services is only a
summary. More specific information about the
Services and the particular investment advisory
services
in
connection with each Service are
further
described below and in the client’s advisory
agreement. Clients are encouraged to review this
Brochure and their advisory agreement carefully.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
target allocations to individual asset types within
the More Risky or Less Risky asset groupings.
Consulting Services
Financial Strategy
financial strategy service
includes
flow. Cash
the
“financial
the
The
development and periodic updating of a
comprehensive financial plan that GWG refers to
as a “financial roadmap”. The financial plan is
based upon GWG’s analysis of a client’s assets,
flows are
liabilities, and cash
determined on an after-tax basis. The goal is to
develop a financial plan that holistically considers
a client’s entire balance sheet, goals and
objectives, including liquidity needs, and a client’s
ability and willingness to accept risk. A client’s
goals, objectives, and ability and willingness to
accept risk may be determined through in person
meetings or based upon a client’s responses and
information provided to GWG through the Client
Profile Questionnaire. Using information from
Accounts held at Baird as well as other
information provided to GWG by the client, GWG
will provide the client an updated personal
balance sheet on a quarterly basis. Financial
planning and
roadmap” are
generally updated annually or on as need basis.
A client should note that GWG’s categorization of
asset types into More Risky and Less Risky
groupings is based on GWG’s view of the
historical performance of asset types and their
relative risks under normal economic and market
conditions. GWG’s use of the terms “More Risky”
and “Less Risky” should not be interpreted to
mean that the asset types included in the More
Risky asset grouping has
relatively higher
investment risk under every circumstance, or,
conversely, that the Less Risky asset grouping
has relatively lower investment risk under every
circumstance. A client should also note that the
particular asset grouping is subject to all of risks
associated with the asset classes and investments
included in the grouping and it is possible that the
Less Risky asset grouping could carry relatively
higher investment risk under certain economic or
market conditions. Please see ““Portfolio Manager
Selection and Evaluation—Methods of Analysis,
Investment Strategies and Risk of Loss—Principal
Risks” below for more information.
the
strategy
and make
fixed
intermediate-term
short-term
fixed
GWG generally reviews a client’s then-current
asset allocation versus
target strategic
allocation and the target tactical allocation on a
quarterly basis. Accounts are generally re-
balanced automatically to the target tactical
allocation, generally quarterly if needed. As part
of this process, GWG will review a client’s current
investment
allocation
suggestions or recommendations to balance risk.
GWG believes the liquidity needs of a client are a
major consideration
in any asset allocation
suggestion or recommendation. Therefore, GWG
will review the expected liquidity within a client’s
balance sheet versus a client’s liquidity needs on
a quarterly basis. On an as need basis, GWG will
also review the liability side of a client’s balance
sheet, which includes loans and liabilities, and
provide a report on how those liabilities impact a
client’s cash flow, taxes, and risk.
time
to
management
decisions
Using a variety of tools, including the financial
roadmap, GWG will develop and recommend a
for
long-term,
the client’s
target allocation
investments, known as a
strategic asset
allocation. The strategic allocation represents the
manner in which GWG believes a client’s assets
should be invested over longer periods of time,
such as five to seven years. When developing the
strategic allocation, GWG generally focuses on a
client’s allocation to, and balance between, assets
that GWG characterizes as “More Risky” and “Less
Risky”. GWG generally defines Less Risky assets
to include the following types of assets: taxable or
tax-exempt
income
income
investments,
investments and cash and cash equivalents. More
Risky assets include all other asset types, such as
equity securities, private equity investments, real
estate, hedge funds, commodities and privately-
held operating businesses should a client have
any. From
time, GWG may also
recommend tactical asset allocations based on
GWG’s perception of how certain asset classes will
perform in the shorter term. Tactical asset
allocation typically involves having allocations to
the More Risky and Less Risky asset groupings
that are either over- or under-weight compared to
the target strategic allocation for those asset
groupings, as well as over- or under-weight the
When requested by a client, GWG will include in
the client’s financial plan Held-Away Assets. A
client should note that Held-Away Assets are
included in a financial plan for the sole purpose of
assisting GWG with making overall asset
allocation recommendations to the client and
making
and
recommendations to the client as to client assets
held in Baird accounts. GWG’s role with respect to
5
BGWG Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Held-Away Assets included in a financial plan is
limited to performance monitoring and tracking
and periodically evaluating them in relation to the
clients’ investment policy/goals, potential risks
and returns, tax consequences and costs. Baird
and GWG do not provide any advice on Held-
Away Assets and
they do not make any
recommendation as to whether a client should
buy, hold or sell any Held-Away Asset.
In certain instances when requested by a client,
GWG may provide a review of past performance
of Held-Away Assets Such performance reviews
and reporting show the historical performance of
a client’s assets and compares various aspects of
such performance to one or more benchmark
indices.
cap value, small cap growth, small cap value,
international and emerging market equities
strategies; different
income styles or
fixed
strategies, such as short or intermediate, taxable,
and tax-exempt bond, international and emerging
market bond, and high yield bond strategies. In
its GWG
many
instances, GWG provides
Investment Management Service
(described
below) to directly manage a core portfolio of
primarily passive and active mutual funds or
ETFs, across the different equity and fixed income
styles described above. This strategy will be
designed to be cost and tax efficient. GWG will
monitor the performance of each active or passive
mutual fund, or ETF investment manager, or
other “investment vehicle” that is part of a client’s
investment strategy on an ongoing basis relative
to the investment manager’s benchmark and peer
group. GWG will also regularly review the cost
and tax efficiency of each investment vehicle.
Risk Management
report.
Inaccuracies
in
strategy
described
A client should note that the inclusion of Held-
Away Assets in a financial plan or performance
report is solely based on information provided by
the client or the client’s agent for the agreed-
upon period and that GWG and Baird do not
conduct a review of, or verify, such information,
and they do not guarantee the accuracy of the
information used to prepare the financial plan or
the
performance
information provided to GWG could impact the
client’s financial plan or performance report in a
materially negative manner.
Investment Strategy
When performing risk management services,
GWG seeks to analyze and review with a client
the risks identified in the financial planning
process described above. GWG seeks to minimize
investment risk through an asset allocation and
investment
above.
Additionally, as needed, GWG will work with
resources internal to Baird or third parties to
evaluate a client’s non-investment risks that can
be addressed by life, annuity, long-term care, and
umbrella insurance policies. GWG will rely on the
financial planning process and input from either
resources internal to Baird or third parties to
determine the appropriateness of a client’s
current life, annuity, long-term care, and umbrella
insurance coverage.
Tax Planning
On an ongoing basis, GWG monitors the market
and the economy utilizing a variety of internal and
external resources to formulate an opinion as to
the current position of the market and economy
relative to the market and economic cycle. GWG
will provide a client a quarterly update either in-
person, or over a video or conference call. GWG
will also provide a client access to a quarterly
webinar and/replay in which GWG will provide an
update on its market and economic view.
to a client’s
information along with GWG’s
Utilizing that
analysis of market valuation and GWG’s
perception of how certain asset classes will
perform, GWG may suggest that a client make
adjustments
target strategic
allocations that were determined using the
financial strategy described above.
tax efficiency across
At a client’s direction, GWG will work directly with
a client’s existing tax advisors in an effort to
manage and reduce ordinary income and capital
gains tax impact. GWG may also review the
service offering of a client’s existing tax advisors
compared to alternative tax advisors identified by
the client. GWG will actively review accounts held
at Baird, and accounts or investments held by a
client or at other firms, assuming the client has
provided access to information on accounts or
investments not held at Baird, in an attempt to
increase
firms and
strategies. GWG will provide a client’s tax
preparer with the relevant data, to the extent
Investment strategy may involve the use of
different equity styles or strategies, such as: large
cap growth, large cap value, mid cap growth, mid
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Family Education
GWG is able to do so, required for a client’s yearly
tax preparation.
Estates and Trusts
At the direction of a client, GWG will assist the
client in organizing, planning the agenda for, and
facilitating a family meeting. From time to time,
or as needed, GWG will provide a client with
relevant financial literacy material. This material
may be produced by resources internal to Baird or
third parties. At a client’s direction, GWG will work
with any other members of the client’s household
to help them develop their own financial plan.
Sounding Board
certain
information and assistance at
they are
titled
that
the characteristics of each
in
GWG’s
asset
At a client’s direction, GWG will work directly with
the client’s existing estate attorney to manage
and reduce estate tax impact. GWG may also
review the service offering of a client’s existing
estate attorney compared to alternative estate
attorneys identified by the client. As needed,
GWG will update a client’s estate attorney as to
relevant changes to the client’s Accounts and
financial or investment strategy. While trust
administration is the duty of a client’s trustee(s)
and custodian(s), GWG will assist
in trust
administration, as needed, by providing relevant
the
Account
direction of the trustee(s). As needed, GWG will
review beneficiary designations with a client
making sure any Accounts or investments held at
Baird that require such designation have the
designation intended by the client. Also as
needed, GWG will review all client Accounts
and/or trust Accounts held at Baird, and accounts
or investments held by the client or at other
firms, assuming the client has provided access to
information on accounts or investments not held
at Baird, making sure
in
accordance with the client’s instructions. As it
relates to estate planning, GWG will review, on an
annual basis, any client trust or partnership to
is
ensure
considered
allocation
recommendations made to a client.
Philanthropic Planning
Some clients may ask GWG to be a “sounding
board” and assist them in evaluating the general
merits of
investment or business
opportunities that are presented to the clients by
third parties (“Special Evaluations”). GWG team
members will work to use their experience,
expertise, and analytical capabilities to be a
resource as a client navigates financial issues and
evaluates investment opportunities presented to a
client by third parties as they arise. Typically, a
Special Evaluation involves GWG providing an
analysis of the financial aspects of the opportunity
presented that assesses the relative merits of the
opportunity in light of the client’s investment
policy/goals, potential risks and returns, tax
consequences, and costs. When additional
resources are needed to solve problems a client
faces, GWG may suggest third party experts be
brought to the table to provide relevant insight.
Upon request, GWG will also perform Special
Evaluations of purchases of substantial non-
investment-related assets being considered by
the client, such as a yacht, private plane, new
home, etc., focusing on the impact to the client’s
balance sheet and cash flow.
is
A client should note that this service solely
information and
consists of GWG providing
analysis to a client. In conducting Special
Evaluations, GWG does not recommend or provide
advice about the desirability of making the
investment or purchase and GWG makes no
recommendation as to whether a client should
buy, hold, or sell any such investment or other
property. Rather, GWG’s role
limited to
evaluating the investment or property in relation
to the clients’ investment policy/goals, potential
risks and returns, tax consequences and costs.
At the direction from a client, GWG will review the
client’s charitable giving plan and assist the client
with an efficient giving strategy, relying on both
internal resources and input from third parties. As
needed and requested by the client, GWG will also
assist a client in identifying a philanthropic
advisor as well as assist a client with an analysis
of the pros and cons of private foundations, donor
advised
funds, and direct giving strategies.
Additionally, on an as needed basis, GWG can
help a client identify appropriate assets for
charitable giving. This would typically include
identifying highly appreciated securities or
investments. GWG will also assist a client by
coordinating direct asset transfers to charitable
organizations as designated by the client.
Data Aggregation
GWG will gather and organize the financial
paperwork, legal and tax documents for all client
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
required
to prepare
the
client in connection with the opening of the
Account.
the heading
and
in various
assets, liabilities, trusts, foundations, and other
entities
“financial
roadmap” as described under “Financial Strategy”
above. GWG will administer all client Accounts
held at Baird providing monthly account
statements, in addition to the quarterly reports
described above under “Investment Strategy.”
Additionally, GWG will maintain any investment
documentation provided by a client as it relates to
investments that the client has made through
other firms or third parties. If requested by a
client, GWG will assist the client in tracking capital
calls related to private investments. A client will
also be able to set up check writing capability on
the client’s cash or money market Accounts held
at Baird to make capital call payments, or any
other payments they choose. Additionally, at a
client’s direction, GWG can have a check drawn
from the client’s Account and mailed to a recipient
designated by the client.
Service
The foregoing list of Services described above is
intended to illustrate the types and levels of
service that GWG offers to clients. The actual
Services and levels of service to be provided to a
client will be set forth in the client’s agreement or
appended to the fee schedule to the agreement.
A GWG Consultant typically recommends or
selects for client accounts investments in mutual
funds and ETFs that pursue the strategies
“Consulting
described under
Investment
Services—Asset Allocation
Strategy Development” above. However, from
time to time, a GWG Consultant may make direct
investments
types of securities,
including, but not limited to, equity securities,
fixed income securities, Non-Traditional Assets
and certain Alternative Investment Products. All
or a portion of the assets in a client’s Account
may be held in cash or cash equivalents, including
securities issued by money market mutual funds,
or may be deposited in interest-bearing bank
accounts. Additional information about the types
of investments a GWG Consultant may use for
client accounts is contained under the heading
Information—Permitted
“Additional
Investments” below. For more information about
the GWG Investment Management Service, see
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Program Portfolio Strategies—GWG
Investment Management Service” below.
Discretionary Services
GWG Investment Management Service
Under the GWG Investment Management Service,
a client grants full discretionary authority and
management of the client’s Account to Baird and
the client’s GWG Consultant.
Baird may remove any GWG Consultant or
strategy from the Service at any time and
transfer day-to-day management responsibility of
a client’s Account to another GWG Consultant or
Baird Financial Advisor at any time without
providing prior notice to, or obtaining the consent
of, a client.
involve
special,
reviews
the client’s
investing
in
Service
Consultant makes
a
Important Information about GWG Investment
Management Service Accounts. GWG Consultants
may invest client accounts in illiquid securities
and Complex Investment Products. These types of
investments
sometimes
significant, risks and are not appropriate for all
clients. A client should understand those risks
those products. See
before
“Additional
Information—Complex
Strategies and Complex Investment Products”
and “Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks” below for more
information.
Associated Investment Products are available to
clients under the GWG Investment Management
In the GWG Investment Management Service, a
client’s GWG Consultant seeks to meet the client’s
particular investment needs by developing a
customized
investment strategy based upon
guidelines that are jointly established by the client
and
the
the client’s GWG Consultant. At
commencement of services, the client’s GWG
Consultant
investment
objectives and risk tolerance using the Consulting
Services described above. Based upon that review
and other information provided by the client, the
GWG
subsequent
recommendation to the client as to which
investment style the GWG Consultant believes is
best suited for the client. A client makes the final
decision as to which investment style is chosen
for the client’s Account. More specific information
as to how the client’s GWG Consultant will
manage the client’s Account is provided to the
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BGWG Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
a GWG RM Strategy. Such brochures are available
upon request.
Service. This presents a conflict of interest. For
more information, see “Additional Information—
Other Financial Industry Activities and Affiliations”
below.
SMA Services
GWG Recommended Managers Service
initially selects
Some of the services provided under the GWG
Recommended Managers Service will be provided
to a client by a GWG Consultant assigned to the
client’s Account. A client, typically working with a
the GWG
GWG Consultant,
Recommended Manager and GWG RM Strategy
for the client’s Account. Thereafter, whenever
Baird or the client’s GWG Consultant deems it
necessary, Baird or the client’s GWG Consultant
will replace a GWG Recommended Manager or
GWG RM Strategy with
another GWG
Recommended Manager or GWG RM Strategy for
the client’s Account.
The GWG Recommended Managers Service is a
program whereby a client provides Baird and the
client’s GWG Consultant with discretionary
authority to appoint investment managers to
manage the client’s Account with full discretionary
authority and to terminate or replace investment
managers for the client’s Account. The GWG
Recommended Managers Service is designed for a
client who wishes to have the client’s Account
investment managers that are
managed by
monitored by GWG and Baird on an ongoing
basis.
the
Under the GWG Recommended Managers Service,
investment
GWG and Baird determine
managers (“GWG Recommended Managers”) and
their strategies (“GWG RM Strategies”) eligible to
participate in the Service through an initial and
ongoing evaluation process.
full discretionary authority
If a client participates in the GWG Recommended
Managers Service, the client authorizes and
directs GWG and Baird
to appoint GWG
Recommended Managers to serve as sub-adviser
to the client’s Account and to otherwise manage
the client’s Account in accordance with the terms
of the GWG Recommended Managers Service. The
client also authorizes and directs the GWG
Recommended Managers to manage the client’s
in
Account with
accordance with the GWG RM Strategy selected.
RM
Strategies
offered
For more specific information about the managers
and SMA Strategies made available through the
GWG Recommended Managers Service and the
level of initial and ongoing research, evaluation,
monitoring and review performed by Baird on
those managers and SMA Strategies, see
“Portfolio Manager Selection and Evaluation—
Selection and Evaluation—GWG Recommended
Managers Service” below.
full discretionary authority
GWG Recommended Managers have varying
investment objectives, styles and strategies, and
they may invest a client’s Account in various
types of securities, which will be chosen by the
GWG Recommended Manager and which may
include mutual funds, ETFs or other investment
products associated with the manager or Baird.
review
information
about
full discretionary authority
Certain GWG RM Strategies are only made
available through Implementation Managers. The
GWG
through
Implementation Managers consist of Manager-
Traded Strategies and Model-Traded Strategies. If
a GWG RM Strategy offered
through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs GWG
and Baird to appoint the Implementation Manager
to serve as sub-adviser to the client’s Account. If
a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to manage the client’s
Account with
in
accordance with the selected GWG RM Strategy.
If a Manager-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to appoint the applicable
GWG Recommended Manager as sub-adviser, and
the client also authorizes and directs such GWG
Recommended Manager to manage the client’s
Account with
in
accordance with the selected GWG RM Strategy.
Clients are urged
the GWG
to
Recommended Manager’s Form ADV Part 2A
contain additional
Brochure, which
should
GWG
the
important
Recommended Manager, including information
about
the GWG Recommended Manager’s
strategies, the types of investments the GWG
Recommended Manager may use for a client’s
Account, and the risks associated with investing in
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BGWG Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
from
the
the
implement
the direction of
the
client’s Account,
the prior manager and
From time to time, GWG or Baird may remove
investment managers
GWG
Recommended Managers Service, and GWG or
Baird may select a replacement manager to
manage the client’s Account. In such event, GWG
or Baird, at
the client’s
replacement manager, or the client’s replacement
manager may sell all or a portion of the securities
or other investments in the Account that were
managed by
the
replacement manager will reinvest the cash
proceeds of those sales. Sales of securities or
other investments could result in adverse tax
consequences for the client.
faithfully
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Implementation Manager will
Account,
the Model Portfolio as
typically
proposed by the Model Provider. However, since
the Implementation Manager has discretionary
authority over
the
Implementation Manager may implement the
Model Portfolio differently than proposed by the
Model Provider if the Implementation Manager
determines such action to be necessary and in the
client’s best interest. A client should note that
GWG and Baird do not monitor or ascertain
whether a third party Implementation Manager is
fully and
implementing the Model
Portfolio on a continuous basis. The client should
periodically discuss the Account’s performance
with the client’s GWG Consultant.
in
If GWG or Baird terminates an investment
manager from the GWG Recommended Managers
Service, a client authorizes GWG and Baird to
invest, with full discretionary authority, the assets
in the client’s Account previously managed by the
terminated
other
investment manager
securities, including, but not limited to, mutual
funds and ETPs. GWG’s and Baird’s discretionary
authority to make such other investments will
continue until a replacement investment manager
is selected or alternative arrangements are made
for the management of the client’s assets.
below
Certain managers of Model-Traded Strategies
offered
through the Overlay Manager have
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a GWG client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of other
client accounts managed by
those Model
Providers. See “Additional Service Information—
Trading for Client Accounts—Trading Practices of
Investment Managers”
for more
information.
the client should understand
the discretionary
A client who prefers to continue using an
investment manager that has been removed from
the GWG Recommended Managers Service, or
who directs or otherwise requests
that a
particular investment manager not recommended
by GWG be selected to manage the client’s
Account, will need to move to another Service,
such as the BSN Program. See “Baird SMA
Network Program” below for more information.
Clients who elect to do so will no longer receive
the same level of rigorous ongoing monitoring,
evaluation, or review of that investment manager
from GWG or Baird.
recommendation or
Important
Information about Affiliated
Managers. The GWG Recommended Managers
Service makes available to clients investment
services that are offered by Baird Advisors and
Baird Equity Asset Management,
investment
management departments of Baird. This presents
a conflict of interest. For more information, see
“Additional Information—Other Financial Industry
Activities and Affiliations” below.
If a client’s Account is managed by an Other
Manager under the GWG Recommended Managers
that,
Service,
notwithstanding
authority
granted to Baird and the client’s GWG Consultant
under the Service: Baird and the client’s GWG
Consultant do not manage the Account and do not
otherwise have any influence over the Other
Manager’s
investment decisions or securities
selections, and therefore, Baird and the client’s
GWG Consultant are not responsible for the
decisions made by the Other Manager; and Baird
and the client’s GWG Consultant do not provide
any
investment advice
regarding the purchase or sale of investment
products made for the client’s Account.
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BGWG Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird SMA Network Program
a
is designed
client who wishes
Clients are urged to review the BSN Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the BSN
Manager, including information about the BSN
Manager’s strategies, the types of investments
the BSN Manager may use for a client’s Account,
and the risks associated with investing in a BSN
Strategy. Such brochures are available upon
request.
The BSN Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
to
client. The BSN Program
accommodate
to
independently select an investment manager not
available in the GWG Recommended Managers
Program to manage the assets in the client’s
Account.
(“BSN
Strategies”)
eligible
Some of the services provided under the BSN
Program may be provided to a client by a GWG
Consultant assigned to the client’s Account, and
the client’s GWG Consultant may provide his or
her own advice and recommendations about BSN
Managers.
Under the BSN Program, Baird determines the
investment managers (“BSN Managers”) and their
strategies
to
participate in the Program through a significantly
less rigorous evaluation process compared to the
GWG Recommended Managers Service. However,
a client should note that GWG and Baird do not
make any recommendation to clients regarding
any BSN Strategy or any
representations
regarding a BSN Manager’s qualifications as an
investment adviser or abilities to manage client
assets.
If a client participates in the BSN Program, the
client authorizes and directs GWG and Baird to
appoint the BSN Manager selected by the client to
serve as sub-adviser to the client’s Account. The
client also authorizes and directs the BSN
Manager to manage client’s Account with full
discretionary authority in accordance with the
BSN Strategy selected by the client.
if any, see
and
Evaluation—Selection
For more specific information about the managers
and SMA Strategies made available through the
BSN Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those managers and SMA
“Portfolio Manager
Strategies,
Selection
and
Evaluation—Baird SMA Network and Dual Contract
Programs” below.
the
A client should only participate in the BSN
Program if the client wishes to take more
responsibility for monitoring the client’s Account,
the GWG Recommended Managers Program does
not contain an SMA Strategy that meets the
client’s particular needs, and
client
understands the risks of doing so.
have
varying
Certain BSN Strategies are only made available
through the Overlay Manager. The BSN Strategies
offered through the Overlay Manager consist of
Manager-Traded Strategies and Model-Traded
Strategies. If a client selects a BSN Strategy
offered through the Overlay Manager for the
client’s Account, the client authorizes and directs
GWG and Baird to appoint the Overlay Manager to
serve as sub-adviser to the client’s Account. If a
client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to manage the client’s Account
with full discretionary authority in accordance
with the BSN Strategy selected by the client. If a
client selects a Manager-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to appoint the applicable BSN
Manager as sub-adviser, and the client also
authorizes and directs such BSN Manager to
manage the client’s Account with full discretionary
authority in accordance with the BSN Strategy
selected by the client.
investment
BSN Managers
objectives, styles and strategies, and they may
invest a client’s Account in various types of
securities, which will be chosen by the BSN
Manager and which may include mutual funds,
ETFs or other investment products associated with
the manager or Baird. Certain managers offer
strategies that exclusively invest in Funds (“Fund
Strategist Portfolios”).
If a client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the Overlay Manager will typically
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the Account and
its
regarding
implement the Model Portfolio as proposed by the
Model Provider. However, since the Overlay
Manager has discretionary authority over the
client’s Account, the Overlay Manager may
implement the Model Portfolio differently than
proposed by the Model Provider if the Overlay
Manager determines such action to be necessary
and in the client’s best interest. A client should
note that GWG and Baird do not monitor or
ascertain whether the Overlay Manager is fully
and faithfully implementing the Model Portfolio on
a continuous basis. The client should periodically
discuss the Account’s performance with the
client’s GWG Consultant.
A client that participates in the BSN Program is
strongly encouraged to contact the client’s GWG
Consultant or BSN Manager on a periodic basis to
investment
discuss:
performance; the BSN Manager’s investment
philosophy and style (to determine if the BSN
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information
the BSN Manager,
described on the manager’s Form ADV, which is
available on the SEC's website at www.adviser
info.sec.gov.
Information—Trading
Certain managers of Model-Traded Strategies
offered
through the Overlay Manager have
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a GWG client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by those Model Providers. See
“Additional Service
for
Client Accounts—Trading Practices of Investment
Managers” below for more information.
for
The BSN Strategies and BSN Managers made
available under the BSN Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the BSN Program,
GWG and Baird cannot appoint a replacement
manager or otherwise manage a client’s Account
assets. Given the terms of the BSN Program,
upon the withdrawal or removal of an investment
manager from the BSN Program, a client’s BSN
Program Account will be automatically removed
from the BSN Program and the Account will
become an unmanaged brokerage account, unless
the client provides contrary instructions to GWG.
See “Portfolio Manager Selection and Evaluation—
Selection and Evaluation—Baird SMA Network and
Dual Contract Programs” below
further
information.
influence over
Important Information about
the BSN
Program. Portfolios managed by 55I, LLC (d/b/a
55ip, “55ip”) are made available under the BSN
Program. 55ip uses research and other services
from Riverfront, an affiliate of Baird, in the
development of certain of those portfolios, and
Riverfront receives compensation from 55ip with
respect to those portfolios. This presents a conflict
of interest. For more information, see “Additional
Information—Other Financial Industry Activities
and Affiliations” below.
reviewing
the
If a client’s Account is managed by an Other
Manager under the BSN Program, the client
should understand that: GWG and Baird do not
manage the Account and do not otherwise have
any
the Other Manager’s
investment decisions or securities selections, and
therefore, GWG and Baird are not responsible for
the decisions made by the Other Manager; GWG
and Baird do not provide any recommendation or
investment advice regarding the purchase or sale
of investment products made for the client’s
Account; and GWG and Baird only provide the
client with certain consulting services, which may
include the client’s GWG Consultant’s assistance
with determining the client’s financial needs,
investment goals and investment restrictions and
manager’s
periodically
performance. GWG and Baird do not undertake to
provide any other consulting or
investment
advisory services under the BSN Program unless
GWG and Baird agree to do so in writing.
appointment
The BSN Program is designed to accommodate a
client who wishes to independently select an
investment manager that is not available in the
GWG Recommended Managers Service to manage
the client’s Account. The client assumes ultimate
responsibility for monitoring the client’s BSN
the BSN Manager’s
Program Account and
and
client’s
performance. A
continued retention of a BSN Manager to manage
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in managing
the client’s Account
A client should only participate in the DC Program
if the client wishes to take more responsibility for
monitoring
the GWG
the client’s Account,
Recommended Managers Program does not
contain an SMA Strategy that meets the client’s
particular needs, and the client understands the
risks of doing so.
the
foregoing when deciding
DC Managers have varying investment objectives,
styles and strategies, and they may invest a
client’s Account in various types of securities,
which will be chosen by the DC Manager and
which may include mutual funds, ETFs or other
investment products associated with the manager
or Baird.
the client’s Account are based ultimately upon the
client’s independent review of the BSN Manager
and the BSN Manager’s services. The client
ultimately determines that the BSN Strategy to be
used
is
consistent with the client’s stated investment
objectives and financial needs and risk tolerance.
Once retained by the client, a BSN Manager will
only be removed from managing the client’s BSN
Program Account upon the manager’s withdrawal,
removal from the BSN Program, or the client’s
direction to do so. A client should carefully
to
consider
participate in the BSN Program and also consider
whether another Service, such as the GWG
Recommended Managers Service, may be more
appropriate for the client.
Dual Contract Program
Clients are urged to review the DC Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the DC
Manager, including information about the DC
Manager’s strategies, the types of investments
the DC Manager may use for a client’s Account,
and the risks associated with investing in a DC
Strategy. Such brochures are available upon
request.
a
is designed
client who wishes
Some of the services provided under the DC
Program may be provided to a client by a GWG
Consultant assigned to the client’s Account, and
the client’s GWG Consultant may provide his or
her own advice and recommendations about DC
Managers.
The DC Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
to
client. The DC Program
accommodate
to
independently select an investment manager not
available in the GWG Recommended Managers
Service or BSN Program to manage the assets in
the client’s Account. The Program is also designed
for a client that wants to independently select a
manager and negotiate the manager’s Portfolio
Fee rate directly with the manager.
Under the DC Program, Baird determines the
investment managers (“DC Managers”) and their
strategies (“DC Strategies”) eligible to participate
in the Program through a significantly less
rigorous evaluation process compared to the GWG
Recommended Managers Service. However, a
client should note that GWG and Baird do not
make any recommendation to clients regarding
any DC Strategy or any representations regarding
a DC Manager’s qualifications as an investment
adviser or abilities to manage client assets.
Under the DC Program, DC Managers are offered
to clients through a dual contract arrangement,
and a client will need to enter into a separate
agreement with the DC Manager in addition to the
advisory agreement the client enters into with
GWG and Baird. A client participating in the DC
Program is solely responsible for negotiating the
client’s agreement with the client’s DC Manager,
and neither GWG nor Baird will participate or
advise a client regarding the terms of such an
agreement, the advisability of entering into such
an agreement, or the retention of the client’s DC
Manager unless GWG and Baird agree to do so in
writing.
if any, see
and
Evaluation—Selection
If a client’s Account is managed by an Other
Manager under the DC Program, the client should
understand that: GWG and Baird do not manage
the Account and do not otherwise have any
influence over the Other Manager’s investment
decisions or securities selections, and therefore,
For more specific information about the managers
and SMA Strategies made available through the
DC Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those managers and SMA
“Portfolio Manager
Strategies,
Selection
and
Evaluation—Baird SMA Network and Dual Contract
Programs” below.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Financial Industry Activities and Affiliations”
below.
appointment
reviewing
the
GWG and Baird are not responsible for the
decisions made by the Other Manager; GWG and
Baird do not provide any recommendation or
investment advice regarding the purchase or sale
of investment products made for the client’s
Account; and GWG and Baird only provide the
client with certain consulting services, which may
include the client’s GWG Consultant’s assistance
with determining the client’s financial needs,
investment goals and investment restrictions and
periodically
manager’s
performance. GWG and Baird do not undertake to
investment
provide any other consulting or
advisory services under the DC Program unless
GWG and Baird agree to do so in writing.
in managing
the client’s Account
the Account and
its
the DC Manager’s
the
foregoing when deciding
The DC Program is designed to accommodate a
client who wishes to independently select an
investment manager. The client assumes ultimate
for monitoring the client’s DC
responsibility
the DC Manager’s
Program Account and
performance. A
and
client’s
continued retention of a DC Manager to manage
the client’s Account are based ultimately upon the
client’s independent review of the DC Manager
and the DC Manager’s services. The client
ultimately determines that the DC Strategy to be
used
is
consistent with the client’s stated investment
objectives and financial needs and risk tolerance.
Once retained by the client, a DC Manager will
only be removed from managing the client’s DC
Program Account upon the manager’s withdrawal,
removal from the DC Program, or the client’s
direction to do so. A client should carefully
consider
to
participate in the DC Program and also consider
whether another Service, such as the GWG
Recommended Managers Service, may be more
appropriate for the client.
Other SMA Strategy Information
A client that participates in the DC Program is
strongly encouraged to contact the client’s GWG
Consultant or DC Manager on a periodic basis to
investment
discuss:
performance;
investment
philosophy and style (to determine if the DC
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information regarding the DC Manager, described
on the manager’s Form ADV, which is available on
the SEC's website at www.adviserinfo.sec.gov.
to
Certain SMA Strategies are available through
multiple Services. The overall cost of an SMA
Strategy and the types and levels of service
provided to a client in connection with an SMA
Strategy will vary depending upon the particular
Service selected by the client. Certain managers
offer lower Portfolio Fee rates to clients through
the DC Program compared
the GWG
Recommended Managers or BSN Programs. A
client considering an SMA Strategy should discuss
with client’s GWG Consultant SMA Strategy
availability and the different Portfolio Fee rates,
costs, and the types and levels of service
provided in connection with the different Services.
A client is solely responsible for selecting the SMA
Strategy and the Service in which the client’s
Account will participate.
The DC Strategies and DC Managers made
available under the DC Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the DC Program,
GWG and Baird cannot appoint a replacement
manager or otherwise manage a client’s Account
assets. Given the terms of the DC Program, upon
the withdrawal or removal of an investment
manager from the DC Program, a client’s DC
Program Account will be automatically removed
from the DC Program and the Account will
become an unmanaged brokerage account, unless
the client provides contrary instructions to GWG.
See “Portfolio Manager Selection and Evaluation—
Selection and Evaluation—Baird SMA Network and
Dual Contract Programs” below
for more
information.
invested
in concentrated and
Information about
A client should note that certain SMA Strategies
less
may be
diversified portfolios of securities and may involve
the use of leverage, margin, and options. A client
should discuss with the client’s GWG Consultant
the specific strategies and investments used by a
the
manager. Additional
information about
the DC
Important
Program. Other
investment management
departments of Baird and Associated Managers
are available to clients under the DC Program.
This presents a conflict of interest. For more
information, see “Additional Information—Other
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
strategies and investments used by a manager
are available in a manager’s Form ADV Part 2A
Brochure.
for
buying,
holding,
Additional Service Information
Investment Discretion
Investment Selection and Trading
Authorizations
A client
retains complete discretion over
investment selection and trading decisions with
respect to assets in a client’s Non-Discretionary
Service Accounts, and GWG and Baird will only
execute transactions for such Accounts pursuant
to the client’s instruction or authorization.
the client. Pursuant
If a client’s Account participates in a Discretionary
Service, the client’s advisory agreement provides
Baird and the client’s GWG Consultant, as
applicable, discretionary authority to manage the
assets in the client’s Account in accordance with
the terms of the Service selected by the client.
investment manager, as applicable, to manage
the client’s Account and to make investment
decisions for the client’s Account, with the
authority to determine the amount, type and
timing
exchanging,
converting and selling securities and other assets
for the client’s Account, subject to the terms of
the Service selected by the client. The client’s
advisory agreement also grants to GWG, Baird,
the client’s GWG Consultant and the client’s
investment manager, as applicable, complete and
unlimited trading authorization and appoints them
as the client’s agents and attorneys-in-fact to
manage the assets in the client’s Account on the
client’s behalf, subject to the terms of the Service
selected by
to such
authorization and powers of attorney, GWG,
Baird, the client’s GWG Consultant and the client’s
investment manager may, in their sole discretion
and at the client’s risk, purchase, sell, exchange,
convert and otherwise trade the securities and
other assets in the client’s Account, as well as
arrange for delivery and payment in connection
with the above, and act on the client’s behalf in
all matters necessary or incidental to the handling
of the client’s Account without prior notice to the
client. Such trading authorizations and powers of
attorney, whether granted to GWG, Baird, the
client’s GWG Consultant or the client’s investment
manager, shall remain in full force and effect until
terminated by the client, the client’s investment
manager, GWG or Baird.
a
If a client’s Account participates in the GWG
Recommended Managers Service, the client’s
advisory agreement provides Baird and the
client’s GWG Consultant discretionary authority to
appoint investment managers to manage the
client’s Account and to terminate or replace
investment managers for the client’s Account for
any reason without prior notice to the client. If
GWG or Baird terminates an investment manager
from management
client’s GWG
of
Recommended Managers Service Account, the
client’s advisory agreement provides GWG and
Baird discretionary authority to manage the
assets in the client’s Account until a replacement
investment manager is selected or alternative
arrangements are made for the management of
the client’s assets.
include
If a client’s Account participates in an SMA
Service, the client’s advisory agreement provides
the investment manager selected to manage the
an
client’s Account, which may
Implementation Manager, discretionary authority
to manage the assets in the client’s Account in
accordance with the terms of the SMA Service
selected by the client.
Orders for the purchase and sale of securities in a
client’s Discretionary Service Accounts will
generally be executed by Baird, in its capacity as
broker-dealer, as further described under the
heading “Trading for Client Accounts” below,
unless Baird’s duty to seek to obtain best
execution otherwise requires or unless the client
has provided other instructions to Baird in writing.
GWG and Baird do not have discretionary
authority over the assets in a client’s SMAs that
are managed by an Other Manager and cannot
purchase or sell such assets without the consent
of the client or such Other Manager. The
investment manager for a client’s SMAs may
initiate securities transactions through Baird, in its
capacity as broker-dealer, as further described
under the heading “Trading for Client Accounts”
below, subject to the manager’s duty to seek to
obtain best execution, or unless a client has
provided other instructions in writing. Baird, as
broker-dealer, will rely upon any such instructions
If a client grants discretionary authority over the
client’s Account to GWG, Baird, the client’s GWG
Consultant or the client’s investment manager,
the client’s advisory agreement authorizes GWG,
Baird, the client’s GWG Consultant and the client’s
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
of any investment managers selected to manage
the client’s Account.
the client’s Account holds any investment vehicle
(such as a mutual fund or ETF), any investment
restrictions the client places on the client’s
Account may not flow through to the securities
owned by that investment vehicle.
Should a client wish to impose or modify existing
restrictions, or the client’s financial condition or
investment objectives have changed, the client
should contact the client’s GWG Consultant.
Associated Investment Products
If a client participates in an SMA Service, the
client authorizes GWG and Baird to share client’s
information with the Overlay Manager and any
Other Manager or
Implementation Manager
managing the client’s Account. The client also
authorizes and directs GWG and Baird to transmit
to the Overlay Manager and any such Other
Manager or
Implementation Manager any
instructions that the client may provide to GWG or
Baird to the extent necessary to carry out the
client’s instructions.
Client Investment Restrictions
other
from
the services
The Services allow GWG and Baird to use the
discretionary authority granted to them by a
client to invest the client’s Account in Associated
Investment Products. Baird and Associated Parties
receive investment management or advisory fees
Associated
compensation
or
Investment Products
they
for
provide, the amount of which generally increases
when clients invest in such products. The amount
of fees or other compensation received by Baird
and Associated Parties is generally described in
the prospectus or other offering or disclosure
documents for the investment product. Additional
information is also available on Baird’s website at
bairdwealth.com/retailinvestor.
The Discretionary and the SMA Services offer a
client the ability to impose reasonable investment
restrictions on the management of an Account,
including the designation of particular securities
or types of securities that should not be
purchased for the client’s Account, but a client
may not require that particular funds or securities
(or types) be purchased for the client’s Account.
Reasonable investment restrictions requested by
a client will apply only to those assets over which
GWG, Baird or a client’s investment manager has
discretion.
investments
to
those
in Associated
GWG may also offer clients a socially responsible
investing (“SRI”) service, which assists a client in
restricting
that are
consistent with the client’s social investment
guidelines or objectives. Clients electing the SRI
service generally bear the cost of the SRI service
as it is generally included in the Advisory Fee.
accounts without
restrictions
By signing an advisory agreement with Baird or
participating in a Service, a client consents to
GWG and Baird investing all or a portion of the
Investment
client’s Account
Products. GWG and Baird will use
their
discretionary authority to invest the client’s
Account in Associated Investment Products when
they determine it to be in the client’s best interest
to do so. Generally, the criteria used by them in
deciding to invest in Associated Investment
Products are the same as those used in deciding
to invest a client’s assets in investment products
unassociated with Baird. For more information
about the criteria used by GWG and Baird, clients
should review the section of the Brochure entitled
“Portfolio Manager Selection and Evaluation”
below. A client’s consent may be revoked at any
time.
In the event that a client’s Account is restricted
from investing in certain securities, GWG, Baird or
the client’s investment manager, as applicable,
will select such other replacement securities, if
any, as they deem appropriate. Accounts with
investment restrictions may perform differently
and
from
performance may be poorer. In addition, in the
event there is a change in the classification or
credit rating of a security held in the client’s
Account, a client’s investment restrictions may
force GWG, Baird or the client’s investment
manager to sell such security at an inopportune
time, possibly negatively
impacting Account
performance and causing the client’s Account to
realize taxable gains or losses, which could be
significant. A client should also be aware that, if
The Services allow Other Managers, including
Associated Managers, to use the discretionary
authority granted to them by a client to invest the
client’s Account in investment products managed
or sponsored by the Other Manager or any of its
associated firms, which may include Baird. The
Other Manager or its associated firms receive
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment management or advisory fees or other
compensation from such products for the services
they provide, the amount of which generally
increases when clients invest in such products.
Account and that the client may not be able to
hold certain Advisory Class Shares in an account
held at another firm. Upon the termination of a
Service for an Account or the closure of an
Account for any reason, GWG and Baird may
convert or exchange the Advisory Class Shares
held in the Account to an appropriate non-
Advisory Class Shares issued by the same fund,
or, if an appropriate non-Advisory Class Shares is
not available, GWG and Baird may redeem or sell
such Advisory Class Shares.
Trading for Client Accounts
GWG’s and Baird’s Trading Practices
Placement of Client Trade Orders
By signing an advisory agreement with Baird or
participating in a Service, a client consents to
each Other Manager, including each Associated
Manager, managing client’s Account investing all
or a portion of the client’s Account in investment
products managed or sponsored by the Other
Manager or any of its associated firms, which may
include Baird. Each Other Manager is responsible
for providing to the client information about the
amount of fees received by the Other Manager
and its associated firms and the criteria used by
the Other Manager in deciding to invest in
products managed or sponsored by the Other
Manager or any of its associated firms. A client
should contact the Other Manager and review the
Other Manager’s Form ADV Part 2A Brochure for
more information. A client’s consent may be
revoked at any time.
Investment Policy Statements
GWG and Baird will not review, monitor, accept or
adhere to an investment policy statement or
similar document that was not prepared by GWG
or Baird, unless they otherwise specifically agree
to do so in writing. Adherence to any such
investment policy statement or similar document
is solely a client’s responsibility.
Conversion, Exchange or Sale of Certain
Investments
GWG and Baird will select the broker-dealers that
will execute trade orders for Non-Discretionary
Accounts and with respect to Accounts that are
managed directly by GWG or Baird unless the
client has provided instructions to GWG to the
contrary. As investment adviser, GWG and Baird
have an obligation to seek “best execution” of
client trade orders. “Best execution” means that
they must place client trade orders with those
broker-dealers that they believe are capable of
providing the best qualitative execution of client
trade orders under the circumstances, taking into
account the full range and quality of the services
offered by the broker-dealer, including the value
of the research provided (if any), the broker-
dealer’s execution capabilities, the cost of the
trade, the broker-dealer’s financial responsibility,
and its responsiveness to GWG and Baird. It is
important to note that GWG’s and Baird’s best
execution obligation does not require them to
solicit competitive bids for each transaction or to
seek the lowest available cost of trade orders, so
long as they reasonably believe that the broker-
dealer selected can be reasonably expected to
provide clients with the best qualitative execution
under the circumstances.
for use
transactions. For
By participating in a Service, a client authorizes
GWG and Baird to convert or exchange any
shares of Funds, such as mutual funds, ETFs,
closed-end funds, UITs, Complex Investment
Products, and other similar investment pools, held
in the client’s Account to a class of shares of the
same
fund, such as advisory class shares,
institutional class shares, financial intermediary
class shares, or another class of shares primarily
designed
advisory programs
in
(collectively, “Advisory Class Shares”), to the
extent made available by the mutual fund or
other Fund in accordance with policies established
by Baird from time to time, including, without
limitation the Mutual Fund Share Class Policy that
is described below.
A client should understand that, the client may
not hold Advisory Class Shares in a non-Advisory
Because a client does not pay commissions to
Baird when Baird, acting as broker-dealer,
executes a client’s trade orders, and because a
client may incur commission costs in addition to
the Advisory Fee if trade orders were to be
executed by another broker-dealer firm, clients
generally receive a cost advantage whenever
Baird executes client
this
reason, and given Baird’s execution capabilities as
broker-dealer, GWG expects that Baird will
generally execute trade orders, as broker-dealer,
for Non-Discretionary Accounts and the client’s
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Accounts that are directly managed by GWG or
Baird.
All advisory clients participating
in a block
transaction will receive the same execution price
for the security bought or sold. Average prices
may be used when allocating purchases and sales
to a client’s Account because such securities may
be purchased and sold at different prices in a
series of block transactions. As a result, the
average price received by a client may be higher
or lower than the price the client may have
received had the transaction been effected for the
client independently from the block transaction.
in
However, in some instances, circumstances may
arise that may require GWG or Baird,
in
compliance with their best execution obligations
to a client, to place a client’s trade order with a
firm other than Baird. If they place trade orders
for the client’s Account for execution by a firm
other than Baird, and the other firm imposes a
commission or equivalent fee on the trade
(including a commission imbedded in the price of
the investment), the client will incur trading costs
in addition to the Advisory Fee.
Trade Aggregation, Allocation and Rotation
Practices
treatment over
GWG and Baird may aggregate contemporaneous
buy and sell orders for the accounts over which
they have discretionary authority (a practice also
known as bunching trades or block transactions).
This practice may enable them to obtain more
favorable execution, including better pricing and
enhanced investment opportunities, than would
otherwise be available
if orders were not
aggregated. Using block transactions may also
assist them in potentially avoiding an adverse
effect on the price of a security that could result
from simultaneously placing a number of
separate, successive or competing, client orders.
the
The amount of securities available
marketplace, at a particular price at a particular
time, may not satisfy the needs of all clients
participating in a block transaction and may be
insufficient to provide full allocation across all
client accounts. To address this possibility, Baird
has adopted
trade allocation policies and
procedures that are designed to make securities
allocations to discretionary client accounts in a
manner such that all such clients receive fair and
equitable
time. If a block
transaction cannot be executed in full at the same
price or time, the securities actually purchased or
sold by the close of each business day will
generally be allocated pro rata among the clients
participating in the block transaction. However,
GWG may also make random allocations to client
accounts in certain circumstances, such as when
Baird deems a partial fill for the total block order
to be low. Adjustments may also be made to
avoid a nominal allocation to client accounts.
under
their
direct
favorable net price
When GWG is not able to aggregate trades, GWG
generally uses a trade rotation process that is
designed to be fair and equitable to its advisory
clients over time. However, a client should be
aware that GWG’s trade rotation practices may at
times result in a transaction being effected for the
client’s Account that occurs near or at the end of
the rotation and, in such event, client’s trade
orders will significantly bear the market price
impact, if any, of those trades executed earlier in
the rotation, and, as a result, the client may
receive a
for the
less
applicable trade.
into
consideration
account
GWG and Baird generally aggregate buy and sell
orders when executing trades for client account
assets
discretionary
management when they have the opportunity to
do so. When utilizing block transactions, GWG and
Baird generally aggregate a client’s trade orders
with trade orders for clients who are participating
in the same Service and pursuing the same model
portfolio or strategy. In some cases, GWG or
Baird may aggregate a client’s trade orders with
trade orders for other advisory clients who are not
participants in the Services described in this
Brochure. However, GWG and Baird determine
whether or not to utilize block transactions for a
client in their sole discretion and GWG’s and
Baird’s decision is subject to their duty to seek
best execution. In determining the amount to be
allocated to an account, if any, GWG and Baird
take
specific
investment restrictions, undesirable position size,
account portfolio weightings, client tax status,
client cash positions and client preferences.
for
fixed
Notwithstanding the foregoing, if an aggregated
trade order involves fixed income securities, GWG
and Baird may allocate the securities based on
the needs of client accounts. In addition, GWG
and Baird will at times place aggregated trade
income securities prior to
orders
determining how the aggregated trade order will
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
be allocated to client accounts. In those instances
when an aggregated trade order for fixed income
securities is placed prior to determining client
allocations or when such trade order is only
partially filled, GWG or Baird will seek to allocate
trades in manner intended to be fair and equitable
to applicable clients over time. Furthermore,
when a trade order for fixed income securities is
only partially filled, GWG and Baird may place
orders for other fixed income securities that have
similar characteristics, such as issuer name,
structure, credit rating, or market sector.
trade orders with orders for other GWG clients. As
a result, a client’s transaction costs may be higher
because the client will not benefit from any
volume discounts or other reduced transaction
costs that GWG may obtain for its other clients. A
client should further note that GWG generally will
not include such client trade orders in its trade
rotation process and that GWG will generally
place the client’s trade orders with the directed
broker-dealer after GWG completes its trading for
other GWG client accounts. The client’s trade
orders will significantly bear the market price
impact, if any, of those trades executed earlier in
GWG’s rotation. As a result, the client may
receive a less favorable net price for the trade.
Because GWG and Baird are unable to buy or sell
any security for a client’s Non-Discretionary
Accounts without the client’s authorization, GWG
and Baird generally do not aggregate or bunch
trades for those Accounts with the same or similar
trades for other client accounts. Because similar
orders for the client and GWG’s or Baird’s other
clients may be placed and filled at different times,
the client may buy or sell securities at prices that
are different from the prices obtained by other
clients who received the same or similar advice
from GWG or Baird.
Directed Brokerage Arrangements
If a client directs GWG to use a particular broker-
dealer, and if the particular broker-dealer referred
the client to GWG or if the particular broker-
dealer refers other clients to GWG or Baird in the
future, GWG and Baird may benefit from the
client’s directed brokerage arrangement. Because
of these potential benefits, GWG and Baird may
have an economic interest in having the client
continue the directed brokerage arrangement.
The benefits that GWG and Baird receive conflict
with the client’s interest in having GWG or Baird
recommend that the client utilize another broker-
dealer to execute some or all transactions for the
client’s Account.
Before directing GWG to use a particular broker-
dealer, a client should carefully consider the
possible costs or disadvantages of directed
brokerage arrangements.
Cross Trading Involving Advisory Accounts
the purchase of
In some cases, a client may direct GWG to use a
particular broker-dealer for execution of the
client’s trade orders (a “directed brokerage
arrangement”), and GWG may agree to the
arrangement. This may occur when a client’s
Account is held at another broker-dealer firm and
a client directs GWG to execute trades through
such firm, or when a client’s Retirement Account
or other account is maintained on a platform
operated and managed by a third party and
trades must be executed through that platform. A
client should understand that GWG and Baird
consider such arrangements to be directed
brokerage arrangements. A client should also
understand that if the client has a directed
brokerage arrangement, GWG and Baird may be
unable to achieve best execution for the client’s
transactions. A client should note that any costs
related to the directed brokerage arrangement
are not included in the Advisory Fee and that the
client will be solely responsible for monitoring,
evaluating and reviewing the arrangement with
the directed broker-dealer and paying any
commissions or markups or markdowns or other
costs imposed by the directed broker-dealer. A
client should also note that GWG generally will
not aggregate the client’s directed brokerage
GWG generally does not in engage in cross
transactions, including agency cross transactions,
except in limited instances such as when clients
buy or sell variable rate demand obligations which
are also known as “put bonds”. When GWG
believes that the transaction is consistent with
each client’s best interest, GWG, acting as
investment manager, may cause (or in the case
of Non-Discretionary accounts, recommend) the
sale of securities from the account of an advisory
client while at or about the same time causing
(or, in the case of Non-Discretionary accounts,
recommending)
the same
securities
for the account of another GWG
advisory client. Such transactions may have the
benefit of reducing transaction and market impact
costs.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
manager has a duty to seek best execution for
the client’s Account.
the
investment manager,
In such cases, because Baird is acting as
investment adviser for both buyer and seller,
Baird is subject to potentially conflicting interests
in causing (or recommending) the transactions.
Also, because Baird is acting as investment
adviser for both buyer and seller, transaction
prices may be determined more by reference to
market information or dealer indications for the
securities involved, and less through the type of
independent arms-length negotiation that might
otherwise occur. Baird has adopted internal
policies and procedures that require GWG and
Baird to obtain approval of Baird’s Compliance
Department before affecting a cross trade.
Trade Error Correction
Investment managers may participate in other
wrap fee programs sponsored by firms other than
Baird. In addition, investment managers may
manage institutional and other accounts not part
fee program. In the event an
of a wrap
investment manager purchases or sells a security
for all accounts using a particular SMA Strategy
offered by
the
investment manager may have to potentially
effect similar transactions through a number of
different broker-dealers. In some cases, to
address this situation, investment managers may
decide to aggregate all such client transactions
into a block trade that is executed through one
broker-dealer. This practice may enable the
investment manager to obtain more favorable
execution, including better pricing and enhanced
investment opportunities, than would otherwise
be available if orders were not aggregated. Using
block transactions may also assist the investment
manager in potentially avoiding an adverse effect
on the price of a security that could result from
simultaneously placing a number of separate,
successive or competing client orders. However,
as it pertains to GWG clients, this practice may
result in “trading away” from Baird, which is more
fully described below.
It is Baird’s policy that if there is a trade error for
which GWG or Baird is responsible, GWG or Baird
will take actions, based on the
facts and
circumstances surrounding the error, to put the
client’s Account in the position that it would have
been in as if the error had not occurred, including
by adjusting or reversing the transaction, entering
an offsetting transaction, or other methods that
may be deemed appropriate by Baird. Errors
caused by GWG or Baird will be corrected at no
cost to client’s Account, with the client’s Account
not recognizing any loss from the error. GWG and
Baird may net gains and losses from a single error
event involving more than one transaction in a
security or transactions in multiple securities. The
client’s Account will be fully compensated for any
losses incurred as a result of an error event. If
the trade error results in a gain, the gain may be
retained by Baird but such gain is not given to or
shared with any GWG or Baird associate.
in
the
GWG and Baird offer many services and, from
time to time, may have other clients in other
programs trading in opposition to a client. To
avoid favoring one client over another client,
Baird attempts to use objective market data in
the correction of any trading errors.
information
Alternatively, an investment manager may utilize
a trade rotation process where one group of
clients may have a transaction effected before or
after another group of the investment manager’s
clients. A client should be aware that an
investment manager’s trade rotation practices
may at times result in a transaction being effected
for the client’s Account that occurs near or at the
end of the investment manager’s rotation and, in
such event, client’s trade orders will significantly
bear the market price impact, if any, of those
trades executed earlier
investment
manager’s rotation, and, as a result, the client
may receive a less favorable net price for the
trade. Additional
regarding an
investment manager’s trade rotation policies, if
any, is available in the investment manager’s
Form ADV Part 2A Brochure.
If a client’s Account is managed by an Other
Manager, the client should review the Other
Manager’s Brochure and contact
the Other
Manager for information about how the Other
Manager corrects trade errors.
Trading Practices of Investment Managers
If a client’s Account or a portion thereof is
managed by an investment manager, the client
should note that, like Baird, such investment
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after
implemented the Model Portfolio
they have
updates for client accounts managed by them or
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
as
broker-dealer,
on
website
capabilities
investment
managers may determine that placing trade
orders for the client’s Account with Baird is the
most favorable option for the client. However,
investment managers may place a client’s trade
orders with a broker-dealer firm other than Baird
if the manager determines that it must do so to
comply with its best execution obligations. This
practice is frequently referred to as “trading
away” and these types of trades are frequently
called “step out trades”. A client’s trade order so
executed is then cleared and settled through
Baird in what is frequently referred to as a “step
in”.
the other
In some instances, step out trades are executed
by
firm without any additional
commission or markup or markdown, but in other
instances, the executing firm may impose a
commission or a markup or markdown on the
trade. If a client’s investment manager places
trade orders for the client’s Account with a firm
other than Baird, and the other firm imposes a
commission or equivalent fee on the trade
(including a commission imbedded in the price of
the investment), the client will incur trading costs
in addition to the Advisory Fee.
in
the Model Provider’s
Some managers have historically placed nearly all
client trades with broker-dealer firms other than
Baird for execution. Some managers have placed
nearly all or all client trades resulting from
changes to their model portfolios or strategies
with firms other than Baird. Similarly, some
managers have frequently placed client trade
orders for fixed income, foreign and small cap
securities with firms other than Baird. In some
cases, the other executing broker-dealer firm
imposes a commission or markup or markdown
(which is embedded in the price of the security)
for executing the trade. As a result, these types of
managers and their strategies could be more
costly to a client than managers that primarily
place client trade orders with Baird for execution.
after they have otherwise completed trading for
those accounts. The Overlay Manager has
provided to Baird a list of Model Providers that
have such trade rotation policies, which list is
available
at
Baird’s
bairdwealth.com/retailinvestor. A GWG client
should understand that an Account pursuing a
Model Portfolio strategy offered by those Model
Providers will have trades executed for the client’s
Account at the end of the Model Provider’s trade
rotation on a regular and consistent basis. As a
result, trade orders for such an Account will
significantly bear the market price impact, if any,
of those trades executed earlier in the Model
Provider’s rotation and the performance of the
Account will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by the Model Provider. In
addition and for the same reasons described
above, the performance of a Model Portfolio, as
reported by the Model Provider, will differ,
perhaps in a materially negative manner, from
the actual performance realized by GWG client
Accounts pursuing the Model Portfolio strategy.
GWG and Baird do not make or control any
investment manager’s trade rotation policies, and
they do not monitor, evaluate or review any
investment manager’s compliance with
the
manager’s trade rotation policies or whether such
trade rotation policies result
inequitable
performance of client Accounts. A client selecting
a Model Portfolio offered by such a Model Provider
is urged to obtain a copy of the Model Provider’s
Form ADV Part 2A Brochure and review the
description of the Model Provider’s trade rotation
policy contained in that document. A copy of a
Model Provider’s Brochure can be obtained by
contacting a GWG Consultant. A client should also
monitor the performance of an Account pursuing
such a Model Portfolio strategy and compare that
performance with the performance reported for
the Model Portfolio by the Model Provider. A client
about Account
should
questions
discuss
performance or
trade
rotation policy with the client’s GWG Consultant.
is based solely upon
independently verified
Because a client does not pay commissions to
Baird when Baird, acting as broker-dealer,
executes a client’s trade orders, and because a
client generally would incur trading costs in
addition to the Advisory Fee if trade orders were
to be executed by another broker-dealer firm,
clients generally
receive a cost advantage
whenever Baird executes GWG client transactions.
For this reason, and given Baird’s execution
A list of managers that have informed Baird that
they have traded away from Baird during 2024 -
2025 and general information about the additional
cost of those trades (if any) is available on Baird’s
website at bairdwealth.com/retailinvestor. The
information about each manager provided on
Baird’s website
the
information provided to Baird by such manager.
the
Baird has not
information, and as a result, none of Baird or any
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
transactions are executed. A client bears such
costs in addition to the Advisory Fee.
of its Associated Parties or associates makes any
representation as to the accuracy of any such
information.
Agency Cross Transactions
incurred
A client should contact
the client’s GWG
Consultant or investment manager if the client
would like to obtain specific information about
trade aways and the amount of commissions or
other costs,
in
if any, the client
connection with step out trades.
A client should note that each
investment
manager is solely responsible for ensuring that it
complies with its best execution obligations to the
client. A client should review the manager’s
trading for the client’s Account because GWG and
Baird do not monitor, review or evaluate whether
the manager is complying with its best execution
obligations to the client. A client should review
the manager’s Form ADV Part 2A Brochure,
inquire about the manager’s trading practices,
and consider that information carefully, before
selecting a manager. In particular, the client
should carefully consider any additional trading
costs the client may incur before selecting a
manager to manage the client’s Account.
GWG generally does not in engage in agency
cross transactions, except in limited instances.
However, in certain circumstances and to the
extent permitted by applicable law and regulation,
Baird and GWG Consultants may effect “agency
cross” transactions with respect to a client’s
Account. An “agency cross” transaction is a
transaction in which Baird or its affiliates act as
broker for the party or parties on both sides of
the transaction. As compensation for brokerage
services, Baird may receive compensation from
parties on both sides of an agency cross
transaction, the amount of which may vary. GWG
Consultants may receive compensation from Baird
related to agency cross transactions. Therefore,
Baird and GWG Consultants may have a
conflicting division of loyalties and responsibilities.
However, in all cases, Baird and GWG Consultants
will seek to obtain the best execution for each
respective advisory client and will effect agency
cross transactions only in accordance with the
requirements of Rule 206(3)-2 under the Advisers
Act. Furthermore, Baird will comply with
additional regulations applicable to Retirement
Accounts.
agency
transactions
A client should note that the client’s advisory
agreement permits GWG and Baird to trade as
principal on orders received from Other Managers.
See “Trade Execution Services Performed by
Baird—Principal Transactions” below for more
information.
Trade Execution Services Performed by Baird
“agency
Where applicable, a client’s advisory agreement
discusses
and
cross
authorizes Baird and GWG Consultants to effect
agency cross transactions for a client’s Account. A
client’s authorization to Baird and GWG
to effect
Consultants
cross”
transactions
is given pursuant to Rule
206(3)-2 under the Advisers Act and may be
revoked at any time by the client in client’s
sole discretion by notifying the client’s GWG
Consultant in writing.
Principal Transactions
If Baird provides trade execution services for a
client’s Account, Baird will generally act as agent
when routing client trade orders for execution.
However, Baird may cross trades between client
accounts or may act as principal for its own
account in certain circumstances to the extent
permitted by applicable law as is more fully
described below.
A client should understand that certain securities,
such as securities traded over-the-counter and
fixed income securities, are primarily traded in
dealer markets. When Baird purchases or sells
these types of securities for client accounts, it
generally does so through broker-dealer firms
acting as a dealer or principal. Dealers executing
principal trades typically
include a markup,
markdown or spread in the net price at which
Subject to the requirements of applicable law,
Baird and GWG Consultants may execute
transactions for a client’s Account while acting as
principal for Baird’s own account. Baird and GWG
Consultants act as principal when they sell a
security from Baird’s inventory to a client or they
purchase a security from a client for Baird’s
inventory. Baird and GWG Consultants also act as
principal when they sell new issue securities to
clients in securities offerings underwritten by
Baird. Baird also acts as principal in riskless
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
transactions.
Riskless
principal
principal
transactions refer to transactions in which Baird,
after having received a client’s order, executes an
identical order in the marketplace to fill the
client’s order while acting as principal.
realize profits
managed by an Other Manager, the client’s
advisory agreement provides Baird and GWG
Consultants with a blanket authorization to act as
principal for Baird’s own account in selling any
security to, or purchasing any security from, the
client’s Account. With this authorization, Baird
and GWG Consultants may effect any and all
principal transactions with the client’s Account
to provide specific written
without having
disclosures or obtain written client consent prior
to completion of each proposed principal trade,
subject to the requirements of an exemptive
order issued by the SEC to Baird (Rel. No. IA-
4596) and other applicable law and regulation.
This authorization to enable Baird and GWG
Consultants to trade as principal with a
client’s Account may be revoked at any time
by the client in client’s sole discretion by
notifying the client’s GWG Consultant in
writing.
Complex Strategies and Complex Investment
Products
or
interests of
incentive
to
including by
investing
and
venture
capital
and
Baird may
from principal
transactions with a client based on the difference
between the price Baird paid for the security and
the price at which Baird sold the security, which
may include a markup, markdown or spread from
the prevailing market price, an underwriting fee,
selling dealer concession, or other incentive to
execute the transaction. GWG Consultants may
receive compensation
from Baird related to
principal trades of securities underwritten by
Baird. Any compensation received by Baird or a
GWG Consultant in a principal transaction is in
addition to the Advisory Fee paid by the client.
Principal trades also allow Baird to sell securities
from its account that it deems undesirable and to
buy securities for its account that it deem
desirable. Thus, in trading as principal with a
client, Baird and GWG Consultants will have
potentially conflicting division of loyalties and
responsibilities regarding their own interests and
the client. This potential
the
compensation may give Baird and GWG
Consultants an
recommend a
transaction in which Baird and GWG Consultants
transactions.
act as principal over other
Nonetheless, Baird and GWG Consultants have a
fiduciary duty to act in the client’s best interest
and to seek best execution for advisory clients.
Baird addresses this conflict through disclosure in
this Brochure. Furthermore, Baird has adopted
internal procedures that require Baird and GWG
Consultants, when acting in a principal capacity,
to disclose all material information regarding
Baird’s interest in the transaction, and obtain the
client’s approval of the transaction prior to
settlement.
such
as
options,
is contained under
A client’s advisory agreement discloses, where
applicable, the possibility of Baird’s role in
potential principal
transactions, and each
transaction confirmation sent to GWG clients
discloses the capacity in which Baird served in the
transaction and whether Baird is a market maker
in each security the client bought or sold.
of
Some Services offer clients the ability to pursue
Alternative Strategies
other Complex
Strategies that involve special risks not apparent
in more traditional investments like stocks and
bonds. Complex Strategies may be pursued in
multiple ways,
in
alternative mutual funds, ETFs, hedge funds,
managed futures, private equity funds and SMAs
third party managers. Some
managed by
Complex Strategies
in Non-Traditional
invest
Assets, such as real estate, commodities (which
may
include metals, mining, energy and
agricultural products), currencies, movements in
securities indices, credit spreads and interest
rates,
buyout
investments in private companies. Some Complex
Strategies engage in the use of margin or
leverage or selling securities short (“short sales”).
Some Complex Strategies invest in derivative
instruments
convertible
securities, futures, swaps, or forward contracts.
Complex Investment Products generally engage in
one or more Complex Strategies. Additional
information about Alternative Strategies and
Complex Strategies
the
“Portfolio Manager Selection and
heading
Evaluation—Methods of Analysis,
Investment
Strategies
Loss—Investment
and Risk
Strategies—Alternative Strategies and Complex
Strategies” below. Additional information about
or
To the extent permitted by applicable law and
regulation, if a client’s Account participates in a
non-
Non-Discretionary Service
is
discretionary service, or
if
other
the Account
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Complex Strategies and Complex Investment
Products, generally, is provided below.
pursued. The use of leverage may also increase
an Account’s volatility.
Non-Traditional Assets
Short Sales
to benefit
currencies,
securities
tokens
investment
Non-Traditional Assets, such as investments in
commodities,
indices,
interest rates, credit spreads, private companies,
and digital assets, such as cryptocurrencies, non-
fungible
stablecoins, and
(“NFTs”),
tokenized
products (collectively,
“Digital Assets”) may be used for diversification
purposes. They may also be used to try to reduce
market and inflation risk. The performance of
Non-Traditional Assets may not correspond to the
performance of the stock markets generally, and
investments
in Non-Traditional Assets will
generally impact an account’s returns differently
than more traditional investments like stocks or
bonds. Non-Traditional Assets are subject to risks
that are different from, and in some instances,
greater than, other assets like stocks and bonds.
Non-Traditional Assets are generally more difficult
to value, less liquid, and subject to greater
volatility compared to stocks and bonds.
Short selling attempts
from an
anticipated decline in the market value of a
security. To affect a short sale, a client sells a
security the client does not own. When a client
sells a security short, Baird borrows the security
from a lender and makes delivery to the buyer on
the client’s behalf. Because short sales involve an
extension of credit from Baird to the client, a
client must use a margin account. A client must
also eventually purchase the same shares sold
short and return them back to the lender. It is
possible that the prices of securities that a client
sells short may increase in value, in which case
the client may lose money on the short position.
Short selling thus runs the risk of loss if the price
of the securities sold short does not decline below
the price at which they were originally sold. This
risk of loss is theoretically unlimited, as there is
no cap on the amount that the price of a security
may appreciate.
Margin and Leverage
Margin
Clients should note that investment managers
managing a client’s Account or
investment
products in the client’s Account may also engage
in short sales. Thus, a client’s Account will be
subject to short sales risks if the investment
manager managing the client’s Account or an
investment product
the client’s Account
in
engages in short sales.
Options and Other Derivative Instruments
Derivative Instruments
instruments,
securities,
futures,
Margin involves borrowing money from a firm,
such as Baird, to buy securities or other property.
If a client wishes to pay for securities by
borrowing part of the purchase price from Baird, a
client must open a margin account with Baird, and
Baird may provide the client with a margin loan.
Securities held in a client’s margin account are
used as Baird’s collateral for the margin loan. The
value of the collateral in the margin account must
be maintained at a certain level relative to the
margin loan for the duration of the loan. If the
securities in the margin account decline in value,
so does the value of the collateral supporting the
margin loan, and as a result, Baird may take
action, such as issue a margin call and sell
securities in the account.
Leverage
than,
the
instruments. While
returns,
traditional
investments.
Investing
involves
Leverage generally attempts to obtain investment
exposure in excess of available assets through the
use of borrowings, short sales and other
leverage can
derivative
potentially enhance
can also
it
exacerbate losses if changes in the markets, or
the values of the investments subject to the
leverage, are adverse to the strategy being
such as options,
Derivatives
convertible
swaps, and
forward contracts are financial contracts that
derive value based upon the value of an
underlying asset, such as a security, commodity,
currency, or index. Derivative instruments may be
used as a substitute for taking a position in the
underlying asset. Derivative instruments may also
be used to try to hedge or reduce exposure to
other risks. They may also be used to make
speculative investments on the movement of the
value of an underlying asset. The use of
derivative instruments involves risks different
from, or possibly greater
risks
associated with investing directly in securities and
other
in
leverage.
derivatives also generally
Derivatives are also generally less liquid, and
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
subject to greater volatility compared to stocks
and bonds.
Options
that
the option will expire without being
exercised. The seller of a put option makes a
profit if the prevailing market price of the
underlying security or index is greater than the
difference between the strike price and the
premium.
Options transactions may involve the buying or
writing of puts or calls on securities. In some
cases, Baird may require clients to open a margin
account to engage in options trading.
security or
In purchasing a put or call option, the purchaser
faces the risk of loss of the premium paid for the
option if the market price moves in a direction
opposite to what the purchaser had expected. In
selling or writing an option, the seller faces
significantly more risk. A seller of a call option
faces the risk of significant loss if the prevailing
market price of the underlying security or index
increases above the strike price, and a seller of a
put option faces the risk of significant loss if the
prevailing market price of the underlying security
or index decreased below the strike price.
With a call option, the purchaser has the right to
buy, and the seller (writer) the obligation to sell,
the underlying
index at a
predetermined price (i.e., the exercise or strike
price) prior to expiration of the option. The
premium paid to the seller (writer) for the option
is in consideration for the underlying obligations
imposed on the seller should the option be
exercised. With a put option, the purchaser has
the right to sell, and the seller has the obligation
to buy, the underlying security or index at the
exercise price prior to expiration of the option.
Clients should note that investment managers
investment
managing a client’s Account or
products in the client’s Account may also engage
in options transactions. Thus, a client’s Account
will be subject to options risks if the investment
manager managing the client’s Account or an
the client’s Account
in
investment product
engages in options transactions.
Complex Investment Products
Products
include
futures, but also
In buying a call option, the purchaser expects
that the market value of the underlying security
or index will appreciate, which would enable the
purchaser of a call to buy the underlying security
or index at a strike price lower than the prevailing
market price. The purchaser of the call option
makes a profit if the prevailing market price is
greater than the sum of the strike price plus the
premium paid for the option. The seller of a call
option earns income in the form of the premium
received from the purchaser for the option and
expects that the market value of the underlying
security or index will depreciate such that the
option will expire without being exercised. The
seller of a call option makes a profit if the
prevailing market price of the underlying security
or index is less than the sum of the strike price
plus the premium received.
ETNs,
business
Complex Investment Products typically invest
primarily in Non-Traditional Assets or engage in
one or more Complex Strategies. Complex
Investment
Alternative
Investment Products, such as hedge funds, funds
of hedge funds, private equity funds, funds of
private equity funds, private debt funds, and
managed
include other
investments
pursuing Complex Strategies,
including but not limited to, exchange or swap
funds, leveraged funds, inverse funds, and other
special situation funds, structured certificates of
(“structured
deposit and
structured notes
development
products”),
companies (“BDCs”), real estate investment trusts
(“REITs”), and master
limited partnerships
(“MLPs”).
thereby making
In buying a put option, the purchaser expects that
the market value of the underlying security or
index will depreciate, which would enable the
purchaser of a put to sell the underlying security
or index at a strike price higher than the
prevailing market price. The purchaser of the put
option makes a profit if the prevailing market
price is less than the sum of the strike price and
the premium paid for the option. The seller of a
put option earns income in the form of the
premium received from the purchaser for the
option and expects that the market value of the
underlying security or index will appreciate such
In addition, a client should be aware that more
traditional investments, such as mutual funds,
ETFs, UITs and variable annuities may also pursue
Complex Strategies,
them
Complex Investment Products. A client should
carefully review the prospectus or other offering
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Complex
Strategies
or
website
document for each investment and understand
the strategy being pursued before deciding to
invest. More detailed information about mutual
funds, ETFs, UITs and variable annuities is
available
at
Baird’s
on
bairdwealth.com/retailinvestor.
Interest
information. A client should also understand that
Baird and the client’s GWG Consultant have a
financial incentive to use, select or recommend
Complex
certain
Investment Products, including margin and short
Information—Code of
sales. See “Additional
Ethics, Participation or
in Client
Transactions and Personal Trading” below.
Additional Important Information
losses
in
As a creditor, Baird may have interests that are
adverse to a client. Neither GWG nor Baird will act
as investment adviser to a client with respect to
the liquidation of securities held in an Account to
meet a call on a margin loan. Any such sale of
assets will be executed in Baird’s capacity as
broker-dealer and creditor and may, as permitted
by law, result in executions on a principal basis.
Permitted Investments
and
any
Investments”).
The use of Complex Strategies or Complex
Investment Products is not appropriate for some
clients because they involve special risks. A client
should not engage in those strategies or invest in
those products unless the client is prepared to
experience significant
the client’s
Account. This is especially true for short selling,
which can result in unlimited losses as there is no
limit to the amount borrowed securities can rise in
value. See “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Principal Risks”
below for more information. Before using those
types of strategies or products, a client is strongly
urged to discuss them with the client’s GWG
Consultant
investment manager
managing the client’s Account. A client should
also carefully review the client’s agreements with
Baird and related disclosure documents, which the
client should have received when opening the
Account. Additional information about Complex
Strategies and Complex Investment Products is
provided under the heading “Portfolio Manager
Selection and Evaluation—Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment Strategies—Alternative Strategies and
Complex Strategies” below and on Baird’s website
at bairdwealth.com/retailinvestor.
Under the Discretionary and Non-Discretionary
Services, Baird determines the asset categories
and investment products that clients may access
for investment (“Permitted Investments”) and
those that are not permitted in Program Accounts
(“Unpermitted
Permitted
Investments vary by Service. Although Baird
determines the Permitted Investments under
those Services, the level of initial and ongoing
evaluation, monitoring and review that GWG and
Baird perform on Permitted Investments varies.
For more information, see the descriptions of each
Service under “Services, Fees and Compensation”
above and under “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Program Portfolio
Strategies” below.
GWG or Baird may add Permitted Investments or
restrict client access to a Permitted Investment at
any time in their sole discretion.
for notifying
and
any
of
an
Account.
See
failure or delay
Some Permitted Investments contain restrictions
that limit their use, and clients will not be
permitted to purchase or hold such investments
outside
“Account
Requirements and Types of Clients” below for
more information.
A client assumes responsibility for engaging in
Complex Strategies and investing in Complex
Investment Products. If a client determines that
the client no longer wants to engage in those
strategies or invest in those products, the client is
responsible
the client’s GWG
Consultant
investment manager
managing the client’s Account. GWG and Baird
are not responsible for any losses resulting from
any Other Manager’s
in
implementing any such instructions.
In certain limited instances, Baird may allow a
client to hold an investment in an Account that is
an Unpermitted Investment.
“Advisory
The use of Complex Strategies or Complex
Investment Products has a unique impact upon
the calculation of a client’s asset-based Advisory
Fee. See
Fees—Calculation and
Payment of Advisory Fees” below for more
Investment Management Service.
GWG
Permitted Investments for the GWG Investment
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Management Service generally include, but are
not limited to, the following types of investments:
termination date at which time they will be
liquidated and the proceeds are billable;
• BDCs, publicly-traded REITs, certain non
publicly-traded (or private) REITs, and MLPs
(which may be organized as limited liability
companies (“LLCs”));
• equity securities, including, but not limited to,
common stocks, American Depositary Receipts
(“ADRs”), and ordinary shares,
including
whether exchange-traded, or over-the-counter
traded;
• ETNs, opportunity zone funds, and other special
situation mutual funds, and exchange or swap
funds;
stocks,
infrastructure
• certain hedge funds, funds of hedge funds,
private equity funds, funds of private equity
funds, funds of real estate, structured products,
private debt funds, private real estate funds,
funds, and managed
private
futures that Baird has selected for use in the
Services; and
• cash and cash equivalents.
• fixed income securities, including but not limited
to, debt securities issued by domestic and
corporations and other entities;
foreign
securities
asset-backed
preferred
(including mortgage-backed securities and
collateralized mortgage obligations (“CMOs”));
convertible debt securities; obligations issued
by U.S., state, or foreign governments or their
agencies, instrumentalities, or authorities, such
as securities issued by the U.S. Treasury,
federal
federal government agencies or
government-sponsored enterprises
(“Agency
securities”), or foreign governments; municipal
securities; money market mutual
funds;
certificates of deposit (“CDs”) (primary or
secondary); commercial paper;
The types of investments that are not permitted
for the GWG Investment Management Service
generally include, but are not limited to:
• rights or warrants on equity securities, written
covered call equity options;
• Class B or Class C shares offered by mutual
funds or any other class of mutual fund shares
that impose a contingent deferred or level sales
charge (back-end or level load);
• inverse funds;
• UITs that impose an initial or deferred sales
load-waived, or
for purchase; shares
charge (load);
• put options;
• all annuities and insurance products;
or
options
on
• commodities,
futures
commodities, and commodity pools; and
investment
funds
• private
• open-end mutual funds shares that Baird has
selected for use in the Service, which generally
includes only those funds with which Baird has a
selling agreement and only those funds that are
institutional are
no-load,
allowed
that were
in a Baird brokerage
originally purchased
account and not sold when transitioned to an
advisory account will held in the account as
non-billable assets when the original purchase
front-end sales charge
was subject to a
(typically 36 months) or until the Contingent
Deferred Sales Charge (CDSC) expires (typically
13 months) if subject to a back-end sales
charge after which time they will be converted
to the appropriate advisory share class and
become billable assets;
and Complex
Investment Products that Baird has not selected
for use in the Services.
for use
in
• closed-end funds, ETFs, and UITs that have cost
fee-based
structures designed
investment advisory programs; UITs originally
purchased in a brokerage account and not sold
when transitioned to an advisory account will be
held as non-billable assets until the UIT
SMA Services. Investment products under the
SMA Services are selected solely by
the
investment manager providing services to the
client. The investment products used by an
investment manager may include products that
Baird does not permit to be used in connection
with the GWG Investment Management Service
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
described above. A client should review the
investment manager’s Form ADV Part 2A
Brochure for more information.
the risk of trade errors, overinvestment, and
negative Account performance. A client should
consult the client’s GWG Consultant for further
information.
Special Considerations for the Services
Third Party Information
Consulting Services. From time to time, GWG
may advise clients with respect to, or may
manage, certain Held-Away Assets such as
investments, and
private REITs, real estate
insurance products held by custodians other than
Baird even though those assets may not be
eligible for Accounts held at Baird. Any such
arrangement will be set forth in the client’s
advisory agreement.
Unsupervised Assets
and
or
supervised
by
them
When providing services to a client, GWG and
Baird rely on information provided by third parties
and other external sources believed to be reliable,
including, but not limited to, information provided
by investment managers. GWG and Baird assume
that all such information is accurate, complete
and current. GWG and Baird do not conduct an in-
depth review of, or verify, such information, and
they do not guarantee the accuracy of the
“Portfolio Manager
information used. See
Selection
Evaluation—Performance
Calculation” and “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Methods of Analysis”
below for more information.
Goal Management
service
If
a
client
holds
Under certain circumstances, Baird, in its sole
discretion, may accept a client request to hold an
asset in an Account that is not included in the
investment advisory services provided by Baird or
a GWG Consultant or otherwise monitored,
overseen
(an
“Unsupervised Asset”). For example, if Baird
permits a client
to hold an Unpermitted
Investment in an Account, the asset is typically
also considered an Unsupervised Asset. Baird, in
its sole discretion, may also designate an asset
that is otherwise a Permitted Investment as an
Unsupervised Asset under certain circumstances,
such as when a client acquires the asset in an
unsolicited transaction, transfers the asset from
firm or Baird
an account held at another
brokerage account, or continues to hold the asset
against Baird’s or the client’s GWG Consultant’s
recommendation.
an
Unsupervised Asset in an Account, the client
should understand that the Unsupervised Asset
may not be included in performance reports
provided to the client and that Baird and GWG
Consultants do not manage, provide investment
advice, or otherwise act as an investment adviser
with respect to the Unsupervised Asset, even if
the Unsupervised Asset is included in account
statements or performance reports provided to
the client. Because Baird and GWG Consultants do
not manage or provide investment advisory
services regarding Unsupervised Assets, no asset-
based Advisory Fee is charged on Unsupervised
Assets. While Unsupervised Assets are not subject
to the asset-based Advisory Fee, Baird may
impose additional fees upon Accounts holding
Unsupervised Assets. See “Other Fees and
Expenses” below for more information. A client
should also understand
that holding an
Unsupervised Asset in an Account may increase
GWG and Baird make available to clients an
(“Goal
optional goal management
Management”). Goal Management provides clients
the ability to set a single, overall investment
objective for all or a portion of assets selected by
the client with the flexibility of using multiple,
eligible Advisory Accounts that may have different
investment strategies or objectives. If a client
elects to have Baird implement a plan of Goal
Management (a “Goal Management Plan”) using
two or more eligible Advisory Accounts (“Goal
Management Accounts”), the Goal Management
Accounts, taken together, will be managed or
advised by Baird and client’s GWG Consultant in
such a way so as to seek to achieve a single,
overall goal or
investment objective (“Goal
Management Objective”) chosen by the client.
Each individual Account included in a Goal
Management Plan will also be managed or advised
in
by Baird and client’s GWG Consultant
accordance with the terms of the applicable
Advisory Program or Service and any investment
strategy or objective applicable to the Account.
However, to the extent consistent with the terms
applicable to an Account included in a Goal
Management Plan, each
individual Account
included in the Goal Management Plan may be
managed or advised in any manner believed by
Baird or the client’s GWG Consultant to be
the Goal
appropriate
necessary
or
for
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Management Accounts, taken together, to seek to
achieve the Goal Management Objective.
risks,
and
allocation risks, capitalization risks, investment
style risks, illiquid securities and liquidity risks,
concentration risks, frequent trading and portfolio
risks, Non-Traditional Assets and
turnover
Complex
Complex
Strategies
Investment Product risks.
is contained under
The Goal Management Objectives that Baird
makes available to clients as part of Goal
Management include: (1) All Growth; (2) Capital
Growth; (3) Growth with Income; (4) Income
with Growth; (5) Conservative Income; and (6)
Capital Preservation. A description of those
objectives
the heading
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Loss—Investment Strategies—Asset
Risk of
Allocation Strategies” below.
included
in
A client should note, particularly if the client
elects to include eligible Advisory Accounts in a
Household Goal Management Plan, that: if an
Account is removed from a Goal Management
Plan for any reason, including if the client ceases
to be a member of the same household, the
Service and strategy for the Account removed
from the Goal Management Plan will remain
unchanged unless a change is requested by the
client; further, the Account removed from the
Goal Management Plan will not be allocated assets
from other Accounts
the Goal
Management Plan unless the client and all other
applicable clients, if any, consent and direct Baird
to do so and then only to the extent permitted by
applicable law; and GWG and Baird will have no
liability for implementing a Goal Management Plan
as requested by the client.
Tax Management Services
In certain circumstances, clients that are part of
the same household may include their eligible
Advisory Accounts in the same Goal Management
Plan (a “Household Goal Management Plan”). It is
the client’s sole responsibility to notify GWG that
the client is part of a household so that GWG is
aware of the client’s eligibility for a Household
Goal Management Plan. It is also the client’s sole
responsibility to notify GWG whenever the client
ceases to be part of a household if an Account is
part of a Household Goal Management Plan.
Failure to do so could have a materially negative
impact on applicable Accounts.
Many Services and managers make available tax
management strategies and services that are
intended to reduce the negative impact of U.S.
federal income taxes on an Account and enhance
Account performance by selectively
trading
investments in the Account to recognize or avoid
investment gains and losses.
An Account will be removed
from a Goal
Management Plan: (1) upon request or consent of
the client, (2) if the Account ceases to be an
eligible Advisory Account, (3) in the event the
Account is part of a Household Goal Management
Plan, if the client notifies GWG that the client
ceases to be a member of the applicable
household, or (4) upon written notice from Baird
that it is no longer able to manage the Account
according to the Goal Management Plan.
Certain Services and managers
include tax
management services as a default feature of the
Services or the manager’s services. A client that
wishes to opt an Account out of participation in a
tax management service should contact the
client’s GWG Consultant.
Tax management services are provided solely
information
the direction and
based upon
provided by a
client. The offering and
performance of tax management services to a
client’s Account does not constitute tax advice. A
client is ultimately responsible for all tax-related
consequences resulting from the client’s decision
to enroll in a Service or select a manager that
utilizes tax management services.
Given the nature of Goal Management, a client
enrolling Accounts in a Goal Management Plan
should understand that each Account enrolled in a
Goal Management Plan may not be invested in a
manner such that the individual Account alone
would be able to achieve the Goal Management
Objective. It is likely that one or more Accounts
included in a Goal Management Plan, taken alone,
will be managed or advised differently and will be
subject to greater or enhanced risks than would
be the case if the Account alone had the same
objective as the Goal Management Objective.
Such enhanced risks include, without limitation,
market risks, investment objective and asset
Tax management strategies are not intended to,
and likely will not, eliminate a client’s U.S. federal
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment strategies
objective of an Account to reduce the negative
impact of U.S. federal income taxes and each
such strategy is implemented together with the
for the
other primary
Account that are designed to achieve the client’s
primary investment objectives or goals.
The GWG TM Strategies features are not available
to Retirement Accounts.
Tax Harvesting Strategy
for
tax
purposes
in
Information—Legal
and
and Risk
of
the GWG Consultant,
as
income tax obligations relating to investments in
an Account. Like all investment strategies, there
is no guarantee that the implementation of a tax
management strategy will be successful. A client’s
use of a tax management strategy may not
actually
lower a client’s tax obligations or
otherwise achieve a client’s tax goals. The
effectiveness of tax managed strategies and
impacted by
services may be negatively
applicable tax rules, such as the IRS wash sales
rules and straddle rules, which will disallow, limit
or defer a client’s ability to recognize losses in an
specified
Account
circumstances. Tax management strategies and
services also involve special risks. See “Additional
Service
Tax
Considerations” and “Portfolio Manager Selection
and Evaluation—Methods of Analysis, Investment
Strategies
Loss—Investment
Strategies—Tax Management Strategies” below
for more information.
A client should understand the terms of the tax
management services that will be implemented,
including the associated limitations, risks and
additional costs, if any, before enrolling an
Account in a Service or selecting a manager for
that Account. A client is strongly urged to consult
with the client’s tax advisor about potential tax
implications before enrolling an Account in a
Service or selecting a manager for that Account. A
client is also encouraged to discuss the client’s tax
management needs with
the client’s GWG
Consultant.
the
IRS wash
sales
GWG Tax Management Strategies
A tax harvesting strategy seeks to improve the
value of an Account, on a post U.S. federal
income tax basis, by offsetting capital losses in
the Account with capital gains. This strategy is
oftentimes referred to a “tax harvesting” or “tax
implementing a tax
loss harvesting”. When
harvesting strategy, the Baird PWM Home Office
or
applicable,
periodically, but at least annually, conducts an
assessment of the Account to identify capital
losses for tax harvesting opportunities. When an
opportunity is identified, the Baird PWM Home
Office or the GWG Consultant, as applicable, sells
(or recommends the sale of) certain securities in
the client’s Account in order for the Account to
recognize the unrealized capital losses identified
as part of the assessment process. The Baird
PWM Home Office or the GWG Consultant will
then reinvest (or recommend the reinvestment
of) the proceeds of such sale in one or more
replacement securities that the GWG Consultant
believes are not “substantially identical” for
purposes of
rules.
include, without
Replacement securities may
limitation, ETFs, cash, cash equivalents or other
securities. Unless the client instructs otherwise,
investment in replacement securities will be made
on a temporary basis and generally only for the
duration of any applicable IRS wash sale rule
period, currently 30 days after the sale, and
within a reasonable time thereafter, the proceeds
will be reinvested in a manner consistent with the
way the Account was invested prior to the
employment of the tax harvesting strategy.
the
implementation of
the
implementation of
Certain GWG Consultants offer tax management
investment strategies (“GWG TM Strategies”),
described below, to non-Retirement Accounts
enrolled in GWG Consultant-directed Services,
including the GWG Investment Management
Service. A client is encouraged to ask the client’s
GWG Consultant if GWG TM Strategies will be
used if the Account is enrolled in a Service. GWG
Consultants who offer GWG TM Strategies will
generally implement such strategies for Accounts
they manage on a discretionary basis unless a
client opts out by contacting the client’s GWG
Consultant. The Baird PWM Home Office will assist
with
the GWG TM
the
Strategies.
Generally,
tax
harvesting strategy is limited to open end mutual
fund and ETF positions with unrealized capital
losses over $1,000 for U.S. federal income tax
purposes, unless Baird and the client otherwise
agree.
Each GWG TM Strategy is a secondary investment
to achieve a secondary
strategy designed
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Capital Gains Avoidance Strategy
the extent such estimates or
strategy,
to
information are incorrect.
for
capital
gains
in Baird’s or
judgment,
negatively
The implementation of the tax harvesting strategy
and capital gains avoidance strategy (or the
recommendation to implement a strategy) is done
in the sole discretion of the Baird PWM Home
Office or GWG Consultant, as applicable, and
securities may be excluded from implementation
of such strategies for a number of reasons,
including without limitation, the length of time the
security has been in the Account, the lack of a
replacement security acceptable to Baird or the
GWG Consultant, withdrawal and deposit activity
in
the Account, market conditions deemed
unfavorable by Baird or the GWG Consultant, or if
the GWG
doing so would,
impact
Consultant’s
management of the Account.
The tax harvesting and capital gains avoidance
strategies are provided by Baird and GWG
Consultants on an Account-by-Account basis.
When employing such strategies for a client
Account, Baird does not monitor or consider the
trading activity in any other client account,
including any Account held at Baird or another
firm.
A capital gains avoidance strategy seeks to avoid
capital gains attributable to an investment in the
Account for U.S. federal income tax purposes by
selling the investment before the capital gain is
distributed by the issuer. When implementing a
capital gains avoidance strategy, the Baird PWM
the GWG Consultant, as
Home Office or
applicable, periodically, but at least annually,
monitors the issuers of investments held in the
Account
distributions
announcements and capital gains avoidance
opportunities. When an opportunity is identified,
the Baird PWM Home Office or the GWG
Consultant, as applicable, sells (or recommends
the sale of) such securities in the client’s Account
identified as part of the monitoring process in
order for the Account to avoid a capital gain
distribution made by the issuer. The Baird PWM
Home Office or the GWG Consultant will then
reinvest (or recommend the reinvestment of) the
proceeds of such sale in cash until the capital gain
distribution has been paid by the issuer, and then
the securities will be purchased again. If the
securities are sold at a loss, then Baird PWM or
the GWG Consultant may employ (or recommend
the employment of) the tax harvesting strategy
described above.
A client should also note that when normal
for the client’s
is resumed
trading activity
Account, such activity could generate taxable
gains or losses.
Third Party Manager Tax Management
Services
the
Generally, the capital gains avoidance strategy is
limited to open end mutual fund positions in a
client Account, and a mutual fund position will be
included in the implementation of the strategy
only if the potential net U.S. federal income tax
benefit to the Account related to such position is
estimated by Baird to be $1,000 or more. For
purposes of calculating the $1,000 threshold, the
Account’s current unrealized gain or loss in each
mutual fund position is analyzed in light of the
applicable amount of capital gains distribution
announced by the mutual fund company.
Some investment managers participating in the
SMA Services offer tax management services and
others do not. A client should consult the client’s
investment
GWG Consultant or review
manager’s Form ADV Part 2A Brochure for specific
information.
Additional Important Information about GWG’s
Tax Management Strategies.
Client-Directed Tax Management Strategies
implementation of a
responsibility
for
A client may direct GWG and Baird, and GWG and
Baird may agree, to implement an investment
strategy designed by the client or client’s tax
advisors for the client’s specific tax purposes (a
“client-designed strategy”). GWG and Baird do
not undertake any
the
development, evaluation or efficacy of any client-
designed strategy.
The
tax management
strategy is based upon Baird’s or the GWG
Consultant’s, as applicable, estimates of capital
gains and losses associated with investments in
client’s Account and information provided to them
by third parties, such as issuers of securities.
Capital losses will remain in an Account following
the implementation of a tax harvesting strategy,
and the Account will realize capital gains following
the implementation of a capital gains avoidance
31
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Investment Objectives
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of fixed income securities and
equity securities, with a bias towards fixed income
securities. Such an Account may also hold other
types of investments.
responsible
for
selecting
for
Generally, every Account will have one of the
investment objectives described below. Although
recommend an
a GWG Consultant may
investment objective for an Account based upon
the information provided by a client, the client is
ultimately
the
the Account. The
investment objective
investment objective will determine, in part, and
limit the Services, investment products and
services that will be made available to the
Account.
Conservative Income. A Conservative Income
investment objective typically seeks to provide
current income. Typically, an Account pursuing a
Conservative Income investment objective will
experience relatively small fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, such an Account
will primarily invest in a mix of fixed income
securities, cash and equity securities, with a
significantly higher allocation to fixed income
securities. Such an Account may also hold other
types of investments.
All Growth. An All Growth investment objective
typically seeks to provide growth of capital.
Typically, an Account pursuing an All Growth
investment objective will experience high
fluctuations in annual returns and overall market
value. Under normal market conditions, such an
Account generally invests nearly all of its assets in
equity securities. Such an Account may also hold
other types of investments.
Capital Preservation. A Capital Preservation
investment objective typically seeks to preserve
capital while generating current income. Typically,
an Account pursuing a Capital Preservation
investment objective will experience relatively
small fluctuations in annual returns and overall
market value. Under normal market conditions,
such an Account generally invests nearly all of its
assets in a mix of fixed income securities and
cash. Such an Account may also hold other types
of investments.
Capital Growth. A Capital Growth investment
objective typically seeks to provide growth of
capital. Typically, an Account pursuing a Capital
Growth
investment objective will experience
moderately high fluctuations in annual returns
and overall market value. Generally, under
normal market conditions, such an Account will
primarily invest in a mix of equity securities and
fixed income securities, with a significantly higher
allocation to equity securities. Such an Account
may also hold other types of investments.
for
a
client’s
specific
Growth with Income. A Growth with Income
investment objective typically seeks to provide
moderate growth of capital and some current
income. Typically, an Account pursuing a Growth
with Income investment objective will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of equity securities and fixed
income securities, with a bias towards equity
securities. Such an Account may also hold other
types of investments.
investment
objective
Opportunistic. An Opportunistic
investment
objective typically seeks to provide long term
growth
through capital appreciation and/or
income by utilizing an active management style
that shifts the percentage of assets held in
various investment categories to take advantage
of the manager’s perception of market pricing
anomalies, market sectors deemed favorable for
investment by the manager, the current interest
rate environment or other macro-economic trends
identified by the manager to achieve growth while
accounting
short,
intermediate and long term investment and/or
cash flow needs. Depending upon the investment
strategy used, an Account pursuing an
Opportunistic
could
experience high fluctuations in annual returns and
overall market value. The types of investments in
which such an Account may invest will also vary
widely, depending upon the particular investment
strategy used.
Income with Growth. An Income with Growth
investment objective typically seeks to provide
current income and some growth of capital.
Typically, an Account pursuing an Income with
Growth
investment objective will experience
moderate fluctuations in annual returns and
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
long-term growth by
investments based upon
in
to
implement a
typically
objective
and
overweighting
index or
Tactical. A tactical investment objective seeks to
provide
tactically and
actively adjusting account allocations to different
the
categories of
manager’s perception of how those investment
the short-term.
categories will perform
tactical
Strategies used
investment
involve
account
underweighting
allocations to certain asset classes, geographic
locations or market sectors relative to an
applicable long-term strategic asset allocation,
the market generally.
benchmark
Accounts with a tactical investment objective may
have investments focused or concentrated in
certain asset classes, geographic locations or
market sectors and they often experience higher
levels of trading and portfolio turnover relative to
accounts with other investment objectives.
A
Tax-Managed
indicates
that
the
account
investment
Tax-Managed.
is
objective
transitioning from one investment strategy to
another using one or more tax management
strategies or tax management considerations. The
primary investment strategy or consideration for
investment
Accounts with a Tax-Managed
objective will involve tax management, and such
accounts may not be successful in pursuing any
other investment strategies, objectives or goals.
Goal. A Goal investment objective indicates that
the Account is a Goal Management Account that is
part of a Goal Management Plan and the Account
will be managed or advised in accordance with
the applicable Goal Management Objective.
of
Investment Objectives
For information about the risks associated with
the investment objectives described above, see
the section of the Brochure entitled “Portfolio
Manager Selection and Evaluation—Methods of
Analysis, Investment Strategies and Risk of
Loss—Principal Risks—Risks Associated with
Certain
and Asset
Allocation Strategies” below.
Mutual Fund Share Class Policy
Most mutual funds offer different share classes.
While each share class of a given mutual fund has
the same underlying investments, those share
classes have different fees, costs and investment
minimums, and they provide different levels of
compensation to Baird. In an effort to provide
clients with appropriate low cost mutual fund
investment options for their fee-based investment
advisory accounts, Baird has established a mutual
fund share class policy (“Share Class Policy”) for
certain GWG-directed Services, including GWG
Investment Management (the “Share Class Policy
Services”). Typically, only one share class of a
given mutual fund family will be made available
for purchase by clients in the Share Class Policy
Services pursuant to the Share Class Policy (the
“Approved Share Class”). When selecting the
Approved Share Class for a mutual fund family,
Baird endeavors to select the share class with the
lowest expense ratio, based upon the average
expense ratio of the class across all mutual funds
in the mutual fund family, that are widely
available for trading on the mutual fund trading
platform of Charles Schwab & Co.,
Inc.
(“Schwab”). In selecting the share class for a
mutual fund family to be made available for
purchase by clients in the Share Class Policy
Services, Baird considers a number of factors,
including the number of funds within the fund
family that offer the share class, client positions
in and demand
funds, and the
for those
availability of the share classes and funds for
purchase on the Schwab mutual fund trading
platform. Generally, share classes designed for
retirement plans and those that pay a distribution
(12b-1) fee to Baird will not be permitted in those
Services, or, if such share classes are permitted
and the client’s Account is subject to an asset-
based fee arrangement, Baird will either: (1)
rebate the distribution (12b-1) fees to a client if
the client is paying an asset-based Advisory Fee
on such investment; or (2) exclude such fund
shares from the calculation of the client’s asset-
based Advisory Fee (sometimes referred to as
“unbillable assets”) for such period of time that
Baird collects and retains the distribution (12b-1)
fee as further described under the heading
“Additional
Ethics,
Information—Code
Participation or Interest in Client Transactions and
Personal Trading—Participation or Interest
in
Client Transactions—Investment Product Selling
or Servicing—Mutual Funds” below. Clients should
note that the Approved Share Class for a mutual
fund family is based upon the average expense
ratio for the class across all mutual funds in the
fund family and not on a fund-by-fund basis.
Further, the expenses of every mutual fund can
and will vary over time. Therefore, while Baird
has endeavored to select the lowest cost share
classes as described above, in some instances,
the Approved Share Class is not the least
expensive share class for a particular mutual
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
fund. Clients may be able to obtain a less
expensive share class in other Programs or at
another firm.
from
payments,
revenue
sharing
client’s Account assets, crediting contributions
and interest and dividends received on securities
held in a client’s Account, and making or
the Account.
“debiting” distributions
Information about account statements and
performance reports, if any, that GWG and Baird
provide to clients is contained under the heading
“Services, Fees and Compensation–Consulting
Services” above and “Additional Information—
Review of Accounts” below.
the applicable mutual
As custodian, Baird may hold a client’s Account
assets in nominee or “street” name, a practice
that refers
to securities and assets being
registered in Baird’s name or in a name that Baird
designates, rather than in a client’s name directly.
Baird will be the holder of record in those
instances.
Baird may utilize one or more subcustodians to
provide for the custody of a client’s assets in
certain circumstances. For instance, Baird utilizes
subcustodians to maintain custody of certain
client assets participating in the Cash Sweep
Program (described below) and securities that are
traded on foreign exchanges.
Interest
Baird receives certain compensation from mutual
fund families in the form of distribution (12b-1)
fees, shareholder servicing fees, transfer agency
fees, networking fees, accounting fees, marketing
support
and
administration fees. The amount of compensation
paid to Baird generally varies based upon the
share class of
fund
purchased by clients. Because the compensation
that Baird receives from certain mutual funds is
based upon share class purchased by clients,
Baird has a financial incentive to make available
to clients those share classes that provide Baird
greater compensation, which, in many instances,
would cause clients investing in those share
classes to incur higher ongoing costs relative to
other share classes made available by the fund
families. This presents a conflict of interest. Baird
addresses this conflict through the Share Class
Policy described above and through disclosure in
this Brochure. For more information about the
compensation that Baird receives from mutual
funds, see “Additional Information—Code of
Ethics, Participation or
in Client
Transactions and Personal Trading—Participation
or Interest in Client Transactions—Investment
Product Selling and Servicing—Mutual Funds”
below.
Shares of mutual funds held in client Accounts
that do not meet the requirements of the Share
Class Policy will generally be converted to the
applicable Approved Share Class subject to
certain restrictions. The Share Class Policy is
subject to change at Baird’s discretion without
notice to clients. Additional information about the
Share Class Policy is available on Baird’s website
at bairdwealth.com/retailinvestor.
The Share Class Policy does not apply to the
portion of a UAS Account managed by third party
managers. Third party managers are responsible
for establishing their own criteria for selecting
investments, including mutual funds, if any.
to client Accounts on
Custody Services
Certain Services may require clients to custody
their Account assets at Baird. If Baird is the
custodian of a client’s assets, Baird will provide
certain custody services, including holding the
GWG and Baird in their sole discretion may accept
into a client’s Account,
Held-Away Assets
including assets
that are held by another
custodian (a “third party custodian”). A client who
uses a third party custodian to hold Account
assets does so at the client’s risk. A client should
understand that GWG and Baird do not monitor,
evaluate or review any third party custodian
unless they otherwise agree to do so in writing.
The client should also understand that the client
will pay a custody fee to the third party custodian
in addition to the Advisory Fee. Baird may also
impose additional fees on Accounts with assets
held by a third party custodian due to the
increase in resources needed to administer those
Accounts. Further, such third party custody
arrangements may
limit the Services made
available to the client. In addition, a client should
understand that: (a) each third party custodian
has exclusive control over the investment options
made available
the
custodian’s platform; (b) GWG and Baird have no
authority or ability to add to, or remove from, a
custodian’s platform any investment option; (c)
any advice given by GWG or Baird with respect to
the Account is inherently limited by the options
available through a custodian’s platform; (d) GWG
or Baird may have provided different investment
34
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
is
available
advice with respect to the Account had they not
been limited to the investment options made
available through the custodian’s platform; and
(e) certain investments, such as mutual fund
shares, could be more or less expensive than if
the investment was obtained from Baird or
another firm. A client should further note that
GWG and Baird may not provide performance
review or reporting for Held-Away Assets. In
addition, a client who uses a third party custodian
is not eligible for cash sweep services offered by
Baird. Clients using a third party custodian are
encouraged to establish appropriate cash sweep
arrangements.
program (currently, $2,500,000 for most account
types and $5,000,000 for joint accounts). A client
receives interest on cash balances in deposit
accounts under the Bank Sweep Feature at tiered
rates that are based on the aggregate value of
the accounts within the client’s household. The
applicable client household tier values are: less
than $1 million; at least $1 million but less than
$2 million; at least $2 million but less than $5
million; and $5 million are more. Current rate
at
information
rwbaird.com/cashsweeps. Each deposit account at
a bank constitutes a direct obligation of the bank
and is not directly or indirectly Baird’s obligation.
(e.g.,
A client who uses a third party custodian
authorizes GWG and Baird to give instructions to
the client’s custodian for all actions necessary or
incidental to the purchase, sale, exchange, and
delivery of securities held in the client’s Account.
Also, the client will receive account statements
directly from the client’s selected custodian. A
client should carefully review those account
statements and
them with any
compare
statements provided by GWG or Baird. A client
should note that the prices shown on a client’s
Account statements provided by the custodian
could be different from the prices shown on
statements and reports provided by GWG or Baird
due to a variety of factors, including the use of
different valuation sources and accounting
methods
settlement date
trade or
accounting) by the custodian and Baird.
Cash Sweep Program
Any aggregate cash balances held by a client in
excess of the applicable aggregate deposit limit
are automatically invested in shares of a money
market mutual fund that Baird makes available in
the Money Market Fund feature of the program.
Cash held in employee benefit plan accounts,
employee health and welfare plan accounts, donor
advised fund accounts, and SEP and SIMPLE IRAs
will be automatically invested or swept into a
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the program. In addition, clients with aggregate
cash balances of $5 million or more across all of
their accounts with Baird within the same
household may opt out of the Bank Sweep
Feature and instead have all of their cash
balances automatically swept into an institutional
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the program. More information about the Money
Market Fund Feature of Baird’s Cash Sweep
Program is available at rwbaird.com/cashsweeps.
to provide FDIC
Baird maintains a Cash Sweep Program that is
intended for clients who want to earn interest and
receive FDIC insurance protection on their cash
over short periods of
time while awaiting
investment. If a client participates in Baird’s Cash
Sweep Program, uninvested cash in the client’s
accounts will be automatically deposited or swept,
on a daily basis, into one or more FDIC-insured
deposit accounts at participating banks (the “Bank
Sweep Feature”) or, under certain conditions, will
be automatically invested in shares of a money
market mutual fund that Baird makes available in
the program (the “Money Market Fund Feature”),
subject to the terms and conditions of the
program. By using multiple participating banks as
opposed to a single bank, the Bank Sweep
Feature seeks
insurance
protection for a client’s cash balances of up to an
aggregate deposit limit determined under the
The Bank Sweep Feature seeks to provide FDIC
insurance protection for a client’s cash balances
up to an aggregate deposit limit determined
under the program. Any deposits, including CDs,
that a client maintains, directly or indirectly
through an intermediary (such as us or another
broker), with a bank participating in the Cash
Sweep Program in the same capacity with the
bank will be aggregated with the client’s cash
balances deposited with the bank under the Cash
Sweep Program for purposes of calculating the
$250,000 FDIC insurance limit. Total deposits
exceeding $250,000 at a bank may not be fully
insured by the FDIC. A client is responsible for
monitoring the total amount of other deposits that
the client has with a bank outside the Cash Sweep
Program in order to determine the extent of
35
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
deposit insurance coverage available. Baird is not
responsible for any insured or uninsured portion
of a client’s deposits at a bank. Cash invested in a
money market mutual fund under the Money
Market Fund Feature is not FDIC insured, but is
protected by Securities
Investor Protection
Corporation (“SIPC”) coverage up to applicable
limits.
Baird for the services Baird provides to the banks
and funds and for Baird’s efforts in maintaining
the Cash Sweep Program. The compensation that
Baird receives from the Cash Sweep Program
gives Baird a financial incentive to recommend
that a client participate in the Cash Sweep
Program and maintain high levels of uninvested
cash balances in the client’s accounts.
receives
compensation
for
account
values
of
As an alternative to the Cash Sweep Program,
Baird makes available other money market
mutual funds and other cash alternatives in which
a client may invest, often at a higher yield,
although these investments do not have an
automatic sweep feature. In addition, instead of
maintaining cash balances in an advisory Account,
a client has the option to maintain such cash
balances in a brokerage account that is not
subject to an asset-based Advisory Fee.
in connection with
less. For
A client should understand that the Cash Sweep
Program is an ancillary account service and it is
not nor is it part of any advisory program or
investment advisory service. GWG and Baird do
not act as investment adviser or a fiduciary to a
client
the Cash Sweep
Program. However, a client should note that the
amount of the client’s advisory Account dedicated
to cash and cash equivalents is part of the overall
investment allocation advice provided to the client
and thus the amount of such cash and cash
equivalents included in the calculation of the
Advisory Fee for the client’s advisory Account.
on
website
More detailed information about the Cash Sweep
Program and the compensation Baird receives is
available
at
Baird’s
www.rwbaird.com/cashsweeps. A
client also
receives information about the compensation
Baird receives from the Cash Sweep Program
through a client’s account statements.
Trust Services Arrangements
trust administration
trust administration, custody,
its
related
to
those assets, and
certain
Baird maintains an alliance with
institutions, both non-affiliated and affiliated,
including Baird Trust Company (“Baird Trust”),
services,
that provide
including
tax
reporting and recordkeeping. GWG Consultants at
times refer clients seeking trust services to
institutions that are members of the alliance.
Subject to
fiduciary duties, the trustee
oftentimes retains Baird to provide investment
advisory services to the client trust. A client
Baird
the
administrative, accounting and other services that
Baird provides under the program, which is paid
out of the aggregate interest that is paid by the
participating banks on the aggregate client
balances in the deposit accounts participating in
the Bank Sweep Feature. Baird’s annual rate of
compensation may be up to 3.60% of the
for clients with
aggregate client balances
household
than
less
$1,000,000, 2.45% for clients with household
account values of $1,000,000 but less than
$2,000,000, 2.00% for clients with household
account values of $2,000,000 but less than
$5,000,000, and 1.75% for clients with household
account values of $5,000,000 or more. In a lower
interest rate environment Baird’s annual rate of
fee-based
compensation will be
investment advisory IRA accounts participating in
the Bank Sweep Feature, Baird’s compensation is
a monthly per account fee (which is the same
regardless of client balances in bank deposit
accounts). The per account fee for these advisory
IRA accounts is generally paid out of the interest
that the banks pay on aggregate client balances
in the deposit accounts, and the per account fee
varies based on the applicable Fed Funds Target
Rate but in no event will it exceed $19.00 per
month. Baird also receives an annual rate of
compensation of up to 0.50% of the aggregate
client balances automatically invested into money
market mutual funds under the Money Market
Fund Feature. A client should note that the client
will be charged the asset-based Advisory Fee on
the value of all of the assets in the client’s
Accounts, including cash that is swept into a bank
deposit account or invested into a money market
mutual fund under the Cash Sweep Program. As a
result, Baird receives two layers of fees on a
client’s assets swept or invested in the Cash
the Advisory Fee, which
Sweep Program:
compensates Baird for the investment advice,
trading and custody services provided to the
client
the
compensation paid by the banks or money market
funds related to those assets, which compensates
36
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
any
trust
website
contact
loan, Baird has an
incentive
financial
incentive
trust administration
should understand that any such referral for trust
services under the Trust Alliance Program made
by Baird and its GWG Consultants is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
services
such
oversee
arrangement. Baird has a financial incentive to
recommend that clients use Baird Trust, an
affiliate, over other non-affiliated trust companies.
As a result of this affiliation, Baird Trust also has
a financial incentive to retain Baird to provide
investment advisory or other services on behalf of
In addition, Baird and GWG
the client.
Consultants have a
to
recommend arrangements that involve Baird and
the GWG Consultant providing
investment
advisory services to the client and the trust
company only providing trust administration
services compared to an arrangement whereby a
trust company would provide both investment
advisory and
services
because it is more profitable to Baird and the
GWG Consultant.
that any margin balance
(i.e.,
ongoing
Baird
Trust
generally
paid
to Baird
margin, the client will pay Baird interest on the
amount the client borrows. The rate of interest
that a client pays on a margin loan will be at a
base rate determined by Baird plus or minus a
specified percentage that varies based on the
outstanding debit balance of the margin loan and
the client’s household account value. Interest
rates are lower for larger debit balances and
those with higher household account balances. As
a result, rates will vary. To determine the actual
interest rate that may apply to a client’s margin
loan,
at
Baird’s
visit
a GWG
rwbaird.com/loanrates or
Consultant. Because a client will pay interest to
Baird on the outstanding balance of the client’s
margin
to
recommend to the client investment products and
services that involve the use of margin. Baird and
GWG Consultants also have an incentive to
recommend investment products and services
that involve the use of margin, because a margin
loan allows a client to make larger securities
purchases and retain assets
in the client’s
Accounts
that pay an ongoing asset-based
Advisory Fee instead of liquidating them to fund a
cash need, which increases the asset-based fees
Baird earns on a client’s Accounts. A client should
note
the
outstanding amounts of the margin loan the client
owes to Baird) in the client’s advisory Accounts
will not be applied to reduce the client’s billable
account value in calculating the client’s asset-
based Advisory Fee, which gives Baird and GWG
Consultants further incentive to recommend client
use of margin instead of liquidating assets to fund
a cash need. Because the interest Baird receives
and fees Baird earns on a client’s Accounts
increase as the amount of the client’s margin loan
increases, Baird and GWG Consultants also have
incentive to recommend that the client
an
continue to maintain a margin loan balance with
Baird at high levels. Baird has the right to lend
the securities a client pledges as collateral for the
client’s margin loan, and Baird receives additional
compensation for lending those securities, which
provides Baird a further incentive to recommend
margin to a client.
In addition, outside of the Trust Alliance Program,
GWG Consultants may refer a client to Baird Trust
to provide investment management and trust
administration services to the client. If a client
enters into such a relationship with Baird Trust,
Baird and the client’s GWG Consultant typically
relationship management
provide
services.
provides
compensation to Baird and the client’s GWG
Consultant for the referral and providing ongoing
services, which may be up to 50% of the ongoing
fees that a client pays to Baird Trust, and which is
credited to the client’s GWG Consultant for
purposes of determining the GWG Consultant’s
compensation. The compensation paid to Baird
and a client’s GWG Consultant does not increase
the fees that the client pays to Baird Trust. Due to
Baird’s affiliation with Baird Trust and the
compensation
and GWG
Consultants, Baird and GWG Consultants have a
financial incentive to favor Baird Trust over other
trust companies.
Margin Loans
Margin involves borrowing money from Baird
using eligible securities as collateral, including for
the purpose of buying securities. If a client uses
A client should note that Baird’s margin loan
program is generally intended to be used to fund
additional purchases of securities. or short-term
liquidity needs. If a client wishes to obtain a loan
for some other purpose, a client should instead
consider whether the client is eligible for Baird’s
Securities-Based Lending Program, which involves
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
clients obtaining loans from third-party lenders for
general use purposes. Baird and GWG Consultants
have a conflict to the extent they would
recommend that a client use the Baird margin
loan program instead of the Securities-Based
Lending Program because a client pays interest
and other fees to Baird instead of a third-party
lender.
financial
incentive
Additional important information about margin,
including the risks and margin interest rates that
apply, is set forth in the “Margin” section of
Baird’s website at bairdwealth.com/retailinvestor.
Securities-Based Lending Program
of
website
party
lender under Baird’s Securities-Based
Lending Program, Baird and GWG Consultants
have an incentive to recommend that a client
obtain loans under that program. Baird and GWG
Consultants will continue to receive compensation
on assets held in a client’s accounts that are
collateral for such loans, including Advisory Fees
on such assets if those assets are in the client’s
advisory Account. As a result, Baird and GWG
Consultants have a
to
recommend that a client obtain a loan under the
program to provide for the client’s needs instead
of liquidating assets in the client’s accounts with
Baird because a decline in the amounts the client
has in the client’s accounts will result in lower
revenues to Baird and compensation paid to the
client’s GWG Consultant. Additional important
information about securities-based lending is set
forth in the “Securities-Based Lending Program”
section
at
Baird’s
bairdwealth.com/retailinvestor.
the
loan or
A client should understand that any referral made
by Baird and GWG Consultants under the
Securities-Based Lending Program is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
oversee any such lending arrangement.
Other Non-Advisory Services
Certain Baird associates from time to time may
provide clients with tax return preparation, bill
pay or related services. In some instances, the
fee for those services may be bundled with the
Advisory Fee. A client should understand that the
provision of such services is separate from, and
not related to, the Services offered under this
Brochure and will be governed by an agreement
separate from the client’s advisory agreement
with Baird. A client should understand that Baird
and its associates do not act as investment
advisor or fiduciary to the client when providing
tax return preparation, bill pay or related non-
advisory services to the client.
Client Responsibilities
Baird offers clients an opportunity to borrow
money from a third party lender under Baird’s
Securities-Based Lending Program. These loans, if
made, can be used for any personal or business
purpose other than to purchase, carry or trade
securities, or to repay margin debt. These loans
are secured by the investments and other assets
in the client’s accounts with Baird. A client will
pay interest on the outstanding balance of the
client’s loan. The rates of interest charged by the
bank depends on many factors, such as the
prevailing interest rate environment, the amount
of
line of credit, a client’s
creditworthiness, and the aggregate assets in a
client’s Baird accounts in the client’s household
(“relationship size”). The interest rates are based
on a benchmark
rate, plus an applicable
percentage that varies based on the approved
loan amount and the relationship size. Rates are
generally higher for smaller loans and relationship
sizes and lower for larger loans and relationship
sizes. The interest rate that will apply to a client’s
loan will be set forth in the loan agreement the
client enters into with the bank. Baird receives an
ongoing administrative fee from the bank, at an
annual rate of up to 2.50% of the outstanding
balance under a client’s loan, which is paid by the
bank out of the interest the client pays to the
bank. A client’s GWG Consultant typically receives
an ongoing referral fee at an annual rate of up to
0.25% of the outstanding balance of the client’s
loan, which is paid out of Baird’s administrative
fee. A client should note that Baird and GWG
Consultants will continue to receive compensation
on assets held in the client’s accounts that serve
as collateral for the client’s loans, including
Advisory Fees. Because Baird
receives an
administrative fee and GWG Consultants receive a
referral fee if a client obtains a loan from a third
A client is responsible for providing information to
Baird and the client’s GWG Consultant reasonably
requested by them in order to provide the
services selected by the client. Baird, the client’s
GWG Consultant and investment managers, if
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
informing
the
for U.S. federal income tax purposes, which has
tax implications different from other types of
investments, including Schedule K-1 reporting.
taxable
Clients with tax-exempt Accounts, such as certain
Retirement Accounts or charitable or religious
organization Accounts, should be aware that some
investments, such as some Non-Traditional
Assets, Alternative Investments and Complex
Investments, may produce
income,
referred to as unrelated business taxable income
(“UBTI”). In such circumstances, such clients will
be required to pay tax on the UBTI produced by
the tax-exempt Accounts.
any, will rely on this information when providing
services to the client. A client is also responsible
for promptly
client’s GWG
Consultant of any significant life changes (e.g.,
change in marital status, significant health issue,
or change in employment) or if there is any
change to the client’s investment objectives, risk
tolerance,
investment
financial circumstances,
needs, or other circumstances that may affect the
manner in which the client’s assets are invested.
None of Baird, the client’s GWG Consultant or any
investment manager managing a client’s Account
for any adverse consequence
is responsible
arising out of the client’s failure to promptly
inform the client’s GWG Consultant of any such
changes. Since investment goals and financial
circumstances change over time, a client should
review the client’s participation in a Service with
the client’s GWG Consultant at least annually.
Retirement Accounts
A client’s ability to recognize losses in an Account
for tax purposes may be disallowed, limited or
deferred by applicable tax rules. For example, IRS
wash sales rules will disallow a client’s tax
deductions for a loss in an Account related to the
sale of an investment if the client purchases
(whether through Baird or another firm) a
“substantially identical” investment within the
wash sale period (currently 30 days before or 30
days after the date of the sale). Similarly, IRS
straddle rules limit and defer a client’s ability to
claim tax deductions related to the loss on a sale
of an investment in an Account if the client holds
an offsetting position in any account held at Baird
or another firm.
the Services,
Additional laws, regulations and other conditions
apply to Retirement Accounts. Each owner,
trustee, plan
sponsor, adopting employer,
responsible plan fiduciary, named fiduciary, or
other fiduciary acting on behalf of a Retirement
Account (“Retirement Account Fiduciary”) should
understand that GWG and Baird do not provide
legal advice regarding Retirement Accounts. A
Retirement Account Fiduciary is urged to consult
with his or her own legal advisor about the laws
and regulations that may apply to Retirement
Accounts. ERISA and the IRC prohibit GWG and
Baird from offering certain types of investment
products and services to Retirement Accounts.
Legal and Tax Considerations
the
tax
implications of
A client’s investment activities may have legal
and tax consequences to the client.
purchases,
sales,
The investment strategies used for a client’s
Account and transactions in a client’s Account,
including
liquidations,
redemptions, and rebalancing transactions, may
cause the client to realize gains or losses for
income
tax purposes. Funds often make
distributions of income and capital gains to
investors, which may cause the client to realize
income for tax purposes.
GWG and Baird do not offer legal or tax advice to
clients. The information, recommendations, and
services provided by GWG and Baird to clients
through
including, without
limitation, tax management strategies, do not
constitute tax advice. A client is responsible for
understanding
the
investment activities in the client’s accounts
(whether held at Baird or another firm) and
complying with applicable tax rules. A client is
strongly urged to consult with the client’s tax
advisor about potential tax implications before
making investment or trading decisions. GWG and
Baird do not undertake any responsibility to
monitor or verify a client’s compliance with
applicable tax rules, and they are not responsible
for any tax‑related effects or obligations resulting
from the investments or transactions in a client’s
Account.
Certain investment products, such as Alternative
Investments and Complex Investments, are
classified as partnerships. Clients invested in such
investment products will be treated as partners
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Advisory Fees
Fee Options and Fee Schedule
Clients with a Unified Advice Fee Arrangement
generally choose a tiered fee schedule for the
Advice Fee portion of the Advisory Fee.
Tiered Advice Fee Schedule
following
fee schedule sets
tiered Advice Fee rates
forth
for
the
the
The
maximum
Services.
A client’s advisory agreement will set forth the
actual compensation the client will pay to Baird.
In most instances, a client pays an ongoing
Advisory Fee based upon the value of assets in
the client’s Account (an “asset-based
fee”),
although other options, such as a flat fee, are
available.
Tiered Advice Fee Schedule
Asset-Based Fee Arrangement
fee
Annual Fee
Rate
Value of Assets
GWG generally offers one asset-based
arrangement: a tiered fee schedule.
On first $25 million ($0 - $25 million)
0.80%
On next $25 million ($25 - $50 million)
0.60%
On next $50 million ($50 - $100 million)
0.40%
Over $100 million
0.20%
Portfolio Fee Schedule
Under a tiered fee schedule, the asset-based fee
will vary for different segments of client assets,
gradually decreasing as the Account balance
increases. For example, a client with an Account
value of $75 million may pay one rate on the first
$25 million of assets in the Account, a lower rate
on the next $25 million of assets in the Account
and a still lower rate on the remaining $25 million
of assets. Use of a tiered fee schedule will result
in a blended asset-based fee rate.
following
fee schedule sets
forth
The Portfolio Fee
rate varies by Service,
investment vehicle, and the type of investment
strategy or style being pursued by the Account.
the
The
maximum Portfolio Fee rates or range of rates for
the Services.
Portfolio Fee Schedule
The typical asset-based fee varies depending
upon the Service and the fee option selected by
the client. Fee options and rates may also differ
among different Accounts held by the same client,
for an
depending on the services selected
Account.
Service
Annual Fee Rate
or Range of Rates
GWG Investment Management
0.00%
GWG Recommended Managers
0.20% - 0.75%
Equity SMA Strategies
All new client Accounts paying an asset-based fee
are generally subject to a unified advice fee
arrangement (“Unified Advice Fee Arrangement”),
which is described below.
0.20% - 0.52%
Balanced SMA Strategies
Unified Advice Fee Arrangement
0.25% - 0.40%
Fixed Income SMA Strategies
0.25% - 0.52%
Global and International SMA
Strategies
0.35% - 0.60%
Alternative SMA Strategies
0.10%
Tax Managed Strategies
Baird SMA Network (BSN)
0.22% - 0.77%
Equity SMA Strategies
0.22% - 0.52%
Balanced SMA Strategies
0.10% - 0.27%
Fixed Income SMA Strategies
0.27% - 0.52%
Global and International SMA
Strategies
Under a Unified Advice Fee Arrangement, the
asset-based Advisory Fee is comprised of an
advice fee (“Advice Fee”) and, for some Services,
an additional portfolio fee (“Portfolio Fee”). The
Advice Fee covers certain investment advisory,
brokerage and custody services provided by GWG
and Baird. The Portfolio Fee covers portfolio
management and other services provided by
Baird and the manager to the client’s Account,
which may include departments or affiliates of
Baird. If a client has a Unified Advice Fee
Arrangement, the client’s Advisory Fee rate will be
equal to the sum of the applicable Advice Fee rate
and the applicable Portfolio Fee rate, if any.
0.37% - 0.77%
Alternative SMA Strategies
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Portfolio Fee Schedule
Programs, deciding to participate in the DC
Program, selecting
the SMA Strategy, and
negotiating and agreeing to the Portfolio Fee rate.
Service
Annual Fee Rate
or Range of Rates
—1
Dual Contract (DC)
Flat or Hourly Fee Arrangement
1 Fees charged by managers under the DC Program are
negotiated by each client pursuant to a separate
agreement that does not include Baird. Baird, therefore,
does not have the necessary information to provide a
definitive range of fees paid to managers under the DC
Program.
Under a flat fee or hourly fee arrangement, the
applicable fee may be determined according to a
fixed asset-based or hourly fee rate or may be a
fixed dollar amount. Specific services may each
have their own, separately-stated, flat fee, or
several services may be grouped together under a
single flat fee. Some services may entail a flat fee
per usage. Flat fees are negotiable and vary by
client. The details of flat fee arrangements,
including fee amounts, the billing schedule, and
the services covered, will be included in the
client’s advisory agreement.
Service Account Minimums
The Portfolio Fee rates are current as of the date
of this Brochure. A client’s actual Portfolio Fees
could be higher or lower than the amounts shown
above if Baird adds new investment managers to
the Services with higher or lower fees or if Baird
and a manager renegotiate the amount of the
subadvisory fee.
The minimum asset value to open an Account in a
Service is set forth in the table below.
Account Minimum
Service
Asset Level
Consulting Services
Negotiable
The Advice Fee and Portfolio Fee rates do not
reflect the internal fees and expenses of any
Funds or other investment products used in
connection with a strategy, the costs of which are
borne by a client in addition to the Advisory Fee.
See “Other Fees and Expenses” below.
Baird SMA Network
$100,000(1)
Dual Contract
$100,000(1)
GWG Investment Management
$50,000
GWG Recommended Managers
$100,000(1)
titled
“Administrative
In some instances, Baird provides operational and
administrative services to third party managers in
connection with their management of client
Accounts. As compensation for those services,
Baird receives a portion of the Portfolio Fee at an
annual rate of up to 0.02% of the value of the
Account. Additional information is contained in the
Servicing,
document
Revenue Sharing, and Other Third Party
Payments” available on Baird’s website at
bairdwealth.com/retailinvestor.
(1) BSN Fund Strategist Portfolios have a minimum
account requirement of $10,000. Other SMA
Strategies typically have an account minimum of
$100,000. However, each investment manager sets
its own minimum account size requirements, which
can range from $25,000 to more than $1,000,000.
As a result, some investment managers may not be
available to clients with smaller accounts.
A client’s Account may also be subject to a
minimum quarterly Advisory Fee that will be set
forth in the client’s advisory agreement regardless
of the value of the assets in the client’s Account.
In addition, if a third party custodian has custody
of the client’s Account assets, Baird may impose
Account requirements different than those set
forth above, including but not limited to higher
minimums, and it may impose additional fees due
to the increase in resources needed to administer
the Account.
Certain managers offer lower Portfolio Fee rates
for SMA Strategies to clients through the DC
Program compared to the GWG Recommended
Managers or BSN Programs. If a client has
decided to participate in the DC Program, upon
the client’s request, the client’s GWG Consultant
may assist the client with the client’s negotiation
with the manager of the Portfolio Fee rate for the
applicable SMA Strategy. The Portfolio Fee
negotiated by the client could be higher or lower
than the Portfolio Fee that applies to the same
SMA Strategy that is available through other
Services. The client is ultimately responsible for
understanding the differences between the SMA
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
result, each such client should understand that
the other clients included in the household fee
arrangement may be able to ascertain the amount
of the client’s assets at Baird.
A client is encouraged to periodically review with
the client’s GWG Consultant the client’s Advisory
Fee and the services provided to determine if the
services and fees continue to meet the client’s
needs.
Calculation and Payment of Advisory Fees
Baird will calculate a client’s Advisory Fee by
applying the applicable fee rate to the value of all
of the assets in the client’s Accounts, including
cash and its equivalent and including all Held-
Away Assets, unless otherwise agreed to in
writing. Liabilities held in a client's Accounts,
including the value of margin debit balances, open
short sale positions and open options positions
with a negative market value will be excluded
from the calculation of a client's Advisory Fee. The
value of cash balances held in a client’s Account
will be excluded from the calculation of a client's
Advisory Fees in an amount equal to the value of
any open short sale positions and options
positions with a negative market value held in the
margin account.
For purposes of calculating a client’s asset-based
Advisory Fee, the value of a client’s assets is
generally determined by Baird. Baird generally
relies upon third party sources, such as third
party pricing services when valuing Account
assets. In some instances, such as when Baird is
unable to obtain a price for an asset from a
pricing service, Baird may obtain a price from its
trading desk or it may elect to not price the asset.
Obtaining a price from its trading desk may
present a conflict of interest. In some cases, Baird
obtains prices from the issuers or sponsors of
investment products in the client’s Account when
prices are not otherwise readily available. This
frequently occurs with respect to the valuation of
annuities and Complex Investment Products. If
the assets in the client’s Account are held by a
custodian other than Baird, Baird may also use
valuation information provided by the client’s
third party custodian in determining the value of
the assets in the client’s Account.
is unreliable. Valuation data
If requested by a client and approved by Baird, a
client’s Advisory Fee may be determined by also
including the aggregate value of assets in certain
other Advisory accounts held by a client and
certain members of the client’s household or
family (a “household fee arrangement”). A client
should note that Retirement Accounts may not be
included in a household fee arrangement to the
extent a prohibited transaction under ERISA or
the IRC may result. The terms of any such
household fee arrangement will be set forth in the
client’s advisory agreement.
third party pricing services,
Neither GWG nor Baird conducts a review of
valuation information provided by third party
pricing services, issuers, sponsors, or custodians,
and they do not verify or guarantee the accuracy
of such information. GWG and Baird do not accept
responsibility for valuations provided by third
parties that are inaccurate unless they have a
reason to believe that the source of such
for
valuations
investments, particularly annuities and Complex
Investment Products, may not be provided to
Baird in a timely manner, resulting in valuations
that are not current. The prices obtained by Baird
from
issuers,
sponsors and custodians may differ from prices
that could be obtained from other sources.
While GWG and Baird may perform an analysis as
to whether any client Accounts may be eligible for
a household fee arrangement, a client should note
that it is client’s sole responsibility to inform the
client’s GWG Consultant that client’s household or
family has two or more Advisory accounts that
are eligible for a household fee arrangement.
GWG and Baird do not undertake any obligation
to ensure client Accounts are eligible for a
household fee arrangement. By agreeing to a
household fee arrangement, each client subject to
such household fee arrangement consents to
GWG and Baird providing to each other client
subject to such household fee arrangement, in
GWG’s or Baird’s sole discretion, information
about the aggregate level, or range, of household
assets used for fee calculation purposes. As a
When determining the value of Held-Away Assets,
prices provided by a client or the client’s agent
will frequently be used and the initial amount
invested by the client will typically be used as the
value of the Held-Away Asset unless the client or
the client’s agent provides updated information.
Neither GWG nor Baird conducts a review of
valuation information provided by a client or the
client’s agent and they do not verify or guarantee
the accuracy of such information. GWG and Baird
for valuations
responsibility
do not accept
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
provided by a client or the client’s agent.
Valuation data may not be current. The prices
provided by a client or the client’s agent may
differ from prices that could be obtained from
other sources.
the
Values used for fee-calculation purposes may vary
from prices received in actual transactions and
are not firm bids, offers or guarantees of any type
with respect to the value of assets in an Account,
and the Advisory Fee for some securities may be
calculated based on values that are greater than
the amount a client would receive if the securities
were actually sold from the client’s Account.
A client’s Advisory Fees are payable in accordance
with the terms of the client’s advisory agreement.
Typically, Advisory Fees are payable on a calendar
quarterly basis, in advance. The initial billing
period begins when
client’s advisory
agreement is accepted by Baird and the Account
is opened by Baird (the “Opening Date”). The
initial Advisory Fee payment will be adjusted for
the number of days remaining in the then current
quarter. The initial Advisory Fee will be based on
the value of assets in the client’s Account on the
Opening Date. The period which such payment
covers shall run from the Opening Date through
the last business day of the then current calendar
quarterly billing period. Thereafter, the quarterly
Advisory Fees shall be calculated based upon the
Account’s asset value on the last business day of
the prior calendar quarter and shall become
payable on the first business day of the then
current calendar quarter.
As mentioned above, Baird will include cash and
cash equivalent balances in a client’s Account
when calculating a client’s asset-based Advisory
Fee. Baird has adopted internal policies that
monitor the percentage of an Account swept into
cash under the Cash Sweep Program. These
internal policies are designed to inform GWG
Consultants and their clients who hold large cash
sweep balances in their Accounts for sustained
periods that those Accounts are holding large
cash sweep balances and that there may be other
investment or account options for their cash and
that Baird receives direct compensation
in
addition to the Advisory Fee from client balances
in the Cash Sweep Program.
the
client’s Account may
A client’s Advisory Fees and other charges will be
automatically deducted from the client’s Account,
unless the client requests, and GWG and Baird
agree, to an alternate arrangement, such as
having Baird issue the client an invoice for the
Advisory Fees (“direct billing”). A client should
understand that the client’s Advisory Fees and
other charges relating to the client’s Account may
be satisfied from free credit balances and other
assets in the client’s Account. If free credit
balances in a client’s Account are insufficient to
pay the Advisory Fees or other charges when due,
investment manager
GWG, Baird and any
managing
sell
investments from the client’s Account to the
extent they deem necessary and appropriate, in
their sole discretion, to pay the client’s Advisory
Fees and other charges.
If a client maintains a debit balance in the client’s
margin account with Baird, such balance has no
bearing on the asset-based Advisory Fees charged
on client’s Account. In other words, the margin
balance (i.e., the outstanding amounts of the
margin loan a client owes to Baird) in client’s
Account will not be applied to reduce the client’s
billable Account value in calculating the Advisory
Fee.
If a client’s Account is subject to direct billing, the
client is required to pay each bill within 30 days of
the date of the invoice. GWG and Baird may
automatically deduct a client’s Advisory Fees and
other charges from the client’s Account as
described above in the event that Baird does not
receive payment from the client within 30 days of
the date of the invoice. GWG or Baird may rescind
a direct billing arrangement with a client at any
time. Direct billing may not be available for
Retirement Accounts.
The Account value used for the Advisory Fee
calculation may differ from that shown on a
client’s Account statement or performance report
due to a variety of factors, including the client’s
use of margin, options, short sales, and other
considerations. If a client has assets held by a
third party custodian, the prices shown on a
client’s Account statements provided by the
custodian could be different from the prices
shown on statements and reports provided by
Baird. See “Services, Fees and Compensation—
Additional Service Information—Custody Services”
above for more information.
To the extent permitted by applicable law, GWG
or Baird may modify a client’s existing fees and
other charges or add additional fees or charges by
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
providing the client with 30 days’ prior written
notice.
applicable to existing clients may not be affected.
Therefore, some clients may pay different fees
than those shown above.
Obtaining Services Separately: Brokerage or
Advisory? Factors to Consider
GWG generally does not offer the Services to
clients on an unbundled basis. In other words, the
Services do not permit clients to pay for services,
such as investment advice, trade execution, and
custody
separately. However, Baird offers
brokerage accounts and other services to clients,
and certain services provided to a client in
connection with a particular Service may be
available to a client outside of the Service
separately. Thus, a client’s participation in a
Service could cost the client more or less than if
the client purchased each service separately. A
number of factors bear upon the relative cost of
each Service. In comparing the Services to
brokerage accounts or other services, a client
should consider a number of factors, including,
but not limited to:
If GWG, Baird or the client terminates the client’s
advisory agreement or the client’s participation in
a Service, a pro-rated refund from the date of
termination through the end of the applicable
billing period will generally be made to the client
in the client’s affected Accounts. GWG and Baird
will not implement a decrease in the client’s fee
rate during a billing period or otherwise reimburse
or adjust Advisory Fees during any such period for
asset value appreciation or depreciation in a
client’s Account during such period. For example,
if a client’s Account is subject to a tiered or
breakpoint fee schedule and the asset levels of
the Account move into a new tier or cross a
breakpoint during such period, no rebate or fee
adjustment will be made. However, GWG and
Baird, in their sole discretion, may make fee
adjustments in response to asset fluctuations in a
client’s Account occurring during a billing period
that result from contributions to, or withdrawals
from, the client’s Account.
• whether a client prefers to have ongoing
monitoring, investment advice or professional
management of the client’s investments, which
are provided to Service Accounts, or whether
the client does not want or need such services;
The minimum asset value in order to retain the
services of GWG is $25 million, and a minimum
annual Advisory Fee of $150,000 may be
assessed to a client regardless of the level of
assets advised by GWG. GWG may waive the
minimum asset value or minimum Advisory Fee at
its discretion. The minimum Advisory Fee is
subject to change upon notice to the client.
• whether the types of investment strategies,
products and solutions the client seeks are
available;
• whether there are limitations on the types of
securities and other investments available for
purchase and whether those limitations are
significant to the client;
• whether the nature and level of transaction
services, account performance reporting, or
other ancillary services the client wants are
available;
The Advisory Fee and minimum account value are
negotiable in certain instances and may vary
based upon a number of factors, including but not
limited to the size and nature of the assets in the
client’s Account, the client’s particular investment
strategy or objective, and any particular services
requested by the client. In some instances, clients
may pay a higher fee than indicated in the fee
schedule above. The fees paid by a client may
differ from the fees paid by other clients based on
a number of factors, including but not limited to
the factors identified above.
• whether the client prefers to pay an ongoing
Advisory Fee for continuous advice or pay
commissions and other fees on a transaction-
by-transaction basis;
• the relative costs and expenses of a Service
Account and a brokerage account, which will
vary depending upon:
The fee schedule set forth above is the current
fee schedule for the Services. Each Service has
had other fee schedules in effect, which may
reflect fees that are lower or higher, as the case
may be, than those shown above. As new fee
schedules are put into effect, they are made
applicable only to new clients, and fee schedules
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
fee or commission rate
the client
o the
negotiates;
o the size of the client’s account;
o the level of trading activity and size of trade
orders;
Portfolio Fee” above. However, Baird, in many
instances, retains a portion of the Portfolio Fee
when a client’s Account is managed by an Other
Manager. The maximum portion of the Portfolio
Fee retained by Baird in those instances is equal
to an annual rate of 0.10% of the value of a
client’s Account. Such amounts are retained by
Baird for the services it provides.
o applicable account fees and charges;
o the client’s use of third party managers who
charge their own fees for managing accounts
in addition to GWG’s Advice Fee; and
As the portion of the Advisory Fee or Portfolio Fee
paid to an Other Manager increases, the portion
of the Advisory Fee or Portfolio Fee that is
retained by Baird decreases. Thus, Baird (but not
GWG) has an incentive to recommend or favor
investment managers that are paid less, because
Baird will receive a higher portion of the Advisory
Fee or Portfolio Fee.
o the amount of the client’s account invested in
investment products that have additional
internal ongoing operating fees and expenses
(e.g., Funds).
Additional important information about brokerage
accounts and facts to consider when making
account type decisions is contained in the Client
Relationship Details document, which should have
been delivered to the client and is available on
Baird’s website at bairdwealth.com/retailinvestor.
In addition, Baird has an incentive to favor
Associated SMA Strategies over other SMA
Strategies because the entire Advisory Fee is
retained by Baird and Associated Managers and
because Baird benefits from its receipt of Advisory
Fees and the overall success of Associated
Managers. For more information, see “Additional
Information—Other Financial Industry Activities
and Affiliations” below.
incentive
A client should review other account types and
programs with the client’s GWG Consultant to
determine whether they are more appropriate or
should be used in addition to a Service.
Advisory Fee Payments to Baird, GWG
Consultants and Investment Managers
Given the nature of the Advisory Fee, Baird also
has an
to select or recommend
investment managers that trade less frequently
with or that trade away from Baird because Baird
will incur lower trading costs with respect to such
managers and such relationships will be more
profitable to Baird.
GWG and Baird and Associated Managers benefit
from the Advisory Fees and charges that clients
pay for the services described in this Brochure.
Fee or
subadvisory
Baird retains the entire Advisory Fee paid by
clients, except as further described below. With
respect to SMA Strategies available under the
SMA Programs managed by Other Managers,
Baird pays Other Managers (including Associated
Managers and Implementation Managers, if any)
fee as
a Portfolio
compensation for the manager’s services as
further described below.
A GWG Consultant is primarily compensated on a
monthly basis based upon a percentage of the
GWG Consultant’s total production each month,
which primarily consists of the total advisory fees
and transaction-based fees paid to Baird by the
GWG Consultant’s clients and any other fees Baird
earns on advisory and brokerage accounts held by
those clients, including trail fees paid by third
parties. The percentage of the GWG Consultant’s
total production actually paid to the GWG
Consultant will increase as the total amount of the
GWG Consultant’s production increases, meaning
that, as the total amount of the GWG Consultant’s
production increases, the rate and amount of
compensation that Baird pays to the GWG
Consultant also
increase. GWG Consultants
generally also receive deferred compensation or
bonuses based on various criteria, including net
Client Accounts are generally subject to a Unified
Advice Fee Arrangement in which the Advisory
Fee consists of an Advice Fee and a separate
Portfolio Fee. Baird pays the manager out of the
Portfolio Fee paid by the client. The Portfolio Fee
rates are set forth under “Fee Options and Fee
Schedules—Unified Advice Fee Arrangement—
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
their
total production
are
for
reimbursements,
awards
of
professional
fees
new assets they gather, performing certain wealth
management activities, such as financial planning,
and
levels. GWG
Consultants who achieve certain production
thresholds
professional
eligible
development conferences, business development
coaching,
and
recognition trips to attractive destinations. GWG
Consultants are also eligible for bonuses for
designations
achievement
depending on a GWG Consultant’s
total
production level. Thus, GWG Consultants have a
general incentive to generate financial and other
plans and charge higher
for advisory
accounts and recommend larger investments in
advisory accounts.
Interest
in
the
Given the structure of their compensation, they
also have an incentive to recommend that a client
transfer the client’s accounts to Baird, establish
new accounts with Baird (including IRA rollovers)
and add more money into the client’s accounts. In
addition, most GWG Consultants are shareholders
of Baird Financial Group, Inc. (“BFG”), Baird’s
ultimate parent company, and thus benefit
financially from the overall success of Baird and
its Associated Parties. The number of shares of
BFG stock that a GWG Consultant may purchase
is based in part on the GWG Consultant’s total
production
level. GWG Consultants generally
receive compensation for referrals to certain
affiliated managers and products and for referrals
to a limited number of other firms. More specific
information
is provided under the headings
“Additional Information—Other Financial Industry
“Additional
Activities and Affiliations” and
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading—Participation or
in Client
Transactions” below. They also generally receive
non-cash compensation and other benefits from
Baird and from sponsors of investment products
with which Baird does business. Such non-cash
compensation and other benefits may include
invitations to attend conferences or educational
seminars, payment of related travel, lodging and
meal expenses, reimbursement for branch and
client events, and
receipt of gifts and
entertainment. Receipt of such compensation and
benefits provides GWG Consultants an incentive
to favor investment products and their sponsors
that provide the greatest levels of compensation
and benefits.
GWG Consultants generally receive recruitment
bonuses and/or special compensation from Baird
when they join Baird from another firm. The
amount of such special compensation is typically
based on the GWG Consultant’s production at the
prior firm for the 1-year period prior to joining
Baird or on the level of the GWG Consultant’s
client assets at the prior firm. All or a substantial
portion of the special compensation is paid in the
form of an upfront bonus when the GWG
Consultant joins Baird, and the remaining portion,
if any, is paid in the form of back end bonuses
generally in equal installments on an annual basis
thereafter
for a certain number of years
(generally from one to three years). Installment
payments are generally contingent upon the GWG
Consultant achieving annual production or client
asset levels that exceed a significant percentage
of the GWG Consultant’s annual production for
the 1-year period prior to joining Baird or the
client assets that the GWG Consultant had prior to
is
joining Baird. The special compensation
intended to compensate GWG Consultants for the
significant effort involved in transitioning their
business from the prior firm. This compensation
provides GWG Consultants who have left another
firm additional incentive to recommend that
clients of the prior firm become Baird clients and
to recommend investment products and services
that increase their production, and thus presents
a conflict of interest. The special compensation is
generally structured in the form of a forgivable
loan from Baird to the GWG Consultant. Under the
terms of the forgivable loan, Baird makes the
upfront or installment payment to the GWG
Consultant in the form of a loan, and Baird
forgives a portion of the loan made to the GWG
Consultant each month for so long as the GWG
Consultant remains Baird’s employee. Should the
GWG Consultant cease to be Baird’s employee
prior to the maturity date of the loan, the GWG
Consultant is required to repay Baird the amount
of the loan outstanding and not forgiven by Baird.
In other words, upon leaving Baird, the GWG
Consultant would be required to repay to Baird a
portion of the special compensation that the GWG
Consultant had received and that had not been
forgiven. The amount of such repayment declines
over time in proportion to the time the GWG
Consultant remains Baird’s employee. Structuring
this special compensation
form of
forgivable loans provides the GWG Consultant
added incentive to remain Baird’s employee and
to recommend that persons become and remain a
Baird client. Additional information about referral
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
to GWG Consultants
under
the
heading
Relationship Details document and Baird’s website
at bairdwealth.com/retailinvestor. A client can
find the actual ongoing fees and expenses of an
investment product that the client will pay or bear
in the product’s prospectus or offering document.
Interest
and non-cash compensation and other financial
is
incentives provided
provided
“Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading—Participation or
in Client
Transactions” below.
Additional Account Fees and Charges
In
those
instances,
website
From time to time, Baird GWG Consultants
outside of GWG may refer their clients to GWG
Consultants.
the GWG
Consultant generally shares a portion of his or her
compensation with the referring Baird Financial
Advisor.
If the client’s Account is custodied at Baird, the
client is also responsible for all applicable account
fees and service charges Baird may impose in
connection with the client’s agreements with
Baird. A schedule of fees and service charges is
at
Baird’s
on
available
bairdwealth.com/retailinvestor.
Other Fees and Charges
In addition to the Advisory Fee described above, a
client of GWG will incur other fees and expenses.
A client is responsible for bearing or paying, in
addition to the Advisory Fee, the costs of all:
Baird addresses the conflicts described above
through disclosure in this Brochure and by
adopting internal policies and procedures for GWG
and Baird and their associates that require them
to provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients).
Other Fees and Expenses
Cost and Expense Information for Certain
Investment Products
• markups, markdowns, and spreads charged by
Baird in a principal transaction with a client or
charged by other broker-dealers that buy
securities from, or sell securities to, the client’s
Account (such costs are inherently reflected in
the price the client pays or receives for such
securities);
• front-end or deferred sales charges, redemption
fees, or other commissions or charges
associated with securities transferred into or
from an Account;
• redemption fees, surrender charges or similar
fees that an investment product or its sponsor
may impose;
• underwriting discounts, dealer concessions or
similar fees related to the public offering of
investment products;
• extra or special fees or expenses that may
result from the execution of odd lot trade orders
(i.e., “odd-lot differential”);
• electronic fund fees, wire transfer fees, fees for
transferring an investment between firms, and
similar fees or expenses related to account
transfers (including any such fees imposed by
Baird);
• currency conversions and transactions;
conversions,
• securities
important
including, without
limitation, the conversion of ADRs to or from
foreign ordinary shares;
A client should be aware that certain investment
products in which the client invests, such as
mutual funds and other Funds, annuities and
other products, have
their own ongoing
fees and
management and other operating
expenses that are deducted from the assets of the
product (or income or gains generated by the
product on its investments) and thus reduce the
value or return of the client’s investment in the
product. These fees and expenses may include
investment management fees, distribution (12b-
1) fees, shareholder servicing fees, transfer
agency fees, networking fees, accounting fees,
marketing support payments, administration fees,
custody
fees, expense reimbursements, and
expenses associated with executing securities
transactions for the investment product’s portfolio
(“ongoing operating expenses”). These ongoing
operating expenses are separate from, and in
addition to, the Advisory Fees. As a result of
making investments in these types of products, a
client should be aware that the client is paying
multiple layers of fees and expenses on the
amount of the client’s assets so invested—the
ongoing operating expenses and the Advisory
Fee. Additional
information about
ongoing fees and expenses that apply to those
types of investments is provided in Baird’s Client
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• interest, fees and other costs related to margin
accounts, short sales and options trades;
related
to
the
• fees
establishment,
administration or termination of Retirement
Accounts, retirement or profit sharing plans,
trusts or any other legal entity, including,
without limitation, the calculation and payment
of unrelated business income tax (“UBIT”);
during a quarterly billing period, that asset will be
excluded for purposes of determining the asset-
based Advisory Fee beginning at the start of the
next quarterly billing period, and no portion of the
asset-based Advisory Fee paid by a client in
advance for the quarter will be refunded or
rebated to the client. Additionally, Unsupervised
Assets in an Account are subject to any applicable
fees
set-up, maintenance and administrative
established by Baird. Baird may waive such fees
in its discretion.
• fees imposed by the SEC or securities markets,
including transaction fees imposed by electronic
trading platforms, which fees may be imbedded
in the price the client receives for the security;
and
imposed upon or
resulting
• taxes
Clients who have Accounts managed by GWG may
also have other accounts with Baird that are not
managed by GWG. Those accounts may be
subject to fees, commissions or other expenses
that are entirely separate from the payment of
fees and expenses for the services provided by
GWG.
from
transactions effected for a client’s Account, such
as income, transfer or transaction taxes, foreign
stamp duties, or any other costs or fees
mandated by law or regulation.
Clients who use a custodian other than, or in
addition to, Baird will pay the other custodian’s
fees and expenses in addition to the Advisory Fee.
In addition, if a third party custodian has custody
of the client’s Account assets, the Account is
subject to any applicable set-up, maintenance and
administrative fees established by Baird. Baird
may waive such fees in its discretion.
In addition to the Advisory Fee, a client will also
be responsible for paying the fees charged by
each investment manager selected by the client
under the Dual Contract Program. If a client
directs GWG or Baird to pay the client’s DC
Manager’s fee out of the client’s Account, and
GWG or Baird agree to do so, GWG and Baird will
not be responsible for verifying the calculation or
accuracy of such fee.
for GWG and Baird and
that
require
them
through another
compensation
and
other
A client may also be assessed other trading costs
in addition to the Advisory Fee if client trades are
executed
firm. Please see
“Services, Fee and Compensation—Additional
Service Information—Trading for Client Accounts”
above for more information.
Compensation Received by GWG and Baird
The individual who recommends a Service to a
client, including a GWG Consultant, receives
compensation from Baird that is based upon the
amount of the Advisory Fee paid by the client.
The amount of the compensation may be more
than what the individual would receive if the client
participated in other Baird investment advisory
services or paid separately for investment advice,
brokerage, and other services. Accordingly, the
individual may have a financial incentive to
recommend a Service over other programs or
services offered by Baird. However, when
providing investment advisory services to clients,
GWG and Baird are fiduciaries and are required to
act solely in the best interest of clients. Baird
addresses this conflict through disclosure in this
Brochure and by adopting internal policies and
their
procedures
to provide
associates
investment advice that is suitable for advisory
clients (based upon the information provided by
such clients). For more specific information about
Baird’s
benefit
arrangements and how Baird addresses the
potential conflicts of interest, please see the
sections “Services, Fees and Compensation—
Additional Service Information” and “Services,
Fees and Compensation—Advisory Fees—Advisory
Fee Payments to Baird, GWG Consultants and
Investment Managers” above, and “Additional
Information—Other Financial Industry Activities
and Affiliations” and “Additional Information—
If a client holds an Unsupervised Asset in the
client’s Account, the client may be charged a
commission, markup or markdown in connection
with its purchase or sale. The cash proceeds from
the sale of an Unsupervised Asset that remain in
a client’s Account are considered Permitted
Investments subject to the asset-based Advisory
Fee. If an asset becomes an Unsupervised Asset
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading” below.
the agreement shall continue until it is terminated
in accordance with the terms described in the
advisory agreement.
Account Requirements and Types of
Clients
Opening an Account
A client that wishes to engage GWG will enter into
an advisory agreement with GWG and Baird. The
client’s advisory agreement will contain the
specific terms applicable to the services selected
by the client, Advisory Fees payable by the client,
and other terms applicable to the client’s advisory
relationship with GWG and Baird.
retain
those documents
for
The terms of a client’s agreements and this
Brochure apply to all Accounts that a client
establishes with GWG, including any Accounts
that a client may open with Baird in the future.
Some of the information in those documents may
not apply to a client now, but may apply in the
future if a client changes services or establishes
other Accounts with GWG. GWG will generally not
provide a client another copy of the agreements
or this Brochure when a client changes services or
establishes new Accounts unless
the client
requests a copy from GWG. Therefore, a client
should
future
reference as they contain important information if
a client changes services or establishes other
Accounts with GWG.
Certain Account Requirements
Minimum Account Size
In addition to the investment advisory services
that GWG and Baird provide in connection with
each Service, Baird, in its capacity as broker-
dealer, also provides clients with trade execution,
custody and other standard brokerage services.
For this reason, a client will also enter into a client
account agreement with Baird if the client has not
already done so. The client account agreement is
a brokerage agreement that authorizes Baird to
execute trades for, and perform related brokerage
and custody services to, the client’s Account.
immediately
terminate
the
Baird generally requires that assets in a client’s
Account be held in a Baird account, for which
Baird acts as custodian. However, in certain
limited circumstances when requested by a client,
Baird may permit a client to include Held-Away
Assets in the client’s Account.
Each Service has a minimum account size and
may have a minimum Advisory Fee, which are
described in the section entitled “Services, Fees
and Compensation—Advisory Fees” above. GWG
or Baird may remove an Account from a Service
and
advisory
agreement with respect to an Account upon
written notice to the client if the client fails to
maintain the required minimum asset levels in an
Account or if the client fails to otherwise abide by
the terms of a Service as determined by GWG or
Baird in their sole discretion.
Account Contributions and Withdrawals
in
to
investment manager until
A client may fund an Account with cash and with
securities that GWG, Baird and the client’s
investment manager,
to be
if any, deem
acceptable
their sole discretion. Funds
deposited or transferred to a client’s SMAs from
another Baird account and funds deposited or
transferred to a client’s SMAs from outside of
Baird will not be available for investment by the
client’s
the next
business day and therefore the investment of
such funds, at the discretion of the manager, will
occur no earlier than the next business day.
After a client has signed and delivered an
advisory agreement to Baird, the agreement is
subject to review and acceptance by the client’s
GWG Consultant, his or her Market Director or
PWM Supervision department supervisor (or his or
her respective designee), and Baird PWM’s Home
Office. The agreement and Baird’s advisory
relationship with a client will become effective
when the client’s paperwork is accepted by Baird
PWM’s Home Office and following such acceptance
the client written
Baird has delivered
confirmation of the Account’s enrollment in the
applicable Service. A client should understand
that the advisory agreement will not become
effective, and Baird will not provide any advisory
services to the client, until such time that Baird
has accepted the advisory agreement. Baird may
delay acceptance of the advisory agreement and
the provision of advisory services to the client for
various reasons, including deficiencies in the
client’s paperwork. Once it has become effective,
Some GWG Consultants will invest, or recommend
investing, cash contributions made to an Account
over a period of time. This method of investment
is sometimes referred to dollar cost averaging
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
certain
security prior to its transfer into the Account. In
addition, if the securities are subject to deferred
sales charges or redemption fees, the client will
be responsible for paying those charges and fees.
To the extent permitted by applicable law, certain
funding transactions may be handled by Baird on
a principal basis, and such transactions are not
considered investment advisory services of GWG,
Baird or the client’s investment manager.
If an asset transferred to an Account is an
Unpermitted Investment under the terms of the
applicable Service, GWG, Baird or the client’s
investment manager may sell the asset or
transfer it into a separate brokerage account.
Alternatively, they may designate such asset as
an Unsupervised Asset as further described under
“Services, Fees and Compensation—Additional
Service
Assets”
Information—Unsupervised
above.
(“DCA”). The goal of this method of investment is
to reduce the risk of making large purchases of
securities at an inopportune time or price. The
investment
and
Overlay Manager
managers also offer an optional DCA service for
Accounts they manage. Additional information will
be provided to a client if the client enrolls in a
DCA service. A client should note that, if dollar
cost averaging is used to invest cash in the
client’s Account, the returns for the Account
could, depending upon market and other
conditions, be lower than the returns that could
have been obtained had all the cash in the
Account been fully invested upon contribution to
the Account. In addition, a client should note that,
when dollar cost averaging is used, the amount of
cash in the client’s Account will be included in the
value of the Account for fee calculation purposes.
Whenever assets are contributed to an Account, a
client should discuss with the client’s GWG
Consultant the timing of when the assets will be
invested. If DCA will be used to invest the assets,
a client should ask for more specific information
about how the assets will be invested and the
associated timing for investing.
that
A client is responsible for notifying GWG and any
investment manager managing
the client’s
Account of any contributions made into the
Account and instructing GWG and any investment
manager to liquidate positions in the event the
from the
client wishes to withdraw assets
Account. GWG and Baird have no responsibility to
invest cash deposits (other than complying with a
client’s cash sweep instructions) or liquidate
positions with respect to an Account managed by
an Other Manager, and they are not responsible
for any losses that may result from a client’s
failure to notify GWG and any
investment
manager managing the client’s Account regarding
deposits or withdrawals.
A client may also incur additional expenses and
liabilities, including tax related liabilities, when
transferring assets out of an Account or Baird’s
custody. See “Termination of Accounts” below.
Liens and Use of Account Assets as Collateral
sale
could
in adverse
As security for the full and complete payment
when due of any debts and other obligations that
a client owes to GWG and Baird, and to the extent
permitted by applicable law or regulation, all
assets in a client’s Account held at Baird will be
subject to a first priority security interest, lien and
right of setoff in favor of Baird. Baird may sell
assets in an Account to satisfy the lien. As a
secured party, Baird may have interests that are
adverse to a client. Neither GWG nor Baird will act
as investment adviser to a client with respect to
When a client funds an Account with securities,
including when a client changes Services for an
Account or changes investment managers for an
Account within the same Service, the client should
understand that GWG’s, Baird’s or the client’s
investment manager’s review of securities used to
fund the Account may delay
investing. In
addition, GWG, Baird or the client’s investment
manager,
the
if any, may determine
securities contributed to the Account may not be
appropriate for the client’s strategy, and GWG,
Baird or the investment manager, if any, may
sell, or recommend the sale of, such securities.
Further, an investment manager may be removed
from the management of a client’s Account and a
replacement
investment manager may be
appointed. In such event, Baird, at the direction
of the client’s replacement manager, or the
client’s replacement manager may sell all or a
portion of the securities or other investments in
the Account that were managed by the prior
manager and the replacement manager will
reinvest the cash proceeds of those sales. Any
tax
result
such
consequences for the client. A client should note
that securities transferred into an Account may be
subject to the Advisory Fee immediately upon its
transfer into the Account, even if the client paid a
commission or front-end sales charge on the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
See
“Services,
Fees
In some instances, Baird and GWG Consultants
may refer a client to a third party lender under
Baird’s Securities-Based Lending Program that
pays Baird and GWG Consultants certain
compensation.
and
Compensation—Additional Service Information—
Securities-Based Lending Program” above for
more information.
such sale of assets held in an Account. Any such
sale of assets will be executed in Baird’s capacity
as broker-dealer and creditor and may, as
permitted by law, result in executions on a
principal basis. Such sales could have adverse tax
consequences, disrupt a client’s
investment
strategy, and have an adverse impact on the
Account’s performance. A client should review the
client’s agreements for more information.
Investment Products” above
Securities purchased on margin are used as
Baird’s collateral for the margin loan. Clients that
have a margin account should review the section
“Services, Fees and Compensation—Additional
Service Information—Complex Strategies and
Complex
for
additional information.
All of the assets in a client’s Account must be free
and clear from any security interest, lien, charge
or other encumbrance (other than a security
interest, lien, charge or other encumbrance in
favor of Baird) and must remain so for the
duration of the client’s relationship with Baird,
unless Baird otherwise specifically agrees in
writing.
Electronic Delivery of Documents
By signing an advisory agreement, a client
consents to the electronic delivery of documents
that GWG or Baird may deliver to the client. The
term of the consent to electronic delivery is
indefinite but a client may revoke the consent at
any time by notifying GWG.
If a client wishes to obtain loans secured by
assets in the client’s Account (commonly referred
to as “securities-based lending”) and GWG and
Baird agree to the arrangement, the client should
understand that the lender may exercise certain
rights and powers over the assets in the Account,
including the disposition and sale of any and all
assets pledged as collateral for the loan to meet a
collateral call, which may occur without prior
notice to the client. A collateral call could have
adverse tax consequences, disrupt a client’s
investment strategy, and have an adverse impact
on the Account’s performance. A client should be
aware of these and other potential adverse effects
of securities-based lending and collateralizing
Accounts before deciding to do so.
A client is required to disclose the terms of the
client’s agreements with Baird to any lender
seeking to use Account assets as collateral. A
client must promptly notify GWG and Baird of any
default or similar event under the client’s
collateral arrangements.
Termination of Accounts
The client’s advisory agreement will survive any
event that causes the client’s GWG Consultant to
be unable to provide services to the client (either
on a temporary or permanent basis), including if
to be
the client’s GWG Consultant ceases
employed by Baird. In any such event, Baird will
endeavor to continue to provide services to the
client and will as promptly as practicable assign
another GWG Consultant or Baird Financial
Advisor to the client’s Accounts (either on a
temporary or permanent basis) and the client will
be notified of any such change or, if Baird
determines that it is unable to continue to provide
advisory services to the client, Baird may remove
the applicable Account from a Service or Program
and convert the Account to a brokerage account
upon notice to the client.
GWG or Baird may remove an Account from a
Service and immediately close an Account upon
written notice to a client if the client fails to abide
by the terms of the Service. GWG or Baird may
also remove an Account from a Service at any
time upon written notice to a client if the client
fails to maintain the required minimum asset
levels in such Account.
A client should understand that neither GWG nor
Baird will provide advice on or oversee a
securities-based lending or collateral arrangement
and they will not act as investment adviser or a
fiduciary to the client with respect to the
liquidation of securities held in the client’s
Account to meet a collateral call. Any such
liquidation will be executed in Baird’s capacity as
broker-dealer and may, as permitted by law,
result in executions on a principal basis.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
costly to the client or have poorer performance. A
client should consider restrictions applicable to
investments carefully before participating in a
Service. A client should contact the client’s GWG
Consultant for specific information as to how
Account closure, termination of an agreement, or
asset transfers might impact the assets in the
client’s Accounts.
individuals and
their
exclusive
responsibility
to
in
writing,
Upon the termination of an Account’s enrollment
in a Service, GWG, Baird and, if relevant, any
other
investment manager managing such
Account, shall have no obligation to act as
investment adviser to such Account. If such
Account is custodied at Baird, the Account shall
be converted to and designated as a brokerage
account. GWG, Baird, and, if relevant, any other
investment manager managing such Account,
shall be under no obligation to recommend any
action with regard to, or to liquidate the securities
or other investments in, such Account. After an
Account is removed from a Service, it is the
issue
client’s
instructions,
the
regarding
management of any assets in such Account.
Types of Clients
GWG offers the Services primarily to: high net
worth
families and
businesses. GWG also provides services to other
types of current or prospective clients, including,
but not limited to: pension and profit sharing
plans; trusts; estates; charitable organizations;
and corporations or other business entities.
Portfolio Manager Selection and
Evaluation
The persons providing portfolio management
services to clients vary by Service. Information
about how Baird may select and evaluate portfolio
managers is further described below.
Selection and Evaluation
GWG Recommended Managers Service
or
If a client directs Baird to liquidate assets in
connection with a closure of an Account, the client
should understand that Baird acts as broker-
dealer, and not
investment adviser, when
processing such a liquidation request and that the
client will generally be charged commissions,
sales charges, sales “loads”, or other applicable
transaction-based fees in accordance with the
applicable Baird fee schedule or other third-party
transaction-based fee schedule for the particular
investment then in effect. Additional information
about the compensation that a client pays to
Baird for effecting brokerage transactions is
contained in Baird’s Client Relationship Details
document, available on Baird’s website at
bairdwealth.com/retailinvestor.
the heading
selecting
other
When
recommending
investment managers
to manage a client’s
Account in the GWG Recommended Managers
Service, GWG typically utilizes managers included
on Baird’s Recommended Managers List described
under
“Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis—Certain Recommended Lists—Baird’s
Recommended Managers List” below. Although in
some circumstances, GWG may select a manager
to manage a client’s Account that is not included
on Baird’s Recommended Managers List.
A client may incur significant expenses and
liabilities, including tax-related liabilities for which
the client will be solely liable, if the client closes
an Account, terminates an advisory agreement, or
transfers assets out of Baird’s custody. GWG and
Baird will not be liable to a client in any way with
respect to the termination, closure, transfer or
liquidation of the client’s Accounts.
organizational
and
GWG will select or replace, or recommend the
selection or replacement of, a particular manager
based upon the client’s particular goals and
circumstances and the client’s selected asset
allocation and
investment strategy. Before
selecting or recommending a manager to a client,
GWG performs
its own quantitative and
qualitative analysis of the manager, focusing on
the manager’s performance and factors GWG
believes will help a manager repeat historical
performance such as the investment process and
personnel,
investment
structure. GWG also focuses on the risk and
Some of the investments offered in connection
with the Services contain restrictions that limit
their use, and such
investments may be
unavailable for purchase or holding outside of an
Account. For example, certain mutual funds, ETFs
or other Funds held in an Account may only be
available to a client through a GWG Service or
may not be held at another firm. If such
restrictions apply and the client terminates a
Service or closes an Account, the Client will be
required to sell or redeem such Funds or
exchange them for other Funds that may be more
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
respect to managers and their strategies eligible
for the GWG Recommended Managers Service.
investment style relative to other investment
strategies already in a client’s portfolio. GWG
generally relies upon Baird’s Advisory Research
group to provide periodic review and evaluation of
managers on Baird’s Recommended Managers
List. To the extent a manager is not on Baird’s
Recommended Managers List, GWG will perform
periodic review and evaluation of the manager
using its own quantitative and qualitative analysis
described above. GWG will remove a manager
from management of a client’s Account when the
manager is removed from Baird’s Recommended
Managers List or if GWG determines that removal
is in the client’s best interest.
BSN and DC Managers are subject to an initial
review by Baird that considers the manager’s
assets under management,
regulatory and
compliance history, and certain other limited
factors deemed
qualitative and quantitative
relevant by Baird. The ongoing review is generally
performed on an annual basis and is generally
limited to significant changes in the managers’
assets under management in the SMA Strategy
and a review of the SMA strategy in comparison
to a relevant peer group or benchmark.
a
client who wishes
Clients should note that an investment manager
managing the client’s Account under the GWG
Recommended Managers Service may not be on
Baird’s Recommended Managers List. A client
should understand that GWG and Baird do not
perform any due diligence or ongoing monitoring,
evaluation or reviews of investment managers
except to the extent GWG otherwise specifically
agrees to do so in writing.
The BSN and DC Programs are designed to
to
accommodate
independently select an investment manager not
available in the GWG Recommended Managers
Service to manage the assets in the client’s
Account. A client should note that GWG and Baird
do not make any recommendation to clients
regarding any BSN Strategy or DC Strategy or
any representations regarding a BSN Manager’s or
DC Manager’s qualifications as an investment
adviser or abilities to manage client assets.
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, a client should note that GWG and Baird
do not monitor or ascertain whether a third party
Implementation Manager is fully and faithfully
implementing the Model Portfolio on a continuous
basis.
The Overlay Manager may provide review and
ongoing evaluations of certain BSN Managers that
it makes available through the BSN Program.
Clients should review Overlay Manager’s Form
ADV Part 2A Brochure for more information, which
is available upon request, or contact their GWG
Consultant for more information.
is
GWG and Baird do not monitor or ascertain
whether the Overlay Manager
fully and
faithfully implementing Model Portfolios under the
BSN Program on a continuous basis.
A client assumes ultimate responsibility
for
client’s selection of an Other Manager under the
GWG Recommended Managers Program (including
any third party Implementation Manager). GWG
and Baird assume no responsibility for the client’s
termination of an Other Manager (including any
third party Implementation Manager), the Other
Manager’s investment decisions, performance,
compliance with applicable laws or regulations, or
for any other matters involving or affecting the
Other Manager.
of
Loss—Principal
Baird SMA Network and Dual Contract
Programs
SMA Strategies offered under the BSN and DC
Programs are subject to certain risks. See
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risks—Available
Risk
Investment Product Risks” below
for more
information.
A client should only participate in the BSN or DC
Programs if the client wishes to take more
responsibility for monitoring the client’s Account,
the GWG Recommended Managers Program does
not contain an SMA Strategy that meets the
Clients participating in the BSN Program or the
DC Program should note that the level of initial
and ongoing review performed by GWG and Baird
on the managers and their SMA Strategies made
available under those Programs, including any
Associated SMA Strategies, is significantly less
than that performed by GWG and Baird with
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the
client
Oversight of the Services
client’s particular needs, and
understands the risks of doing so.
Asset Management,
PWM
retention of an
oversees
The Investment Advisory Oversight Committee
(“IAOC”) of Baird, which includes members of
Sales
Baird’s
Management,
Investment Solutions, Asset
Manager Research, Compliance, Legal, and Risk
Management
the
Departments,
standards and implementation of the Services.
A client should note that the client’s appointment
and continued
investment
manager to manage the client’s Account in
connection with the BSN or DC Programs are
based ultimately upon the client’s independent
review of the investment manager and the
investment manager’s services. Once retained by
the client, an investment manager will only be
removed from managing the client’s Account upon
the investment manager’s withdrawal, removal
from the Program, or the client’s direction to do
so.
(including any
responsibility
for
the
The IAOC delegates its day-to-day oversight
responsibilities to certain subcommittees of the
IAOC, the applicable Market Director and Baird’s
PWM Supervision, Investment Solutions and
Compliance Departments to monitor the Services.
The applicable Market Director, along with Baird’s
PWM Supervision and Compliance Departments
and other designees, provide periodic review of
the performance of GWG Consultants providing
portfolio management services under the GWG
Investment Management Service. Performance
information
is provided to the IAOC or a
subcommittee or delegate thereof.
(including
any
third
calculates
Performance Calculation
As part of Baird’s selection and evaluation of
the
portfolio managers, Baird
investment performance of:
for
A client assumes ultimate responsibility
client’s selection of a manager under the BSN or
DC Programs
third party
Implementation Manager). GWG and Baird
assume no
client’s
termination of a manager under the BSN or DC
Programs
party
Implementation Manager). GWG and Baird also
assume no responsibility for any Other Manager’s
investment decisions, performance, compliance
with applicable laws or regulations, or for any
other matters involving or affecting the Other
Manager.
the GWG
• GWG and Baird associates acting as portfolio
managers under
Investment
Management Service and PWM-Managed
Portfolios; and
• Other Managers participating in the GWG
Recommended Managers, BSN and DC
Programs that directly manage client accounts
under a Manager-Traded Strategy.
Portfolio management services under the DC
Program may be provided by an investment
management department of Baird if the client
selects such an SMA Strategy. In order to provide
portfolio management services under the DC
Program, Baird requires that Baird associates
meet all applicable requirements set forth by
applicable law and regulations of self-regulatory
organizations, such as the Financial Industry
Inc., exchanges, and
Regulatory Authority,
governmental agencies.
GWG Investment Management Service
Portfolio management services under the GWG
Investment Management Service are provided by
Baird and GWG Consultants.
Fixed
When Baird calculates a manager’s investment
performance, Baird generally uses composites of
the manager’s client accounts to calculate the
manager’s performance. A composite
is an
aggregation of client accounts managed by the
manager that are representative of a particular
investment strategy, style, or objective. Examples
of composites include large cap growth, all cap
value, balanced (which includes equity and fixed
income securities), and fixed income. Composites
may be further broken down to separate taxable
and non-taxable portfolios.
income
composites may be categorized by portfolio
duration.
In order
to provide portfolio management
services, Baird requires that GWG Consultants
and other Baird associates meet all applicable
requirements set forth by applicable law and
regulations of self-regulatory organizations, such
as the Financial Industry Regulatory Authority,
Inc., exchanges, and governmental agencies.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Investment
recommendations. Baird
When calculating composite performance, Baird
seeks to utilize calculation methods that adhere to
Performance Standards
Global
calculates
(GIPS®)
composite performance generally using
the
following principles:
that
such
investment
• A total return calculation is used in reporting.
• Current market value including accrued income
is used.
time to time may not be calculated by GWG or
Baird but may be calculated by the managers
themselves or derived from external sources.
GWG and Baird do not audit or verify that
investment performance information presented to
clients that is calculated by managers or external
sources is accurate. In addition, a client should
note
performance
information may not be calculated on a uniform or
consistent basis or reviewed by any independent
third party. A client should ask the client’s GWG
Consultant for more information.
• Trade date accounting is used in deriving
valuations.
the
• Monthly returns are calculated using
Modified Dietz calculation.
and
Associated Managers.
• Returns for periods greater than a month are
calculated by geometrically linking the monthly
returns. Returns for periods greater than one
year are annualized.
• Reporting is net of fees at the total portfolio,
but gross of fees for individual investment
categories (e.g., equity or fixed income).
Portfolio Management by GWG, Baird and
Associated Managers
Portfolio management services under the GWG
Investment Management, GWG Recommended
Managers and DC Programs may be provided by
Baird
Such
arrangements create a potential conflict of
interest because Baird and Associated Managers
may receive higher aggregate compensation if
clients retain Baird and Associated Managers
instead of retaining unassociated managers.
its
or
No independent third party reviews the composite
performance information calculated by Baird to
verify
compliance with
accuracy
presentation standards.
departments,
reviewing
those portfolio managers
and
Evaluation—Selection
The following Services exclusively offer portfolio
management by Baird, its GWG Consultants, its
PWM home office investment professionals, its
investment management
or
investment managers that are affiliated with
Baird: GWG Investment Management Service.
The processes, if any, used by Baird for selecting
and
is
described under the headings “Portfolio Manager
and
Selection
Evaluation” above and
“Portfolio Manager
Selection and Evaluation—Methods of Analysis,
Investment Strategies and Risk of Loss—Program
Portfolio Strategies” below.
independent
third party
reviews
To the extent Baird selects or reviews other
portfolio managers participating in the Programs,
Baird does not calculate investment performance
information for such managers. Baird obtains
investment performance information for those
managers directly from the managers (including
the Overlay Manager) or from other external
sources that Baird believes to be reliable. A client
should understand
that: Baird does not
recalculate the performance provided by such
managers or external sources; neither Baird nor
any
the
performance
information provided by such
managers to verify its accuracy or compliance
with presentation standards unless otherwise
stated in writing; those managers may not
calculate performance on a uniform or consistent
basis; and Baird does not guarantee the accuracy
of information provided by such managers or any
external source.
A client should note that the processes and
standards used by Baird in determining whether
to make affiliated investment options available
under the GWG Investment Management Service
differ from those processes and standards used
by Baird in determining whether to make non-
affiliated investment options available under other
Services. Baird approves, and continues to make
available, affiliated investment options under the
GWG Investment Management Service that would
not be approved for, or would have been removed
from, such other Services. This practice presents
a conflict of interest because Baird has a financial
incentive to maximize the number of affiliated
A client should note that Baird does not generally
present its investment performance calculations
to clients. The information that GWG or Baird
provides to clients about portfolio managers from
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird is owned indirectly by its associates through
several holding companies. Baird
is owned
directly by Baird Financial Corporation (“BFC”).
BFC is, in turn, owned by Baird Financial Group,
Inc. (“BFG”), which
is the ultimate parent
company of Baird. Associates of Baird own
substantially all of the outstanding stock of BFG.
investment options it makes available under the
GWG Investment Management Service due to the
fact that, by increasing investment options, Baird
will likely attract more client assets and thereby
increase Baird’s revenues. A client participating in
the GWG Investment Management Service should
monitor the client’s Account performance and
periodically discuss the performance of such
Account with the client’s GWG Consultant.
analysis
and
professionals,
an
research,
analysis
planning;
investment
or
for
and
account
transactions
and
Baird offers various investment advisory services
to clients, including services not described in this
Brochure. The investment advisory services Baird
include: portfolio management and
offers
recommendations
analysis;
investment
regarding asset allocation and
strategies;
and
recommendations regarding investment managers
and individual securities; investment consulting;
policy
financial
development;
performance
monitoring. Baird also offers clients execution of
brokerage
administrative
services, including maintaining custody of account
assets. Clients may also negotiate other services
with Baird. Baird offers its services separately or
in combination with other services. GWG and
Baird tailor advisory services to the individual
needs of clients. For more information about the
services offered by GWG and Baird, please see
“Services, Fees and Compensation” above.
and
Evaluation—Selection
Portfolio management services under the GWG
Recommended Managers Service or DC Program
could be provided by Baird PWM home office
investment
investment
management department of Baird or an
Associated Manager should a client select an
Associated SMA Strategy. When Baird selects SMA
Strategies, or otherwise determines manager
availability
the Baird
eligibility,
Recommended Managers List or the DC Program,
Associated SMA Strategies and Associated
Managers are subject to the same selection and
review processes, if any, that Baird applies to
unassociated SMA Strategies and investment
managers participating in each respective Service.
The processes, if any, used by Baird for selecting
and reviewing SMA Strategies and Associated
SMA Strategies for those Services are further
described under the heading “Portfolio Manager
Selection
and
Evaluation” above.
see
above
Subject to the agreement of GWG, a client may
impose reasonable restrictions on the securities or
types of securities to be held in the client’s
Account. Please
“Services, Fees and
Compensation—Additional Service Information—
for more
Investment Discretion”
information.
by
clients
providing
Baird participates in wrap fee programs not
described in this Brochure and it provides portfolio
management services in connection with those
programs. Baird receives a portion of the wrap fee
paid
portfolio
for
management services under those wrap fee
programs.
When providing investment advisory services to
clients, GWG and Baird are fiduciaries and are
required to act solely in the best interest of
clients. Baird addresses the conflicts described
above through disclosure in this Brochure and by
adopting internal policies and procedures for GWG
and Baird and their associates that require them
to provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients). For more specific
information about these potential conflicts and
how Baird addresses them, please see the
sections “Additional Information—Other Financial
Industry Activities and Affiliations” and “Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
under management,
As of December 31, 2025, Baird had
approximately $394.0688 billion in regulatory
approximately
assets
$289.4898 billion of which was managed on a
discretionary basis and approximately $104.5790
billion of which was managed on a non-
discretionary basis.
Advisory Business
Baird is privately-held, employee-owned global
investment and wealth management firm formed
in the State of Wisconsin in 1919.
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Equity Strategies
Performance-Based Fees and Side-By-Side
Management
GWG does not advise any client accounts that are
subject to performance-based fee arrangements.
focused,
Act.
Performance-based
Equity strategies generally have an objective to
provide growth of capital and primarily invest in
equity securities, such as common stocks.
However, these strategies may also invest in
other types of investments, such as fixed income
securities and cash. Equity strategies may invest
in companies of all market capitalization ranges or
may
focus on any combination of specific
capitalization ranges, such as large cap, mid cap
or small cap companies. Equity strategies may be
combined with other strategies described below,
such as growth, value, income, economic industry
or sector
international, global, or
geographic region or country focused strategies.
Fixed Income or Bond Strategies
Baird advises client accounts not participating in
services described in this Brochure that are
subject to performance-based fee arrangements.
Performance-based fee arrangements involve the
payment of fees based upon the capital gains or
capital appreciation of a client’s account. Any such
fee arrangements are made in compliance with
applicable provisions of Rule 205-3 under the
Advisers
fee
arrangements present a potential conflict of
interest for Baird (but not GWG) with respect to
other client accounts that are not subject to
performance-based fee arrangements because
such arrangements give Baird an incentive to
favor client accounts subject to performance-
based fees over client accounts that are not
subject to performance-based fees.
interest
the
arrangements
holdings
inequitable
region or
country
Fixed income or bond strategies generally have
one or more of the following objectives: (1)
provide current income; or (2) preservation of
capital. These strategies primarily invest in fixed
income securities, such as corporate bonds,
municipal securities, mortgage-backed or asset-
backed securities, or government or agency debt
obligations. However, these strategies may also
invest in other types of investments, such as
equity securities or cash. Fixed income strategies
may invest in debt obligations having any credit
rating, maturity or duration, or they may focus on
specific credit ratings, maturities or durations,
such as investment grade, non-rated, or high
yield (“junk”) bonds, or bonds having short-term,
intermediate-term or long-term maturities. Fixed
income strategies may be combined with other
strategies described below, such as economic
industry or sector focused, international, global,
or geographic
focused
strategies.
Balanced Strategies
In addition to complying with its fiduciary duties
by disclosing this conflict of interest to clients
through this Brochure, Baird generally addresses
posed by
of
potential
conflicts
by
performance-based
fee
periodically monitoring
and
performance of performance-based fee accounts
and comparing them to accounts not subject to a
performance fee that are also managed using a
similar strategy in an attempt to detect any
possible
treatment. Baird also
attempts to minimize potential conflicts of interest
posed by performance-based fee arrangements
through internal trade allocation procedures that
are designed to make securities allocations to
discretionary client accounts in a manner such
that all such clients receive fair and equitable
treatment over time.
Methods of Analysis, Investment
Strategies and Risk of Loss
Investment Strategies
The investment styles, philosophies, strategies,
techniques and methods of analysis that GWG,
investment
Baird, Baird PWM’s home office
professionals, and Other Managers use
in
formulating investment advice for clients vary
widely by Service and the person providing the
advice. A brief description of commonly used
strategies is provided below.
Balanced strategies generally have one or more of
the following objectives: (1) provide current
income; (2) growth of capital/principal or income;
or (3) preservation of capital. These strategies
primarily invest in a mix of equity, fixed income
securities and cash. Balanced strategies may
invest in companies of all market capitalization
ranges and in investments having any credit
rating, maturity or duration, or they may focus on
specific capitalization ranges, credit ratings,
maturities or durations as described above.
Balanced strategies may be combined with other
strategies described below, such as economic
industry or sector focused, international, global,
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
region or market
focused
regions, credit
ratings,
or geographic
strategies.
sectors, geographic
maturities or durations.
Value Strategies
Global Strategies
A value strategy typically invests primarily in
equity securities of value companies, which are
those that the investment manager believes are
out of favor with investors, appear underpriced by
the market relative to their earnings or intrinsic
value, or have high dividend yields. This strategy
is subject to investment style risks.
ranges,
regions, credit
Growth Strategies
Generally, global strategies invest in a mix of
securities issued by U.S. and foreign companies,
which may include companies in developed and
emerging markets. Global strategies may invest
in companies of all market capitalization ranges
and in investments having any credit rating,
maturity or duration, or they may focus on
industries or
specific capitalization
ratings,
sectors, geographic
maturities or durations.
Geographic Region or Country Focused Strategies
A growth strategy typically invests primarily in
equity securities of growth companies, which are
those that the investment manager believes
exhibit signs of above-average growth relative to
peers or the market, even if the share price is
high relative to earnings or intrinsic value. This
strategy is subject to investment style risks.
Income Strategies
fixed
invest
Geographic region or country focused strategies
primarily invest in companies located a particular
part of the world, such as Latin America, Europe
or Asia, in a group of similarly-situated countries,
such as developed or emerging markets, or one
or more specific countries. These strategies alone
generally are not intended to satisfy a client’s
entire portfolio diversification needs. These
strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
Tactical and Rotation Strategies
An income strategy typically invests primarily in
income-producing securities, such as dividend-
paying equity securities and
income
in a
securities. This strategy may
combination of investment grade and high yield
bonds. This type of strategy may also invest in
yield- or
income-producing, Non-Traditional
Assets.
Economic Industry or Sector Focused Strategies
technology,
underweighting
and
Economic industry or sector focused strategies
primarily invest in companies in one or more
economic industries or sectors, such as the
telecommunications,
industrial,
materials, or financial sectors. These strategies
alone generally are not intended to satisfy a
client’s entire portfolio diversification needs.
These strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
International Strategies
include companies
Generally, international strategies primarily invest
in securities issued by foreign companies, which
may
in developed and
emerging markets. International strategies may
invest in companies of all market capitalization
ranges and in investments having any credit
rating, maturity or duration, or they may focus on
industries or
specific capitalization
ranges,
strategies are often
subject
Tactical strategies typically tactically and actively
adjust account allocations to different categories
of investments, such as asset classes, geographic
locations or market sectors, based upon the
manager’s perception of how those investments
will perform in the short-term. Similarly, rotation
strategies
typically actively adjust account
allocations to different market sectors based upon
the manager’s perception of how those market
sectors will perform in the short-term. Tactical
and rotation strategies are often driven by
technical analysis or methodologies and typically
involve
overweighting
account allocations to certain asset classes,
geographic locations or market sectors relative to
an applicable long-term strategic asset allocation,
benchmark index or the market generally. These
strategies often will be focused or concentrated in
one or more asset classes, geographic locations or
market sectors from time to time, and it is likely
that they will have limited or no exposure to one
or more asset classes, geographic locations or
market sectors. For that reason, tactical and
to
rotation
concentration risk. Because the decision-making
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
these
strategies
for tactical and rotation strategies is based upon
the manager’s short-term market outlook,
accounts pursuing
often
experience higher levels of trading and portfolio
turnover relative to other strategies.
management strategy as the primary investment
strategy or tax management may be their primary
consideration when managing client Accounts,
such as when the manager is transitioning an
Account from one investment strategy to another.
Opportunity or Opportunistic Strategies
the
strategy, particularly
utilizes
strategy
Accounts pursuing a tax management strategy in
some instances will be subject to additional or
different risks of loss, which may be material. The
holdings of Accounts pursuing tax management
strategies will often differ from the holdings of
similarly-managed accounts that do not utilize
tax
such a
if
management
replacement
securities. Therefore,
the performance of
Accounts utilizing a tax management strategy will
vary from similarly-managed accounts that do not
utilize such a strategy, possibly in a materially
negative manner, and such Accounts may not be
successful in pursuing any other investment
strategies, objectives or goals.
investment strategies, there
Tax management strategies are not intended to,
and likely will not, eliminate a client’s tax
obligations relating to investments in an Account.
Like all
is no
guarantee that the implementation of a tax
management strategy will be successful. A client’s
use of a tax management strategy may not
actually
lower a client’s tax obligations or
otherwise achieve a client’s tax goals.
than other strategies. The
to
Opportunity strategies will generally be invested
in a manner that seeks to provide long term
growth
through capital appreciation and/or
income by utilizing an active management style
that shifts the amount of investment made in
different asset classes and market sectors to take
advantage of the manager’s perception of market
pricing anomalies, those market or industry
sectors deemed favorable for investment by the
manager, the current interest rate environment
and/or other macro-economic trends identified by
the manager. Opportunity strategies often involve
the use of other strategies, particularly tactical or
rotation strategies, and will have the risks
associated with those strategies. Opportunity
Strategies may also involve investment in a more-
limited number of companies compared to other
strategies. As a result, a decline in value of one or
a few investments will more adversely impact
performance than if assets were more evenly
invested in a larger number of companies.
Opportunity strategies often experience higher
fluctuations in annual returns and overall market
types of
value
investments used
implement opportunity
strategies vary widely by manager and could
include equity securities, fixed income securities,
Non-Traditional Assets, Alternative Investment
Products and cash.
Tax Management Strategies
taxable
involve
Tax management strategies involve buying and
selling investments in a manner intended to
reduce the negative impact of U.S. federal income
taxes. They often involve buying or selling
investments to limit taxable investment gains or
investment gains with
to offset
investment losses or selling investments to avoid
recognition of taxable investment gains.
tax management strategy
is
the
The effectiveness of tax management strategies
will be reduced if a client’s ability to recognize
losses for tax purposes is disallowed, limited or
deferred under applicable tax rules, such as the
IRS wash sales rules, which disallow losses if
substantially identical securities are purchased by
a client (whether through Baird or another firm)
within 30 days before or after a sale, and IRS
straddle rules, which limit and defer a client’s
ability to claim tax deductions related to the loss
on a sale of an investment in an Account if the
client holds an offsetting position in any account
firm. Some tax
held at Baird or another
management strategies
the sale of
securities at a loss and the reinvestment of the
proceeds into a replacement security that the
to not be “substantially
manager believes
identical” for purposes of the IRS wash sales rule.
A manager’s belief may be incorrect, resulting in
a disallowance of the loss and reducing the
intended benefits of
tax management
strategy.
A
typically a
secondary strategy used to achieve a secondary
tax management objective and it is typically
together with other primary
implemented
investment
to achieve
strategies designed
primary investment objectives or goals. However,
managers in certain situations may use a tax
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
limitations of
tax management
risks and
strategies.
the wash sales
resulting
losses. The
rules,
risk of
Alternative Strategies and Complex Strategies
involved
invest
Trading activity in a client’s accounts (whether at
Baird or another firm) may also inadvertently
violate
in
inadvertent
disallowed
violations increases as the number of client
accounts and managers
increases
because there is a higher chance of uncoordinated
or conflicting trading activity in those accounts.
Automatic purchases in client accounts, such as
dividend
reinvestment programs, may also
inadvertently violate wash sales rules. A client’s
investments held in other accounts at Baird or
another firm may be deemed to be offsetting
positions for purposes of the IRS straddle rules,
which will also negatively impact the client’s
ability to deduct losses and will reduce the
intended benefit of the tax management strategy.
Alternative Strategies and other Complex
Strategies may
in a wide range of
investments, which may include equity securities,
fixed income securities, Non-Traditional Assets,
Alternative
Investment Products and cash.
Alternative Strategies and other Complex
Strategies generally involve the use of margin,
leverage, short sales and derivative instruments.
Many Alternative Strategies and other Complex
Strategies have no substantive restrictions on the
types of investments that may be used. Examples
of Alternative Strategies and other Complex
Strategies include the following.
resulting
from
• Relative Value Strategies. Relative value
strategies generally involve the purchase of
traditional assets, such as stocks and bonds,
and Non-Traditional Assets and the use of short
sales and derivative instruments in an attempt
to exploit price differences among securities
that share similar economic or
financial
characteristics.
• Long/Short Strategies. Long/short strategies
generally involve the purchase of securities
believed to be undervalued and selling short
securities believed to be overvalued. They may
also involve the use of Non-Traditional Assets,
leverage and derivative instruments.
Managers do not consider the holdings or
transactions in other client accounts (whether
held at Baird or another firm) when implementing
tax management strategies. Managers do not
undertake any responsibility to monitor or verify a
client’s compliance with applicable tax rules, and
they are not responsible for any tax‑related
effects or obligations
the
investments or transactions in a client’s Account.
A client is responsible for ensuring that the
holdings and transactions in the client’s other
accounts at Baird or another firm do not violate
appliable tax rules and bears the risk of such
violations. A client is strongly urged to consult the
client’s tax advisor prior to pursuing a tax
management strategy.
Direct Indexing Strategies
that
• Market Neutral Strategies. Market neutral
strategies generally involve the purchase of
securities and selling securities short in similar
dollar amounts in an attempt to produce returns
that are
independent of general market
performance. They may also involve the use of
Non-Traditional Assets, leverage and derivative
instruments.
• Statistical Arbitrage Strategies. Statistical
Arbitrage is based on the theory that stocks
have a tendency to return to a short-term trend
line. This type of strategy typically involves the
“systematic” or automated trading of securities
based upon where a security is relative to its
trend line.
Direct indexing strategies involve investing in a
basket of individual securities, such as stocks,
that seeks to track a selected benchmark index.
Direct indexing strategies may be more costly
than other
track
investment options
benchmark indices, such as mutual funds and
ETFs. Direct indexing strategies also generally
include the use of tax management strategies in
an attempt to enhance Account performance. The
use of tax management strategies will cause an
Account to deviate from the benchmark index,
which will cause the Account’s returns to vary
from that of the benchmark index. The use of tax
management strategies may not be successful
and the performance of Accounts pursuing a
direct index strategy could be materially lower
than the benchmark index. See “Tax Management
Strategies” above for more information about the
• Convertible Arbitrage Strategies. Convertible
arbitrage involves the purchase and short sale
of multiple securities of the same company. The
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
is
buy-outs,
restructurings
short
securities believed
and
leveraged
liquidations. These strategies often
involve
short selling, options trading, and the use of
other derivative instruments.
strategy
implemented by purchasing
securities believed to be undervalued and
selling
to be
overvalued. Often, the strategy involves the
purchase of a convertible bond issued by a
company and selling short that company’s
common stock. This strategy may involve the
use of a wide range of derivative instruments.
• Fixed
• Distressed Strategies. Distressed strategies
generally involve the purchase of securities in
companies that are in financial distress, or
companies that are entering into or are already
in bankruptcy. They may also involve the use of
short sales and derivative instruments.
Income Arbitrage Strategies. Fixed
income arbitrage strategies generally seek to
profit from interest rate, credit spread and other
arbitrage opportunities by investing in fixed
income securities, interest rate instruments and
derivative instruments.
• Macro Strategies. Macro strategies generally
involve the purchase of traditional assets, such
as stocks and bonds, and Non-Traditional Assets
and the use of short sales and derivative
instruments in an attempt to profit from
anticipated changes
in securities markets,
commodities markets, currency values, and/or
interest rates.
and
Systematic
• Discretionary
• Capital Structure Arbitrage Strategies. Capital
structure arbitrage generally involves investing
in multiple levels of a single company’s capital
structure, often taking long and short positions
in a company’s debt or equity in order to
capitalize on perceived mispricings resulting
from market inefficiencies or different pricing
assumptions. This type of strategy typically
involves the use of derivatives and structured
products.
strategies
generally
rely
Trading
Strategies. Discretionary
trading strategies
generally attempt to identify and capitalize on
patterns or trends in the markets. Systematic
on
trading
computerized trading systems or models to
identify and capitalize on those patterns or
trends. These strategies often involve the use of
Non-Traditional Assets, short sales, derivative
instruments and significant leverage.
• Private Investment Strategies.
• Absolute Return, Total Return and Real Return
Strategies. Absolute return, total return and
real return strategies generally involve the
purchase of traditional assets, such as stocks
and bonds, and Non-Traditional Assets in an
attempt to generate performance that has low
correlation to the major equity markets over a
complete market cycle. They may also involve
the use of derivative instruments.
generally
in
companies
involve
in
• Event-Driven
events
(such
and
liquidations).
Event-driven
Strategies.
strategies generally involve the use of Non-
Traditional Assets, short sales and derivative
instruments in an attempt to seek arbitrage
opportunities, particularly those triggered by
as mergers,
corporate
restructurings,
These
strategies typically involve the assessment of if,
how and when an announced transaction will be
completed.
arbitrage
strategies
involve
in corporate
o Private Equity Strategies. Private equity
equity
strategies
investments
private
transactions. These investments are typically
made through participation in private equity
funds or funds of private equity funds. Private
equity strategies may invest in companies of
all market capitalization ranges or may focus
on any combination of specific capitalization
ranges. They may also focus on companies in
one or more economic industries or sectors or
geographic regions. Some private equity
strategies focus on companies that are newly
formed, in financial distress or already in
bankruptcy. The securities purchased are
typically unregistered and illiquid. Private
equity strategies may also involve the use of
leverage.
• Merger Arbitrage/Special Situations Strategies.
Merger
the
purchase and sale of securities of companies
involved
reorganizations and
business combinations, such as mergers,
exchange offers, cash tender offers, spin-offs,
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
types and sizes of investments and may,
therefore, also lack diversification.
typically unrated or
• Leveraged Strategies. Leveraged strategies
generally involve the use of Non-Traditional
Assets, leverage, short sales and derivative
instruments in an attempt to amplify returns or
produce returns that are a multiple of a
benchmark index.
types of
referred
to as
floating
• Inverse Strategies. Inverse strategies generally
involve the use of Non-Traditional Assets,
leverage, short sales and derivative instruments
in an attempt to produce returns that are the
opposite of a benchmark index.
in
smaller
o Private Debt or Private Credit Strategies.
Private debt (also known as private credit)
strategies invest in loans or debt instruments
issued by companies in private transactions.
These investments are typically made through
participation in private debt funds or funds of
private debt funds. The investments involved
are
rated below
investment grade and are illiquid. Oftentimes,
the interest rate paid by the companies is
determined by a reference interest rate, such
as the federal funds rate, which is periodically
investments are
reset. These
sometimes
rate
corporate debt, floating rate loans or floating
rate bank loans. Private debt strategies often
involve the use of leverage and may involve
capitalization,
investment
distressed or bankrupt companies.
industrial
typically made
Alternative Strategies and other Complex
Strategies are not appropriate for some clients
because they are subject to special risks. See
“Services, Fees and Compensation—Additional
Service Information—Complex Strategies and
Investment Products” above and
Complex
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks—Non-Traditional
Assets and Complex Strategies Risks” below for
more information.
Asset Allocation Strategies
risks
related
Certain Services, including the GWG Investment
Management Service, make available asset
allocation strategies. Asset allocation strategies
involve investing in one or more of the following
categories of assets:
o Private Real Estate Strategies. Private real
estate strategies invest in physical properties,
such as office buildings, apartments, retail
facilities. These
centers, and
investments are
through
participation in private REITs. Private real
focus on specific
estate strategies may
geographic
types, or
regions, property
economic sectors. Investments in private real
estate can be illiquid, meaning they may take
time to sell or refinance. Property values can
fluctuate due to market conditions, supply
and demand, and other factors. There are
also
tenant vacancies,
to
property damage, or environmental hazards.
Leverage is often used in private real estate
investments, which can increase potential
returns but also amplifies potential losses.
o Private
invest
companies; U.S.
types. Examples of
cap
located
include,
These
among
utilities,
investments
• the equity securities asset category, which is
comprised of certain asset classes, such as,
equity securities issued by: U.S. large cap
growth companies; U.S.
large cap value
companies; U.S. large cap core companies; U.S.
mid cap growth companies; U.S. mid cap value
companies; U.S. mid cap core companies; U.S.
small cap growth companies; U.S. small cap
small
core
value
companies;
in
foreign companies
developed markets; foreign companies located
in emerging markets; U.S. REITs; and foreign
REITs;
as:
short-term
taxable
Infrastructure Strategies. Private
infrastructure
in
strategies
infrastructure projects and assets and may
involve exposure to a range of economic or
market sectors, geographic locations and
infrastructure
asset
others,
investments
and
telecommunication,
transportation.
are
typically made through participation in private
infrastructure funds. Investments in private
infrastructure strategies are often illiquid.
They may focus on certain sectors, industries,
geographic regions, size ranges or stages of
development or operations, or on certain
• the fixed income securities asset category,
which is comprised of certain asset classes,
such
bonds;
intermediate term taxable bonds; long-term
taxable bonds; short-term tax-exempt bonds;
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
intermediate term tax-exempt bonds; long-term
tax-exempt bonds; high yield fixed income
securities; foreign fixed income securities; and
broad fixed income securities;
Baird’s
projections
assumptions made by Baird about how markets
will perform in the future. There is no assurance
that asset classes or markets will perform in
or
accordance with
assumptions. For more information about Baird’s
Capital Market Assumptions, a client should
contact the client’s GWG Consultant.
and
• the Non-Traditional Assets category, which is
comprised of certain asset classes, such as:
commodity-linked
commodities
instruments; and currencies and currency-
linked instruments, and Digital Assets;
Baird’s most common asset allocation strategies
are described below. A client should note that the
specific investments in an Account following a
particular asset allocation strategy could vary
from the description below for a number of
reasons, including market conditions.
• the Alternative Investment Products category
which is comprised of certain asset classes,
such as: hedge funds, private equity funds and
managed futures; and
• cash.
allocation
strategies
have
also
have
varying
invest
All Growth Portfolio. An All Growth Portfolio
typically seeks to provide growth of capital.
Typically, an All Growth Portfolio will experience
high fluctuations in annual returns and overall
market value. Under normal market conditions,
this strategy generally invests nearly all of its
assets in equity securities. This strategy may also
invest in other asset classes, such as fixed income
securities, Non-Traditional Assets and cash. This
strategy may also
in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
investing, which
and
actively
typically
adjusting
tactical
Asset
varying
investment objectives, ranging from growth of
capital to preservation of capital. Asset allocation
investment
strategies
strategies. Some asset allocation strategies use
strategic investment strategies, which involve
investing accounts
in accordance with a
predetermined target allocation to different asset
classes. Some asset allocation strategies use
involves
tactical
tactically
account
allocations to different asset classes based upon
the manager’s perception of how those asset
classes will perform in the short-term. Some asset
allocation strategies involve the use of both
strategic and
investment strategies,
sometimes referred to as dynamic strategies.
Asset allocation strategies may be implemented
using a variety of investment types, such as
individual securities, mutual funds and ETPs. The
amount allocated to an asset class or investment
type varies by strategy, and some strategies may
have little or no allocation to one or more asset
classes or types of investments described above.
Capital Growth Portfolio. A Capital Growth
Portfolio typically seeks to provide growth of
capital. Typically, a Capital Growth Portfolio will
experience moderately high fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, this strategy will
primarily invest in a mix of equity securities and
fixed income securities, with a significantly higher
allocation to equity securities. This strategy may
also invest in other asset classes, such as Non-
Traditional Assets and cash. This strategy may
also invest in Alternative Investment Products or
may involve the use of leverage, short sales and
derivative instruments. Generally, under normal
market conditions, this strategy will have a
significantly higher allocation to equity securities
than fixed income securities.
typically seeks
involves
Growth with Income Portfolio. A Growth with
Income Portfolio
to provide
moderate growth of capital and some current
income. Typically, a Growth with Income Portfolio
will experience moderate fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, this strategy will
primarily invest in a mix of equity securities and
Baird uses its Capital Market Assumptions in
developing its proprietary model asset allocation
strategies, including those used by some GWG
Consultants. In determining its Capital Market
Assumptions, Baird conducts an analysis of
different asset classes and the different levels of
risk associated with those investments. That
analysis
the consideration of past
performance and the use of forward-looking
certain
projections
that are based upon
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and
targets only. There
fixed income securities, with a bias towards equity
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
equity securities than fixed income securities.
Strategies”
below
Some GWG Consultants
investment
managers use asset allocation strategies that
include target asset allocation percentages for
equity and/or fixed income investments in the
names or descriptions of the strategies (e.g., 80-
20, 60-40, 40-60, 20-80, etc.). A client should
note that those percentages are intended to be
asset allocation
is no
guarantee that Accounts following asset allocation
strategies will be invested strictly in accordance
with target asset allocations. It is likely that the
actual investments in Accounts following those
strategies will vary, sometimes significantly, from
the target asset allocations and may include other
asset classes due to market conditions and the
GWG Consultant’s or
investment manager’s
assessment of how to best invest a client’s
Accounts. See “Important Information about
Implementation of Investment Objectives and
Investment
for more
information.
Income with Growth Portfolio. An Income with
Growth Portfolio typically seeks to provide current
income and some growth of capital. Typically, an
Income with Growth Portfolio will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, this strategy will primarily
invest in a mix of fixed income securities and
equity securities, with a bias towards fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
fixed income securities than equity securities.
For information about the risks associated with
the asset allocation strategies described above,
see the section of the Brochure entitled “Principal
Risks—Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies” below.
Important Information about Implementation of
Investment Objectives and Investment Strategies
experience
relatively
Conservative Income Portfolio. A Conservative
Income Portfolio typically seeks to provide current
Income
income. Typically, a Conservative
Portfolio will
small
fluctuations in annual returns and overall market
value. Generally, under normal market conditions,
this strategy will primarily invest in a mix of fixed
income securities, cash and equity securities, with
a significantly higher allocation to fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets.
Generally, under normal market conditions, this
strategy will have a significantly higher allocation
to fixed income securities and cash than equity
securities.
A client should note that, to implement an
investment strategy, a client’s GWG Consultant or
investment manager may use or recommend
mutual funds, ETPs or other Funds that primarily
invest in particular types of securities instead of
direct investment in those types of securities. A
client should also note that the client’s GWG
Consultant or investment manager may use a
strategy not described above or they may use a
strategy with the same or similar name that is
implemented differently. A client should ask the
client’s GWG Consultant or investment manager
for more specific information about the strategy
being used for the client’s Account.
Preservation
A
Portfolio.
A client’s Account
is subject to the risks
associated with the Account’s particular strategies
and investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
From time to time, the client’s GWG Consultant or
invest the client’s
investment manager will
Capital
Capital
Preservation Portfolio typically seeks to preserve
capital while generating current income. Typically,
a Capital Preservation Portfolio will experience
relatively small fluctuations in annual returns and
overall market value. Under normal market
conditions, this strategy generally invests nearly
all of its assets in a mix of fixed income securities
and cash. This strategy may also invest in other
asset classes, such as equity securities and Non-
Traditional Assets.
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in an attempt
• Quantitative Analysis. Quantitative analysis is a
method of evaluating securities by analyzing a
large amount of data through the use of
to
algorithms or models
understand behavior, predict market events,
market prices, etc., and generate an investment
decision. As it pertains to managers and
investment products, quantitative analysis may
review of manager performance,
include
investment style, style consistency, risk, and
risk-adjusted performance.
• Technical Analysis. Technical analysis is a
method of analyzing past price and volume
patterns and trends in the trading markets to
attempt to predict the direction of both the
overall market and specific investments.
investment
restrictions,
• Top-Down Analysis. Top-down analysis involves
a consideration of certain macroeconomic
trends, such as general economic conditions,
geographic or market sector performance, fiscal
and monetary policy, taxes, or interest rates, to
make investment decisions.
Analysis. Bottom-up
• Bottom-Up
investment,
Account, or recommend that the client invest the
Account, in a manner that is inconsistent with the
investment strategy or
investment objective
selected by the client for the Account when the
client’s GWG Consultant or investment manager
determines that it is appropriate to do so, such as
using defensive strategies in response to adverse
market or other conditions or engaging in tax
management. Similarly, a client’s Account may be
invested in a manner inconsistent with the
investment strategy or
investment objective
selected by the client for the Account in certain
other circumstances, such as when the client’s
Account
is transitioning to a new Service,
investment objective or investment strategy, or
due to other factors, such as market appreciation
or depreciation of the assets in the client’s
Account, deposits and withdrawals made by the
client, and
if any,
imposed by the client. A client’s Account may not
be able to achieve its investment objectives
during any such period of time and the Account
may be subject to different or enhanced risks
than would be the case had the Account been
invested in a manner wholly consistent with the
investment objective or
investment strategy
selected by the client. Clients are encouraged to
discuss with their GWG Consultant on a regular
basis how the Account is being managed or
advised and whether any such conditions exist.
Methods of Analysis
analysis
involves consideration of factors particular to a
particular
such as business
financials (e.g., balance sheet strength and
cash flows), financial ratios (e.g., price-to-
earnings ratio), and business fundamentals
(e.g., management and product or services
performance) to make investment decisions.
Baird, its home office investment professionals,
and GWG Consultants may use various forms of
investment analyses, including the following:
• Fundamental Analysis. Fundamental analysis
involves an approach to investing through a
detailed analysis of specific companies, such as
their financial statements and financial ratios,
management, competitive advantages and
markets, in an attempt to determine the value
of an investment. Fundamental analysis may
include qualitative and quantitative analyses.
Analysis. Qualitative
• Qualitative
When providing investment advice to clients,
GWG Consultants utilize research reports and
other research material created by Baird PWM
Research Groups, such as PWM Equity Research,
PWM Fixed Income Research, and Asset Manager
Research. GWG Consultants may also utilize
research reports created by Baird’s Institutional
Equities & Research Department. It should be
noted that GWG Consultants are not obligated to
act in a manner consistent with those research
reports and they may act in a manner that is
contrary to those reports if they deem it to be in
the client’s best interest.
PWM Research Groups
analysis
involves the use of subjective judgment to
analyze factors that may be difficult to quantify
or measure objectively. As it pertains to
managers and investment products, qualitative
analysis may include review of the background
and experience of a manager or a mutual fund
company.
and GWG
Baird
Consultants use various third party information
and tools when formulating investment advice.
The sources of information and tools may include,
among others, information provided or created by
issuers and their sponsors (which may include
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information that is reported publicly, provided
directly to Baird, or reported through third party
platforms) and information and tools provided by
third party research firms, which may include
firms affiliated with Baird. Although Baird has
deemed the information and tools provided by
third party research firms to be generally reliable,
Baird does not independently verify or guarantee
the accuracy of the information or tools used.
(“AI”)
(described below) made available by Baird’s PWM
Research Groups, or they may use investment
products that Baird has generally deemed to be
“available” for use in its advisory programs
(“Available Investment Products”). The level of
initial and ongoing evaluation, monitoring and
review that GWG and Baird perform on managers
and on investment products varies. Available
Investment Products generally do not receive the
same level of initial or ongoing evaluation,
monitoring or review by Baird as those managers
or products that are included in a model portfolio
or on a recommended or eligible product list. As a
result, Available Investment Products are subject
to certain risks. See “Portfolio Manager Selection
and Evaluation—Methods of Analysis, Investment
Strategies and Risk of Loss—Principal Risks—
Available Investment Product Risks” below for
more information.
in
formulating
Baird PWM home office investment professionals
and GWG Consultants may use artificial
tools, such as machine
intelligence
learning, predictive analytics and probabilistic
modeling tools, data processing and automation
tools, generative AI tools, visual, speech and
audio tools, specialized domain tools, and other
similar technologies and tools (collectively, “AI
Tools”),
investment advice.
Generally, the use of AI Tools is limited to certain
aspects of Baird’s investment-advice process,
such as assisting with drafting of materials,
automation of workflow processes, and the
compilation,
organization,
reproduction,
summarization, analysis and interpretation of
information. The use of AI Tools is only supportive
of Baird’s investment-advice process and does not
replace the professional judgment of Baird PWM
home office investment professionals or GWG
Consultants. All AI Tool-assisted outputs used in
formulating investment advice are subject to
human
inform
review before such outputs
recommendations or investment decisions.
More specific information about Baird PWM model
portfolios, recommended lists and eligible product
lists is provided below. A client should note that
investment products recommended to the client
or selected for the client’s Account, including
investment managers or products included on a
Baird PWM recommended or eligible product list,
are those which, in Baird’s professional judgment,
may be appropriate to help the client pursue the
client’s financial goals. GWG and Baird do not
represent or guarantee that such investment
managers or products are or will be the best
investment managers or products available.
could negatively
influence
Under certain circumstances when requested by a
client, GWG and Baird may allow a client to
transfer from another firm or select an investment
product that is not on a Baird recommended or
eligible product list or that does not qualify as an
Available Investment Product. A client should note
that, unless GWG and Baird otherwise agree in
writing, GWG and Baird do not provide any initial
or ongoing evaluation, monitoring or review of
any such investment product and that the client’s
decision to transfer or select such investment
product is based solely upon the client’s review of
the investment product.
Certain PWM-Managed Portfolios
Baird Recommended Portfolio
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations,
deceptive behaviors and other flaws due to the
construction of their underlying models and the
composition of their training data, which can
result in outputs that seem plausible but are in
fact inaccurate, incomplete, or misleading. The
use of AI Tools creates a risk that erroneous
information
the
investment-advice process. Baird has established
policies and procedures designed to address the
risks posed by AI Tools, which
include
requirements that AI Tools pass a firm-level due
diligence process and that Baird associates obtain
training and independently verify AI Tool outputs.
However, such measures cannot eliminate the
risks posed by AI Tools.
The Baird Recommended Portfolio, which
is
managed by Baird’s PWM Equity Research team,
seeks to outperform the S&P 500 Index by
investing in a diversified core portfolio of 35–50
When providing investment advice to clients,
GWG Consultants may also use the model
portfolios or recommended or eligible product lists
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investment
approach
removed due to changes in valuation, company
fundamentals or the perceived ability to continue
to raise its dividend in the future—among a
variety of other potential reasons for portfolio
changes including a change in industry sector
weighting. The Portfolio is intended as a long-
term investment strategy.
AQA Portfolios
to
clients
Analysis
performance.
The
analysis
stocks. The portfolio invests primarily in stocks
with market capitalization greater than or equal to
$10 billion (large cap). The portfolio may also
contain stocks with market caps below $10 billion
but these stocks generally will not represent more
than 35% of the total portfolio. The team’s top–
down
begins with
macroeconomic and market outlooks from Baird’s
Investment Strategy team. This information is
used to underweight or overweight particular
industry sectors compared to the S&P 500 Index.
Individual stocks are selected with an emphasis
on higher quality companies that the team
believes have strong fundamental characteristics
teams, attractive growth
and management
prospects, and
reasonable price-appreciation
expectations. Each stock selected is assigned a
weighting as a percentage of the portfolio. No
single company stock will comprise more than the
greater of 5% of the portfolio or 1.5 times the
stock’s market weight in the S&P 500 index;
provided that a stock will not be removed due to
capital appreciation. Stocks can be sold or
positions reduced for a variety of reasons such as
valuation, a change in company or industry
fundamentals, or a change in industry sector
weighting. The Portfolio is intended as a long-
term investment strategy.
Baird Rising Dividend Portfolio
certain
Baird makes available
Automated Quantitative
(“AQA”)
Portfolios, which are managed by Baird’s PWM
Equity Research team. AQA is an analytical tool
that seeks to identify stocks of companies that
are undervalued by calculating the intrinsic values
for the stocks and comparing the calculated
values to current market prices. Focusing on a
company’s past
financial performance, AQA
analyzes fundamental ratios and trends of the
most recent eight-year history of a company and
each company in its peer group, excluding
estimates of future balance sheet and income
statement
is
quantitative and
ignores certain qualitative
information such as company-specific material
news and events. Stocks are ranked from the
most undervalued to the most overvalued based
on the difference between the values calculated
by AQA and current market prices. The stocks
identified by AQA as being the most undervalued
are then selected for investment. Baird offers the
following four (4) AQA Portfolio strategies, each of
which invest in undervalued stocks identified
using AQA, excluding securities issued by banks,
REITS and insurance companies: (1) the AQA All
Cap Strategy, which primarily invests in stocks
across market capitalizations, generally those
included in the S&P 500®, S&P MidCap 400® or
S&P SmallCap 600® Indices; (2) the AQA Large
Cap Strategy, which primarily invests in large cap
stocks, generally those included in the S&P 500®
Index; (3) the AQA Mid Cap Strategy, which
primarily invests in mid cap stocks, generally
those included in the S&P MidCap 400® Index;
and (4) the AQA Small Cap Strategy, which
primarily invests in small cap stocks, generally
those included in the S&P SmallCap 600® Index.
Certain Recommended Lists
Baird’s Recommended Managers List
The Baird Rising Dividend Portfolio, which is
managed by Baird’s PWM Equity Research team,
seeks to provide a core equity strategy with a
portfolio yield above that of the S&P 500 Index.
The team’s top–down investment approach begins
with macroeconomic and market outlooks from
Baird’s Investment Strategy team. The 30–50
stocks in the portfolio are primarily large cap
stocks—as defined by a market capitalization of
$10 billion or greater at the time of investment—
and all are above $5 billion at the time of
investment. The team looks for quality companies
with strong
fundamental characteristics and
management, attractive dividend yields, and the
ability to increase their dividends. Companies are
screened for dividend history and consistency,
earnings growth expectations, and balance sheet
quality. Each stock selected
is assigned a
weighting as a percentage of the portfolio. No
single company stock will comprise more than the
greater of 5% of the portfolio or 1.5 times the
stock’s market weight in the S&P 500 index;
provided that a stock will not be removed due to
capital appreciation. A position can be reduced or
When selecting managers and BRM Strategies for
Baird’s Recommended Managers List, Baird often
seeks registered investment advisory firms having
portfolio managers with academic credentials
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and how the manager adds value. The final
determination of Baird’s Recommended Managers
List
is subject to the approval of Baird’s
Investment Committee.
conference
calls,
for
removal
such as a master’s degree or participation or
completion of the Chartered Financial Analyst
(“CFA”) program. Baird also typically looks for a
portfolio manager with greater than three (3)
years of investment experience focusing on the
particular investment style that is offered by the
portfolio manager. Baird generally looks for
portfolio managers
that have demonstrated
success, that have performance histories showing
sufficient ability to achieve returns in excess of
their respective benchmarks, and that have
investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird
also considers other qualitative and quantitative
factors.
change
Baird’s Asset Manager Research Department is
primarily responsible for selecting and evaluating
included on Baird’s
investment managers
Recommended Managers List.
selecting
In
investment managers, Baird’s Asset Manager
Research Department utilizes quantitative and
qualitative measures to evaluate managers based
on the:
Ongoing manager evaluation generally includes
quarterly
performance
attribution and periodic onsite visits. Material
adverse changes affecting a manager may result
in the manager being placed on “watch” status.
Managers on “watch” status are scrutinized to see
if improvement or degradation is taking place.
from Baird’s
Potential causes
Recommended Managers List include fundamental
changes in the operations of the manager,
turnover in key personnel, substantial changes in
management or ownership, a
in
investment philosophy or style, significant drift
from stated objectives, major legal, regulatory or
compliance difficulties, impairment of financial
condition, sustained underperformance in relation
to its peers, or other adverse changes affecting
the manager that in Baird’s opinion warrants the
manager’s removal.
• quality and stability of their organization
• soundness and clarity of their investment
philosophy
• reliability and consistency of their investment
process
• competitiveness of their investment
performance
Baird’s Asset Manager Research Department may
also employ the use of computers and third party
software to more readily display information and
assist with the evaluation and analysis.
its discretion, decides
If a Model-Traded BRM Strategy is selected for a
client’s Account, it is important to note that
Baird’s selection and ongoing evaluation of a BRM
Strategy is based upon an assumption that the
Recommended Manager’s Model Portfolio will be
fully and faithfully implemented by the Overlay
Manager or Implementation Manager on a
continuous basis. A client should understand that
the Overlay Manager or Implementation Manager
has discretion over the client’s Account and may
invest the client’s Account in a manner that differs
from the Model Portfolio. Baird does not monitor
the Account’s performance nor does it ascertain
whether the Overlay Manager or Implementation
Manager is implementing the Model Portfolio as
provided by the Recommended Manager. If the
Overlay Manager or Implementation Manager, in
the exercise of
to
implement the Model Portfolio differently, the
performance of a client’s Account could be
negatively impacted. Baird is not monitoring,
evaluating or reviewing the Overlay Manager or
Implementation Manager or the performance of a
client’s Account under those circumstances.
Baird’s initial screening process begins with a
proprietary, multi-factor model that evaluates
managers on different factors including risk-
adjusted performance, consistency of returns and
downside protection. These factors are scored
over various time periods and relative to a
specific peer group universe, narrowing the pool
of managers for further evaluation. Baird’s Asset
Manager Research Department then performs a
more in-depth evaluation of managers that are
identified through the initial screening process,
which generally includes a review of the following
factors: stability of the firm/team, the robustness
and repeatability of the investment process, the
portfolio’s past returns pattern and tax-efficiency,
Certain SMA Strategies offered by Baird Equity
Asset Management have been selected by Baird
for inclusion on Baird’s Recommended Managers
List. This presents a conflict of interest. However,
the criteria used by Baird in deciding to select
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SMA
Strategies
for
Associated
Baird’s
Recommended Managers List are the same as
those used for unassociated SMA Strategies.
Baird’s Recommended Mutual Fund List
Strategies or other Complex Strategies. Some
FOHFs primarily use credit-oriented investment
strategies, which Baird classifies as fixed income
diversifiers. Some FOHFs primarily use equity-
oriented investment strategies and are classified
as equity diversifiers. Other FOHFs use a
combination of credit- and equity-oriented
strategies, which Baird views as balanced
diversifiers. In certain circumstances, FOHFs may
be an appropriate substitute for part of a client’s
allocation to traditional high yield fixed income or
equity investments.
that
to
the
for
the
fund; and
Baird’s
Asset Manager
To be added to Baird’s Recommended FOHF List,
a FOHF must generally meet the
following
requirements: the investment advisor to the FOHF
is registered as an Investment Adviser under the
Advisers Act; the fund has stable to growing
assets under management as determined by
Baird, principals of the fund have an appropriate
level of hedge fund management experience and
a sufficient network of contacts in the industry as
determined by to Baird; in Baird’s opinion, the
fund has adequate diversification by number of
hedge funds and type of hedge fund strategy;
effective risk management programs have been
the service
established
providers to the fund (e.g., auditor, administrator,
and legal counsel) are deemed to be reputable in
the judgment of Baird. Baird also seeks FOHFs
that it believes possess one or more unique
attributes that may lead to favorable performance
relative to their peers going forward.
Investment Committee
legal documents
offering memorandum,
inclusion
Baird’s Recommended Mutual Fund List
is
designed to include mutual funds and ETFs across
numerous asset classes. When selecting funds for
inclusion on the List, Baird generally seeks funds
that have investment managers with tenure of at
least three (3) years and have underlying
investments
fund’s
adhere
market capitalization policy and are consistent
with the manager’s stated investment process
and philosophy. Baird generally looks for funds
that are among the top-performing funds in a
style category in terms of risk-adjusted returns or
that are managed by individuals or firms that
have demonstrated success in other, related asset
classes; that have performance histories showing
sufficient ability to achieve returns in excess of
their respective style index; and that have
investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird’s
Asset Manager Research Department is primarily
for assisting with selecting and
responsible
evaluating funds included on the List. In selecting
funds,
Research
Department utilizes a quantitative and qualitative
evaluation process of the investment managers of
such funds. The process Baird uses for selecting
and removing funds for the Baird Recommended
Fund List is similar to the process Baird uses to
select and remove BRM Strategies described
under “Baird’s Recommended Managers List”
is
above. Baird’s
ultimately responsible for selecting funds included
on the List. The Baird Ultra Short Bond Fund,
Baird Short-Term Bond Fund, Baird Aggregate
Bond Fund, Baird Quality Intermediate Municipal
Bond Fund, Baird Core Intermediate Municipal
Bond Fund, and Baird Mid Cap Growth Fund,
mutual funds affiliated with Baird, have been
selected by Baird
in Baird’s
for
Recommended Mutual Fund List. This presents a
conflict of interest. However, the criteria used by
Baird in deciding to select Associated Funds for
Baird’s Recommended Mutual Fund List are the
same as those used for unassociated funds.
Baird’s Recommended Funds of Hedge Fund List
Baird’s Recommended Funds of Hedge Fund List
may contain several types of funds of hedge
funds (“FOHFs”) that pursue various Alternative
Before adding a prospective FOHF to the List,
Baird’s Asset Manager Research Department
conducts an in-depth due diligence process. The
process begins with a review of the FOHF’s
responses to a due diligence questionnaire and of
(such as,
marketing and
subscription documentation, investor agreements,
and
organizational
documents, and the investment advisor’s Form
ADV Part 2A Brochures). This is followed by an
onsite review, where Baird meets with one or
more principals and analysts to assess how the
FOHF identifies, hires, monitors, and terminates
individual hedge funds. Baird also evaluates how
the FOHF constructs its hedge fund portfolio and
manages risk. At the conclusion of the onsite
review, an investment thesis is presented to and
discussed with a Baird Investment Committee.
The Committee votes on whether to add the FOHF
to Baird’s Recommended Funds of Hedge Fund
the
List.
In making
that determination,
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funds,
funds
or
Committee considers the information presented,
taking into account the merits of the individual
FOHF, how that FOHF compares to other FOHFs
that Baird offers, and the level of expected
demand for the particular FOHF.
client’s allocation
to
and
onsite
situations or distressed
investments. The
investments are typically structured in the form of
primary
co-
secondary
investments. Most will be to “middle market”
companies, many of which have above average to
high levels of leverage, or debt relative to equity.
In certain circumstances, funds of private equity
funds may be an appropriate substitute for part of
traditional equity
a
investments.
changes
that pursue
or
After a FOHF is added to Baird’s Recommended
Funds of Hedge Fund List, it is monitored each
quarter,
reviews
subsequent
periodically take place. As part of its quarterly
monitoring, Baird evaluates a FOHF’s assets under
(subscriptions and
management and
flows
(e.g.,
redemptions), organizational
personnel changes or new offerings), recent
changes made to the FOHF portfolio (e.g., hedge
funds added or removed), and reasons for
performance differences between the FOHF and
its benchmark. Subsequent onsite reviews are
similar in nature and scope to the initial on-site
review.
Baird’s Recommended Private Debt Fund List
contains private debt funds (also known as
private
certain
funds)
credit
Alternative Strategies
other Complex
Strategies. The private debt funds on Baird’s
Private Debt Funds List generally make first lien,
second lien and unsecured loans, primarily to
middle market companies sponsored by private
equity firms. In certain circumstances, private
debt funds may be an appropriate substitute for
part of a client’s allocation to traditional high yield
fixed income or equity investments.
funds
that
or
utilities,
telecommunication,
The
investments may
with
companies
that
Baird may place a FOHF on “watch” status if it has
experienced a material event that, in Baird’s
opinion, may negatively affect
the FOHF’s
performance going forward or possibly lead to the
departure of an important member(s) of the
FOHF. Examples include a large decline in assets
under management, high rate of redemptions,
notable change in the investment or compliance
teams, weakening performance, or regulatory
problems. Any firm that is placed on “watch”
status is evaluated more closely to determine if
the problem is likely to be temporary or long-
term, and whether it can be remedied. Baird will
remove a FOHF from “watch” status and return it
to active status if, in Baird’s opinion, the problem
has been or is in process of being adequately
addressed. However, Baird will terminate a FOHF
from the List if it believes the issue is likely to be
long-term and adversely affect the FOHF’s future
performance.
Baird’s Recommended Private Real Assets Fund
List contains private real estate and private
certain
pursue
infrastructure
Alternative Strategies
other Complex
Strategies. These strategies invest in different
real assets and may involve exposure to a range
of economic or market sectors, geographic
locations and asset
types. Examples of
investments may include, among others, real
and
estate,
transportation.
be
structured in the form of asset ownership or
leasing or include direct investment in or joint
ventures
control
infrastructure assets. In certain circumstances,
private real assets funds may be an appropriate
substitute for part of a client’s allocation to
traditional fixed income or equity investments.
Baird’s Recommended Private Funds Lists
Baird maintains lists of recommended private
Funds (“Recommended Private Funds”), including
a Recommended Funds of Private Equity Funds
List, a Recommended Private Debt Fund List, and
a Recommended Private Real Assets Fund List.
Baird’s Recommended Funds of Private Equity
Funds List contains funds of private equity funds
that pursue certain Alternative Strategies or other
Complex Strategies. These strategies can include
buyout, growth equity, venture capital, special
To be added to a Baird Recommended Private
Fund List, a fund must generally meet the
following requirements: the investment advisor to
the fund is registered under the Advisers Act ; the
fund has stable
to growing assets under
management as determined by Baird; principals
of the fund have an appropriate level of applicable
experience and a sufficient network of contacts in
the industry as determined by Baird; effective risk
management programs have been established for
the fund; and the service providers to the fund
(e.g., auditor, administrator, and legal counsel)
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are deemed to be reputable in the judgment of
Baird. Baird also seeks funds that it believes
possess one or more unique attributes that may
lead to favorable performance relative to their
peers going forward.
fund
change in the investment or compliance teams,
weakening performance, or regulatory problems.
Any fund that is placed on “watch” status is
evaluated more closely to determine if the
problem is likely to be temporary or long-term,
and whether it can be remedied. Baird will
remove a fund from “watch” status and return it
to active status if, in Baird’s opinion, the problem
has been or is in process of being adequately
addressed. However, Baird will remove a fund
from a Recommended Private Fund List if it
believes the issue is likely to be long-term and
adversely affect the fund’s future performance.
Certain Eligible Product Lists
Annuities
the
strength
ratings
When determining whether to make an annuity
product available to Baird clients, Baird reviews
the offering documents for the product and
considers: the size of the insurer and the insurer’s
credit rating,
insurer’s distribution and
support model, and product specifications and
features of the product. Baird favors highly-rated
insurers and evaluates them by using credit rating
agencies
and
financial
independent third-party research.
Baird’s ETF Focus List
the
Before adding a prospective
to a
Recommended Private Fund List, Baird’s Asset
Manager Research Department conducts an in-
depth due diligence process. The process begins
with a review of the fund’s responses to a due
diligence questionnaire (known as a DDQ or RFI)
and of marketing and legal documents (such as,
subscription documentation, investor agreements,
offering memorandum, organizational documents,
and the investment advisor’s Form ADV Part 2A
Brochures). This is followed by an onsite review,
where Baird meets with one or more principals
and analysts to assess how the fund makes
investment decisions. Baird also evaluates how
the fund constructs its portfolio and manages risk.
In addition, Baird may undertake a brief review of
the fund’s third-party service providers. At the
conclusion of the onsite review, an investment
thesis is presented to and discussed with a Baird
Investment Committee. The Committee votes on
whether to add the fund to a Baird Recommended
Private Fund List. In making that determination,
the Committee
information
considers
presented, taking into account the merits of the
individual fund, how that fund compares to other
similar funds that Baird offers, and the level of
expected demand for that particular fund.
indices,
Baird’s ETF Focus List is designed to encompass
numerous asset classes and varied investment
objectives. Baird generally seeks to include ETPs,
primarily ETFs, with transparent, experienced
sponsors that have stable or growing assets under
management and have demonstrated consistent
strategy performance over time. Baird tends to
favor ETPs that have well-known, diversified
benchmark
fees and tracking
lower
errors, and higher trading liquidity relative to
other ETPs. Inclusion on or exclusion from the
Baird ETF Focus List is not meant to be a buy or
sell recommendation. Rather, the List
is a
collection of ETPs that may be appropriate to
meet particular client investment goals.
PWM Stock Opportunities List
After a fund is added to a Baird Recommended
Private Fund List, it is monitored each quarter,
and subsequent onsite reviews periodically take
place. As part of its quarterly monitoring, Baird
evaluates a fund’s assets under management and
flows (subscriptions and redemptions),
fund
organizational changes (e.g., personnel changes
or new offerings), recent changes made to the
portfolio, and reasons for performance differences
between the fund and its benchmark. Subsequent
onsite reviews are similar in nature and scope to
the initial on-site review.
The PWM Stock Opportunities List is comprised of
stocks that Baird’s PWM Equity Research team
believes offer timely investment opportunities
based on market, sector, and
fundamental
analysis. Stocks on the list must be covered by
Baird, Evercore ISI, or Morningstar and are
screened to curb near-term fundamental risk. The
List focuses on large cap and mid/small cap
Baird may place a Recommended Private Fund on
“watch” status if it has experienced a material
event that, in Baird’s opinion, may negatively
affect the fund’s performance going forward or
possibly lead to the departure of an important
member(s) of the
investment team.
fund’s
Examples include a large decline in assets under
management, high rate of redemptions, notable
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investments with
yield,
and
Available Hedge Funds
companies,
speculative investment opportunities.
Managed Futures
Effective March 1, 2018, Baird ceased maintaining
an official list of managed futures funds that are
structured as limited partnerships. Therefore,
Baird does not, and will not in the future, provide
any evaluation, monitoring or review of those
funds or their sponsors. A client’s decision to
invest in, or to maintain an investment in, a
managed futures fund is based solely upon the
client’s own review and evaluation of the fund.
Structured Products
Baird makes hedge funds available to clients in
certain Programs sponsored by, affiliated with or
offered by Capital Integration Systems LLC or
CAIS Capital LLC (“CAIS”). An independent third-
party research firm provides research and due
diligence materials to Baird on the hedge funds
available on the CAIS platform (“Available Hedge
Funds”). Clients interested in an Available Hedge
Fund or invested in an Available Hedge Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely
relies upon the independent third-party research
firm to provide an independent analysis of each
Available Hedge Fund, Baird does not conduct its
own research or due diligence on any Available
Hedge Fund, and Baird does not verify the
accuracy of the information contained in the
research and due diligence materials.
Available Private Funds
is calculated,
When determining whether to make a structured
product available to Baird clients, Baird reviews
the offering documents for the structured product
and considers: the size of the issuer and issuer’s
credit rating, the maturity of the product, how
the underlying asset
interest
category (e.g., a basket of securities or currencies
or a market index), applicable caps, barriers, and
participation rate, and whether the structured
product has principal protection.
third-party
research
firm
Baird tends to favor larger-sized issuers of
structured products over smaller-sized issuers
and also tends to favor structured products that
have shorter maturities, less complex payout
structures, underlying assets that are more liquid
or transparent, and offer full or partial principal
protection. If a product does not offer full
principal protection, Baird also considers how
much principal is exposed to loss, whether, in
Baird’s judgment, there is reasonable risk/reward
trade-off for that exposure, as well as the events
that could trigger loss of principal and Baird’s
belief as to the likelihood of the occurrence of
such events.
Investment Solutions Department
In addition to Recommended Private Funds, Baird
makes available to clients in certain Programs
other private funds sponsored by, affiliated with,
or offered by CAIS (“Available Private Funds”),
including Available Private Equity Funds, Available
Private Debt Funds, Available Private REITs and
Available Private Infrastructure Funds. When
determining whether to make a fund an Available
Private Fund, Baird utilizes the services of an
that
independent
provides research and due diligence materials to
Baird on the private funds available on the CAIS
platform. Clients interested in an Available Private
Fund or invested in an Available Private Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely
relies upon the independent third-party research
firm to provide an independent analysis of each
Available Private Fund, Baird does not conduct its
own research or due diligence on any Available
Private Fund, and Baird does not verify the
accuracy of the information contained in the
research and due diligence materials.
the
Programs.
Baird’s
Affiliated Private Equity Funds
Compliance,
Legal,
and
Baird’s
is
primarily responsible for selecting and evaluating
structured products made available to clients
under
Alternative
Investment Committee, which includes members
of Baird’s Investment Solutions, Asset Manager
Research,
Risk
Management Departments, ultimately determines
whether to make a structured product available to
Baird clients.
In addition to Recommended Funds of Private
Equity Funds and Available Private Equity Funds,
Baird makes available to clients private equity
funds that are affiliated with Baird (“Affiliated
Private Equity Funds”). Baird does not subject
Affiliated Private Equity Funds to the criteria
imposed upon Recommended Funds of Private
Equity Funds or Available Private Equity Funds
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allocation of 70% of its assets to equity securities
and 30% of its assets to fixed income securities.
Financial
Industry
Activities
Relationships
described above when making them available to
clients, and Baird does not perform any
evaluation, monitoring or review of Affiliated
Private Equity Funds. This presents a potential
conflict of interest. See “Additional Information—
and
Other
Affiliations—Certain
and
Arrangements—Baird and Associated Parties”
below.
Other Funds
fixed
The Baird Trust Core + Satellite 50/50
(4)
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation portion of the
portfolio while providing exposure to satellite
asset classes (such as mid cap and small cap
companies) and fixed income securities through
the use of ETFs that principally invest in equity
securities and
income securities. This
strategy has a target allocation of 50% of its
assets to equity securities and 50% of its assets
to fixed income securities.
(5)
The Baird Trust Equity Income strategy
primarily invests in dividend paying companies
that Baird Trust believes have the ability to
consistently grow their dividend at attractive rates
over the long‑term.
In certain instances when GWG believes it to be
consistent with a client’s investment goals, GWG
may recommend to the client certain Funds that
are not on a Baird recommended or available
Fund list or offered through CAIS. Baird does not
provide any research or due diligence on such
Funds, but they are reviewed by GWG
in
accordance with its investment process described
below.
Baird Trust Strategies
More specific information about the particular
investment strategies and methods of analysis
that Baird uses in connection with each Program
is further described below.
The GWG Investment Process
Baird makes available to clients five (5) portfolio
strategies developed and maintained by Baird
Trust (“Baird Trust Strategies”) described below.
The Baird Trust Strategies invest in a mix of
equity securities and ETFs.
(1)
The Baird Trust Large Cap Equity strategy
invests in a fairly concentrated portfolio of large
cap equity securities. This strategy is intended for
clients seeking investment in large cap companies
as one part of their overall asset allocation. This
strategy is generally not intended to be a
complete investment program.
(2)
The Baird Trust Core + Satellite 100
strategy is a diversified portfolio with a 100%
target equity allocation. The strategy uses the
Baird Trust Large Cap Equity strategy as the core
allocation of
the portfolio while providing
exposure to satellite asset classes (such as mid
cap and small cap companies) through the use of
ETFs that principally invest in equity securities.
This model does not include fixed income.
When providing advice to clients, GWG starts with
the “financial
framework” and risk analysis
developed for a client in connection with the
financial planning process described above. Using
a variety of tools, GWG then develops and
recommends a
strategic asset
long-term,
allocation and investment strategy for the client’s
portfolio that is appropriate for the client’s risk
and
return objectives. GWG develops a
customized asset allocation strategy by dividing
client assets into what GWG views as “Less Risky”
and “More Risky” asset classes. GWG then
develops an investment strategy by diversifying
the client’s portfolio among different investments
in each asset class with the goal to manage risk.
Investment strategies may involve the use of
different equity styles or strategies, such as: large
cap growth, large cap value, mid cap growth, mid
cap value, small cap growth, small cap value,
international and emerging market equities
strategies; different
income styles or
fixed
strategies, such as short or intermediate, taxable
and tax-exempt bond, international and emerging
market bond, and high yield bond strategies. In
certain instances when appropriate for a client,
Investment strategies may involve different Non-
Traditional Asset strategies, such as real estate
(3)
The Baird Trust Core + Satellite 70/30
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation of the portfolio
while providing exposure to satellite asset classes
(such as mid cap and small cap companies) and
fixed income securities through the use of ETFs
that principally invest in equity securities and
fixed income securities. This strategy has a target
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Program Portfolio Strategies
GWG Investment Management Service
and real estate fund and commodity strategies;
and Alternative Strategies, which may include the
use of hedge funds, funds of hedge funds, private
equity funds, funds of private equity funds, and
managed
futures. See “Services, Fees and
Compensation—Consulting Services” above for
more specific information.
Under the GWG Investment Management Service,
GWG may use various investment strategies. A
client’s particular investment strategy is typically
determined by GWG in consultation with the client
using the investment process described in the
section “The GWG Investment Process” above.
time
to
From
time, and depending on
macroeconomic conditions, GWG may also
recommend or implement a slight, short-term
tactical tilt to the client’s chosen asset allocation
that is above or below the long-term strategic
asset allocation.
GWG typically recommends or selects mutual
funds and ETFs for GWG Investment Management
Accounts. However, other types of securities may
be recommended or selected for those Accounts.
lists,
see
GWG Consultants, as a group, utilize a variety of
investment styles and strategies, including the
investment strategies described in the sections
“Methods of Analysis, Investment Strategies and
Risk of Loss—Investment Strategies” and “The
GWG Investment Process” above. They may also
use the model portfolios or recommended or
eligible product lists made available by Baird’s
PWM Research Groups, or they may use lists of
investment products that Baird has generally
deemed to be “available” for use in its advisory
programs. For more information about Baird
model portfolios, recommended lists and eligible
product
“Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis” above.
for
the client. Once
and
When recommending or selecting a particular
mutual fund or ETF for client Accounts, GWG
begins by reviewing a client’s asset allocation and
investment strategy needs and identifying the
characteristics of the types of mutual funds or
the
ETFs appropriate
characteristic types of mutual funds or ETFs are
identified, GWG looks for investments that meet
those requirements. GWG tends to look for
passively managed funds when selecting funds
that invest primarily in equity securities and
actively managed funds when selecting funds that
invest primarily in fixed income securities. GWG
also looks for funds that have higher trading
volumes and lower expense ratios. Once GWG has
identified a potential fund for a client, GWG
conducts a quantitative and qualitative analysis of
the investment manager for the fund similar to
the analysis it performs on investment managers
described under “Portfolio Manager Selection and
Evaluation—Selection
Evaluation—GWG
Recommended Managers Service” above.
GWG manages client assets using investment
strategies and investment products based upon a
client’s particular
investment objectives and
financial goals. GWG may use a wide variety of
investment products to implement the client’s
investment strategy, which
investments are
further described under “Services, Fees and
Compensation—Additional Service Information—
Permitted Investments” above. GWG may also
use certain
investment strategies, such as
concentrated investment strategies and margin,
and certain types of investments, such as illiquid
securities and Complex Investment Products,
including REITs, private equity funds, funds of
private equity funds, leveraged or inverse funds
and structured products. These
investment
strategies and products involve special risks and
may not be appropriate for all clients. Please see
“Principal Risks” below for more information.
Principal Risks
In order to implement the overall client portfolio
strategy, GWG may utilize one or more of the
Services and a
combination of different
investment vehicles, such as SMAs, mutual funds
and ETFs.
More specific information about the particular
investment strategies and methods of analysis
that GWG and Baird use in connection with each
Service is further described below.
Risk is inherent in any investment product and
GWG and Baird do not guarantee any level of
return on a client’s investments. There is no
assurance that a client’s investment objectives
will be achieved, and a client could lose all or a
portion of the amount invested. The management
of client accounts and recommendations made to
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experience increases in value, the client’s Account
may experience a decline in value due to the
underperformance of the stocks selected for
investment in the client’s Account.
conditions and other
the associated
Investment Objective and Asset Allocation
Risks. A client’s investment objective and asset
allocation strategies involve the risk that certain
asset classes selected for the client’s Account may
not perform as well as other asset classes during
varying periods. In addition, clients who pursue
more aggressive investment objectives and asset
allocation strategies, while hoping to achieve high
returns, may face greater risk of loss than clients
with more conservative objectives and strategies.
In developing investment objectives and asset
allocation strategies, clients should carefully
consider their financial situation and needs,
investment goals, investment time horizon and
risk tolerance. A client should inform the client’s
GWG Consultant of these considerations so the
GWG Consultant can assist in determining the
client’s investment objectives and asset allocation
strategies.
clients are based in part upon the use of forward-
looking projections, which in turn are based upon
certain assumptions about how markets will
perform in the future. There can be no guarantee
that markets will perform in the manner assumed
and the actual performance of markets and a
client’s Account could differ materially from those
assumptions. Also, a client’s Account value may
fluctuate, sometimes dramatically, depending
upon the nature of the client’s investments,
market
factors. By
participating in a Service, a client may be subject
to certain risks, including, but not limited to the
risks described below. The risks discussed below
vary by Service, investment style or strategy, and
the investments in the client’s Account, and each
risk may or may not apply to a client. Clients
should not pursue a strategy or invest in an
investment product unless they are prepared to
accept
risks. Clients are
encouraged to discuss with their GWG Consultant
the risks that apply to them. A client should also
review
the prospectus or other disclosure
document for any security or other investment
product in which the client invests, as it will
contain important information about the risks
associated with investing in such security or other
investment product.
Investment Risk Information
The investment risks of the Services generally
include the following:
Conflicts of Interest Risks. Issuers, advisors or
other sponsors of investment products or their
affiliates may engage in business practices that
conflict with the interests of investors. Among
other things, these business practices can have a
negative impact on the market price of the
investment product. Clients are encouraged to
review
the prospectus or other disclosure
document for the investment product and also
discuss with their GWG Consultant the conflicts of
interest risks that may apply to them.
Stock Market Risks. Equity security prices vary
and may fall, thus reducing the value of a client’s
investments. Certain stocks selected for a client’s
Account may decline in value more than the
overall stock market.
Market Risks. A client’s Account may change in
value due to overall market fluctuations. General
economic conditions, political developments,
international events and other factors may cause
the overall market to decline, which in turn may
reduce the value of the client’s Account regardless
of the relative strength of the securities held in
the Account. Securities prices often vary for
reasons unrelated to matters directly affecting the
issuers of the securities.
fluctuate
client
accounts
about
Equity Securities Risks. Equity securities may
experience sudden, unpredictable drops in value
or long periods of decline in value. This may occur
because of factors that affect the securities
markets in general, such as adverse changes in
economic conditions, the general outlook for
corporate earnings, interest rates or investor
sentiment. Equity securities may also lose value
because of factors affecting an entire industry or
sector, such as increases in production costs, or
Management and Securities Selection Risks.
A client’s Account may
in value
differently than, or in the opposite direction as,
the overall market or applicable benchmark
because of the selection of individual securities for
the Account. The judgments made by the persons
managing
the
attractiveness, value and potential appreciation of
particular securities may prove to be incorrect.
For example, while the stock markets may
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factors directly related to a specific company,
such as decisions made by its management.
unable to meet its payment obligations. Municipal
obligations in particular may be adversely affected
by political and economic conditions and
developments (for example, legislation reducing
state aid to local governments.) Bonds receiving
the lowest investment grade rating or a non-
investment grade rating may have speculative
characteristics and, compared to higher grade
debt obligations, may have a weakened capacity
to make principal and interest payments due to
changes in economic conditions or other adverse
circumstances. Ratings agencies such as Moody’s,
Fitch and S&P provide ratings on bonds based on
their analyses of information they deem relevant.
Ratings are essentially opinions or judgments of
the credit quality of an issuer and may prove to
be inaccurate. In addition, there may be a delay
between events or circumstances adversely
affecting the ability of an issuer to pay interest
and/or repay principal and an agency’s decision to
downgrade a security.
Common Stock Risks. Common stocks are
susceptible to general stock market fluctuations
and to volatile increases and decreases in value
as market confidence in and perceptions of their
issuers change. These investor perceptions are
based on various and unpredictable
factors
including: expectations regarding government,
economic, monetary and fiscal policies; inflation
and
interest rates; economic expansion or
contraction; and global or regional political,
economic and banking crises. Holders of common
stocks are generally subject to greater risk than
holders of preferred stocks and debt obligations of
the same issuer because common stockholders
generally have inferior rights to receive payments
from issuers in comparison with the rights of
preferred stockholders, bondholders and other
creditors.
less
liquid
larger companies. Therefore,
Fixed Income Security Risks. Fixed income
securities are subject to certain risks, including
interest rate risk, credit risk and liquidity risk. In
addition, they are subject to maturity risk.
Generally, the longer a bond’s maturity, the
greater the interest rate risk and the higher its
yield. Conversely, the shorter a bond’s maturity,
the lower the interest rate risk and the lower its
yield. Non-rated, split-rated, below investment
grade, and asset-backed securities, including
mortgage-backed securities and CMOs, have
additional, special risks.
them more susceptible
Capitalization Size Risks. A client may be
invested in small and mid cap stocks, which are
often more volatile and
than
investments in larger companies. The frequency
and volume of trading in securities of such
companies may be substantially less than is
typical of
the
securities of such companies may be subject to
greater and more abrupt price fluctuations. In
addition, small- and mid-size companies may lack
the management experience, financial resources
and product diversification of larger companies,
making
to market
pressures and business failure.
foreign
Interest Rate Risk. The value of some
investment products, particularly fixed income
securities, is affected significantly by changes in
interest rates. Generally, when interest rates rise,
the product’s market value declines and when
interest rates decline, its market value rises. In
addition, a rise in interest rates may have a
negative impact on the issuer, which, in turn,
could have a negative impact on the market value
of the investment product.
Credit Risk. The value of some investment
products, particularly fixed income securities, is
affected by changes in the product’s credit quality
rating or the issuer’s financial condition. If the
credit quality rating or the issuer’s financial
condition declines, so may the value of the
investment product. Issuers may experience
unanticipated financial problems and may be
Foreign Issuer and Investment Risks.
Securities of
issuers, ADRs, Global
Depositary Receipts (“GDRs”) and European
Depositary Receipts (“EDRs”), and investments in
foreign markets generally, are subject to certain
inherent risks, such as political or economic
instability of the country of issue, the difficulty of
predicting international trade patterns and the
possibility of imposition of exchange controls.
Such securities may also be subject to greater
fluctuations in price than securities of domestic
corporations. Investors in foreign markets may
face delayed settlements, currency controls and
adverse economic developments as well as higher
overall transaction costs. In addition, fluctuations
in the U.S. dollar’s value versus other currencies
may enhance, erode, reverse gains or widen
losses from investments denominated in foreign
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or
penalties,
reputational
investigate,
or
remediate
in
the
section
titled
currencies. For instance, foreign governments
may limit or prevent investors from transferring
their capital out of a country. This may affect the
value of a client’s investment in the country that
adopts such currency controls. Exchange rate
fluctuations also may impair an issuer’s ability to
repay U.S. dollar denominated debt, thereby
increasing the credit risk of such debt. In
addition, there may be less publicly available
information about a foreign company than about a
domestic company. Foreign companies generally
are not subject to uniform accounting, auditing
and financial reporting standards comparable to
those applicable to domestic companies. With
respect to certain foreign countries, there is a
possibility of expropriation or
confiscatory
taxation, or diplomatic developments, which could
affect investment in those countries.
their
own
information
Investments
related
incidents
market
depth,
incidents,
Emerging Markets Risks.
in
emerging markets can involve risks in addition to
and greater than those generally associated with
investing in more developed foreign markets. The
extent of economic development, political
stability,
infrastructure,
capitalization, and regulatory oversight can be
less than in more developed markets. Emerging
market economies can be subject to greater
social, economic,
regulatory, and political
uncertainties. All of these factors can make
emerging market securities more volatile and
potentially less liquid than securities issued in
more developed markets.
(such as through denial of service attacks). Such
events can impede critical functions, compromise
sensitive business and protected customer
information, and may result in financial losses,
business interruptions, impediments to the ability
to process transactions, breaches of applicable
privacy, data protection, or other laws, regulatory
fines
harm,
reimbursement or other remediation costs, and
increased compliance or operational expenses.
Substantial costs may be incurred to prevent,
detect,
future
technology related incidents. Issuers’ increasing
use of AI systems introduces additional risks
discussed
“Artificial
Intelligence Risks” below. Issuers may also rely
on third party or cloud based platforms that
security,
present
cybersecurity, and other technology‑related risks.
Similar adverse consequences may arise from
technology
affecting
regulatory bodies,
governmental authorities,
financial market systems, exchanges, brokers-
dealers, banks, insurance companies, custodians,
or other market participants. Although issuers and
their service providers may adopt business
continuity plans, information security controls,
and risk management programs designed to
prevent or mitigate such
these
measures are subject to inherent limitations,
including the possibility that certain risks may not
be identified or fully addressed. As a result, client
Accounts and investments may be negatively
affected.
Intelligence Risks.
increasingly use AI systems
the
that
could
compromise
technology
Such
incidents may
in
fact
inaccurate,
Issuers of
Artificial
investments
in
various aspects of their business operations,
creating competitive market pressures to increase
the development and use of AI systems. Failure to
effectively develop or use AI systems may place
an issuer at a competitive disadvantage. At the
same time, AI systems present significant risks
that could materially affect an issuer’s business
and financial performance. AI Tools rely on
complex models, large datasets, and evolving
algorithms. AI Tools are highly-useful but
complex and fallible systems that can exhibit bias,
hallucinations, deceptive behaviors and other
flaws due to the construction of their underlying
models and the composition of their training data,
which can result in outputs that seem plausible
but are
incomplete, or
misleading. The use of erroneous outputs can
undermine customer trust and expose issuers to
Information Security, Cybersecurity and
Technology-Related Risks. As issuers and their
service providers increasingly rely on digital
technologies, such as
Internet, cloud
computing, and AI‑enabled systems, they face
heightened information security, cybersecurity,
including
and other technology‑related risks,
incidents
the
confidentiality, integrity, or availability of their
systems, data, or
infrastructure.
Technology-related incidents may result from
deliberate adversarial actions (such as cyber
attacks) or unintentional events (such as systems
or human error) and could have a materially
adverse impact on the issuer’s performance and
operations.
involve
unauthorized access, disclosure, use, corruption,
degradation, or destruction of systems or data
(such as
through hacking, malware, social
engineering or theft of digital devices); or the
disruption of systems access to authorized users
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regulatory
scrutiny,
those listed above, no assurance can be given
that it will always do so.
rely
on
third-party
AI
falling. Since
interest
federal
taxation,
in such
use
protected
Municipal Securities Risks. Repayment of
municipal securities depends on the ability of the
issuer or project backing such securities to
generate taxes or revenues. Municipal securities
may also decrease in value during times when tax
rates are
income on
municipal securities is normally not subject to
regular
the
income
attractiveness of municipal securities in relation to
other investment alternatives is affected by
changes in federal income tax rates applicable to,
or the continuing federal tax-exempt status of,
such interest income. Any proposed or actual
changes
rates or exempt status,
therefore, can significantly affect the liquidity,
marketability and supply and demand
for
municipal securities, which would in turn affect
Baird’s ability to acquire and dispose of municipal
securities at desirable yield and price levels.
Investment in tax-exempt debt obligations poses
additional risks. In many cases, the IRS has not
ruled on whether the interest received on a tax-
exempt obligation is tax-exempt, and accordingly,
purchases of these municipal securities are based
on the opinion of bond counsel to the issuers at
the time of issuance. Thus, there is a risk that
interest may be taxable on a municipal security
that is otherwise expected to produce tax-exempt
interest.
litigation,
substantial
remediation costs, and reputational harm. AI tools
require timely access to high‑quality, compliant
data, and any disruption in data availability can
impair or disable AI Tool functionality. Issuers
often
systems,
infrastructure, and data, which can create vendor
dependency, limit visibility into and validation of
AI model performance, and increase the risk of
disruption in data availability. The regulatory
environment for AI is rapidly evolving and may
involve inconsistent or conflicting requirements
jurisdictions. Compliance may require
across
significant investment, changes to AI systems, or
the discontinuation of certain AI‑enabled features.
Non‑compliance may lead to fines, enforcement
actions, or operational constraints. AI systems are
vulnerable to cyberattacks or other adversarial
actions that can impair system performance and
integrity and compromise sensitive business and
protected customer information. The impairment
of AI systems or the unauthorized disclosure of
sensitive business or protected information can
result in material disruption and damage to
legal and
significant
business operations,
regulatory
remediation
liabilities, substantial
expenses, and reputational harm. AI systems may
inadvertently
information,
potentially giving rise to intellectual property
infringement claims and substantial damages.
Public concerns regarding fairness, transparency,
and responsible use of AI may reduce demand for
an issuer’s products or services. Failure to use AI
responsibly may harm an issuer’s reputation and
competitive position.
securities,
and/or
issued by
Government Obligation Risks. Client assets
may be invested in securities issued, sponsored or
guaranteed by the U.S. Government, its agencies
and instrumentalities. However, no assurance can
be given that the U.S. Government will provide
financial support to U.S. Government-sponsored
agencies or instrumentalities where it is not
obligated to do so by law. For instance, securities
issued by the Government National Mortgage
Association (“Ginnie Mae”) are supported by the
faith and credit of the United States.
full
Securities
the Federal National
Mortgage Association (“Fannie Mae”) and the
Federal Home Loan Mortgage Corporation
(“Freddie Mac”) have historically been supported
only by the discretionary authority of the U.S.
Government. While the U.S. Government provides
financial support to various U.S. Government-
sponsored agencies and instrumentalities, such as
Money Market Fund Risks. A money market
fund is a type of mutual fund that generally
invests in short-term debt instruments. Many
investors use money market funds to store cash.
There are three primary types of money market
funds: (1) government money market funds
(funds that invest nearly all assets in cash,
government
repurchase
agreements collateralized by cash or government
securities); (2) retail money market funds (funds
that have policies and procedures reasonably
designed to limit beneficial ownership to natural
persons); and (3) institutional money market
funds (funds that permit beneficial ownership by
institutions and natural persons). The rules
governing money market funds vary based on the
type of money market fund. Government and
retail money market funds generally try to keep
their net asset value (NAV) at a stable $1.00 per
share using special pricing and valuation
conventions. Institutional money market funds
are required to calculate their NAV in a manner
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desirable for those financial intermediaries to hold
large inventories of debt securities. Because
market makers provide stability to a market
through their intermediary services, a reduction in
dealer inventories may lead to decreased liquidity
and increased volatility in the fixed income
markets. In the event the client directs Baird to
liquidate an illiquid investment, the client should
understand that Baird may have difficulty finding
a buyer in the market for such investment and
such investment may be held in the Account for a
period of time while Baird attempts to satisfy the
client’s liquidation request.
for purchases or withdrawals.
redemptions
in
Concentration Risks. A client’s Account may
consist of a portfolio of securities that
is
concentrated in an issuer or group of issuers, an
industry or economic sector or group of related
industries or sectors, or concentrated in limited
asset classes. Client accounts with concentrated
positions are susceptible to greater volatility and
increased risk of loss than an Account that is
diversified across several issuers and industries or
sectors and asset classes. A client should not
engage in strategies using concentration unless
the client is prepared to experience significant
losses in the value of the client’s Account.
such that the NAV will vary based upon the
market value of assets and liabilities of the fund
(also known as a “floating NAV”). An investment
in a money market fund is not insured or
guaranteed by the FDIC or any other government
agency. Although some money market funds seek
to preserve the value of an investment at $1.00
per share, there can be no assurance that will
occur, and it is possible to lose money should the
fund value per share fall. In some circumstances,
money market funds may be forced to cease
operations when the value of a fund drops. In
that event, the fund's holdings may be liquidated
and distributed to the fund's shareholders. This
liquidation process could take time to complete.
During that time, the amounts a client has
invested in the money market fund would not be
In
available
addition, retail and institutional money market
funds are required to impose redemption fees
(also known as liquidity fees) and suspend
redemptions (also known as redemption gates) in
certain
circumstances. Government money
market funds may also impose redemption fees
and suspend
those same
circumstances. More specific information about
how a money market fund calculates its NAV and
the circumstances under which it will impose a
redemption fee or suspend redemptions is set
forth in the prospectus for that money market
fund.
to
lower
to make a market
for
Frequent Trading and Portfolio Turnover
Risks. Some of the investment strategies offered
to clients in this Brochure may involve frequent or
active trading for client accounts, which could
result in high portfolio turnover. Strategies that
involve frequent or active trading increase the
management and securities selection
risks
because the persons managing the accounts are
making more trading decisions, which may prove
to be incorrect. A portfolio with a high turnover
rate will also incur more transaction costs than
one with a lower rate. Higher transaction costs
may negatively impact the return of the portfolio.
High portfolio turnover may also cause a client to
experience adverse tax consequences due to the
fact that the client may have increased instances
of realized gains and losses and such gains and
losses may commonly be characterized as short
term gains and losses under applicable tax law.
Illiquid Securities and Liquidity Risks.
Liquidity risk is the risk that certain investments
may be difficult or impossible to sell at the time
and price that a client would like to sell. Clients
may have
the price, sell other
investments or forego an investment opportunity,
any of which may have a negative effect on the
management or performance of client accounts.
The liquidity of a particular investment depends
on the strength of demand for the investment,
which is generally related to the willingness of
broker-dealers
the
investment as well as the interest of other
investors to buy the investment. During periods of
economic uncertainty, significant economic and
market downturns and periods in which financial
services firms are unable to commit capital to
make a market in, or otherwise buy, certain
investments, a client may experience challenges
in selling such investments at optimal prices. In
addition, recent regulatory changes applicable to
financial intermediaries that make markets in
debt securities have restricted or made it less
Asset-Backed Securities Risks. Asset-backed
securities are securities secured or backed by
mortgage loans, student loans, automobile loans,
installment sale contracts, credit card receivables
or other assets and are issued by entities such as
commercial banks, trusts, financial companies,
industrial companies,
finance subsidiaries of
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risk,
foreign
investment style
issuer and
investment risk, and emerging market risk.
Certain mutual funds pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of mutual fund selected. Also, investment
return and principal value will fluctuate, and
shares, when redeemed, may be worth more or
less than their original cost.
savings and loan associations, mortgage banks
and investment banks. These securities represent
interests in pools of assets in which periodic
payments of interest or principal on the securities
are made, thus, in effect passing through periodic
payments made by the individual borrowers on
the assets that underlie the securities, net of any
fees paid to the issuer or guarantor of the
securities. Asset-backed securities are issued in
multiple classes (or tranches) and their relative
payment rights may be structured in many ways.
Asset-backed securities may be subject to greater
risk of default during periods of economic
downturn than other instruments. Asset-backed
securities also can be more sensitive to interest
rate risk than other types of fixed income
securities. Modest movements in interest rates
(both increases and decreases) may quickly and
significantly reduce the value of certain types of
these securities. Asset-backed securities are
subject to a number of other risks, including, but
not limited to, market and valuation risks,
liquidity risk, and prepayment risk.
Split-Rated,
and
equity,
securities
include market
selection
Non-Rated,
Below
Investment Grade Securities (High Yield or
“Junk” Bonds) Risks. Investing in securities or
other investment products that are not rated,
split-rated or are below investment grade (also
known as high yield or “junk” bonds) involve
significant, special risks. As a result, they may not
be suitable for some clients. The risks associated
with these investments include, but not limited to,
price volatility risk, credit risk, default risk, and
liquidity risk. Clients investing in securities or
other investment products that are not rated,
split-rated or are below investment grade should
have a high tolerance for risk, including the
willingness and ability to accept significant price
volatility, potential lack of liquidity and potential
loss of their investment.
credit
capitalization
risk,
foreign
including equity,
fixed
investment
style,
Exchange Traded Fund Risks. An ETF is
different from a mutual fund in that an ETF does
not sell its shares directly to public investors and
does not redeem shares from public investors.
Rather, shares of an ETF are commonly purchased
or sold in the secondary market on a securities
exchange, like common stocks. An ETF maintains
a net asset value but, based on demand and
other factors, the market price of shares of an
ETF may vary from its net asset value. ETFs
invest in and hold securities and other assets,
such as stocks, bonds, commodities and
currencies, and have stated investment objectives
and principal strategies. ETFs can have many
different investment objectives and strategies,
including
income, balanced,
fixed
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. Many ETFs seek to track the
performance of an index or other underlying
benchmark. Passively managed ETFs will not be
able to replicate exactly the performance of the
indices the ETFs track because the total return
generated by the securities will be reduced by
management fees, transaction costs and other
expenses incurred by the ETF. ETFs have other
risk,
risks, which may
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
rate
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk.
Certain ETFs pursue Complex Strategies, which
are subject to special risks. The degree of these
and other risks will vary depending on the type of
ETF selected.
securities
selection
Mutual Fund Risks. Mutual funds can have
many different
investment objectives and
income,
strategies,
balanced, international, and global strategies, and
strategies that focus on a particular market
capitalization,
economic
industry or sector, or geographic region. Mutual
funds have risks, which may include market risk,
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
risk,
rate
risk,
credit
capitalization
Closed-End Fund Risks. Unlike mutual funds
which continuously offer and redeem their shares
on a daily basis at net asset value, closed-end
funds typically raise money by selling a fixed
number of shares of common stock in a single,
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equity,
that
fund
that
for purposes of making
securities
selection
period, although there is no guarantee that the
objective will be met. UITs can have many
different investment objectives and strategies,
income, balanced,
fixed
including
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. UITs are passively managed
and follow a “buy and hold” strategy, meaning
that UITs buy a fixed portfolio of securities and
hold on to that portfolio until their termination
date at which time the portfolio is liquidated with
the net proceeds paid to investors. UITs, thus,
generally have a relatively higher risk of loss than
other funds in the event of adverse changes in
market or economic conditions. UITs have other
risks, which may
include management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, and emerging market
risk. Certain UITs pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of UIT selected. Also, investment return and
principal value will fluctuate, and units, if and
when redeemed, may be worth more or less than
their original cost.
credit
capitalization
risk,
foreign
closed-end
one-time offering, much the way a company
issues stock in an initial public offering. Closed-
end funds can have many different investment
objectives and strategies, including equity, fixed
international, and global
income, balanced,
strategies, and strategies
focus on a
particular market capitalization, investment style,
industry or sector, or geographic
economic
shares are not
region. Closed-end
redeemable, meaning
investors cannot
require closed-end funds to buy back their shares,
although closed-end fund shares are listed and
traded on an exchange. For many reasons,
closed-end fund shares often trade at a discount
to their net asset value and the market prices of
closed end fund shares often fall below their
public offering prices. Clients are therefore
cautioned about buying shares of a closed-end
fund in its initial public offering. Closed-end funds
often engage in leverage to raise additional
capital
investments
through borrowings and issuances of senior
securities (such as preferred stock). Such
leverage may present the opportunity to enhance
potential returns but also involve the risk of
exacerbating losses and depreciation in the value
of the underlying securities. Closed-end funds
have other risks, which may include market risk,
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate
risk,
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk.
funds pursue Complex
Certain
Strategies, which are subject to special risks.
Some closed-end funds are organized as interval
funds, which differ from traditional closed-end
funds in that their shares do not trade on the
secondary market, but instead their shares are
subject to repurchase offers from the fund.
Closed-end funds structured as an interval fund
will, therefore be relatively less liquid. Interval
funds also often impose a redemption fee when
shares are sold back to the fund. The degree of
these and other risks will vary depending on the
type of close-end fund selected.
is selected by
negative
tax
consequences.
Unit Investment Trust Risks. A UIT is a pooled
in which a portfolio of
investment vehicle
securities
the sponsor and
deposited into the trust for a specified period of
time. The portfolio of a UIT is designed to follow
an investment objective over a specified time
Risks Common to All Funds; Purchase and
Redemption Risks. Funds are generally subject
to the same risks as the securities or other assets
in which they invest. In addition, from time to
time Baird, a GWG Consultant, or an investment
manager may decide to add or remove a Fund to
or from an investment strategy or Service. In
addition, they may decide to increase or decrease
their clients’ account allocations to a Fund. In
general, they will place transactions for all
affected Accounts at one time, which may cause
the Fund to experience relatively large purchases
or
redemptions. Significant purchases and
redemptions may adversely affect the Fund in
question and consequently, a client’s investment.
A Fund receiving large purchase orders may have
difficulty investing the cash, which may have a
negative impact on the Fund’s performance. A
Fund experiencing large redemption orders may
have to sell portfolio securities, which may
negatively impact performance and which may
have
Large
redemptions could also reduce liquidity as the
Fund may suspend or delay redemptions. These
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risks are more pronounced with respect to newer
Funds and those with smaller asset sizes.
by
the
Risks Associated with Certain Investment
Strategies
that were not predicted by
can be no assurance
that
expected, for short or extended periods of time,
the portfolios
which may adversely affect
generated
investment manager’s
quantitative methodologies and processes. It is
also possible that prices of securities may move in
directions
the
investment manager’s quantitative methodologies
and processes or may fail to move as much as
predicted, for reasons that were not expected.
There
these
methodologies will enable a client to achieve the
client’s objective.
Growth and Value Investment Style Risks.
Investment styles or strategies that focus on
growth stocks may perform better or worse than
styles or strategies that focus on value stocks or
that are broader or more diversified. Similarly,
investment styles or strategies that focus on
value stocks may perform better or worse than
styles or strategies that focus on growth stocks or
that are broader or more diversified. A particular
style of investing may go out of favor at times
and for extended periods. Growth stocks are often
characterized by high price-to-earnings ratios and
may be more volatile than stocks with lower
price-to-earnings ratios. Value stocks are subject
to the risk that the broader market may not agree
with the manager’s assessment of, or recognize,
the investments’ intrinsic value.
Technical Strategy Risks. Some investment
managers and DDK Consultants may employ
technical analysis or investment methodologies to
make investment decisions or recommendations.
The primary risk of using technical analysis is that
past price and volume patterns and trends in the
trading markets cannot predict future prices,
volume patterns or trends. There is no guarantee
that technical investment methods used are
designed properly, are updated with new data as
it becomes available, or can accurately predict
future market or investment performance. In
order for technical investment methods to work,
there must be sufficient data about the markets
available so that trends can be identified and
predictions can be made. A technical method may
fail to identify trends or be able to accurately
predict future prices if a market does not have
sufficient data or trends or if the market behaves
erratically.
ESG Considerations Risk. Consideration of ESG
factors in the investment process may cause an
advisor or manager to forgo opportunities to
recommend or invest in certain companies or to
gain exposure to certain industries or regions.
Therefore, there is a risk that, under certain
market conditions, an Account pursuing strategies
that consider ESG factors may underperform
accounts that do not consider such factors. There
are not universally accepted ESG factors and
advisors and managers typically consider them in
their discretion.
and Risk
of
Other Strategy Risks. The risks associated with
other types of investment strategies are described
under the heading “Portfolio Manager Selection
and Evaluation—Methods of Analysis, Investment
Strategies
Loss—Investment
Strategies” above.
Non-Traditional Assets and Complex
Strategies Risks
such as
commodities,
an
investment
traditional
Quantitative Strategy Risks. Some investment
managers may employ quantitative investment
methodologies or processes to make investment
the quantitative
decisions. The success of
investment methodologies and processes used by
investment managers depends on the analyses
and assessments that were used in developing
such methodologies and processes, as well as on
the accuracy and reliability of models and data
provided by third parties. Incorrect analyses and
assessments or inaccurate or incomplete models
and data would adversely affect performance.
manager’s
Additionally,
methodologies and processes are predictive in
nature, based on historical outcomes and trends.
Certain low-probability events or factors that are
assigned little weight may occur or prove to be
more likely or may have more relevance than
Non-Traditional Assets Risks. Non-Traditional
Assets,
currencies,
securities indices, interest rates, credit spreads,
private companies, and Digital Assets, are subject
to risks that are different from, and in some
instances, greater than, other assets like stocks
and bonds. Some Non-Traditional Assets are less
transparent and more sensitive to domestic and
foreign political and economic conditions than
more
investments. Non-Traditional
Assets are also generally more difficult to value,
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less liquid, and subject to greater volatility
compared to stocks and bonds.
Risks.
Investments
investments
risk of loss. The use of leverage may also increase
an Account’s volatility. Strategies
involving
margin can cause a client to lose more money
than deposited in the client’s margin account. A
client should not engage in strategies involving
leverage or margin unless the client is prepared
to experience significant losses in the value of the
client’s Account.
in
securities.
investment and
trading activities
or
consuming
Short Sales Risks. Short selling runs the risk of
loss if the price of the securities sold short does
not decline below the price at which they were
originally sold. This risk of loss is theoretically
unlimited, as there is no cap on the amount that
the price of a security may appreciate. In
addition, a
lender may request, or market
conditions may dictate, that securities sold short
be returned to the lender on short notice, which
may result having to buy the securities sold short
at an unfavorable price. A client should not
engage in short sales unless the client is prepared
to experience significant losses in the client’s
Account.
contracts
other
in
Commodities
commodities markets or a particular sector of the
commodities markets, and
in
securities or other instruments denominated in or
indexed or linked to commodities, are subject to
certain risks. Those investments generally will
subject a client Account to greater volatility than
investments
The
traditional
commodities markets are impacted by a variety of
factors, including changes in overall market
movements, domestic and foreign political and
economic conditions, interest rates, inflation rates
and
in
commodities. Prices of commodities may also be
affected by factors such as drought, floods,
weather, livestock disease, embargoes, tariffs and
other regulatory developments. The prices of
commodities can also fluctuate widely due to
in major
supply and demand disruptions
producing
regions. Certain
commodities may be produced in a limited
number of countries and may be controlled by a
small number of producers or groups of
producers. As a result, political, economic and
supply related events in such countries could have
a disproportionate impact on the prices of such
commodities. No active trading market may exist
for certain commodities investments, which may
impair the value of the investments.
instruments
in
that
Derivative Instrument Risks. The values of
options, convertible securities, futures, swaps,
derivative
and
forward
instruments is derived from an underlying asset,
such as a security, commodity, currency, or
index. Derivative instruments often have risks
similar to the underlying asset, however, in
certain cases, those risks are greater than the
risks presented by
the underlying asset.
Derivative instruments may experience dramatic
price changes and imperfect correlations between
the price of the derivative and the underlying
asset, which may increase volatility. Derivatives
generally create leverage, and as a result, a small
movement in the underlying asset's value can
result in large change in the value of the
derivative instrument. Derivatives are also subject
to liquidity risk, interest rate risk, market risk,
credit risk, management risk and counterparty
risk. The use of these
is not
appropriate for some clients because they involve
special risks. A client should not invest in these
instruments unless the client is prepared to
experience volatility and significant losses in the
client’s Account.
Currency Risks. Investments in currencies, and
investments in securities or other instruments
denominated in or indexed or linked to currencies,
are subject to certain risks. Those investments
are subject to all of the risks associated with
foreign investing generally. In addition, currency
markets generally are not as regulated as
securities markets. Also, changes in currency
exchange rates could adversely
impact the
investment. Devaluation of a currency by a
country will also have a significant negative
investment
the value of any
impact on
denominated
currency. Currency
investments may also be positively or negatively
affected by a country’s strategies intended to
make its currency stronger or weaker relative to
other currencies.
the
Leverage and Margin Risks. Leveraging
strategies may amplify
impact of any
decrease in the value of underlying securities in
the client’s Account, thereby increasing a client’s
Options Risks. In purchasing a put or call
option, the purchaser faces the risk of loss of the
premium paid for the option if the market price
moves in a direction opposite to what the
purchaser had expected. In selling or writing an
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Complex Investment Product Risks
the underlying security or
option, the seller faces significantly more risk. A
seller of a call option faces the risk of significant
loss
if the prevailing market price of the
underlying security or index increases above the
strike price, and a seller of a put option faces the
risk of significant loss if the prevailing market
price of
index
decreased below the strike price.
funds have unique
Hedging Risks. When a derivative instrument is
used as a hedge against an opposite position, any
loss on the derivative instrument should be
substantially offset by gains on the hedged
investment, and vice versa. Although hedging can
be an effective way to reduce the investment risk,
it may not always perfectly offset one position
with another. As a result, there is no assurance
that hedging transactions will be effective.
for those
fee
an
incentive
in
the marketplace and
Assets
involve
technological
limited
short
sales,
trading,
settlement,
and
risks may
validators, miners,
or
securities
include: market
selection
limited number of
credit
capitalization
risk,
foreign
Digital Assets Risks. Digital Assets are not
appropriate for some clients because they involve
substantial risk of loss including special risks not
present in traditional financial markets. Digital
Assets derive value primarily from the demand for
such assets
their
association with decentralized networks and other
technology. Digital Assets may lack an intrinsic
value and markets
for Digital Assets are
susceptible
to extreme and sudden price
movements and fragmented liquidity. Markets for
lack
Digital Assets continue to evolve, but
certainty regarding the status of regulation and
investor protections. The use and custody of
Digital
and
cybersecurity risks, including the potential for
flaws, operational
system outages, protocol
disruptions, hacking incidents, or failures of
third-party platforms and service providers that
support
storage
infrastructure. Many Digital Assets depend on
external
protocol
developers whose actions or inaction can impact
network stability or asset functionality and affect
value. Market structure risks—such as reliance on
trading venues or
a
counterparties—may impair the ability to transact
or liquidate positions during periods of market
stress. A client should not invest in these
instruments unless the client is prepared to
experience extreme volatility and significant
losses in the client’s Account.
Hedge Funds and Funds of Hedge Fund
Risks. Hedge funds typically engage in one or
more Complex Strategies, including the use of
Non-Traditional Assets, short sales, leverage and
other derivative instruments. Funds of hedge
funds typically invest substantially all of their
assets in other hedge funds. Hedge funds and
funds of hedge
tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Some
hedge funds and funds of hedge funds are subject
to limited regulation and offer limited disclosure
and transparency. Also, the costs of hedge funds
and funds of hedge funds are typically higher than
other types of funds. Investment advisers or
funds often receive a
managers
management
or
plus
performance-based fee. Because of the existence
of a performance-based fee, fund managers may
be motivated to make riskier investments that
have the potential for significant growth in value.
Hedge funds and funds of hedge funds are also
subject to a higher risk of incorrect valuations.
Many hedge funds hold investments for which
market quotations are not readily available, which
necessitates the use of “fair value” pricing. Fair
value pricing is an inherently subjective process
and may not accurately reflect the prices that can
actually be obtained upon sale of the assets for
which fair values are used. Investments in hedge
funds and funds of hedge funds also have reduced
liquidity compared to other investments and are
generally subject to a higher risk of volatility.
Investing in hedge funds and funds of hedge
funds involves other special risks, including, but
to, risks associated with Non-
not
Traditional Assets,
leverage,
derivative instruments, and Complex Strategies.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
risk,
risk,
rate
investment style
issuer and
investment risk, and emerging market risk. Hedge
funds and funds of hedge funds are complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in hedge funds or funds
of hedge funds should have a high tolerance for
risk, including the willingness and ability to accept
lack of
significant price volatility, potential
liquidity and potential loss of their investment.
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investments
Private equity funds and funds of private equity
funds are complex
that have
significant, special risks. As a result, they may not
be suitable for some clients. Clients investing in
private equity funds and funds of private equity
funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
in
certain
that may
sectors,
funds are subject to
to administrative service
in certain sectors,
compared
other
expect
debt
funds
have
unique
receive a management
risk,
foreign
transaction
Private Equity Funds and Funds of Private
Equity Funds Risks. Private equity funds are
pools of actively managed capital that invest
primarily in private companies with the intent of
creating value in the companies in which they
invest by improving operations, reducing costs,
selling non-core assets and maximizing cash flow.
Private equity funds usually have an investment
focus on
objective or strategy
companies
industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes of investments. Funds of private equity
funds typically invest substantially all of their
assets in other private equity funds. Private
equity funds and funds of private equity funds
have unique tax characteristics. A client should
consult with a tax advisor before investing in
those funds. Private equity funds and funds of
private equity
limited
regulation and offer
limited disclosure and
transparency. Also, the costs of private equity
funds and funds of private equity funds are
typically higher than other types of
funds.
Investment advisers or managers for those funds
often receive a management fee plus an incentive
fee or carried interest. Private equity funds and
funds of private equity fund are also generally
subject
fees and
portfolio company transaction fees. Because of
the existence of a carried interest, fund managers
may be motivated to make riskier investments
that have the potential for significant growth in
value. Investments in private equity funds and
funds of private equity funds also have reduced
investments.
to
liquidity
Investors
receive
to
should not
distributions from a fund for a number of years.
Private equity investing is very risky. Many
investments made in portfolio companies are not
profitable. In addition, investments made by
private equity funds and funds of private equity
funds may be concentrated in one or more
economic
industries or sectors, geographic
regions, stages of development or operation, or
sizes of companies. Investing in private equity
funds and funds of private equity funds involves
other special risks, including, but not limited to,
dependence upon key personnel and conflicts of
interest risks. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
issuer and
investment style
investment risk, and emerging market risk.
Private Debt Funds (or Private Credit Funds)
and Funds of Private Debt Funds Risks.
Private debt funds (also known as private credit
funds) are pools of actively managed capital that
invest primarily in loans or debt instruments
issued by companies in private transactions.
Sometimes, repayment of the loan is secured by
assets of the companies obtaining the loans.
However, the companies often have low or no
credit ratings. Thus, investments held by private
debt funds generally are subject the same risks as
below investment grade or “junk” bonds. Trading
markets for the investments held by those funds
are also limited and their investments may be
illiquid. Oftentimes, the interest rate paid by the
companies is determined by a reference interest
rate, such as the federal funds rate, which is
periodically reset. These types of investments are
sometimes referred to as floating rate corporate
debt, floating rate loans or floating rate bank
loans. Private debt
funds usually have an
investment objective or strategy that may focus
on companies
industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes, including focusing investments on
smaller capitalization, distressed or bankrupt
companies. Private debt funds commonly use
borrowings or leverage to make investments.
Funds of private debt funds typically invest
substantially all of their assets in other private
debt funds. Private debt funds and funds of
private
tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
debt funds and funds of private debt funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private debt funds and funds of private debt funds
are typically higher than other types of funds.
Investment advisers or managers for those funds
often
fee plus a
performance fee. Private debt funds and funds of
private debt fund are also generally subject to
fees.
operational expenses and
Because of the existence of a performance fee,
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should not
expect
to
funds
involves special
in which
they are
risk,
foreign
fund
risks, currency
risk, growth
fund managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Investments in private debt
funds and funds of private debt funds also have
reduced liquidity compared to other investments.
Investors
receive
distributions from a fund for a number of years.
Private debt investing is very risky. Investments
made by private debt funds and funds of private
debt funds may be concentrated in one or more
economic
industries or sectors, geographic
regions, stages of development or operation, or
sizes. Investing in private debt funds and funds of
private debt
risks,
including, but not limited to, dependence upon
key personnel, conflicts of interest risks, market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
investment
risks and
leveraging risks. Private debt funds and funds of
private debt funds are complex investments that
have significant, special risks. As a result, they
may not be suitable for some clients. Clients
investing in private debt funds and funds of
private debt funds should have a high tolerance
for risk, including the willingness and ability to
accept lack of liquidity and potential loss of their
investment.
risk, credit
risk,
foreign
Private REITs are generally subject to limited
regulation and offer
limited disclosure and
transparency. The shareholders of a REIT are
responsible for paying taxes on the dividends that
they receive and on any capital gains associated
with their investment in the REIT. Dividends paid
by REITs generally are treated as ordinary income
and are not entitled to the reduced tax rates on
other types of corporate dividends. Prices of REIT
securities and trading volumes may be more
volatile that other investments. Many REITs focus
on a particular sector of the real estate market,
such as apartments, student housing, hotels and
hospitality, health care, office buildings, shopping
malls, warehouses, self-storage facilities and the
like. Those REITs are subject to risks associated
with sectors
focused.
Additionally, many REITs may own properties that
are concentrated in a particular geographic region
or regions, which subject them to the risk of
deteriorating economic conditions in those areas.
Investing in REITs involves other special risks,
including, but not limited to, real estate portfolio
risk
(including development, environmental,
competition, occupancy and maintenance risk),
liquidity risk, leverage risk, distribution risk,
risk,
capital markets access
interest risk,
counterparty risk, conflicts of
dependence upon key personnel
risk, and
regulatory risk. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, interest
rate
issuer and
investment risk, and emerging market risk. REITs
involve significant, special risks and may not be
suitable for some clients. Clients investing in
REITs should have a high tolerance for risk,
including the willingness and ability to accept
significant price volatility and volatility of regular
distribution amounts, potential lack of liquidity
and potential loss of their investment.
warehouses,
investments. Some may
in properties
industries,
involved
located
Real Estate Investment Trusts (“REITs”) and
Private REIT Risks. A REIT is a corporation,
trust or association that owns and typically
operates income-producing real estate or real
estate-related assets. The income-producing real
estate assets owned by a REIT may include office
buildings, shopping malls, multi-family housing,
student housing, hotels, resorts, hospitals and
health care facilities, self-storage facilities, data
centers,
telecommunications
facilities, and mortgages or loans. Many REITs are
registered with the SEC and their common stock
and preferred stock are publicly traded on a stock
exchange. These are known as publicly-traded
REITs. Others may be registered with the SEC but
are not publicly traded. These are known as
private REITs (also known as non-traded or non-
exchange traded REITs). There is no public
trading market for private REITs and the sole
method for disposing of the shares may be limited
to a periodic offer to redeem the shares by the
issuer, if the issuer offers a redemption program.
Private Real Estate Funds and Private Real
Estate Fund of Funds. Private real estate funds
are pools of actively managed capital that directly
invest primarily in investments in real estate and
real estate-related
investments. Private real
estate funds may invest in any number of types of
real estate, such as office, apartment, retail,
lodging, industrial and other real estate and real
focus
estate-related
in certain
investment
certain
in
sectors or
geographic regions or that have certain sizes of
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
improved management
a result, they may not be suitable for some
clients. Clients investing in private real estate
funds and funds of private real estate funds
should have a high tolerance for risk, including
the willingness and ability to accept lack of
liquidity and potential loss of their investment.
real estate
funds
typically
telecommunication,
Private
utilities,
infrastructure
for those
for those
fees and
should not
expect
to
investing
for
significant growth
reduced
liquidity compared
investments made
by
industries or
risks may
fund
risks, currency
securities
include: market
selection
operations or investment requirements. Some
may focus investment on properties the manager
or
sponsor believes are undervalued or
undercapitalized or that require repositioning,
redevelopment,
or
additional capital to reach their full value. Private
real estate funds commonly use borrowings or
leverage to make investments. Trading markets
for investments held by those funds are limited
and their investments may be illiquid. Funds of
private
invest
substantially all of their assets in other private
real estate funds. Private real estate funds and
funds of private real estate funds have unique tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
real estate funds and funds of private real estate
funds are subject to limited regulation and offer
limited disclosure and transparency. Also, the
costs of private real estate funds and funds of
private real estate funds are typically higher than
other types of funds. Investment advisers or
managers
funds often receive a
management fee plus a performance fee. Private
real estate funds and funds of private real estate
fund are also generally subject to operational
expenses and transaction fees. Because of the
existence of a performance fee, fund managers
may be motivated to make riskier investments
that have the potential for significant growth in
value. Investments in private real estate funds
and funds of private real estate funds also have
reduced liquidity compared to other investments.
Investors
receive
distributions from a fund for a number of years.
is very risky.
Private real estate
Investments made by private real estate funds
and funds of private real estate funds may be
concentrated in properties involved in one or
more economic industries or sectors, geographic
regions, stages of development or operation, or
sizes. Investing in private real estate funds and
funds of private real estate funds involves special
risks, including, but not limited to, dependence
upon key personnel, conflicts of interest risks,
market risk, management and securities selection
risk, investment objective and asset allocation
risk, interest rate risk, credit risk, capitalization
risk, investment style risk, foreign issuer and
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
investment
risks and
leveraging risks. Private real estate funds and
funds of private real estate funds are complex
investments that have significant, special risks. As
Private Infrastructure Funds Risks. Private
infrastructure funds are pools of actively managed
capital that invest primarily in infrastructure
projects and assets and may involve exposure to
a
range of economic or market sectors,
geographic locations and asset types. Examples of
infrastructure investments may include, among
and
others,
transportation.
funds
usually have an investment objective or strategy
that may focus on certain sectors, industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes of investments. Private infrastructure
funds have unique tax characteristics. A client
should consult with a tax advisor before investing
in those funds. Private infrastructure funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private infrastructure funds are typically higher
than other types of funds. Investment advisers or
managers
funds often receive a
management fee plus an incentive fee. Private
infrastructure funds are also generally subject to
administrative service
investment
transaction fees. Because of the existence of
incentive fees, fund managers may be motivated
to make riskier
investments that have the
in value.
potential
Investments in private infrastructure funds also
have
to other
investments. Investors should not expect to
receive distributions from a fund for a number of
years. Private infrastructure investing is very
risky. Many investments are not profitable. In
addition,
private
infrastructure funds may be concentrated in one
sectors,
or more economic
geographic regions, stages of development or
operation, or sizes of companies. Investing in
private infrastructure funds involves other special
risks, including, but not limited to, dependence
upon key personnel and conflicts of interest risks.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
issuer and
investment style
risk,
foreign
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infrastructure
funds
are
are complex investments and involve significant,
special risks. As a result, ETNs may not be
suitable for some clients.
pools
(typically
structured
investment risk, and emerging market risk.
Private
complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in private infrastructure
funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
throughout
in managed
currencies,
Assets,
leverage,
Managed Futures Risks. Managed futures are
commodity
as
investment partnerships) managed by a futures
trading adviser that trade speculatively in various
derivative instruments and other investments.
There are significantly higher fees and expenses
associated with investments in managed futures
than other types of funds. Sponsors or managers
for these pools often receive a management fee
plus incentive or performance-based fee. Because
of the existence of a performance-based fee,
managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Managed futures may seek
exposure to different asset classes, such as equity
securities, fixed income securities, commodities
(such as metals, agricultural products, and energy
products), currencies, interest rates, and indices.
Managed futures often obtain this exposure
through derivative instruments, which may be
traded on U.S. or foreign exchanges or markets.
Managed futures often employ computerized,
systematic and often proprietary trading models
and systems. Investing
futures
involves special risks, including, but not limited
to, liquidity risks and risks associated with
and other Non-
commodities,
Traditional
derivative
instruments and Complex Strategies. Other risks
may include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
foreign issuer and investment risk, and emerging
market risk. Managed futures can be speculative
investments because of the types of investments
they make and they involve significant, special
risks. As a result, they may not be suitable for
some clients. Clients investing in these funds
should have a high tolerance for risk, including
the willingness and ability to accept significant
price volatility, potential lack of liquidity and
potential loss of their investment.
credit
capitalization
risk,
foreign
Exchange Traded Notes Risks. An ETN is a
type of debt security that trades on an exchange
and provides a return linked to the performance
of an underlying benchmark. The underlying
benchmark can be a particular security, bond,
commodity, currency, or other Non-Traditional
Asset type, a group or basket of companies,
securities, commodities, currencies, derivative
instruments, Non-Traditional Asset investments or
other assets, or an index or other benchmark
linked to stocks, market volatility, bonds, interest
rates, Treasury yields, yield curves and spreads,
derivative instruments, strategies, commodities,
currencies or other assets. ETNs trade on
exchanges
the day at prices
determined by the market. Unlike ETFs, issuers of
ETNs do not buy or hold assets to replicate or
approximate the performance of the underlying
benchmark. Also in contrast to ETFs, ETNs also do
not calculate their net asset value, are generally
not redeemable on a daily basis, and are not
registered under the Investment Company Act of
1940. Issuers may also have the right and option
to redeem ETNs. Redemptions are made at the
ETN’s “indicative value” or “closing indicative
value”. An ETN's closing indicative value is
computed by the issuer and is distinct from an
ETN's market price, which is the price at which an
ETN trades in the secondary market. Issuers of
ETNs may also issue and redeem notes as a
means to keep the ETN’s market price in line with
its indicative value, which have caused significant
fluctuations in ETN prices. Investing in ETNs
involves special risks, including, but not limited
to, risks associated with Non-Traditional Assets
and derivative instruments and the risk that the
actual market price for an ETN may vary
significantly from the indicative value computed
by the issuer. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate
risk,
risk,
risk,
issuer and
investment style
investment risk, and emerging market risk. ETNs
Leveraged Fund and Inverse Fund Risks.
Leveraged funds and inverse funds may be
structured as ETNs, ETFs or open-end mutual
funds. Leveraged funds seek to deliver multiples
of the performance of the index or benchmark
they track. Inverse funds seek to deliver the
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risk,
emerging market
inverse
investment
risk,
commodities risk and currency risk. Structured
products are complex investments and involve
special risks. As a result, they may not be suitable
for some clients.
is
those
funds and they
opposite of the performance of the index or
benchmark they track. Leveraged inverse funds
seek to achieve a return that is a multiple of the
inverse performance of the underlying index. Most
leveraged and
funds “reset” daily,
meaning that they are designed to achieve their
stated objectives on a daily basis. Because of the
effects of compounding, volatility and the fund
expenses, the returns of a leveraged or inverse
fund over longer periods of time can differ
significantly from the performance (or inverse of
the performance) of their underlying index or
benchmark during the same period of time. To
achieve their objectives, leveraged and inverse
funds typically employ aggressive investment
techniques, such as the use of leverage, short
sales, swap contracts, futures, options and other
derivative instruments. Investing in leveraged
funds and inverse funds involves special risks,
including, but not limited to, risks associated with
Non-Traditional Assets, short sales, leverage, and
derivative instruments. Other risks may include:
market risk, management and securities selection
risk, investment objective and asset allocation
risk, stock market risk, equity securities risk,
common stock risk, fixed income securities risk,
interest rate risk, credit risk, foreign issuer and
investment risk, and emerging market risk.
Leveraged funds and inverse funds are complex
investments that have an increased risk of loss
involve
compared to other
significant, special risks. As a result, they may not
be suitable for some clients. A client should not
invest in these securities unless the client is
prepared to experience significant losses in the
value of the client’s Account.
risk, capital markets access
Investing
risks may
securities
include: market
selection
Business Development Company Risks. A
closed-end
typically a domestic,
BDC
investment company that is operated for the
purpose of making equity and debt investments in
small and developing businesses, as well as
financially troubled businesses. As a result,
investments made by BDCs tend to be risky and
speculative. Investment advisers or managers for
BDCs often receive a management fee plus
incentive or performance-based fee. Because of
the existence of a performance-based
fee,
managers may be motivated to make riskier
investments that have the potential for significant
growth in value. BDCs commonly use borrowings
or leverage to make investments in portfolio
companies. Adverse interest rate movements can
negatively
impact a BDC’s ability to make
investments. Investments made by BDCs are
typically illiquid, and valuing such investments is
challenging. It is possible that valuations on
investments used are materially different from the
values that BDCs will ultimately receive upon
disposition of
investments. Changing
market and economic conditions affecting a BDC’s
investments may cause significant volatility in the
BDC’s net asset value and stock price. Due to the
nature of BDCs’ investments, securities issued by
BDCs are subject to greater liquidity risk than
other investments. A debt security or preferred
stock issued by a BDC, in many cases, is non-
rated or is rated below investment grade, which
can carry its own risks. Investing in BDCs involves
other special risks, including, but not limited to,
portfolio company credit and investment risk,
risk,
leverage
dependence upon key personnel
risk, and
regulatory risk. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, and
interest rate risk. BDCs can be speculative
investments because of the types of investments
they make and involve significant, special risks.
As a result, BDC investments may not be suitable
for some clients. Clients investing in BDCs should
have a high tolerance for risk, including the
willingness and ability to accept significant price
Structured Products Risks. Structured products
are a hybrid between two asset classes (typically
issued in the form of a CD or note) but instead of
having a pre-determined rate of interest, the
return is linked to the performance of an
underlying asset class, such as single security or
basket or index of securities; a commodity or
basket or index of commodities, including futures;
and a foreign currency or basket of foreign
currencies.
in structured products
involves special risks, including, but not limited
to, risks associated with derivative instruments.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
issuer and
rate
risk, credit
risk,
foreign
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
volatility, potential lack of liquidity and potential
loss of their investment.
Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies
Each Account is subject to the risks associated
with the investments in the Account. Generally,
an Account will be subject to the risks associated
with the portfolio listed below that corresponds to
the investment objective of the Account or the
asset allocation strategy pursued by the Account.
risk,
common
stock
to other primary
risks,
risks,
foreign
including, but not
All Growth Portfolio. An All Growth Portfolio will
generally be invested in a manner that seeks to
provide growth of capital. All Growth Portfolios
have historically experienced high fluctuations in
annual returns and overall market value, typically
as a result of changes to market and economic
conditions. The Portfolio’s investments are subject
to a high risk of price declines, especially during
periods when stock markets in general are
declining. An All Growth Portfolio’s primary risks
generally include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities
risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, emerging market risks, fixed
income security risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
Master Limited Partnership Risks. An MLP is a
form of publicly-traded partnership that is taxed
as a partnership. MLPs have unique
tax
characteristics. A client should consult with a tax
advisor before investing in MLPs. An MLP must
generally earn at least 90% of its income from
certain qualifying sources, which includes income
and gains from certain activities involving natural
resources such as oil, natural gas, natural gas
liquids, refined petroleum products, coal, carbon
dioxide and biofuels. An MLP
is generally
structured as a limited partnership or limited
liability company and managed and operated by a
general partner or manager. Owners of an MLP
are called “limited partners” or “unit holders”.
Unit holders own interests or units in the MLP
(“units”) that are traded on a stock exchange.
MLPs make distributions to unit holders of their
available cash flows. Many MLPs focus on a
particular sector or industry. Those MLPs are
subject to risks associated with sectors or
industries in which they are focused. The value of
an investment in an MLP and the amount of
distributions it makes may depend on the prices
of the underlying commodity, such as oil or
natural gas. Many MLPs are sensitive to changes
in the prevailing level of commodity prices. MLPs
have also shown sensitivity to interest rate
movements. Investing in MLPs involves other
special risks,
limited to,
macroeconomic risk, interest rate risk, liquidity
risk, operating risk, capital markets access risk,
growth risk, distribution risk, conflicts of interest
risk, and regulatory risk. MLPs are complex
investments that have significant, special risks. As
a result, MLPs may not be suitable for some
clients. Clients investing in MLPs should have a
high tolerance for risk, including the willingness
and ability to accept potential lack of liquidity and
potential loss of their investment.
information
about
upon
Portfolio’s
foreign
issuer and
investment
certain
Additional
Complex Investment Products and other
investments pursuing Complex Strategies,
including the risks associated with those
investments, is available on Baird’s website
at bairdwealth.com/retailinvestor and on
FINRA’s website
at www.finra.org/
Investors. A client is encouraged to read the
disclosure documents
included on those
websites carefully before investing.
Capital Growth Portfolio. A Capital Growth
Portfolio will generally be invested in a manner
that seeks to provide growth of capital. Capital
Growth Portfolios have historically experienced
moderately high fluctuations in annual returns
and overall market value, typically as a result of
changes to market and economic conditions. The
Portfolio’s investments are subject to a risk of
price declines, especially during periods when
stock markets in general are declining. A Capital
Growth Portfolio’s primary risks generally include:
market risk, management and securities selection
risk, investment objective and asset allocation
risk, stock market risk, equity securities risk,
common stock risk, and capitalization risks.
Depending
specific
the
investments, the Portfolio may also be subject to
other primary risks, including investment style
risks,
risks,
emerging market risks, fixed income securities
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
risks,
foreign
the headings
risk, interest rate risk, credit risk, asset-backed
securities risks, below investment grade (high
yield or “junk” bonds) securities risks, and the
“Non-
risks described under
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
Portfolio’s specific investments, the Portfolio may
also be subject to other primary risks, including
investment style
issuer and
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
to
economic
The
to other primary
risks,
risks,
foreign
to other primary
risks,
risks,
foreign
Growth with Income Portfolio. A Growth with
Income Portfolio will generally be invested in a
manner that seeks to provide moderate growth of
capital and some current income. Growth with
Income Portfolios have historically experienced
moderate fluctuations in annual returns and
overall market value, typically as a result of
changes to market and economic conditions and
interest rates. The Portfolio’s investments are
subject to a risk of price declines, especially
during periods when stock markets in general are
declining or when interest rates are rising. A
Growth with Income Portfolio’s primary risks
generally include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
subject
including
investment style
issuer and
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
Conservative Income Portfolio. A Conservative
Income Portfolio will generally be invested in a
manner that seeks to provide current income.
Relative
the portfolios described above,
Conservative Income Portfolios have historically
experienced smaller fluctuations in annual returns
and overall market value as a result of changes in
stock market conditions, but have experienced
fluctuations in relation to changes in interest rates
and
Portfolio’s
conditions.
investments are subject to risk of price declines,
especially during periods when interest rates are
rising. A Conservative Income Portfolio’s primary
risks generally include: market risk, management
and securities selection risk, investment objective
and asset allocation risk, fixed income securities
risk, interest rate risk, credit risk, money market
fund risk, equity securities risk, and common
stock risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
income. Relative
to
interest
rates are
fixed
Income with Growth Portfolio. An Income with
Growth Portfolio will generally be invested in a
manner that seeks to provide current income and
some growth of capital. Income with Growth
Portfolios have historically experienced moderate
fluctuations in annual returns and overall market
value, typically as a result of changes to interest
rates and market and economic conditions. The
Portfolio’s investments are subject to a risk of
price declines, especially during periods when
interest rates are rising or when stock markets in
general are declining. An Income with Growth
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
fixed income securities risk, interest rate risk,
credit risk, money market fund risk, stock market
risk, equity securities risk, common stock risk,
and capitalization risks. Depending upon the
Capital Preservation Portfolio. A Capital
Preservation Portfolio will generally be invested in
a manner that seeks to preserve capital while
the
generating current
portfolios described above, Capital Preservation
Portfolios have historically experienced smaller
fluctuations in annual returns and overall market
value as a result of changes in stock market
conditions, but have experienced fluctuations in
relation to changes in interest rates and economic
conditions. The Portfolio’s investments are subject
to risk of price declines, especially during periods
rising. A Capital
when
Preservation Portfolio’s primary risks generally
include: market risk, management and securities
selection risk, investment objective and asset
allocation risk,
income securities risk,
interest rate risk, credit risk, and money market
fund risk. Depending upon the Portfolio’s specific
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investments, the Portfolio may also be subject to
other primary risks, including foreign issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
and Investment Strategies” above for more
information. In addition to the specific risks
described above, a client’s Account may be
subject to additional risks, depending upon the
particular investments in the client’s Account. A
client should discuss the risks of particular
investments with the client’s GWG Consultant. A
client should also note that there is no guarantee
as to how an Account will perform in the future. It
is possible that an Account could experience more
dramatic return or market value fluctuations than
occurred in the past.
to
perception
take advantage of
of market
Available Investment Product Risks
the
that Baird
establishes
for
Portfolios
have
the
investments made,
less
if an Available
Product
experiences
organizational,
is a higher risk
that
fixed
income
security
Product
that
experiences
Opportunistic Portfolio. An Opportunistic
Portfolio will generally be invested in a manner
that seeks to provide long term growth through
capital appreciation and/or income by utilizing an
active management style that shifts the amount
of investment made in different asset classes and
the
market sectors
manager’s
pricing
anomalies, those market or industry sectors
deemed favorable for investment by the manager,
the current interest rate environment and/or
other macro-economic trends identified by the
manager to achieve growth while accounting for a
client’s specific short, intermediate and long term
investment and/or cash flow needs. Depending
investment strategy used, some
upon
Opportunistic
historically
experienced high fluctuations in annual returns
and overall market value, typically as a result of
changes to market and economic conditions.
Depending upon the investment strategy used
and
the Portfolio’s
investments may be subject to a high risk of price
declines, especially during periods when stock
markets in general are declining. An Opportunistic
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, and capitalization risks. Depending
upon the Portfolio’s specific investments, the
Portfolio may also be subject to other primary
risks, including investment style risks, foreign
issuer and investment risks, emerging market
risks,
risks, below
investment grade (high yield or “junk” bonds)
securities risks, and the risks described under the
headings “Non-Traditional Assets and Complex
Investment
Strategies Risks” and “Complex
Product Risks” above.
the
list of
The use of Available Investment Products,
including SMA Strategies made available under
the BSN and DC Programs, are subject to
additional risks compared to the use of Baird
recommended
investment products. Available
Investment Products are investment products that
generally do not meet the qualifications and
its
standards
recommended product lists. As a result, there is a
higher likelihood that some Available Investment
Products will have poor performance and will
to an
significantly underperform compared
applicable benchmark
index or peer group.
Available Investment Products are also subject to
significantly
review by Baird
rigorous
compared to recommended investment products.
Investment Product
Thus,
experiences significant performance problems or
if the manager or sponsor of an Available
significant
Investment
management,
operational,
compliance, legal, regulatory or other problems,
there
the Available
Investment Product will be made available (and
will continue to be made available) to clients by
Baird. An investment by a client in an Available
Investment
the
occurrence of any such event could negatively
impact the client’s Account. Available Investment
Products should only be used by a client if the
client wishes to take more responsibility for
monitoring and managing the assets in the
client’s Account,
recommended
products does not contain an investment product
that meets the client’s particular needs, and the
client understands the risks of doing so.
Recent Events
financial markets have continued to
Global
experience periods of elevated volatility, driven by
Additional Considerations. A client should note
that an Account pursuing a particular investment
objective or asset allocation strategy will from
time to time be subject to actual risks that are
higher or lower than, or different from, the risks
described above under certain circumstances. See
“Investment Strategies—Important Information
about Implementation of Investment Objectives
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environment. As a result, fluctuations in asset
prices may increase, and such volatility could
adversely affect the value of a client’s Account .
priorities,
changes
in
a combination of economic, political, and broader
macroeconomic developments. Conditions across
major economies have been influenced by shifting
geopolitical
policy
relationships, and evolving investor expectations.
Voting Client Securities
Non-Discretionary Accounts
With respect to any Accounts over which the
client retains discretionary investment authority,
a client retains the right to vote proxies with
respect to the securities held in such Accounts.
Accordingly, the client is responsible for voting
proxies and otherwise addressing all matters
submitted for consideration by security holders,
and GWG and Baird are under no obligation to
take any action or render any advice regarding
such matters. The client’s GWG Consultant may,
upon the client’s request, provide advice on proxy
voting or what other action the client could take.
Separately Managed Accounts
Within the United States, the current U.S.
intent on
administration has demonstrated
implementing policy changes through executive
orders and legislation, contributing to a less
certain policy environment. Potential adjustments
to federal programs, regulatory initiatives, and
legislative priorities create additional factors for
markets to assess, which may cause meaningful
inflation reduction
market uncertainty. While
remains a central
for policymakers,
focus
achieving the U.S. Federal Reserve Board’s long
term inflation target of 2% continues to prove
challenging. Although annual price increases have
generally moderated, the price of many goods
and services remains elevated compared to levels
from a few years ago. Leadership changes at the
Federal Reserve and political divisions and discord
add further uncertainty to the economic outlook.
Internationally, geopolitical risks have increased
as the U.S. and Israel are engaged in a military
conflict with Iran. The conflict has disrupted
global trade and caused an increase in the price
of oil. The continuation or escalation of military
strikes could lead to a lengthy period of military
conflict, and Iran’s military attacks and other
hostile actions against other countries present a
risk of widening the conflict. In addition, the war
between Ukraine and Russia is now passing its
fourth anniversary, instability in parts of the
Middle East persist, and relations between the
U.S. and other countries are strained.
instances. For
Under the GWG Recommended Managers Service,
Baird SMA Network Program and Dual Contract
Program, a client may retain the right to vote
proxies with respect to the securities held in the
client’s Account, or, in most instances, the client
may delegate such right to the investment
manager selected to manage the client’s Account
(which may include Baird, the Overlay Manager or
an Implementation Manager). A client may select
either option by making the appropriate election
in the client’s advisory agreement (and in the
case of a dual contract arrangement under the
Dual Contract Program, by providing proper
instructions to the manager directly). Some
managers do not offer proxy voting services in
connection with certain strategies, such as option
strategies. Clients pursuing those strategies will
automatically retain the right to vote proxies in
those
information about a
manager’s voting policies and procedures, clients
should review the manager’s Form ADV Part 2A
Brochure.
Discretionary Services
Rapid advancements in artificial intelligence (AI)
and automation are increasingly influencing global
economic trends, corporate decision making, and
financial market dynamics. Expanding investment
in these technologies is contributing to shifts in
how industries operate, compete, and allocate
resources. The fast pace of technological change,
potential disruptions to existing business models,
and evolving regulatory responses
introduce
additional uncertainty and may contribute to
market volatility.
Under the GWG Investment Management Service,
a client may retain the right to vote proxies with
respect to the securities held in the client’s
Account, or a client may delegate such right to
Baird.
Taken together, these developments may have a
significant negative impact upon global economic
conditions and contribute to a heightened risk
If a client retains proxy voting authority, Baird will
forward proxy materials that Baird actually
receives to the client. The client will then be
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solely responsible for analyzing the materials and
casting the vote.
If a client delegates voting authority to Baird,
Baird will vote proxies solicited by, or with respect
to, securities held in the client’s Account for the
exclusive benefit of the client and in accordance
with policies and procedures adopted by Baird.
For those matters for which the independent
proxy voting service does not provide a specific
voting recommendation, each GWG Consultant
will cast the vote in a manner he or she believes
is in the best interest of clients. The votes cast for
a client’s Account may differ from those votes
cast for other Baird clients based on differing
views of GWG Consultants and other Baird
portfolio managers.
contacting
Baird has adopted written policies and procedures
that are reasonably designed to ensure that it
votes client securities in the best interests of
clients. Those procedures address material
conflicts of interest that may arise between
Baird’s interests and those of its clients. Although
a description of Baird’s proxy voting policies and
procedures is provided below, Baird will furnish a
copy of its proxy voting policies and procedures to
clients upon their request. Additionally, clients
may obtain information on how Baird actually
voted proxies with respect to the securities held in
their GWG
their accounts by
Consultant or by calling (414) 765-3500.
Baird uses ISS’s electronic vote management
system to cast votes on behalf of clients. In
connection with Baird’s use of that system, ISS
pre-populates how client votes should be cast
based upon ISS’s voting recommendations. The
system allows Baird to change the pre-populated
vote (to the extent permitted by Baird’s proxy
voting policies) up until a certain time prior to the
applicable meeting (the “voting cut-off time”).
Baird’s proxy voting policies are designed to
address situations when additional information
becomes available after the votes are pre-
populated in the system and before the voting
cut-off time. However, there is no guarantee that
all information that could affect Baird’s proxy
voting decision will be received or considered by
Baird prior to a vote being cast.
interests. Baird utilizes
governance
services,
(or
voting
recommendations.
interests of
The proxy voting policies and procedures also
address instances in which Baird’s interests may
appear to conflict with client interests, such as
when Baird or an affiliate of Baird is managing or
administering
to manage or
seeking
administer) a corporate retirement, pension or
employee benefit plan or providing (or seeking to
provide) advisory or other services to a company
whose management is soliciting proxies. In such
instances, there may be a concern that Baird
would be inclined to vote in favor of management
because of Baird’s relationship or pursuit of a
relationship with the company. In situations
where there is a potential conflict of interest,
Baird’s
Proxy Voting Sub-Committee will
determine the nature and materiality of the
conflict. If the conflict is determined to not be
material, the Sub-Committee will vote the proxy
in a manner the Sub-Committee believes is in the
best
the client and without
consideration of any benefit to Baird or its
affiliates. If the potential conflict is determined to
be material, Baird’s Proxy Voting Sub-Committee
will take one of the following steps to address the
potential conflict: (1) cast the vote in accordance
with the recommendations of ISS or other
independent third party; (2) refer the proxy to
In situations in which a client has delegated to
Baird voting authority with respect to securities in
the client’s Account, Baird will vote proxies in a
manner that Baird believes is consistent with the
client’s best
an
independent provider of proxy voting and
currently
corporate
Institutional Shareholder Services (“ISS”), to
analyze proxy materials and votes and make
independent
ISS
provides proxy voting guidelines regarding its
position on various matters presented by
companies to their shareholders for consideration.
Baird will typically vote shares in accordance with
the recommendations made by ISS. However,
ISS’s guidelines are not exhaustive, do not
address all potential voting issues, and do not
necessarily correspond with the opinions of GWG
Consultants. In the event the client’s GWG
Consultant believes the ISS recommendation is
not in the best interest of the client, the GWG
Consultant will bring the issue to Baird’s Proxy
Voting Sub-Committee through a proxy challenge
process. The Sub-Committee will
then be
responsible for determining how the vote will be
cast. The decision made by the Proxy Voting Sub-
Committee on the proxy challenge applies to all
advisory accounts managed by
the GWG
Consultant (or team of GWG Consultants), unless
the client has directed Baird to utilize specific
voting guidelines (e.g., Taft-Hartley guidelines).
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other authorized party) does not provide timely
voting instructions, Baird will vote such securities
to the extent permitted by law and in compliance
with the rules of the New York Stock Exchange
and the SEC relating to such matters.
the client or to a fiduciary of the client for voting
purposes; (3) suggest that the client engage
another party to determine how the proxy should
be voted; (4) if the matter is not addressed by
ISS, vote in accordance with management’s
recommendation; or (5) abstain from voting.
Legal Proceedings and Corporate Actions
Generally, none of GWG, Baird or any Other
Manager responsible for managing all or a portion
of the assets in a client’s Account will render
advice or take action on a client’s behalf with
respect to securities that are or were held in the
client’s Account, or the issuers thereof, which go
into default or become the subject of legal
proceedings, such as class action claims, defaults
or bankruptcies. Also, they may or may not vote
or advise clients on other corporate actions, like
tender offers, that are not solicited by a proxy
statement. At a client’s request, Baird will forward
information that Baird actually receives to the
client.
While Baird uses its best efforts to vote proxies,
there are instances when voting is not practical or
is not, in Baird’s or GWG Consultants’ view, in the
best interest of clients. For example, casting a
vote on a foreign security may involve additional
costs or may prevent, for a period of time, sales
of shares that have been voted. Also, when a
client has entered into a securities lending
program, Baird generally will not seek to recall
the securities on loan for the purpose of voting
the securities; however, Baird reserves the right
to recall the shares on loan on a best efforts basis
if the client’s GWG Consultant becomes aware of
a proxy proposal where the proxy vote is
materially important to the client’s Account.
In addition to the services described above, Baird
has engaged ISS for vote execution and record-
keeping services.
Other Proxy Voting Information
client establishes
such managers.
includes
risk
the client’s
tolerance and
Clients wishing to direct particular votes once
they have granted Baird discretionary voting
authority may do so by contacting their GWG
Consultant. However, if Baird has been granted
discretionary voting authority, neither GWG nor
Baird will provide a client with notice that Baird
has received a proxy solicitation, nor will they
consult with the client before casting a vote,
unless the client otherwise directs them to do so.
Client Information Provided to
Portfolio Managers
Under the GWG Recommended Managers Service,
GWG and Baird provide certain information about
the client to the investment managers managing
the client’s Account (which may include the
Overlay Manager or an Implementation Manager)
the advisory
the
when
Such
relationship with
investment
information
objectives and
lot
tax
information for the applicable Account assets.
Under the GWG Recommended Managers Service,
GWG and Baird also provide to the investment
manager a client’s age, investment timeframe,
and liquidity requirements.
Except to the extent a client has delegated proxy
voting authority to Baird, GWG and Baird have no
authority, direct or implicit, and accept no
responsibility for taking any action or rendering
any advice with respect to the voting of proxies
related to securities held in a client’s Accounts.
Unless specifically requested to do so by a client,
GWG and Baird do not generally provide such
information about the client on an ongoing basis
to the investment manager managing the client’s
Account.
Providing Baird Voting Instructions
Baird also generally provides the following to the
client’s manager unless otherwise instructed by a
client: trade confirmations, account statements,
and access to client’s Account on Baird’s system.
Client Contact with Portfolio Managers
GWG and Baird do not place any restrictions upon
clients who wish to contact or consult with Other
As mentioned above, Baird may be the holder of
record for certain securities in a client’s Account.
If the client retains voting authority over such
securities (or delegates such authority to party
other than Baird), and a proxy is solicited with
respect to any such securities, the client (or other
authorized party) will need to provide voting
instructions to Baird. To the extent the client (or
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Managers managing
their accounts. GWG
encourages clients to discuss their accounts with
their GWG Consultant.
WSPs, for correcting trade errors that was
reasonably designed to ensure compliance with
applicable securities laws, regulations and rules.
Baird was censured and fined $200,000.
certain of
the
its
to adopt or
to
designed
provide
to Baird’s clients and
Additional Information
Disciplinary Information
In April 2016, Baird, without admitting or denying
the findings, consented to the sanctions and
findings of the Financial Industry Regulatory
Authority, Inc. (“FINRA”) that it violated NASD
Conduct Rule 3010, FINRA Rule 3110, and FINRA
Rule 2010, by failing to establish and maintain a
supervisory system and procedures reasonably
designed to ensure that customers who purchased
mutual fund shares received the benefit of
applicable sales charge waivers. In May 2015,
Baird began a review to determine whether Baird
had provided available sales charge waivers to
eligible customers. Based on this review, in May
2015, Baird self-reported to FINRA that various
eligible customers had not received available
sales charge waivers. Baird was found to have
retirement plan and
disadvantaged certain
charitable organization customers
that were
eligible to purchase Class A shares in certain
mutual funds without a front-end sales charge.
The findings also stated that these customers
were instead sold Class A shares with a front-end
sales charge or Class B or C shares with higher
ongoing fees and the potential application of a
contingent deferred sales charge. Baird was
censured and required to pay restitution to
affected customers estimated to be approximately
$2.1 million including interest.
supervisor within
In September 2016, the SEC announced that
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
subadvisors
practices by
participating in Baird’s wrap fee programs offered
through
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
implement policies and
failed
specific
procedures
information
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. Baird also was ordered to cease
and desist committing or causing any violations
and any future violations of Section 206(4) of the
Advisers Act and Rule 206(4)-7 thereunder and
pay a civil money penalty in the amount of
$250,000.
Initiative.” Under
In July 2016, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that the firm and a
firm
its Private Wealth
reasonably
Management business did not
supervise a former Financial Advisor who misused
a customer’s funds. The findings stated that the
supervisor did not reasonably follow-up on red
flags associated with a trade correction request
submitted by the Financial Advisor that should
have alerted him to the Financial Advisor's misuse
of a customer’s funds. The supervisor also did not
follow certain of Baird’s written supervisory
procedures (“WSPs”) relating to trade corrections.
After the supervisor realized that the Financial
Advisor misused the customer’s funds, Baird
reimbursed the customer for the loss. The
findings also included that Baird did not establish
and maintain a supervisory system, including
In March 2019, Baird, without admitting or
denying the findings, consented to an order of the
SEC, which found that it violated Sections 206(2)
and 207 of
for making
the Advisers Act
inadequate disclosures to advisory clients about
mutual fund share classes. The order was part of
a voluntary self-reporting program initiated by the
SEC called the “Share Class Selection Disclosure
(or SCSD)
the program,
firms were offered the
investment advisory
opportunity to voluntarily self-report violations of
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supervisory
system
firms bought
fees and/or
the conflict of
retail equity trades and failed to establish and
maintain a
reasonably
designed to prevent charging a customer a
commission that is unreasonable or unfair in
violation of FINRA Rules 3110, 2121, and 2010.
Baird also consented to a censure, a fine in the
amount of $150,000, and the payment of
restitution of $266,481 plus interest. The findings
related to FINRA’s routine examination of Baird in
2020. During that examination, Baird modified its
minimum commission schedule and supervisory
procedures. Baird also took steps to make
payments to the affected customers, which on
average amounted 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. The brokerage customers identified by
FINRA did not include any GWG client and no
GWG client was alleged to have been charged an
unfair commission.
its
the federal securities laws relating to mutual fund
share class selection and related disclosure issues
and agree to settlement terms imposed by the
including returning money to affected
SEC,
investment advisory clients. The central issue
identified by the SEC was that, in many cases,
investment advisory
for or
recommended to their investment advisory 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
advisory clients, and the investment advisory
firms did not adequately disclose their receipt of
12b-1
interest
associated with those 12b-1 paying share classes.
Baird and many other firms self-reported under
into substantially
the program and entered
identical orders. By self-reporting and consenting
to the order, Baird agreed to a censure and to
cease and desist from committing or causing any
violations and future violations of Sections 206(2)
and 207 of the Advisers Act. Baird also agreed to
establish a distribution fund and to deposit into
that fund the improperly disclosed 12b-1 fees
received by Baird plus prejudgment interest,
which will be paid to affected advisory clients.
More information about the order is contained in
Baird’s Form ADV, which is available on the SEC’s
Investment Advisory Public Disclosure website at
https://www.adviserinfo.sec.gov/IAPD/Default.as
px or in the SEC’s press release about the SCSD
Initiative at https://www.sec.gov/news/press-
release/2019-28.
other
reports about an
reports was engaged
to disclose
In June 2019, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that between late
April 2013 and early July 2013 it published
issuer without
research
disclosing that the research analyst who authored
the
in employment
discussions with the issuer that constituted an
actual, material conflict of interest and that the
research analyst’s
the
failure
employment discussions with the issuer in the
research reports made those reports misleading.
Baird was censured and fined $150,000.
the
brokerage
customers
an
it charged
In September 2023, Baird entered into an Offer of
Settlement with the SEC, 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
business-related
associates’
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
text and
properly retaining business-related
instant messages
off-channel
and
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.
While Baird had policies and procedures in place
prohibiting such off-channel communications, it
was discovered that certain Baird supervisors
communicated
off-channel using non-Baird
approved methods on their personal devices
investment
about Baird’s broker-dealer and
adviser businesses, and
findings were
reported to the SEC. Baird took steps prior to and
after the SEC’s review, including implementing a
for Baird
new communication tool designed
associates’ personal devices, conducting training,
In August 2022, Baird, without admitting or
denying the findings, consented to the entry of
findings of FINRA, which found that it charged
certain
unfair
its published
commission when
minimum commission amount of $100 on 7,277
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
of Baird to the extent necessary or appropriate to
perform their job responsibilities.
communications. As part of
Certain Relationships and Arrangements
Baird and Associated Parties
including
for eligible
the
those
amount
the
training,
and periodically requiring requisite associates to
provide an attestation relating to their business-
related
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
surveillance program,
procedures,
technology solutions and similar matters related
to off-channel communications.
timing
of
state
investment
Financial
Advisors
located
Baird PWM has relationships or arrangements with
other Baird businesses units and the Associated
referral
Parties described below,
programs that pay special compensation to GWG
referrals. Additional
Consultants
referral programs,
information about
referral
of
including
compensation, is disclosed on Baird’s website at
bairdwealth.com/retailinvestor.
These
relationships or arrangements present a conflict of
interest because they provide a financial incentive
to Baird and GWG Consultants to use, select or
recommend the investment products and services
of Baird and Associated Parties over those of
unassociated parties and those that pay the
greatest level of compensation. Baird addresses
this potential conflict through disclosure in this
Brochure. Further, when acting as fiduciaries,
Baird and GWG Consultants are required to select
or recommend investment products only when
they determine it to be in the client’s best interest
to do so.
In March 2026, Baird entered into an Offer of
Settlement with the Massachusetts Securities
Division to settle a regulatory matter relating to
the
adviser
representative registration approvals for two of
in
Baird’s
Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals
provided investment advisory services before
their Massachusetts registrations were completed
as a form was missing from their application
materials. 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.
Additional information about Baird’s disciplinary
history is available on the SEC’s website at
www.adviserinfo.sec.gov.
Baird Asset Management
Baird’s Asset Management business, Baird
Advisors, Baird Equity Asset Management, and
Chautauqua Capital Management (“CCM”), part of
Baird Equity Asset Management,
provide
investment management services to institutional
clients and Funds. GWG Consultants who refer
clients to Baird Asset Management are eligible for
referral compensation to be paid by Baird. GWG
Consultants, therefore, have a financial incentive
to favor the services provided by Baird Asset
those provided by other
Management over
managers.
Other Financial Industry Activities and
Affiliations
Baird’s Broker-Dealer Activities
Baird Funds
including
Baird PWM offers brokerage accounts and related
services to its clients. Baird is also engaged in a
broad range of broker-dealer activities through
its Global
other business units,
Investment Banking, Fixed
Income Capital
Markets (including Baird Public Finance) and
Institutional Equities and Research Departments.
Certain GWG and Baird associates and certain
management persons of Baird are registered, or
have an application pending to register, as
registered representatives and associated persons
Baird is the investment adviser and principal
underwriter for Baird Funds, Inc. (the “Baird
Funds”). Baird Advisors provides
investment
management, administrative, and other services
to certain Baird Funds investing primarily in fixed
income securities (the “Baird Bond Funds”). Baird
Equity Asset Management and CCM provide
investment management and other services to
certain Baird Funds investing primarily in equity
securities (the “Baird Equity Funds”), and
Greenhouse Funds LLLP, a party related to Baird,
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
of such issuers. Baird may, therefore, have an
incentive to favor the securities of issuers for
which Baird provides such services over the
securities of issuers for which Baird does not
provide such services.
of
referral
is the investment subadvisor to one of those
Funds, the Baird Equity Opportunity Fund. In
certain instances, GWG Consultants who refer
clients to the Baird Funds are eligible for referral
compensation to be paid by Baird. Due to the
amount
compensation, GWG
Consultants have a financial incentive to favor the
Baird Equity Funds over the Baird Bond Funds.
Baird Trust
engaging
Trust
for
Baird is affiliated, and may be deemed to be
under common control, with Baird Trust, a
Kentucky-chartered trust company, because both
entities are indirectly wholly owned by BFG. Baird
and GWG Consultants receive compensation from
Baird Trust for referring clients and providing
ongoing relationship management services to
clients
trust
Baird
administration services as described under the
heading “Services, Fees and Compensation—
Additional Service Information—Trust Services
Arrangements” above.
Baird Capital
A GWG Consultant who refers a client to Baird
Investment Banking for a possible transaction in
which Baird Investment Banking earns a financial
advisory or underwriting fee receives a portion of
such fee. A GWG Consultant who refers a client to
Baird Public Finance for a municipal advisory or
underwriting opportunity receives a portion of the
compensation earned by Baird Public Finance on
that opportunity. Baird and GWG Consultants thus
have an incentive to recommend the securities
issued in those offerings. A GWG Consultant who
to Baird’s Institutional
refers a corporation
Equities business for a stock buy-back program
receives a portion of the commissions earned by
Baird’s Institutional Equities business. Baird and
its GWG Consultants may, therefore, have an
incentive to buy, and to recommend that clients
sell, the securities of issuers that are part of
Baird’s buyback services.
Sagard
Baird is engaged in a global private equity
business through Baird Capital (“Baird Capital”).
Baird and GWG Consultants may refer clients to
Baird Capital. GWG Consultants who assist in
obtaining a client’s investment in a private equity
fund offered through Baird Capital are eligible for
referral compensation.
Baird has a financial incentive to the extent it
would recommend that a client invest in a
portfolio company owned by a Baird Capital
private equity fund. A list of the portfolio
companies held by Baird Capital private equity
funds is located on Baird Capital’s website located
at https://www.bairdcapital.com/portfolio/baird-
capital-portfolio.aspx.
additional
compensation
Baird Global Investment Banking
Baird Institutional Equities and Research
Baird Public Finance
Sagard-affiliated
its Global
information
Baird’s direct parent corporation, BFC, has a
minority ownership interest (about 5%) in Sagard
Holdings Management, Inc. (“Sagard”) and the
right to appoint a member to Sagard’s board of
directors, which
is currently a management
person of Baird. Baird has agreed to use best
efforts, to the extent consistent with its fiduciary
interest obligations, and other
duties, best
regulatory responsibilities, to offer to clients
investment products managed by affiliates of
Sagard. Baird has an incentive to do so because
not reaching minimum thresholds would give
Sagard a right to redeem BFC’s ownership
interest
in Sagard and reaching significant
thresholds would give BFC the right to increase its
ownership interest. GWG Consultants do not
receive
for
any
investment
recommending
products. Additional
identifying
Sagard-affiliated
investment products will be
provided to clients prior to investment.
municipal
advisory,
55ip
55I, LLC (d/b/a 55ip, “55ip”) uses research and
other services from Riverfront, an affiliate of
Baird, in the development of its portfolios under
receives
the BSN Program, and Riverfront
Through
Investment Banking,
Institutional Equities and Research, and Public
Finance Businesses, Baird provides investment
securities
banking,
underwriting, stock buyback and related services
to various corporate, municipal, and other issuers
of securities. Baird receives compensation from
such issuers in connection with the services it
provides, and the success of its services generally
depends upon Baird’s ability to sell the securities
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
compensation from 55ip with respect to those
portfolios. Due to its affiliation with Riverfront,
Baird has a financial incentive to favor 55ip
portfolios that use Riverfront services.
incentive
to
favor
the
Associated Investment Products and
Services
Baird and GWG Consultants may select or
recommend Associated Investment Products and
Services, including the Associated Funds and
Associated SMA Strategies, listed in Appendix A to
this Brochure.
through disclosure
in
and BFG benefit financially if a client utilizes those
investment products and services rather than
unassociated investment products and services,
and GWG Consultants benefit financially from the
overall success of Baird and BFG. Similarly, Baird
and GWG Consultants also generally have a
financial
investment
products and services of Baird over Associated
Parties and to favor those of Associated Parties in
which BFG has a materially greater indirect
ownership interest over those of Associated
Parties in which BFG has a materially lesser
indirect ownership interest. Baird addresses this
potential conflict
this
Brochure. Further, when acting as fiduciaries,
Baird and its GWG Consultants are required to
select or recommend investment products only
when they determine it to be in the client’s best
interest to do so. The criteria used by them in
deciding to select or recommend Associated
Investment Products are generally the same as
those used for unassociated investment products.
However, a client should note that certain
Services and certain categories of investment
products only offer investment products and
services of Associated Parties. In those cases,
Baird and GWG Consultants do not impose the
same criteria or level of review.
Relationships and Arrangements with
Investment Managers
managers,
including
Certain Associated Parties are associated with
Baird because BFC, Baird’s parent corporation,
owns some or all of the Associated Parties’ voting
securities. BFC’s parent corporation (and Baird’s
ultimate parent corporation), BFG, may be
deemed to indirectly own or control such voting
securities. Baird is deemed to be under common
control and “affiliated” with an Associated Party
when BFG indirectly owns or controls 25% or
more of such Associated Party’s voting securities
(or of an entity deemed
to control such
Associated Party). Baird considers itself “related”
to an Associated Party when BFG indirectly owns
or controls at least 10% but less than 25% of
such Associated Party’s voting securities (or of an
entity deemed to control such Associated Party).
Baird considers
itself “associated” with an
Associated Party when certain other relationships
or other arrangements exist between Baird and
such Associated Party that might present a
conflict of interest with clients.
An Associated Party receives fees or other
compensation for investment advisory or other
services that it provides to an Associated Fund.
The amount of fees and other compensation paid
by an Associated Fund to an Associated Party is
disclosed in the Associated Fund’s prospectus or
other offering document. An Associated Party also
receives fees from a client for services that it
provides related to the client’s Associated SMA
Strategy. Information about the amount of fees
paid to an Associated Party with respect to an
SMA Strategy is contained in the applicable Baird
Form ADV Part 2A Brochure, the applicable
Program Account Schedule, or in some instances,
the client’s contract with the Associated Party.
Investment
those
participating in the Services, may select Baird, in
its capacity as a broker-dealer, to execute
portfolio trades for their clients, including for
Funds they advise and in which Baird clients
invest. Investment managers may also select
Baird to provide custody, research or other
services. Baird receives compensation for those
services. This may create an incentive for Baird to
favor the investment products and services of
such investment managers. However, Baird is a
fiduciary that is required to act in the best
interest of advisory clients when selecting or
recommending investment managers or their
investment products and services to such clients.
Baird addresses this potential conflict through
disclosure in this Brochure. Baird does not
consider the extent to which an investment
manager directs or is expected to direct trading,
custody or research services to Baird when
considering
investment
the eligibility of an
manager or its investment products or services
for the Services.
Baird and GWG Consultants have a financial
incentive to use, select or recommend Associated
Investment Products and Services because Baird
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
associates providing advisory-related services to
clients.
Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
Code of Ethics
Participation or Interest in Client
Transactions
Investment Advisory Accounts
incentive
to recommend an
Subject to the restrictions described below, Baird
and its affiliates and associates may engage in
securities transactions for their own accounts,
including the same or related securities that are
recommended to or owned by Baird clients. These
transactions may include trading in securities in a
manner that differs from, or is inconsistent with,
the advice given to Baird clients, and the
transactions may occur at or about the same time
that such securities are recommended to or are
purchased or sold for client accounts. This creates
a potential for a conflict between the interest of
clients and the interests of Baird and its affiliates
and associates.
Asset-based Advisory Fee arrangements create an
incentive for Baird and GWG Consultants to set
the applicable fee rate at a high level and to
encourage clients to add more money into their
accounts. Baird and GWG Consultants also have
investment
an
advisory account to a client rather than a
brokerage account if the client has, or is expected
to have, lower levels of trading activity in the
client’s account. Select clients may pay a fixed
dollar fee, which presents a conflict in that such
fee does not give the GWG Consultant an
incentive to make recommendations that could
benefit the client’s account, or a performance or
incentive fee, which presents a conflict because it
incentive to
gives the GWG Consultant an
recommend riskier
in order to
investments
achieve the level of performance in the account
that would result in payment of the fee.
Accounts and Investments Provide Different
Levels of Compensation
The types of accounts and investment products
to clients provide Baird and GWG
offered
Consultants different levels of compensation.
Baird and GWG Consultants have an incentive to
generate revenues
from client accounts by
selecting and recommending account types and
investment products that will provide them the
greatest level of compensation.
or
by
Baird’s
Recommendations of Associated Investment
Products and Services
the
they will benefit
To address the potential for conflicts of interest,
Baird has adopted a Code of Ethics (the “Code”)
that applies to
its associates that provide
investment advisory services to clients, including
GWG Consultants, their supervisors, and certain
associates who have access
to non-public
information relating to advisory client accounts
(“Access Persons”). The Code prohibits Access
Persons from using knowledge about advisory
client account transactions to profit personally,
directly, or indirectly, by trading in his or her
personal accounts. The Code also generally
from executing a
prohibits Access Persons
security transaction for their personal accounts
during a blackout period one business day before
or after the date that a client transaction in that
same security is executed. The Code provides for
certain exceptions deemed appropriate by Baird
management
Compliance
Department. In addition, orders for the accounts
of Access Persons and other Baird associates that
are under discretionary management by Baird
may be aggregated with orders for other Baird
client accounts, so long as the order is executed
as part of a block transaction with client orders. A
copy of the Code is available to clients or
prospective clients upon request.
Arrangements—Associated
Baird and GWG Consultants have an incentive to
use, select or
investment
recommend
products and services of Associated Parties
because
financially. See
“Additional Information—Other Financial Industry
Activities and Affiliations—Certain Relationships
and
Investment
Products and Services” above and “Certain Parties
Associated with Baird” on Baird’s website at
bairdwealth.com/retailinvestor.
Referral Compensation Paid to GWG Consultants
Baird has also implemented certain policies and
procedures relating to Baird’s and its associates’
trading activities that are designed to prevent
them from improperly benefiting from the trading
activities of Baird’s advisory clients. In addition,
Baird’s Compliance Department monitors the
personal trading activities of all of Baird’s
GWG Consultants receive additional compensation
for referring clients to certain Associated Parties
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Financial
Industry
Activities
Relationships
estimated based on the average daily balance of
the mutual fund shares in the Account and the
annual rate of the 12b-1 fee paid by the
applicable fund. If any rebated fees remain in a
client’s Account at the time of billing, those
rebated amounts will be included in the Account
assets subject to the Advisory Fee.
Such
to
those Associated Parties and
described above. See “Additional Information—
and
Other
Affiliations—Certain
and
Arrangements—Baird and Associated Parties”
above. GWG Consultants also receive additional
compensation for referring clients to unaffiliated
banks that make loans to clients under Baird’s
Securities-Based Lending Program. See “Services,
Fees and Compensation—Additional Service
Information—Securities-Based Lending Program”
above.
gives GWG
compensation
Consultants an incentive to recommend or refer
to
clients
recommend that a client participate in the
Securities-Based Lending Program. For more
information about referral compensation paid to
GWG Consultants and related conflicts of interest,
please see “Baird Referral Programs” on Baird’s
website at bairdwealth.com/retailinvestor.
Ongoing Product Fees
If Baird receives 12b-1 fees with respect to
mutual fund shares that are designated as
unbillable assets in a client’s Account, Baird will
retain such 12b-1 fees. This presents a conflict of
interest because it provides Baird and its GWG
Consultants an
incentive to use, select or
recommend mutual fund shares that pay greater
12b-1 fees. Baird addresses this conflict by
adopting a Mutual Fund Share Class Policy
described above and by adopting internal policies
that limit the circumstances under which mutual
fund investments in client accounts can be
designated as unbillable assets and 12b-1 fees
can be retained.
receives ongoing
fees
Marketing Support and Revenue Sharing from
Mutual Fund and UIT Sponsors
invested
from certain
Baird
investment products that are purchased and held
in client Accounts. Those fees, such as distribution
(12b-1) and/or service fees (“12b-1 fees”) from
mutual funds, are based on the value of client
assets
in those products. A GWG
Consultant’s compensation increases as those
fees increase. Thus, Baird and GWG Consultants
have an incentive to use, select or recommend
such products and to recommend such products
that pay the greatest ongoing fees.
Certain mutual funds charge 12b-1 fees, which
are paid to Baird. Baird receives 12b-1 fees on an
ongoing basis as compensation for the services
Baird provides to the applicable mutual fund. The
12b-1 fees paid by a mutual fund are disclosed in
the mutual fund’s prospectus.
Baird receives marketing support or revenue
sharing payments (“marketing support”) from the
sponsors and investment advisers of certain
mutual funds. These payments, which are based
on sales of, or client assets invested in, such
funds, are intended to compensate Baird for
providing marketing, distribution and other
services for the mutual funds. Marketing support
is not paid by sponsors or investment advisers of
mutual funds on mutual fund assets held in
investment advisory Retirement Accounts to the
extent prohibited by applicable
law. Baird
received marketing support payments over the
past two calendar years from the sponsors or
investment advisers of Alliance Bernstein Funds,
American Funds, Franklin Templeton Funds,
Goldman Sachs Funds, Hartford Funds, Invesco
Funds, John Hancock Funds, JPMorgan Funds,
Lord Abbett Funds, MFS Funds, PIMCO Funds and
Principal Funds. Baird also generally receives
marketing support related to the sale of units of
UITs. Sponsors of UITs typically make marketing
or concession payments to the firms that sell their
including Baird. These payments are
UITs,
typically calculated as a percentage of the total
volume of sales of the sponsor’s UITs made by
the
firm during a particular period. That
percentage typically increases as higher sales
volume levels are achieved. Descriptions of these
Baird generally does not allow mutual funds with
12b-1 fees to be purchased for GWG Service
Accounts. If Baird receives 12b-1 fees from a fund
with respect to a client’s mutual fund investment
in the client’s Account and the client’s Account is
subject to an asset-based fee arrangement, Baird
either: (1) rebates such 12b-1 fees to the client’s
Account if the client is paying an asset-based
Advisory Fee on such investment; or (2) excludes
such fund shares from the calculation of the
client’s asset-based Advisory Fee (sometimes
referred to as “unbillable assets”) for such period
of time that Baird collects and retains the 12b-1
fee. 12b-1 fees rebated to a client’s Account are
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
fees as further described under the heading
“Ongoing Product Fees” above.
Baird Conference Sponsorships
Trust
Portfolios
and
funds,
the opportunity
Please
see
seminars
supporting Baird
Please
see
additional payments are provided in a UIT’s
prospectus. UIT sponsors that have paid volume
concessions to Baird over the past two calendar
years include Advisors Asset Management (AAM),
First
Guggenheim
Investments. Receipt of marketing support
payments from sponsors and investment advisers
of mutual funds and UITs provides Baird an
incentive to use, select and recommend such
mutual funds and UITs and to favor mutual funds
and UITs with sponsors or investment advisers
that make the greatest levels of such payments.
Baird does not share these payments with GWG
Consultants.
“Revenue
Sharing/Marketing Support and Other Third Party
Payments” at bairdwealth.com/retailinvestor for
more information.
Schwab Clearing Arrangement
Baird hosts a number of seminars and
conferences for GWG Consultants in any given
year, including Baird’s PWM Symposium, which
gives sponsors of investment products, such as
mutual
to make
presentations at, and contribute money toward
the cost of, such seminars and conferences. This
presents a conflict of interest in that it gives Baird
an incentive to promote or market the sponsors’
investment products in order to persuade them to
and
continue
conferences.
“Revenue
Sharing/Marketing Support and Other Third Party
Payments” at bairdwealth.com/retailinvestor for
more information.
GWG Consultants Receive Benefits from Product
Providers
Party
Payments”
for
GWG Consultants generally receive non-cash
compensation and other benefits from Baird and
from sponsors of investment products with which
Baird does business. Such non-cash compensation
and other benefits may include invitations to
attend conferences or educational seminars,
payment of related travel, lodging and meal
expenses, and receipt of gifts and entertainment.
For example, GWG Consultants are invited to
educational conferences hosted by sponsors of
mutual funds, annuities and other investment
products, with the costs associated with such
conference (including travel and lodging) paid by
the sponsors. In addition, GWG Consultants hold
client events with some or all of the costs of such
events paid by sponsors of investment products.
Product sponsors may also provide gifts and
entertainment in connection with those or other
events. These benefits present a conflict of
interest in that they give GWG Consultants an
incentive to use, select or recommend investment
products and their sponsors that provide the
greatest levels of such benefits. Please see
“Revenue Sharing/Marketing Support and Other
Third
at
bairdwealth.com/retailinvestor
more
information.
Cash Sweep Program
Baird has a clearing arrangement with Charles
Schwab & Co., Inc. (“Schwab”) whereby Schwab
maintains an omnibus account with certain
mutual fund families for Baird on behalf of Baird
clients. Under the clearing arrangement, Schwab
provides clearing services for most “no load”
funds and “load” funds held by Baird clients.
Although Baird pays Schwab a fee for its clearing
and omnibus services, Schwab generally passes
through to Baird the shareholder servicing fees
that Schwab receives from the funds. Shareholder
servicing fees are not paid by Schwab on mutual
fund assets held in Retirement Accounts to the
extent prohibited by applicable law. The amount
of the shareholder servicing fees paid to Baird is
based on the value of the client assets invested in
those funds. However, the shareholder servicing
fee rate varies based on the type of fund (load or
no load), the value of client assets in those funds,
and the relationship that Schwab has with those
funds (whether or not Schwab receives payments
from those funds or their sponsors, and the rates
of such payments). As a result, Baird has an
incentive to use, select or recommend mutual
funds from which Baird would receive higher
payments from Schwab. However, Baird generally
does not compensate GWG Consultants based
upon the amounts Baird receives from Schwab
except with respect to amounts attributable to
sales loads and 12b-1 fees that Baird would
otherwise receive directly from a fund if it were
not for the existence of the clearing arrangement
with Schwab. If Baird receives 12b-1 fees from
Schwab with respect to a mutual fund investment
in a client’s Account, Baird rebates or retains such
Baird has an incentive to have clients participate
and maintain significant balances in Baird’s Cash
receives
because
Sweep
Program
Baird
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Investment Advisory and Brokerage Account and
Service Recommendations
to
clients
rather
substantial compensation on client cash balances
that are automatically swept into bank deposit
accounts and invested in money market mutual
funds under the program. Please see “Services,
Fees and Compensation—Additional Service
Information—Cash Sweep Program” above for
more detailed information.
Trust Services Arrangements
firm
and
to
Consultant
receive
it
incentive
to recommend an
Compensation—Additional
Baird and GWG Consultants have an incentive to
recommend that a client retain Baird Trust for the
client’s trust services needs rather than an
recommend
unassociated
arrangements that involve Baird and the GWG
Consultant providing investment advisory services
to the client and Baird Trust only providing trust
is more
administration services because
profitable for them. Please see “Services, Fees
and
Service
Information—Trust Services Arrangements” above
for more detailed information.
Margin Loans
fee. Please see
Baird and GWG Consultants generally have a
financial incentive to recommend investment
advisory Accounts
than
brokerage accounts because Advisory Fee
revenue
is recurring, more predictable and
typically greater than the revenues Baird earns,
and the compensation GWG Consultants receive,
from brokerage accounts. In addition, because
Advisory Fees are paid by a client regardless of
the trade activity in the client’s advisory Account,
Baird will receive greater revenue, and the client’s
GWG
greater
will
compensation, from a low trade-activity advisory
Account than from a low trade-activity brokerage
account. Baird and GWG Consultants thus have
an
investment
advisory Account to a client rather than a
brokerage account if the client has, or is expected
to have, lower levels of trading activity in the
client’s account. However, because Baird’s
revenues and the compensation paid to GWG
Consultants from brokerage accounts increase as
the level of trading increases, Baird and GWG
Consultants have an incentive to recommend a
brokerage account to a client rather than an
investment advisory Account if the client has, or
is expected to have, significant trading activity in
the client’s account. GWG Consultants also have a
financial incentive to recommend certain wealth
management services, such as financial planning.
Please see “Services, Fees and Compensation—
Advisory Fees—Advisory Fee Payments to Baird,
GWG Consultants and Investment Managers”
above for more detailed information.
Loans” above
Baird has an incentive to recommend that a client
use margin because Baird receives interest on
loans, and Baird and GWG
client margin
Consultants also have an incentive to recommend
that a client use margin, because a margin loan
allows the client to make larger and more
securities purchases. It also increases the value of
a client’s Account and thus the Advisory Fee
associated with that Account because the margin
loan is not deducted for purposes of calculating
the
“Services, Fees and
Compensation—Additional Service Information—
Margin
for more detailed
information.
Account Transfers and New Accounts
Securities-Based Lending Program
GWG
Consultants
receive
for
Baird and a client’s GWG Consultant have an
incentive to recommend that the client transfer
the client’s accounts to Baird and establish new
accounts with Baird (including IRA rollovers)
because doing so will result in increased revenues
the GWG
to Baird and compensation
Consultant.
Recommendations to Open Different Types of
Accounts
Baird and GWG Consultants have an incentive to
recommend that a client participate in Baird’s
Securities-Based Lending Program because Baird
and
referral
compensation and such loans allow a client to
keep more assets in the client’s Accounts, which
result in more advisory fees for us and paid to the
client’s GWG Consultant. Please see “Services,
Fees and Compensation—Additional Service
Information—Securities-Based Lending Program”
above for more detailed information.
Baird and GWG Consultants have an incentive to
recommend that a client open different types of
accounts with Baird, such as individual accounts,
IRA rollovers, joint accounts, 529 plan accounts
and UGMA/UTMA accounts, because if a client has
different types of accounts with Baird, the client
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Relationships with Issuers of Securities
in companies or
brings more of the client’s investable assets to
Baird, on which fees can be generated, thereby
increasing Baird’s revenues and the client’s GWG
Consultant’s compensation. Also, if a client has
more account types with Baird, the client is
statistically more likely to maintain the client’s
relationship with Baird and the client’s GWG
Consultant for longer periods of time.
Baird Stock Ownership
From time to time, Baird may have proprietary
investments
issuers whose
securities are offered and sold to clients, a GWG
Consultant or another Baird associate may have
significant investments in companies or issuers
whose securities are offered and sold to clients, or
a GWG Consultant or another other Baird
associate (or their spouses, partners or family
members) may have a position as an officer or
director of a company or issuer whose securities
are offered and sold to clients. In such cases,
Baird and/or a client’s GWG Consultant will have
an incentive to recommend that the client invest
in those companies.
GWG Consultants Transferring to Baird
that
increase
A GWG Consultant joining Baird from another firm
has an incentive to recommend that a client to
transfer the client’s accounts from such firm to
Baird because doing so will increase the GWG
Consultant’s compensation. Please see “Services,
Fees and Compensation—Advisory Fees—Advisory
Fee Payments to Baird, GWG Consultants and
Investment Managers” above for more detailed
information.
Principal Trading
with
Baird,
even
if
compensation
agent,
such
commissions.
select or
Most GWG Consultants own common stock of
BFG, Baird’s ultimate parent, and when offered
the opportunity to buy BFG stock they usually do
so. The amount of BFG stock that a GWG
Consultant may purchase is based in part on the
GWG Consultant’s total production level. A client’s
GWG Consultant thus has an incentive to make
recommendations
the GWG
Consultant’s total production on the client’s
accounts with Baird. Moreover, revenues from
Baird’s PWM department,
in which GWG
Consultants operate, contribute substantially to
BFG’s overall revenues and profitability, and the
performance of BFG’s stock price is largely due to
the profitability of Baird’s PWM department. As a
result, a client’s GWG Consultant’s ownership of
BFG stock creates a financial incentive to make
recommendations to the client that increase the
amount of revenues generated from the client’s
accounts
those
recommendations will not increase the GWG
Consultant’s production, so as to increase the
revenues and profitability of Baird’s PWM
department and thus of BFG, which will serve to
grow the value of the BFG stock. For example,
ownership of BFG stock, the performance of which
is impacted by the success of Associated Parties,
provides a client’s GWG Consultant an incentive
to use,
recommend Associated
Investment Products and Services to a client even
though such recommendation does not increase
the client’s GWG Consultant’s production.
Other Client Relationships
Baird and GWG Consultants have an incentive to
execute a trade for a client on a principal basis.
The
that Baird and GWG
Consultants receive on principal trades, such as a
markup or markdown, is often higher than the
compensation they receive when executing trades
The
as
as
compensation received by Baird and GWG
Consultants is in addition to the asset-based
Advisory Fee a client pays on the client’s advisory
Accounts. Thus, Baird and GWG Consultants have
an incentive to trade as principal rather than as
agent. Principal trades also allow Baird to sell
securities from Baird’s account that Baird deems
undesirable and to buy securities for Baird’s
account that Baird deems desirable. For more
information, please see “Services, Fees and
Compensation—Additional Service Information—
Trading for Client Accounts—Trade Execution
Services Performed by Baird—Principal Trades”
above.
Certain client accounts overseen by Baird and
GWG Consultants may have similar investment
objectives and strategies but may be subject to
different fee schedules or commission rates. Thus,
Baird and its GWG Consultants have an incentive
to favor client accounts that generate a higher
level of compensation.
Baird Underwritten Offerings
Baird and GWG Consultants have an incentive to
recommend that clients purchase securities in
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Compensation—Additional Service Information—
Trading for Client Accounts—Trade Execution
Services Performed by Baird” above.
offerings underwritten by Baird because the
underwriting compensation that Baird and GWG
Consultants will earn on those offerings tends to
be higher than the compensation they would
normally receive if clients were to buy them in the
secondary market, and because the profitability of
underwritten offerings to Baird depends upon
Baird’s ability to sell the securities allocated to
Baird in the offering.
to
Allocations of IPOs and Other Public Offerings
“Additional
Baird and GWG Consultants have an incentive to
favor the securities of issuers for which Baird’s
Global Investment Banking, Fixed Income Capital
Markets (including Baird Public Finance) and
Institutional Equities and Research Departments
provide services due
the compensation
received by Baird and Baird Financial Advisors.
Information—Other Financial
See
and Affiliations—Certain
Industry Activities
Relationships and Arrangements—Baird and
Associated Parties” above.
GWG Consultants have the incentive to favor
some clients over other clients when allocating
shares issued in public offerings, particularly
those clients with larger accounts or accounts that
generate high fees and compensation, as a
reward for their past business or to generate
future business.
Trade Error Correction
As a registered broker-dealer, Baird effects
transactions in securities on a national exchange
and may receive and retain compensation for
such services, subject to the limitations and
restrictions made applicable to such transactions
by Section 11(a) of the Exchange Act and Rule
11a2-2(T) thereunder.
It is Baird’s policy that a client’s account will be
fully compensated for any losses incurred as a
result of a trade error for which Baird is
responsible. If the trade error results in a gain,
the gain may be retained by Baird. For more
information, please see “Services, Fees and
Compensation—Additional Service Information—
Trading
for Client Accounts—Baird’s Trading
Practices—Trade Error Correction” above.
Baird’s Other Broker-Dealer and Related Activities
A client may choose to hold cash balances in the
client’s eligible accounts as broker-dealer “free
credits.” To the extent a client elects to hold cash
balances as free credits, a client understands that
Baird does not pay interest on such balances and
Baird may benefit from the possession or use in
the ordinary course of its business of any free
credit balances in the client’s accounts, subject to
restrictions imposed by Rule 15c3-3 under the
Exchange Act.
the size of
the order,
The investment advice provided to a client may
be based on the research opinions of Baird’s
research departments. Baird does, and seeks to
do, business with companies covered by those
research departments and as a result, Baird may
have a conflict of interest that could affect the
content of its research reports.
automated
sell
investments
recommended
non-institutional
participants
in
Baird selects securities trade execution venues
based on
trading
characteristics of the security, speed of execution,
likelihood of price improvement, availability of
transaction processing,
efficient
guaranteed automatic execution levels and other
qualitative factors. Baird receives payment or
liquidity rebates on certain options or equity
securities orders
to some venues
routed
(commonly known as “payment for order flow”).
The existence and amount of payments are
dependent upon the size and type of the routed
order. The
source and amount of any
compensation received by Baird in connection
with payment for order flow will be disclosed to
the
the
transaction upon request. This compensation
gives Baird an incentive to route client orders for
securities transactions to those venues that
Baird and its Associated Parties and associates
may buy or
that are
recommended to or owned by a client for their
own accounts, or they may act as broker or agent
those
for other clients buying or selling
investments. Those transactions may include
buying or selling investments in a manner that
differs from, or is inconsistent with, the advice
given to a client, and those transactions may
occur at or about the same time that such
investments are
to or are
purchased or sold for a client’s account. Baird
may also engage in agency cross transactions and
principal transactions with clients as further
and
described
under
“Services,
Fees
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Addressing Conflicts
provide Baird the greatest levels of compensation,
but Baird’s routing decision is always based upon
obtaining favorable executions for clients rather
than the availability of payment for order flow.
Information about Baird’s order routing practices
are
at:
available
http://www.rwbaird.com/help/account-
disclosures/routing-equity-orders.aspx.
for Baird and
from
time
The foregoing activities could create a conflict of
interest with clients. In addition to the measures
described above, Baird addresses conflicts posed
by those activities through disclosure in this
Brochure, the client’s agreements with Baird, the
Client Relationship Booklet and prospectuses,
offering documents or other disclosure documents
provided or made available to clients. Baird has
also adopted a Code of Ethics and other internal
policies and procedures
its
associates that:
• require them to provide investment advice that
is suitable for advisory clients (based upon the
information provided by such clients);
that
• are designed
securities
to ensure
allocations made to discretionary client accounts
are made in a manner such that all such clients
receive fair and equitable treatment over time;
Baird and its associates, by reason of Baird’s
investment banking or other
broker-dealer,
activities, may
time acquire
to
information deemed confidential, material and
non-public, about corporations or other entities
and their securities. Baird and its associates are
prohibited by applicable law or agreements from
disclosing such information to clients or acting
upon such information with respect to any client
Account. Baird’s other activities thus present a
potential conflict of
interest because such
activities may limit Baird’s ability to advise or
manage client Accounts.
Other Conflicts of Interest
• address Baird’s and its associates’ trading
activities and are designed to prevent them
from improperly benefiting from the trading
activities of Baird’s advisory clients; and
• address and limit cash and non-cash benefits
provided to GWG Consultants by third parties in
an attempt to avoid any question of propriety or
any conduct inconsistent with Baird’s high
standards of ethics.
Duration Compensation Will Be Received
Baird offers to clients other investment products
and services not described in this Brochure. These
investment products and
services provide
different levels of compensation to Baird and its
GWG Consultants. Baird and its GWG Consultants
have an incentive to favor those investment
products and services that generate a higher level
of compensation than those that generate a lower
level of compensation. For more information
about the other investment products and services
offered by Baird, clients should contact Baird or a
GWG Consultant.
extend beyond
a
client’s
financial
interest or practices
If a client holds any of the investment products
described above, Baird, its Associated Parties and
associates will receive the fees and payments
described above for the duration of the client’s
In some
relationship with Baird.
advisory
circumstances, the receipt of such compensation
may
advisory
relationship with Baird if the client continues to
hold those assets at Baird.
Fees—Advisory
Managers”
and
and
Referrals
and
Other sections of this Brochure also describe
instances when Baird and its GWG Consultants
may recommend to clients, and may buy and sell
for client’s Account, securities in which Baird and
its Associated Parties and associates have a
material
that
interest. For more
present a conflict of
information, please see “Services, Fees and
Compensation—Advisory
Fee
to Baird, GWG Consultants and
Payments
Investment
“Additional
Information—Other Financial Industry Activities
“Additional
and
above,
Affiliations”
Information—Client
Other
Compensation” below.
If Baird, or an Associated Party or associate of
Baird, receives any compensation or benefit
described in this Brochure from or related to a
client’s investment, they will generally retain the
compensation or benefit. Except as otherwise
described above, Baird generally does not rebate
these amounts to a client’s Account or credit the
amount against the Advisory Fees payable by a
client unless such compensation may not be
retained under applicable law or regulation.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Review of Accounts
Client Account Review
A client should note that past performance does
not indicate or guarantee future results. None of
GWG, Baird, or investment managers managing
the client’s Account promise or guarantee any
level of investment returns or that the client’s
investment objective will be achieved.
Client accounts are monitored on a periodic basis
by the client’s GWG Consultant and are subject to
review by the Baird Market Director or PWM
Supervision department supervisor (or his or her
respective designee) responsible for supervising
the client’s GWG Consultant. A client’s GWG
Consultant generally reviews the performance of
the client’s Account at least annually. However,
the client’s GWG Consultant may not review the
performance of a client’s SMAs managed by Other
Managers under the Baird SMA Network Program
or Dual Contract Program. Baird has designated
individuals who are responsible for monitoring a
client’s GWG Consultant with respect to the client
account’s trading activity and attempting to
ascertain whether client accounts within each
composite are being treated equitably.
Benchmarks shown in performance reports are for
informational purposes only. GWG’s selection and
use of benchmarks is not a promise or guarantee
that the performance of a client’s Account will
meet or exceed the stated benchmark. When the
client compares Account performance to the
performance of a market index, the client should
recognize that a market index merely reflects the
performance of a list of unmanaged securities
included in the index and the index performance
does not take into account management fees,
execution costs, and other expenses related to
investing for a client’s Account. The securities
included in a client’s Account generally do not
exactly mirror the securities included in the index.
Account Statements and Performance
Reports
performance
comparisons
If Baird provides transaction execution services to
a client, Baird will generally provide the client
with a monthly brokerage account statement
that month.
when activity occurs during
Otherwise, Baird will provide the client with a
quarterly statement if there has not been any
intervening monthly transaction activity.
The benchmarks used by Baird with respect to a
client’s SMA may differ from the benchmarks used
by the manager of the client’s SMA. As a result,
in Baird’s
the
performance reports may differ from reports
provided to clients directly by the investment
manager for the client’s SMA.
A client’s GWG Consultant will provide the client
with a written report on the client’s Account’s
performance as often as the client and the GWG
Consultant may from time to time mutually agree.
Performance reporting may not be available for
Account assets that are not custodied at Baird.
For more information about performance reports
provided by GWG, see “Services, Fees and
Compensation—Description of Advisory Services”
above. GWG or Baird may change or discontinue
performance reporting to a client at any time for
any reason upon notice.
calculation of
Client performance reports usually contain a
portfolio valuation and typically show the asset
allocation of the client’s portfolio, changes in a
client’s portfolio, and account performance
compared to a benchmark market index or indices
(such as the S&P 500® Index or the Bloomberg
U.S.
Intermediate Government/Credit Bond
Index). The benchmark may be a blended
benchmark that combines the returns for two or
more indices.
The performance of investment managers may,
under certain circumstances, be presented to
clients on a “gross” or “gross of fees” basis, which
means the performance results being presented
does not reflect the deduction of Advisory Fees
and other costs that clients have incurred and will
incur when retaining the manager. Had applicable
Advisory Fees and other costs been included in
the manager’s
the performance calculation,
performance results would have been lower than
the performance results presented. Documents
presenting a manager’s performance results on a
gross of
fees basis should contain certain
disclosures about the performance results being
presented. Clients are urged to review carefully
those disclosures because they contain important
information about
the
the
performance results. If a client is presented
performance information for a manager’s strategy
on a gross of fees basis and the client has an
Account managed by that manager pursuant to
that strategy,
the client should obtain a
performance report for the Account and review
that performance information carefully because
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the performance report for the Account will reflect
the deduction of applicable Advisory Fees and
other costs.
from other sources. Values used in account
statements and performance reports may vary
from prices received in actual transactions and
are not firm bids, offers or guarantees of any type
with respect to the value of assets in an Account,
and the values may be greater than the amount a
client would receive if the securities were actually
sold from the client’s Account.
If a client has assets held by a third party
custodian, the prices shown on a client’s Account
statements provided by the custodian could be
different from the prices shown on statements
and reports provided by GWG or Baird. See
“Services, Fees and Compensation—Additional
Service Information—Custody Services” above for
more information.
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after
implemented the Model Portfolio
they have
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. As a result, the performance of a
Model Portfolio, as reported by the Model
Provider, will differ, perhaps in a materially
negative manner, from the actual performance
realized by Baird client Accounts pursuing the
Model Portfolio strategy. See “Additional Service
Information—Trading for Client Accounts—Trading
Practices of Investment Managers” above for
more information.
including, but not
limited
to,
role
in developing
the
these
fees
to
Client Referrals and Other Compensation
GWG or Baird may provide compensation to
individuals who refer clients in some instances.
When applicable, the compensation paid is a
percentage of the client’s fee payments or the
value of the client’s Account. The amount of
compensation will vary, with the specific level
determined based upon consideration of various
factors
the
individual’s
client
relationship and the assets under management.
Baird may pay
registered
representatives of Baird and its Associated Parties
as well as to unassociated solicitors that have
entered into a written agreement with Baird.
When preparing a client’s Account statements and
performance reports, GWG and Baird generally
rely upon third party sources, such as third party
pricing services. In some instances, such as when
Baird is unable to obtain a price for an asset from
a pricing service, Baird may obtain a price from
its trading desk or it may elect to not price the
asset. Obtaining a price from its trading desk may
present a conflict of interest. In some cases, Baird
obtains prices from the issuers or sponsors of
investment products in the client’s Account when
prices are not otherwise readily available. This
frequently occurs with respect to the valuation of
annuities and Complex Investment Products. If
the assets in the client’s Account are held by a
custodian other than Baird, Baird may also use
valuation information provided by the client’s
third party custodian.
GWG and Baird and Baird’s Associated Parties and
associates may receive certain economic benefits
in connection with providing advisory services to
clients, which are described in the sections
entitled “Services, Fees and Compensation”,
“Account Requirements and Types of Clients”,
“Additional Information—Other Financial Industry
Activities and Affiliations” and
“Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” above.
is unreliable. Valuation data
Financial Information
GWG does not require or solicit prepayment of
more than $1,200 in fees per client six months or
more in advance and, thus, has not included a
balance sheet of Baird’s most recent fiscal year.
Neither Baird nor GWG is aware of any financial
condition that is reasonably likely to impair their
ability to meet their contractual commitments to
GWG and Baird do not conduct a review of
valuation information provided by third party
pricing services, issuers, sponsors, or custodians,
and they do not verify or guarantee the accuracy
of such information. GWG and Baird do not accept
responsibility for valuations provided by third
parties that are inaccurate unless they have a
reason to believe that the source of such
valuations
for
investments, particularly annuities and Complex
Investment Products, may not be provided to
GWG or Baird in a timely manner, resulting in
valuations that are not current. The prices
obtained by GWG and Baird from the third party
pricing services, issuers, sponsors and custodians
may differ from prices that could be obtained
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
clients, nor has either been the subject of a
bankruptcy petition at any time during the past
ten years.
investment
other
compensation
related
to
to
the applicable
Special Considerations for Retirement
Accounts
Each Retirement Account Fiduciary of a client
should understand that GWG or Baird may invest
for the client, recommend that the client invest in,
or make available
to plan
for
participants, Associated Investment Products, that
Baird and its Associated Parties will receive fees
such
or
investments, and that they will retain such
compensation
the extent permitted by
applicable law, rule or regulation, including,
without limitation, Department of Labor (“DOL”)
Prohibited Transaction Exemption (“PTE”) 77-4,
DOL PTE 2020-02 or other advisory opinions
issued by the DOL.
Account, each of which include a summary of all
fees that may be paid by the Associated
Investment Products to Baird or its Associated
Parties; and (iv) the client received information
concerning
the nature and extent of any
differential between the rate of such Associated
Investment Product fees and the Advisory Fees
payable by the client. The differential between the
fees to be charged by GWG and Baird for the
investment advisory services they provide to the
client and, if applicable, the investment advisory
and other similar fees paid by the Associated
Investment Product to Baird or its Associated
Parties with respect to the services Baird or any of
its Associated Parties provides to the Associated
Investment Product is the difference between the
Advisory Fee disclosed in the client’s advisory
investment
agreement and
management, investment advisory and other
similar fees detailed in the applicable prospectus
or other offering or disclosure documents for the
Associated Investment Product.
that
directed
the
fiduciary
Fiduciary
such Fiduciary
is
that
for complying with all
Parties
from
transactions, and
the duty
broker-dealer,
and
terminating
monitoring
a
for
the Associated
If the client’s Account is a Retirement Account
and if GWG is directed to implement a directed
brokerage arrangement for the Account, each
Retirement Account Fiduciary of the client should
understand:
brokerage
the
arrangement must be for the exclusive benefit of
participants and beneficiaries of the Retirement
Account; and
responsibilities
discussed in ERISA Technical Bulletin 86-1. Each
should also
Retirement Account
solely
understand
responsible
fiduciary
in ERISA Technical
responsibilities discussed
Bulletin 86-1, including, without limitation, the
duty to make an initial determination that the
directed broker-dealer is capable of providing best
execution for the client’s brokerage transactions,
the duty to monitor the services provided by the
directed broker-dealer so as to assure that the
client has received best execution of the client’s
brokerage
to
determine that the commissions paid by the client
and any other fees or costs incurred by the client
are reasonable in relation to the value of the
brokerage and other services received by the
client. The client and each Retirement Account
Fiduciary of the client should also understand that
the client and the client’s Retirement Account
Fiduciaries are solely responsible for engaging a
directed
its
performance
directed
brokerage arrangement, and that GWG and Baird
To the extent Baird and its Associated Parties rely
upon PTE 77-4, each Retirement Account
Fiduciary should also understand that when GWG
or Baird invests the assets of a Retirement
Account in an Associated Investment Product that
pays investment advisory fees to Baird or any of
its Associated Parties, Baird and its Associated
Parties will receive such investment advisory fees
in accordance with the terms of DOL PTE 77-4,
and, as required thereby, GWG and Baird will
waive the asset-based Advisory Fees on that
portion of the assets invested in the Associated
Investment Product for such period of time so
invested or Baird will offset the investment
advisory fees received by Baird or any of its
the
Associated
Associated
Investment Product against
the asset-based
Advisory Fee that GWG and Baird charge to the
client. For the purpose of complying with the
terms of DOL PTE 77-4, the client and each
Retirement Account Fiduciary of
the client
acknowledge in the client’s advisory agreement
that: (i) the investment in Associated Investment
Products for the client’s Account is appropriate
because of, among other things, the investment
goals, redeemability, liquidity, and diversification
of those products; (ii) subject to the terms of the
applicable Service, all assets of the client’s
Account may be invested in one or more of the
Associated Investment Products; (iii) the client
and such Retirement Account Fiduciary received
prospectuses or other offering or disclosure
Investment
documents
Products that may be used in connection with the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
are not responsible for determining whether a
directed broker-dealer is capable of providing best
execution.
than
the
client
client’s GWG Consultant.
If a client’s Account is a Retirement Account and if
the client is selecting Associated Investment
Products and Services, each Retirement Account
Fiduciary of the client understands and agrees
that in making such selection: (a) Baird and its
Associated Parties may receive higher aggregate
compensation
selected
if
investment managers, funds or other products
not associated with Baird and thus Baird may
have an incentive to offer Associated Investment
Products and Services; (b) Baird makes available
to the client investment managers, funds and
products not associated with Baird and the client
may obtain additional information about such
unassociated investment managers, funds or
products at any time by contacting the client’s
GWG Consultant; and (c) the client is free to
choose another investment option or participate
in another Baird advisory program that does not
use investment managers, funds or products
associated with Baird at any time by contacting
the
For more
information about Associated Investment Products
and Services, please see “Additional Information—
Other Financial Industry Activities and Affiliations”
above.
111
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Appendix A
Associated Investment Products and Services
Entity Type
Name
Relationship
Baird Advisors1
Baird Department
Baird Equity Asset Management1
Baird Department
Chautauqua Capital Management1
Baird Department
55I, LLC (d/b/a 55ip, “55ip”)
Associated
Investment Advisor
GAMMA Investing, LLC
Affiliated
Greenhouse Fund GP LLC
Related
Greenhouse Funds LLLP
Related
LoCorr Fund Management, LLC
Related
Reinhart Partners, LLC
Affiliated
Riverfront Investment Group, LLC
Affiliated
Dual Registrant2
Strategas Securities, LLC
Affiliated
Trust Company
Baird Trust Company1
Affiliated
Baird Funds, Inc.1
Affiliated
Bridge Builder Trust (Baird series)
Affiliated
Mutual Fund
Financial Investors Trust (Riverfront series)
Affiliated
LoCorr Investment Trust
Related
Managed Portfolio Series Trust (Reinhart series)
Affiliated
Pace® Select Advisors Trust (Baird Series)
Affiliated
Advisors’ Inner Circle Fund III (Strategas series)
Affiliated
ETF
ALPS ETF Trust (Riverfront Series)
Affiliated
First Trust Exchange-Traded Fund III (Riverfront series)
Affiliated
Automated Quantitative Analysis (AQA®) Portfolio Series
Affiliated
UIT
Dividend Income Trust (DIT) Series
Affiliated
Strategas Trust, Series 1-1
Affiliated
CIT
Reliance Trust Institutional Retirement Trust (Baird/Chautauqua series)
Affiliated
Greenhouse Master Fund LP
Related
Hedge Fund
Greenhouse Onshore Fund LP
Related
Greenhouse Overseas Fund Ltd.
Related
Chautauqua Global Growth Equity QP Fund, LP
Affiliated
Private Fund
Chautauqua International Growth Equity QP Fund, LP
Affiliated
Chautauqua Series Fund, LLC
Affiliated
Appendix A - 1
BGWG Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Venture Partners Management Company III, LLC
Baird Venture Partners III Limited Partnership
Affiliated
BVP III Affiliates Fund Limited Partnership
BVP III Special Affiliates Limited Partnership
Baird Venture Partners Management Company IV, LLC
Baird Venture Partners IV Limited Partnership
Affiliated
BVP IV Affiliates Fund Limited Partnership
BVP IV Special Affiliates Limited Partnership
Baird Venture Partners Management Company V, LLC
Baird Venture Partners V Limited Partnership
Affiliated
BVP V Affiliates Fund Limited Partnership
BVP V Special Affiliates Fund Limited Partnership
Baird Capital Partners Management Company V, LLC
Baird Capital1,3
Baird Capital Partners V Limited Partnership
Affiliated
Investment Advisor
BCP V Affiliates Fund Limited Partnership
Private Equity Fund
BCP V Special Affiliates Limited Partnership
Baird Capital Management Company, LLC
Baird Venture Partners GP VI, LLC
Baird Venture Partners VI LP
Affiliated
BVP VI Affiliates Fund LP
BVP VI Special Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management I LP
Baird Capital Global Fund I LP
Affiliated
Baird Capital Global Fund I-DE LP
BCGF I Special Affiliates LP
BCGF I Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management II LLC
Baird Capital Global Fund II Limited Partnership
Affiliated
BCGF II Affiliates Fund Limited Partnership
BCGF II Special Affiliates Limited Partnership
Appendix A - 2
BGWG Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Capital Management Company, LLC
Baird Capital Global GP III LLC
Baird Capital Global Fund III LP
Affiliated
Baird Capital1,3
BCGF III Affiliates Fund LP
Investment Advisor
BCGF III Special Affiliates LP
Private Equity Fund
Baird Capital Partners Europe Limited4
Baird Capital Partners Europe II LP
Affiliated
Baird Capital Partners Europe II Special Affiliates LP
The Growth Fund
Baird Principal Group Management Company I, LLC
Baird Principal Group5
Baird Principal Group Partners Fund I Limited Partnership
Investment Advisor
Baird Principal Group Management Company II, LLC
Affiliated
Private Equity Fund
Baird Principal Group Partners Fund II Limited Partnership
Baird Principal Group Management Company, LLC
Baird Principal Group Partners Fund III, LP
Holding Company
Sagard Holdings Management, Inc.6
Associated
1. Participates in a Baird PWM Referral Program that pays compensation to GWG Consultants for eligible referrals.
2. Registered with the SEC as a broker-dealer and investment advisor.
3. Baird Capital, Baird’s private equity business.
4. Baird Capital Partners Europe Limited, an English limited company, is regulated and authorized by the Financial
Conduct Authority.
5. Baird Principal Group, a group within Baird that has private equity funds only available to Baird employees.
6. Baird has a contractual relationship with and a small minority investment in Sagard Holdings Management, Inc., a
holding company for various financial services businesses whose investment products are made available to clients under
the Services. See “Additional Information—Other Financial Industry Activities and Affiliations—Certain Relationships and
Arrangements—Baird and Associated Parties” above for more information.
Appendix A - 3
BGWG Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Additional Brochure: BAIRD INSTITUTIONAL CONSULTING SERVICES (2026-03-27)
View Document Text
Baird Private Wealth Management
Brochure
March 27, 2026
Plan Consulting Services
Institutional Consulting Services
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue
Milwaukee, WI 53202
1-800-792-2473
rwbaird.com
Member FINRA & SIPC
SEC File No. 801-7571
This brochure (“Brochure”) provides information about the qualifications and business practices of
Robert W. Baird & Co. Incorporated (“Baird”) and its Private Wealth Management Department’s Plan
Consulting Services and Institutional Consulting Services. You should carefully consider this
information before becoming a client of Baird. If you have any questions about the contents of this
Brochure, please contact us at the toll-free phone number listed above. The information contained in
this Brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority. Additional information about Baird is available on the
SEC’s website at www.adviserinfo.sec.gov.
Material Changes
Robert W. Baird & Co. Incorporated (“Baird”) updated the Form ADV Part 2A brochure for its Private Wealth Management
Department’s Plan Consulting Services and Institutional Consulting Services (the “Brochure”) on March 27, 2026. The
following summary discusses the material changes that Baird has made to the Brochure since March 21, 2025, the date of
the last annual update to the Brochure.
• Baird has updated the Institutional Consulting Services program to distinguish between Plan Consulting Services, which
include non-discretionary consulting services provided to qualified and non-qualified plan clients, including defined benefit
plans and participant-directed defined contribution plans (collectively, “Plans”), and Institutional Consulting Services,
which include non-discretionary consulting services provided to eligible non-Plan clients. No change will be made to the
services provided to any existing client or the terms and conditions applicable to such services as a result of this update.
• In January 2026, Baird’s direct parent corporation, Baird Financial Corporation (“BFC”), made a significant minority
investment in Reinhart Partners, LLC (“Reinhart”), an investment advisor that offers investment products and
services. As a result of the investment transaction, Baird and Reinhart are affiliated, providing Baird a financial
incentive to recommend Reinhart investment products and services.
• In September 2025, Baird entered into a strategic partnership with Sagard Holdings Management, Inc. (“Sagard”).
Baird’s direct parent corporation, BFC, acquired a minority ownership interest in Sagard and the right to appoint a
member to Sagard’s board of directors. Baird agreed to use best efforts, consistent with its fiduciary duties and other
regulatory responsibilities, to offer investment products managed or sponsored by affiliates of Sagard deemed
suitable by Baird for its PWM clients, providing Baird a financial incentive to recommend such investment products.
See the Section of the Brochure entitled “Other Financial Industry Activities and Affiliations—Certain Relationships
and Arrangements—Baird and Associated Parties” for more information.
• Baird updated information about Baird’s regulatory assets under management. See the Section of the Brochure
entitled “Advisory Business—Robert W. Baird & Co. Incorporated” for more information.
• Baird updated its disclosures about the research, information and tools used by Baird PWM home office investment
professionals and Baird Consultants when formulating investment advice, which may include the use of artificial
intelligence (“AI”) tools, and the related risks. See the Section of the Brochure entitled “Methods of Analysis,
Investment Strategies and Risk of Loss—Methods of Analysis” for more information.
investment risk
information related to
• Baird updated
information security, cybersecurity, and other
technology‑related events, issuers’ use of AI, investments in digital assets, such as cryptocurrencies, and those
associated with recent events, such as those associated with the U.S. administration’s policy initiatives, inflation,
conflicts in Iran and the Middle East, the war between Ukraine and Russia, and the strain in relationships between
the U.S. and other countries. See the Section of the Brochure entitled “Methods of Analysis, Investment Strategies
and Risk of Loss—Principal Risks—Investment Risk Information” for more specific information.
• In March 2026, Baird entered into an Offer of Settlement with the Massachusetts Securities Division to settle a
regulatory matter relating to the timing of state investment adviser representative registration approvals for two of
Baird’s Financial Advisors located in Massachusetts. The Division alleged that, for a limited period in early 2025, the
two individuals provided investment advisory services before their Massachusetts registrations were completed as a
form was missing from their application materials. 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.
• Baird updated information about firms, affiliated with, related to, or otherwise associated with Baird. See the Section
of the Brochure entitled “Other Financial Industry Activities and Affiliations” and Appendix A to the Brochure for more
information.
A client should note that the foregoing summary only discusses material changes made to the Brochure since March 21,
2025. The updated Brochure contains changes that are not listed above.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Table of Contents
Advisory Business .......................................................................................................... 1
Robert W. Baird & Co. Incorporated .............................................................................. 1
The Client-Baird Fiduciary Relationship .......................................................................... 1
Summary of Services .................................................................................................. 2
Description of Services ................................................................................................ 3
Limitations on the Services .......................................................................................... 5
Additional Service Information ...................................................................................... 5
Fees and Compensation ................................................................................................. 8
Advisory Fees ............................................................................................................. 8
Other Fees and Expenses ........................................................................................... 10
Other Compensation Received by Baird ....................................................................... 11
Performance-Based Fees and Side-By-Side Management ............................................. 11
Types of Clients ............................................................................................................ 12
Methods of Analysis, Investment Strategies and Risk of Loss ...................................... 12
Investment Strategies ............................................................................................... 12
Methods of Analysis ................................................................................................... 16
Principal Risks .......................................................................................................... 22
Disciplinary Information .............................................................................................. 35
Other Financial Industry Activities and Affiliations ...................................................... 37
Baird’s Broker-Dealer Activities ................................................................................... 37
Certain Relationships and Arrangements ...................................................................... 37
Relationships and Arrangements with Investment Managers ........................................... 39
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading...................................................................................................... 39
Code of Ethics .......................................................................................................... 39
Participation or Interest in Client Transactions .............................................................. 39
Brokerage Practices ..................................................................................................... 43
Review of Accounts ...................................................................................................... 43
Client Referrals and Other Compensation ..................................................................... 43
Custody ........................................................................................................................ 43
Investment Discretion .................................................................................................. 43
Voting Client Securities ................................................................................................ 43
Financial Information ................................................................................................... 43
Associated Investment Products and Services ............................................ Appendix A-1
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
strategies;
research,
analysis
its services separately or
regarding asset allocation and
recommendations
investment
and
recommendations regarding investment managers and
individual securities; investment consulting; financial
planning; investment policy development; and account
performance monitoring. Baird also offers clients
execution of brokerage transactions and administrative
services, including maintaining custody of account
assets. Clients may also negotiate other services with
in
Baird. Baird offers
combination with other services.
Neither PCS nor ICS are wrap fee programs. However,
Baird participates in wrap fee programs not described in
this Brochure and it provides portfolio management
services in connection with those programs. Baird
receives a portion of the wrap fee paid by clients for
providing portfolio management services under those
wrap fee programs.
billion
in
regulatory
assets
As of December 31, 2025, Baird had approximately
$394.0688
under
management, approximately $289.4898 billion of which
was managed on a discretionary basis and approximately
$104.5790 billion of which was managed on a non-
discretionary basis.
amended
(“IRC”)
(collectively,
Advisory Business
This Brochure describes the plan consulting services
(“PCS”) and institutional consulting services (“ICS”) that
the Private Wealth Management (“PWM”) Department of
Robert W. Baird & Co. Incorporated (“Baird”) offers to its
clients through Baird Financial Advisors who have been
approved to provide PCS and ICS (“Baird Consultants”).
Information about other investment advisory services
and the terms and conditions, fees and costs and
potential conflicts of interest associated with those
services is contained in separate brochures. This
Brochure references other documents that contain
additional important information about Baird. Those
documents describe the types of investment products and
services that Baird makes available to clients, including
the terms, conditions, fees, costs, risks, and conflicts of
interest applicable to those investment products and
services. Those documents are available on Baird’s
website at bairdwealth.com/retailinvestor. Included on
that website is Baird’s Client Relationship Booklet, which
contains Baird’s Form CRS Client Relationship Summary
and Baird’s Client Relationship Details document. The
Client Relationship Booklet also contains an important
disclosure document for retirement investors that have
retirement accounts, which include employee pension
benefit plan accounts that are subject to the Employee
Retirement Income Security Act of 1974, as amended
(“ERISA”) and individual retirement accounts (“IRAs”)
that are subject to the Internal Revenue Code of 1986,
“Retirement
as
Accounts”).
A client of Baird who is a retail investor should have
already received a copy of the Client Relationship
Booklet. A client or prospective client who wishes to
obtain a brochure for another investment advisory
service provided by Baird, or a paper copy of any of the
other documents referenced in this Brochure, including
the Client Relationship Booklet, should contact a Baird
Consultant or call Baird toll-free at 1-800-792-2473.
The information contained in this Brochure is current as
of the date above and is subject to change at Baird’s
discretion. Please retain this Brochure for your records.
information
is privately-held,
Robert W. Baird & Co. Incorporated
Baird
employee-owned global
investment and wealth management firm formed in the
State of Wisconsin in 1919. Baird is owned indirectly by
its associates through several holding companies. Baird
is owned directly by Baird Financial Corporation (“BFC”).
BFC is, in turn, owned by Baird Financial Group, Inc.
(“BFG”), which is the ultimate parent company of Baird.
Associates of Baird own substantially all of the
outstanding stock of BFG.
The Client-Baird Fiduciary Relationship
Baird is registered with the Securities and Exchange
Commission (“SEC”) as an investment adviser under the
Investment Advisers Act of 1940, as amended (the
“Advisers Act”). Baird and its associates are deemed to
have a fiduciary relationship with a client when providing
the investment advisory services that are described in
this Brochure. That means that Baird and its associates
are required to act in the best interest of the client when
providing investment advisory services. From time to
time, Baird or its associates may engage in certain
business practices or may receive compensation or other
benefits that create a potential for conflict between the
interests of clients and the interests of Baird or its
associates. Baird generally addresses potential conflicts
of interest by disclosing them to clients through
documents provided to clients,
including, without
limitation, this Brochure, Brochure supplements that
contain
individuals providing
about
investment advice to clients and the services they
provide, and the agreements clients enter into with Baird.
In addition, Baird has adopted internal policies and
procedures for Baird and its associates that require them
to: provide investment advice that is suitable for advisory
clients (based upon the information provided by such
clients); make full disclosure of all potential, material
conflicts of interest; and act with utmost care and good
faith in dealings with advisory clients. The specific
business practices that create potential conflicts of
interest with clients and additional measures used by
Baird to address them are discussed in other sections of
this Brochure.
Baird offers various investment advisory services to
clients, including services not described in this Brochure.
The investment advisory services Baird offers include:
portfolio management and analysis; analysis and
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment strategy
that
is most
A client should note that registration as an investment
adviser does not imply a certain level of skill or training.
Services and
appropriate for the client.
Baird Consultants tailor their advisory services to the
individual needs of clients. Clients may negotiate with
Baird Consultants to provide other services.
Summary of Services
This Brochure describes certain investment advisory and
other consulting services (collectively, the “Services”)
generally offered by Baird to qualified and non-qualified
plan clients (collectively, “Plans”), including participant-
directed defined contribution Plans (“Participant-Directed
Plans”) and other eligible clients. Certain Services are
limited to specified types of clients.
Plan Consulting Services
Baird makes available the following Services to Plan
clients under the Plan Consulting Services program (the
“PCS Services”). The PCS Services consist of:
• non-discretionary investment advisory services (“Non-
Discretionary Services”), whereby Baird and one or
more Baird Consultants provide investment advice and
recommendations to Plan clients, which may include
advice and recommendations related to a Participant-
Directed Plan client’s menu of designated investment
alternatives (a “DIA Lineup”), but the Plan client
retains full authority with respect to the management
of the client’s assets and/or DIA Lineup; and
• additional non-investment advisory consulting services
(“Consulting Services”).
Institutional Consulting Services
Baird makes available the following Services under the
Institutional Consulting Services program (the “ICS
Services”). The ICS Services consist of:
A prospective client that wishes to participate in a Service
will enter into an investment advisory agreement (a
“Consulting Agreement”) with Baird. The Consulting
Agreement will contain the specific terms applicable to
the services selected by the client, advisory fee
(“Advisory Fee”) payable by the client and other terms
applicable to the client’s advisory relationship with Baird.
A client should note that the client’s advisory relationship
with Baird does not begin until Baird enters into an
advisory agreement with the client, which occurs when
Baird’s home office has accepted the client’s Consulting
Agreement and determined that all of the client’s
paperwork is in order and Baird has delivered to the client
all applicable Consulting Agreement- and Brochure-
related documents. A client should understand that the
Consulting Agreement will not become effective, and
Baird will not provide any advisory services selected by
the client, until such time that Baird has accepted the
Consulting Agreement. Baird may delay acceptance of
the Consulting Agreement and the provision of advisory
services to the client for various reasons, including
deficiencies in the client’s paperwork. Once it has become
effective, the Consulting Agreement shall continue until it
is terminated in accordance with the terms described in
the Consulting Agreement. A client should note, unless
Baird has otherwise agreed in writing, the Services are
provided only to the client specifically referenced in the
Consulting Agreement and not for any other clients,
assets or accounts (including but not limited to a
Participant-Directed Plan’s participants).
• Non-Discretionary Services, whereby Baird and one or
more Baird Consultants provide investment advice and
recommendations but the client retains full authority
with respect to the management of the client’s assets;
and
• certain eligible Consulting Services.
“Associated
Investment
Products
The Services may be aggregated to oversee an entire
investment program or may be utilized separately.
Typically, the Services are related to client assets held in
one or more accounts maintained by a client’s
recordkeeper, plan platform provider or other custodian
(an ”Account”).
The Services are non-discretionary in nature and a client
retains full discretionary authority to manage the client’s
assets.
ICS clients typically work with or are introduced to a Baird
Consultant. Baird PWM’s home office
investment
professionals may also provide advice and assistance to
the client. The client, with the assistance of a Baird
Consultant, determines the services that are most
appropriate given the client’s goals and circumstances.
However, it is the client that ultimately selects the
In connection with provision of the Services, a Baird
Consultant may present, discuss, analyze and/or
recommend a wide variety of different investment
products and services, including certain investment
products and services managed, advised or sponsored by
Baird or other parties affiliated with, related to, or
(such parties,
otherwise associated with Baird,
“Associated Parties” and such investment products and
services,
and
Services”). Associated Investment Products and Services
generally consist of mutual funds, ETFs, unit investment
trusts (“UITs”), collective investment trusts (“CITs”),
private equity funds, hedge funds, and other private
funds (“Associated Funds”) and other
investment
products (collectively, “Associated Investment Products”)
managed, advised or sponsored by Baird or Associated
Parties and separately managed account (“SMA”)
strategies managed or advised by Baird or Associated
Parties (“Associated SMA Strategies”). Baird and Baird
Consultants may use, select or recommend Associated
Investment Products and Services. This may present a
conflict of interest. A client is free at any time to select
investment products and services that are not associated
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
with Baird. For specific information about Associated
Parties and Associated
Investment Products and
Services, see “Other Financial Industry Activities and
Affiliations” below.
policy statement approved by the client (including any
revisions or modifications), is provided to the client’s
Baird Consultant before the client’s Baird Consultant
begins any asset allocation review.
Subject to the terms of the client’s agreement, the
client’s Baird Consultant will periodically review and
evaluate the client’s current asset allocation and
recommend revisions to the allocation based upon
changes to the client’s situation.
Investment Due Diligence
Description of Services
The description of the Services below is only a general
description of the consulting services offered by Baird to
clients. The specific Services, the level of service to be
provided, and the frequency of periodic reviews, if any,
will be set forth in the client’s Consulting Agreement. A
client should refer to the client’s Consulting Agreement
for more specific information about the Services being
provided. Unless otherwise indicated, the Services
described below are available to PCS and ICS clients.
Non-Discretionary Services
If a client elects to have Baird provide Investment Due
Diligence, the client’s Baird Consultant assists the client
in analyzing current and/or prospective investment
options. The client is solely responsible for selecting an
investment option and is solely responsible for hiring,
terminating, and/or replacing an investment manager,
and for buying, selling, or otherwise replacing any
investment option.
Investment Recommendations
Baird and its Baird Consultants make available the
following non-discretionary investment advisory services
for which they act as a “fiduciary” under the Adviser’s Act.
When Baird provides Non-Discretionary Services to
Retirement Accounts, Baird also provides such services
as a “fiduciary” as that term is defined under Section
3(21)(A) of ERISA and/or Section 4975 of the IRC.
Investment Policy Statement Creation or Review
If a client elects to receive Investment Recommendation
Services, the client’s Baird Consultant will provide the
client investment options consistent with the client’s
investment objectives, investment guidelines and asset
allocation needs. Investment options may include, but
are not limited to:
investment
time horizon,
• equity securities, including, but not limited to, common
stocks, American Depositary Receipts (“ADRs”), and
ordinary shares, including whether exchange-traded,
or over-the-counter traded;
A client may elect to have Baird provide assistance in
creating an investment policy statement or reviewing an
existing investment policy statement. If a client elects
this Service, the client’s Baird Consultant will typically
assist the client in determining the client’s investment
objectives,
investment
constraints, investment diversification requirements, and
risk tolerance. The Baird Consultant will also typically
assist the client with incorporating that information into
an
investment policy statement, or updating the
information in an existing document, as the case may be.
The investment policy statement is intended to provide
guidance to the client by establishing performance
benchmarks that account for changing market conditions.
issued by the U.S. Treasury,
The client is responsible for the review and final approval
of the client’s investment policy statement.
Asset Allocation Review
• fixed-income securities, including but not limited to,
debt securities issued by domestic and foreign
corporations and other entities; preferred stocks,
asset-backed securities (including mortgage-backed
securities and collateralized mortgage obligations
(“CMOs”)); convertible debt securities; obligations
issued by U.S., state, or foreign governments or their
agencies, instrumentalities, or authorities, such as
securities
federal
government agencies or
federal government-
sponsored enterprises (“Agency securities”), or foreign
governments; municipal securities; money market
mutual funds; certificates of deposit (“CDs”) (primary
or secondary); commercial paper;
• cash and cash equivalents;
• open-end mutual funds, closed-end funds, ETFs, UITs,
and CITs;
the need
for
• insurance company separate accounts and variable
annuities; and
• SMA services provided by investment managers.
A client may elect to have Baird provide an Asset
Allocation Review. This Service is designed to identify
investment portfolio options for the client, weighing risk
versus potential return on investment based upon the
client’s investment objectives, investment time horizon,
investment constraints,
investment
diversification, and risk tolerance. The client’s Baird
Consultant makes allocation recommendations to the
client after analyzing asset mixes as they correlate to
identified risk parameters, thereby assisting the client in
establishing reasonable investment return expectations.
in concentrated and
The client is responsible for ensuring that all relevant
information, including but not limited to, an investment
In some cases, Baird Consultants may recommend
investments
less diversified
portfolios of securities. They may also recommend
investments in illiquid securities and/or investments in
3
Baird ICS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment
strategies
Baird and the client’s Baird Consultant rely upon
information provided by the client and/or the client’s
custodians when performing a performance review. Baird
and Baird Consultants do not conduct a review of
valuation information provided by clients or third party
custodians, and they do not verify or guarantee the
accuracy of such information.
Consulting Services
(collectively,
“Complex
alternative
(“Alternative
Strategies”) or other non-traditional or complex
investment strategies that involve special risks not
apparent in more traditional investments like stocks and
bonds (collectively, “Complex Strategies”). Similarly,
Baird Consultants may recommend that clients invest in
non-traditional or real assets (“Non-Traditional Assets”).
Some Services also offer the ability to invest in
investment products that pursue Alternative Strategies
(“Alternative Investment Products”) or other Complex
Strategies
Investment
Products”).
Baird and Baird Consultants also make available the
additional Consulting Services for which neither Baird nor
a client’s Baird Consultant acts as a “fiduciary” under the
Adviser’s Act, ERISA, the IRC or any other applicable law
or regulation.
Plan Participant Education
Baird assumes no responsibility
for a manager’s
investment decisions, performance, compliance with
applicable laws or regulations, or for any other matters
involving or affecting the manager.
Periodic Performance Reviews
If a client elects to have Baird provide periodic
performance reviews, a client’s Baird Consultant will
provide the client with a written report on the client’s
Account’s performance as often as the client and the
Baird Consultant may from time to time mutually agree.
The client’s Baird Consultant typically performs a review
of the client’s asset allocation and provides an evaluation
of the historical performance of the client’s investments
by comparing the performance of those investments with
benchmark indices, which may be determined by the
client’s Baird Consultant or may be jointly determined by
the client and Baird Consultant.
If a client elects to have Baird provide plan participant
education, the client’s Baird Consultant, in cooperation
with the client’s plan provider, will offer general guidance
to the client in the development and implementation of
educational campaigns for plan participants. The general
education services provided by the client’s Baird
Consultant and the client’s plan provider may include, but
are not limited to, topics such as plan options, saving for
retirement, asset allocation, and the benefits of
diversification. The client’s Baird Consultant may also
work with the plan provider to distribute plan provider
educational materials to the client’s employees. A client
should understand that this service is limited to general
education only and that Baird does not provide
investment advice to retirement plan participants unless
Baird otherwise agrees in writing.
Plan Fee Review
A client should note that past performance does not
indicate or guarantee future results. None of Baird, its
associates or investment managers managing the client’s
Account promise or guarantee any level of investment
returns or that the client’s investment objective will be
achieved.
If a client elects to have Baird provide a plan fee review,
the client’s Baird Consultant will perform a fee analysis
which includes a review of costs incurred by the plan, the
benefits derived from payment for such services, and
compares them to industry costs and services. The
client’s Baird Consultant typically also summarizes the
results in writing, and provides those results to the client.
The client’s Baird Consultant’s analysis does not generally
consider fees and charges assessed to the client pursuant
to the client’s Consulting Agreement.
Plan Provider Review
The selection and use of benchmarks is not a promise or
guarantee that the performance of a client’s Account will
meet or exceed the stated benchmark. When the client
compares Account performance to the performance of a
market index, the client should recognize that a market
index merely reflects the performance of a list of
unmanaged securities included in the index and the index
performance does not take into account management
fees, execution costs, and other expenses related to
investing for a client’s Account. The securities included in
a client’s Account generally do not exactly mirror the
securities included in the index.
The benchmarks used by Baird with respect to a client’s
SMA may differ from the benchmarks used by the
manager of the client’s SMA. As a result, the performance
comparisons in Baird’s performance reports may differ
from reports provided to clients directly by the
investment manager for the client’s SMA.
If a client elects to have Baird provide a retirement plan
provider review, the client’s Baird Consultant will perform
an analysis of the client’s plan provider. This analysis
includes a review of services and benefits provided to the
client by the plan provider, as well as the costs incurred
to receive such services. The client’s Baird Consultant
typically also summarizes the results in writing and
provides those results to the client. The client’s Baird
Consultant relies upon information provided by the client
and third party sources to provide this Service. Baird and
Baird Consultants do not conduct a review of such
information, and they do not verify or guarantee the
accuracy of such information.
4
Baird ICS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Service Provider Request for Proposal
investing in alternative mutual funds, ETFs, hedge funds,
managed futures, private equity funds and SMAs
managed by third party managers.
Complex Strategies and Complex Investment
Products
If a client elects to have Baird provide a plan or other
service provider request for proposal (“RFP”) Service, the
client’s Baird Consultant will assist the client in preparing
RFP documents, identifying and distributing the RFP
documents to multiple service providers, and analyzing
their responses to the RFP. The client’s Baird Consultant
typically performs a cost-benefit analysis of the services
offered by each provider and the fees, summarizes the
results in writing, and provides those results to the client.
The client’s Baird Consultant relies upon information
provided by the client, RFP participants, and third party
sources to provide this Service. Baird and Baird
Consultants do not conduct a review of such information,
and they do not verify or guarantee the accuracy of such
information. A client should note that the client’s Baird
Consultant will solicit providers based solely on the
criteria the client has provided to the client’s Baird
Consultant.
Other Services
swaps, or
The client’s Baird Consultant may offer other consulting
Services specifically tailored for the client. Any such
Services will be set forth in the client’s Consulting
Agreement.
Strategies
and
Alternative Strategies or other Complex Strategies
involve special risks not apparent in more traditional
investments like stocks and bonds. Complex Strategies
may be pursued in multiple ways, including by investing
in alternative mutual funds, ETFs, hedge funds, managed
futures, private equity funds and SMAs managed by third
party managers. Some Complex Strategies invest in Non-
Traditional Assets, such as real estate, commodities
include metals, mining, energy and
(which may
agricultural products), currencies, movements
in
securities indices, credit spreads and interest rates, and
venture capital and buyout investments in private
companies. Some Complex Strategies engage in the use
of margin or leverage or selling securities short (“short
sales”). Some Complex Strategies invest in derivative
instruments such as options, convertible securities,
futures,
contracts. Complex
forward
Investment Products generally engage in one or more
information about
Complex Strategies. Additional
Alternative Strategies and Complex Strategies
is
contained under the heading “Methods of Analysis,
Investment Strategies and Risk of Loss—Investment
Strategies—Alternative
Complex
Strategies” below. Additional information about Complex
Strategies and Complex Investment Products, generally,
is provided below.
Non-Traditional Assets
investments
Limitations on the Services
A client may, pursuant to an arrangement with its
recordkeeper or other third party service provider or
otherwise, require Baird and a client’s Baird Consultant
provide the Services with respect to a limited universe of
potential investment options made available. A client
should understand that, if so restricted, Baird and a
client’s Baird Consultant will only provide the Services
with respect to those investment options made available.
When the availability of potential investment options is
limited or the use of certain investment options is
required, a client should note that: (i) any advice given
by Baird or a client’s Baird Consultant is inherently limited
by the options made available, (ii) Baird or a client’s Baird
Consultant may have provided different investment
advice had they not been limited to the investment
options made available, and (iii) certain investments,
such as mutual funds, may offer classes of shares with
lower or higher operating expenses that are not made
available.
Non-Traditional Assets, such as
in
commodities, currencies, securities indices, interest
rates, credit spreads, private companies, and digital
assets, such as cryptocurrencies, non-fungible tokens
(“NFTs”), stablecoins, and tokenized investment products
(collectively, “Digital Assets”) may be used
for
diversification purposes. They may also be used to try to
reduce market and inflation risk. The performance of
Non-Traditional Assets may not correspond to the
performance of the stock markets generally, and
investments in Non-Traditional Assets will generally
impact an Account’s returns differently than more
traditional investments like stocks or bonds. Non-
traditional assets are subject to risks that are different
from, and in some instances, greater than, other assets
like stocks and bonds. Non-traditional assets are
generally more difficult to value, less liquid, and subject
to greater volatility compared to stocks and bonds.
Unless Baird has otherwise agreed in writing, neither
Baird nor a client’s Baird Consultant may be listed as
broker of record for any of the DIAs selected for the
Participant-Directed Plan’s investment menu. Neither
Baird nor any of
its affiliates provide actuarial,
administrative or recordkeeping services to plans.
Margin and Leverage
Margin
Margin involves borrowing money from a firm to buy
securities or other property. Securities held in a client’s
margin account are used as the firm’s collateral for the
margin loan. The value of the collateral in the margin
account must be maintained at a certain level relative to
Additional Service Information
Baird and Baird Consultants may recommend a client
pursue Alternative Strategies or other Complex
Strategies that involve special risks not apparent in more
traditional investments like stocks and bonds. Complex
Strategies may be pursued in multiple ways, including by
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Baird ICS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Derivatives are also generally less liquid, and subject to
greater volatility compared to stocks and bonds.
Options
the margin loan for the duration of the loan. If the
securities in the margin account decline in value, so does
the value of the collateral supporting the margin loan,
and as a result, the firm may take action, such as issue a
margin call and sell securities in the account.
Leverage
Options transactions may involve the buying or writing of
puts or calls on securities. In some cases, a firm may
require clients to open a margin account to engage in
options trading.
Leverage generally attempts to obtain investment
exposure in excess of available assets through the use of
borrowings, short sales and other derivative instruments.
While leverage can potentially enhance returns, it can
also exacerbate losses if changes in the markets, or the
values of the investments subject to the leverage, are
adverse to the strategy being pursued. The use of
leverage may also increase an Account’s volatility.
Short Sales
With a call option, the purchaser has the right to buy, and
the seller (writer) the obligation to sell, the underlying
security or index at a predetermined price (i.e., the
exercise or strike price) prior to expiration of the option.
The premium paid to the seller (writer) for the option is
in consideration for the underlying obligations imposed
on the seller should the option be exercised. With a put
option, the purchaser has the right to sell, and the seller
has the obligation to buy, the underlying security or index
at the exercise price prior to expiration of the option.
Short selling attempts to benefit from an anticipated
decline in the market value of a security. To effect a short
sale, a client sells a security the client does not own.
When a client sells a security short, a firm borrows the
security from a lender and makes delivery to the buyer
on the client’s behalf. Because short sales involve an
extension of credit from the firm to the client, a client
must generally use a margin account. A client must also
eventually purchase the same shares sold short and
return them back to the lender. It is possible that the
prices of securities that a client sells short may increase
in value, in which case the client may lose money on the
short position. Short selling thus runs the risk of loss if
the price of the securities sold short does not decline
below the price at which they were originally sold. This
risk of loss is theoretically unlimited, as there is no cap
on the amount that the price of a security may
appreciate.
In buying a call option, the purchaser expects that the
market value of the underlying security or index will
appreciate, which would enable the purchaser of a call to
buy the underlying security or index at a strike price
lower than the prevailing market price. The purchaser of
the call option makes a profit if the prevailing market
price is greater than the sum of the strike price plus the
premium paid for the option. The seller of a call option
earns income in the form of the premium received from
the purchaser for the option and expects that the market
value of the underlying security or index will depreciate
such that the option will expire without being exercised.
The seller of a call option makes a profit if the prevailing
market price of the underlying security or index is less
than the sum of the strike price plus the premium
received.
Clients should note that investment managers managing
a client’s Account or investment products in the client’s
Account may also engage in short sales. Thus, a client’s
Account will be subject to short sales risks if the
investment manager managing the client’s Account or an
investment product in the client’s Account engages in
short sales.
Options and Other Derivative Instruments
Derivative Instruments
In buying a put option, the purchaser expects that the
market value of the underlying security or index will
depreciate, which would enable the purchaser of a put to
sell the underlying security or index at a strike price
higher than the prevailing market price. The purchaser of
the put option makes a profit if the prevailing market
price is less than the sum of the strike price and the
premium paid for the option. The seller of a put option
earns income in the form of the premium received from
the purchaser for the option and expects that the market
value of the underlying security or index will appreciate
such that the option will expire without being exercised.
The seller of a put option makes a profit if the prevailing
market price of the underlying security or index is greater
than the difference between the strike price and the
premium.
In purchasing a put or call option, the purchaser faces the
risk of loss of the premium paid for the option if the
market price moves in a direction opposite to what the
purchaser had expected. In selling or writing an option,
the seller faces significantly more risk. A seller of a call
option faces the risk of significant loss if the prevailing
Derivatives instruments, such as options, convertible
securities, futures, swaps, and forward contracts are
financial contracts that derive value based upon the value
of an underlying asset, such as a security, commodity,
currency, or index. Derivative instruments may be used
as a substitute for taking a position in the underlying
asset. Derivative instruments may also be used to try to
hedge or reduce exposure to other risks. They may also
be used to make speculative investments on the
movement of the value of an underlying asset. The use
of derivative instruments involves risks different from, or
possibly greater than, the risks associated with investing
directly in securities and other traditional investments.
Investing in derivatives also generally involves leverage.
6
Baird ICS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investing
in Complex
market price of the underlying security or index increases
above the strike price, and a seller of a put option faces
the risk of significant loss if the prevailing market price of
the underlying security or index decreased below the
strike price.
A client assumes responsibility for engaging in Complex
Strategies and
Investment
Products. If a client determines that the client no longer
wants to engage in those strategies or invest in those
products, the client is responsible for notifying the client’s
Baird Consultant and any investment manager managing
the client’s Account. Baird is not responsible for any
losses resulting from any third party manager’s failure or
delay in implementing any such instructions.
Trust Services Arrangements
Clients should note that investment managers managing
a client’s Account or investment products in the client’s
Account may also engage in options transactions. Thus,
a client’s Account will be subject to options risks if the
investment manager managing the client’s Account or an
investment product in the client’s Account engages in
options transactions.
Complex Investment Products
tax
reporting and
Investment Products
Complex Investment Products typically invest primarily in
Non-Traditional Assets or engage in one or more Complex
Strategies. Complex
include
Alternative Investment Products, such as hedge funds,
funds of hedge funds, private equity funds, funds of
private equity funds, private debt funds, and managed
futures, but also include other investments pursuing
Complex Strategies, including but not limited to exchange
or swap funds, leveraged funds, inverse funds, and other
special situation funds, structured certificates of deposit
and structured notes (“structured products”), ETNs,
business development companies (“BDCs”), REITs, and
master limited partnerships (“MLPs”).
In addition, a client should be aware that more traditional
investments, such as mutual funds, ETFs, UITs and
variable annuities may also pursue Alternative
Strategies, thereby making them Alternative Investment
Products. A client should carefully review the prospectus
or other offering document for each investment and
understand the strategy being pursued before deciding to
invest. More detailed information about mutual funds,
ETFs, UITs and variable annuities is available on Baird’s
website at bairdwealth.com/retailinvestor.
Additional Important Information
Baird maintains an alliance with certain institutions, both
including Baird Trust
non-affiliated and affiliated,
trust
provide
that
Trust”),
(“Baird
Company
administration services, including trust administration,
custody,
recordkeeping. Baird
Consultants at times refer clients seeking trust services
to institutions that are members of the alliance. Subject
to its fiduciary duties, the trustee oftentimes retains Baird
to provide investment advisory services to the client
trust. A client should understand that any such referral
for trust services under the Trust Alliance Program made
by Baird and its Baird Consultants is an ancillary account
service and it is not an, nor is it part of any, Advisory
Program or investment advisory service. They do not act
as investment adviser or a fiduciary to the client when
making such a referral and they will not provide advice
on or oversee any such trust services arrangement. Baird
has a financial incentive to recommend that clients use
Baird Trust, an affiliate, over other non-affiliated trust
companies. As a result of this affiliation, Baird Trust also
has a financial incentive to retain Baird to provide
investment advisory or other services on behalf of the
client. In addition, Baird and Baird Consultants have a
financial incentive to recommend arrangements that
involve Baird and the Baird Consultant providing
investment advisory services to the client and the trust
company only providing trust administration services
compared to an arrangement whereby a trust company
would provide both investment advisory and trust
administration services because it is more profitable to
Baird and the Baird Consultant.
In addition, outside of the Trust Alliance Program, Baird
Consultants may refer a client to Baird Trust to provide
investment advisory and trust administration services to
the client. If a client enters into such a relationship with
Baird Trust, Baird and the client’s Baird Consultant
typically provide ongoing relationship management
services. Baird Trust generally provides compensation to
Baird and the client’s Baird Consultant for the referral and
providing ongoing services, which may be up to 50% of
the ongoing fees that a client pays to Baird Trust, and
which is credited to the client’s Baird Consultant for
the Baird Consultant’s
purposes of determining
compensation. The compensation paid to Baird and a
client’s Baird Consultant does not increase the fees that
the client pays to Baird Trust. Due to Baird’s affiliation
with Baird Trust and the compensation paid to Baird and
Baird Consultants, Baird and Baird Consultants have a
The use of Complex Strategies or Complex Investment
Products is not appropriate for some clients because they
involve special risks. A client should not engage in those
strategies or invest in those products unless the client is
prepared to experience significant losses in the client’s
Account. This is especially true for short selling, which
can result in unlimited losses as there is no limit to the
amount borrowed securities can rise in value. See
“Methods of Analysis, Investment Strategies and Risk of
Loss—Principal Risks” below for more information. Before
using those types of strategies or products, a client is
strongly urged to discuss them with the client’s Baird
Consultant and any investment manager managing the
client’s Account. Additional information about Complex
Strategies and Complex Investment Products is provided
under the heading “Methods of Analysis, Investment
Strategies and Risk of Loss—Investment Strategies—
Alternative Strategies and Complex Strategies” below
and on Baird’s website at bairdwealth.com/retailinvestor.
7
Baird ICS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
financial incentive to favor Baird Trust over other trust
companies.
from other types of investments, including Schedule K-1
reporting.
Client Responsibilities
charitable or
taxable
income
(“UBTI”).
In
Clients with tax-exempt Accounts, such as certain
Retirement Accounts or
religious
organization Accounts, should be aware that some
investments, such as some Non-Traditional Assets,
Alternative Investments and Complex Investments, may
produce taxable income, referred to as unrelated
business
such
circumstances, such clients will be required to pay tax on
the UBTI produced by the tax-exempt Accounts.
tolerance,
financial circumstances,
investment goals and
A client’s ability to recognize losses in an Account for tax
purposes may be disallowed, limited or deferred by
applicable tax rules. For example, IRS wash sales rules
will disallow a client’s tax deductions for a loss in an
Account related to the sale of an investment if the client
purchases (whether through Baird or another firm) a
“substantially identical” investment within the wash sale
period (currently 30 days before or 30 days after the date
of the sale). Similarly, IRS straddle rules limit and defer
a client’s ability to claim tax deductions related to the loss
on a sale of an investment in an Account if the client holds
an offsetting position in any account held at Baird or
another firm.
A client is responsible for providing information to Baird
and the client’s Baird Consultant reasonably requested by
them in order to provide the services selected by the
client. Baird, the client’s Baird Consultant and investment
managers, if any, will rely on this information when
providing services to the client. A client is also responsible
for promptly informing the client’s Baird Consultant if
there is any change to the client’s investment objectives,
risk
investment
needs, or other circumstances, and, if the client is an
individual, if there are any significant life changes (e.g.,
change in marital status, significant health issue, or
change in employment), that may affect the manner in
which the client’s assets are invested. None of Baird, the
client’s Baird Consultant or any investment manager
managing a client’s Account is responsible for any
adverse consequence arising out of the client’s failure to
promptly inform the client’s Baird Consultant of any such
changes. Since
financial
circumstances change over time, a client should review
the client’s participation in a Service with the client’s
Baird Consultant at least annually.
Retirement Accounts
Additional laws, regulations and other conditions apply to
Retirement Accounts. Each owner, trustee, plan sponsor,
adopting employer, responsible plan fiduciary, named
fiduciary, or other fiduciary acting on behalf of a
Retirement Account (“Retirement Account Fiduciary”)
should understand that Baird Consultants and Baird do
not provide legal advice regarding Retirement Accounts.
A Retirement Account Fiduciary is urged to consult with
his or her own legal advisor about the laws and
regulations that may apply to Retirement Accounts.
ERISA and the IRC prohibit Baird Consultants and Baird
from offering certain types of investment products and
services to Retirement Accounts.
Baird and its associates do not offer legal or tax advice to
clients. The information, recommendations, and services
provided by Baird and its associates to clients through the
Services, including, without limitation, tax management
strategies, do not constitute tax advice. A client is
responsible for understanding the tax implications of the
investment activities in the client’s accounts (whether
held at Baird or another firm) and complying with
applicable tax rules. A client is strongly urged to consult
with the client’s tax advisor about potential tax
implications before making
investment or trading
decisions. Baird and its associates do not undertake any
responsibility to monitor or verify a client’s compliance
with applicable tax rules, and they are not responsible for
any tax‑related effects or obligations resulting from the
investments or transactions in a client’s Account.
Legal and Tax Considerations
A client’s investment activities may have legal and tax
consequences to the client.
Fees and Compensation
Advisory Fees
Fee Options and Fee Payments
liquidations,
redemptions, and
The investment strategies used for a client’s Account and
transactions in a client’s Account, including purchases,
rebalancing
sales,
transactions, may cause the client to realize gains or
losses for income tax purposes. Investment Funds often
make distributions of income and capital gains to
investors, which may cause the client to realize income
for tax purposes.
Baird generally offers four (4) fee alternatives for the
Services: (i) an asset-based Advisory Fee paid quarterly,
in advance, (ii) an asset-based Advisory Fee paid
quarterly, in arrears, (iii) an annual fixed rate Advisory
Fee that is paid by the client over four calendar quarters,
paid quarterly, in advance or (iv) a one-time fixed rate
Advisory Fee paid at the time that the Consulting
Agreement is accepted by Baird.
in such
Because the Services selected and the level of service
varies by client, Baird has no fee schedule for the
Services. The maximum annual rate for an asset-based
Certain
investment products, such as Alternative
Investments and Complex Investments, are classified as
partnerships. Clients
investment
invested
products will be treated as partners for U.S. federal
income tax purposes, which has tax implications different
8
Baird ICS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Advisory Fee charged by Baird for the Services is 1.00%
(100 basis points).
such agreement
Advisory Fee adjustments are not made during any
period because of appreciation or depreciation in the
client’s Account asset value during any billing period.
Baird, in its sole discretion, may make fee adjustments in
response to Account asset fluctuation resulting from
contributions to, or periodic withdrawals from, the client’s
Account.
If the asset-based Advisory Fee is elected, the client’s
initial billing period begins when the client signs the
Consulting Agreement and
is
subsequently accepted by Baird, or billing begins at a pre-
defined date that is mutually agreeable to Baird and the
client.
The minimum Account or household size is $10 million for
individuals and $25 million for institutional Accounts.
Baird, in its sole discretion, may waive the Account
minimum requirement.
The Advisory Fee and minimum Account value are
negotiable in certain instances and may vary based upon
a number of factors, including but not limited to the
client’s particular investment style or objective and any
particular services requested by the client. The fees paid
by a client may differ from the fees paid by other clients
based on a number of factors, including but not limited to
the factors identified above.
The initial asset-based Advisory Fee is based upon the
value of the assets in the client’s Account(s) as displayed
on a custodian’s quarterly statement on the day the
agreement is accepted by Baird or an agreed upon
effective date. The initial Advisory Fee may also be based
upon an estimated value of assets mutually agreed upon
by both parties. Thereafter, the applicable asset-based
quarterly Advisory Fee are calculated in accordance with
the client’s Account asset value as displayed on a
custodian’s quarterly statement as of the last business
day of the prior calendar quarter, such payment to be
made by the client to Baird on the first business day of
the then current quarter or upon receipt of a Baird
invoice.
Baird may increase a client’s Advisory Fee upon 30 days
written notice to the client.
Advisory Fee Payments to Baird and Baird
Consultants
Baird and its associates benefit from the Advisory Fees
and charges clients pay for the services described in this
Brochure.
Baird retains the entire Advisory Fee paid by clients.
Baird does not conduct a review of valuation information
provided by client’s custodian, and it does not verify or
guarantee the accuracy of such information. Baird does
not accept responsibility for valuations provided by third
parties that are inaccurate unless Baird has a reason to
believe that the source of such valuations is unreliable.
The prices obtained by Baird from a client’s custodian
may differ from prices that could be obtained from other
sources. Values used for fee-calculation purposes may
vary from prices received in actual transactions and are
not firm bids, offers or guarantees of any type with
respect to the value of assets in a client’s Account, and
the fee for some securities may be calculated based on
values that are greater than the amount a client would
receive if the securities were actually sold from the
client’s Account.
increases,
The annual and the one-time fixed rate Advisory Fee
options are negotiated at the time the Consulting
Agreement is signed by the client and accepted by Baird.
If the client elects the annual fixed rate Advisory Fee,
Baird will bill the client the quarterly amount of the annual
fixed rate Advisory Fee, in advance. Billing is adjusted for
the number of days remaining in the current calendar
quarter. The client receives an invoice from Baird
detailing the quarterly fee. The client must pay Baird
within fifteen (15) days after receipt of the bill.
coaching,
In the event that either Baird or the client terminates the
Consulting Agreement, the client shall receive a pro-rated
refund for amounts paid in advance for the period
including the date of termination through the end of the
applicable billing period.
A Baird Consultant is primarily compensated on a
monthly basis based upon a percentage of the Baird
Consultant’s
total production each month, which
primarily consists of the total advisory fees and
transaction-based fees paid to Baird by the Baird
Consultant’s clients and any other fees Baird earns on
advisory and brokerage accounts held by those clients,
including trail fees paid by third parties. The percentage
of the Baird Consultant’s total production actually paid to
the Baird Consultant will increase as the total amount of
the Baird Consultant’s production increases, meaning
that, as the total amount of the Baird Consultant’s
production
rate and amount of
the
compensation that Baird pays to the Baird Consultant
also increase. Baird Consultants generally also receive
deferred compensation or bonuses based on various
criteria, including net new assets they gather, performing
certain wealth management activities, such as financial
planning, and their total production
levels. Baird
Consultants who achieve certain production thresholds
are eligible for professional development conferences,
business development
reimbursements,
awards and recognition trips to attractive destinations.
Baird Consultants are also eligible for bonuses for
achievement of professional designations depending on a
Baird Consultant’s total production level. Thus, Baird
Consultants have a general incentive to generate
9
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
financial and other plans and charge higher fees for
advisory Accounts and recommend larger investments in
advisory Accounts.
financial
incentives provided
in the form of a forgivable loan from Baird to the Baird
Consultant. Under the terms of the forgivable loan, Baird
makes the upfront or installment payment to the Baird
Consultant in the form of a loan, and Baird forgives a
portion of the loan made to the Baird Consultant each
month for so long as the Baird Consultant remains Baird’s
employee. Should the Baird Consultant cease to be
Baird’s employee prior to the maturity date of the loan,
the Baird Consultant is required to repay Baird the
amount of the loan outstanding and not forgiven by Baird.
In other words, upon leaving Baird, the Baird Consultant
would be required to repay to Baird a portion of the
special compensation that the Baird Consultant had
received and that had not been forgiven. The amount of
such repayment declines over time in proportion to the
time the Baird Consultant remains Baird’s employee.
Structuring this special compensation in the form of
forgivable loans provides the Baird Consultant added
incentive to remain Baird’s employee and to recommend
that persons become and remain a Baird client. Additional
information about referral and non-cash compensation
and other
to Baird
Consultants is provided under the heading “Code of
Ethics, Participation or Interest in Client Transactions and
Personal Trading—Participation or Interest in Client
Transactions” below.
related
travel,
From time to time, Baird Financial Advisors outside of the
ICS Program may refer their clients to Baird Consultants.
In those instances, the Baird Consultant generally shares
a portion of his or her compensation with the referring
Baird Financial Advisor.
Given the structure of their compensation, they also have
an incentive to recommend that a client transfer the
client’s Accounts to Baird, establish new accounts with
Baird (including IRA rollovers) and add more money into
the client’s Accounts. In addition, most Baird Consultants
are shareholders of Baird Financial Group, Inc. (“BFG”),
Baird’s parent company, and thus benefit financially from
Baird’s overall success. The number of shares of BFG
stock that a Baird Consultant may purchase is based in
part on the Baird Consultant’s total production level.
Baird Consultants generally receive compensation for
referrals to certain affiliated managers and products and
for referrals to a limited number of other firms. More
specific information is provided under the headings
“Other Financial Industry Activities and Affiliations” and
“Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading—Participation or
Interest
in Client Transactions” below. They also
generally receive non-cash compensation and other
benefits from Baird and from sponsors of investment
products with which Baird does business. Such non-cash
compensation and other benefits may include invitations
to attend conferences or educational seminars, payment
of
lodging and meal expenses,
reimbursement for branch and client events, and receipt
of gifts and entertainment. Receipt of such compensation
and benefits provides Baird Consultants an incentive to
favor investment products and their sponsors that
provide the greatest levels of compensation and benefits.
Baird addresses the conflicts described above through
disclosure in this Brochure and by adopting internal
policies and procedures for Baird and its associates that
require them to provide investment advice that is suitable
for advisory clients (based upon the information provided
by such clients).
Other Fees and Expenses
The fees paid to Baird by the client only cover the
Services provided by Baird. The fees do not include any
fees that may be charged by investment managers
recommended by Baird. A client may also pay for other
services, such as custody and
trade execution,
separately, when implementing recommendations made
by Baird.
A client is responsible for bearing or paying, in addition
to the Advisory Fee, the costs of all:
• commissions, sales charges, markups, markdowns,
and spreads charged by broker-dealers that buy
securities from, or sell securities to, the client’s
Account (such costs may be inherently reflected in the
price the client pays or receives for such securities);
Baird Consultants generally receive recruitment bonuses
and/or special compensation from Baird when they join
Baird from another firm. The amount of such special
compensation is typically based on the Baird Consultant’s
production at the prior firm for the 1-year period prior to
joining Baird or on the level of the Baird Consultant’s
client assets at the prior firm. All or a substantial portion
of the special compensation is paid in the form of an
upfront bonus when the Baird Consultant joins Baird, and
the remaining portion, if any, is paid in the form of back
end bonuses generally in equal installments on an annual
basis thereafter for a certain number of years (generally
from one to three years). Installment payments are
generally contingent upon the Baird Consultant achieving
annual production or client asset levels that exceed a
significant percentage of the Baird Consultant’s annual
production for the 1-year period prior to joining Baird or
the client assets that the Baird Consultant had prior to
joining Baird. The special compensation is intended to
compensate Baird Consultants for the significant effort
involved in transitioning their business from the prior
firm. This compensation provides Baird Consultants who
have left another firm additional incentive to recommend
that clients of the prior firm become Baird clients and to
recommend investment products and services that
increase their production, and thus presents a conflict of
interest. The special compensation is generally structured
• underwriting discounts, dealer concessions or similar
fees related to the public offering of investment
products;
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• custody fees;
product, annuity or its sponsor may impose on the client.
A client should review the prospectus or other applicable
offering documents for each investment product or
annuity in which the client invests for further information.
• extra or special fees or expenses that may result from
the execution of odd lot trade orders (i.e., “odd-lot
differential”);
• electronic fund fees, wire transfer fees, fees for
transferring an investment between firms, and similar
fees or expenses related to Account transfers
(including any such fees imposed by Baird);
Clients may also subscribe to other services or programs
offered by Baird. Those service and programs may be
subject to fees, commissions or other expenses that are
entirely separate from the payment of fees and expenses
for the Service.
• currency conversions and transactions;
• securities conversions, including, without limitation,
the conversion of ADRs to or from foreign ordinary
shares;
• interest, fees and other costs related to margin
accounts, short sales and options trades;
• fees related to the establishment, administration or
termination of Retirement Accounts, retirement or
profit sharing plans, trusts or any other legal entity,
including, without limitation, the calculation and
payment of unrelated business income tax (“UBIT”);
• fees imposed by the SEC or securities markets,
including transaction fees imposed by electronic
trading platforms, which fees may be imbedded in the
price the client receives for the security; and
• taxes imposed upon or resulting from transactions
effected for a client’s Account, such as income, transfer
or transaction taxes, foreign stamp duties, or any other
costs or fees mandated by law or regulation.
If the client’s Account is custodied at Baird, the client is
also responsible for all applicable account fees and
service charges Baird may impose in connection with the
client’s agreements with Baird. A schedule of fees and
service charges is available on Baird’s website at
bairdwealth.com/retailinvestor.
and other
similar
Other Compensation Received by Baird
Baird is registered as a broker-dealer under the Securities
Exchange Act of 1934, as amended (the “Exchange Act”),
and its Financial Advisors, including Baird Consultants,
are registered broker-dealer representatives of Baird. In
such capacities, Baird and Baird Consultants provide
brokerage and related services to clients, including the
purchase and sale of individual stocks, bonds, mutual
funds, private investment funds, and other securities,
and sales of life insurance policies and annuities. Baird
and Baird Consultants receive compensation based upon
the sale of such securities and other investment products,
including asset-based sales charges and service fees on
the sale of mutual funds. This practice presents a conflict
of interest because it gives Baird and Baird Consultants
an incentive to use, select or recommend investment
products based upon the compensation received rather
than on a client’s needs. However, when providing
investment advisory services to clients, Baird and Baird
Consultants are fiduciaries and are required to act solely
in the best interest of clients. Baird addresses this conflict
through disclosure in this Brochure and by adopting
internal policies and procedures for Baird and its
associates that require them to provide investment
advice that is suitable for advisory clients (based upon
the information provided by such clients). For more
specific information about Baird’s compensation and
other benefit arrangements and how Baird addresses the
potential conflicts of interest, please see the sections
“Advisory Business” and “Fees and Compensation”
above, and “Other Financial Industry Activities and
Affiliations” and “Code of Ethics, Participation or Interest
in Client Transactions and Personal Trading” below.
fees, marketing
support
fees,
custody
fees,
Baird Consultants will recommend the purchase of,
various investment products, including “no load” mutual
fund or mutual funds with waived sales loads. A client has
the option to purchase investment products through
other brokers or agents that are not affiliated with Baird.
in
this Brochure
that are subject
Performance-Based Fees and Side-By-Side
Management
Baird advises client accounts not participating in services
described
to
performance-based fee arrangements. Performance-
based fee arrangements involve the payment of fees
based upon the capital gains or capital appreciation of a
client’s account. Any such fee arrangements are made in
compliance with applicable provisions of Rule 205-3
Certain investment products, such as mutual funds, ETFs,
closed-end
investments
funds, UITs, alternative
products,
investment pools
(collectively, “Investment Funds”) and annuities, have
their own internal fees and expenses that are borne either
directly or indirectly by their holders, including a client.
These fees and expenses may include investment
management fees, distribution (12b-1) fees, shareholder
servicing fees, transfer agency fees, networking fees,
payments,
accounting
expense
administration
reimbursements, and expenses associated with executing
securities transactions for the investment product’s
portfolio (“ongoing operating expenses”). These ongoing
operating expenses are separate from, and in addition to,
the Advisory Fees. As a result of making investments in
these types of products, a client should be aware that the
client is paying multiple layers of fees and expenses on
the amount of the client’s assets so invested—the
ongoing operating expenses and the Advisory Fee. A
client is also responsible for any redemption fees,
surrender charges or similar fees that the investment
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the Advisers Act. Performance-based
investment
styles, philosophies,
The
strategies,
techniques and methods of analysis that Baird PWM home
office investment professionals, its Baird Consultants and
investment managers use in formulating investment
advice for clients vary widely. A brief description of
commonly used strategies is provided below.
under
fee
arrangements present a potential conflict of interest for
Baird with respect to other client accounts that are not
subject to performance-based fee arrangements because
such arrangements give Baird an incentive to favor client
accounts subject to performance-based fees over client
accounts that are not subject to performance-based fees.
Equity Strategies
industry or
sector
Equity strategies generally have an objective to provide
growth of capital and primarily invest in equity securities,
such as common stocks. However, these strategies may
also invest in other types of investments, such as fixed
income securities and cash. Equity strategies may invest
in companies of all market capitalization ranges or may
focus on any combination of specific capitalization
ranges, such as large cap, mid cap or small cap
companies. Equity strategies may be combined with other
strategies described below, such as growth, value,
focused,
income, economic
international, global, or geographic region or country
focused strategies.
In addition to complying with its fiduciary duties by
disclosing this conflict of interest to clients through this
Brochure, Baird generally addresses potential conflicts of
interest posed by performance-based fee arrangements
by periodically monitoring the holdings and performance
of performance-based fee accounts and comparing them
to accounts not subject to a performance fee that are also
managed using a similar strategy in an attempt to detect
any possible inequitable treatment. Baird also attempts
to minimize potential conflicts of interest posed by
performance-based fee arrangements through internal
trade allocation procedures that are designed to make
securities allocations to discretionary client accounts in a
manner such that all such clients receive fair and
equitable treatment over time.
Fixed Income or Bond Strategies
trusts;
estates;
foundations
Types of Clients
Baird offers the Services to all types of current or
prospective clients, including, but not limited to: Plans,
including Participant-Directed Plans, pension plans and
profit sharing plans; family offices; banks or thrift
institutions;
and
endowments; charitable organizations; corporations or
other business entities;
sovereign nations and
individuals. Applicable requirements such as minimum
Account size, are discussed in the section entitled “Fees
and Compensation” above. Clients are not required to
open or maintain a trading account with Baird or an
affiliated broker-dealer or retain Baird or its affiliates to
serve as a client’s custodian to receive the Services.
Fixed income or bond strategies generally have one or
more of the following objectives: (1) provide current
income; or (2) preservation of capital. These strategies
primarily invest in fixed income securities, such as
corporate bonds, municipal securities, mortgage-backed
or asset-backed securities, or government or agency debt
obligations. However, these strategies may also invest in
other types of investments, such as equity securities or
cash. Fixed income strategies may invest in debt
obligations having any credit rating, maturity or duration,
or they may focus on specific credit ratings, maturities or
durations, such as investment grade, non-rated, or high
yield (“junk”) bonds, or bonds having short-term,
intermediate-term or long-term maturities. Fixed income
strategies may be combined with other strategies
described below, such as economic industry or sector
focused, international, global, or geographic region or
country focused strategies.
Balanced Strategies
investment
Balanced strategies generally have one or more of the
following objectives: (1) provide current income; (2)
growth of capital/principal or income; or (3) preservation
of capital. These strategies primarily invest in a mix of
equity, fixed income securities and cash. Balanced
strategies may invest in companies of all market
capitalization ranges and in investments having any
credit rating, maturity or duration, or they may focus on
specific capitalization ranges, credit ratings, maturities or
durations as described above. Balanced strategies may
be combined with other strategies described below, such
as economic industry or sector focused, international,
global, or geographic region or market
focused
strategies.
for approving any
Methods of Analysis, Investment Strategies
and Risk of Loss
Investment Strategies
In providing the Services, a Baird Consultant may use
strategies because
various different
strategies are customized for each client. If a client has
selected the Investment Policy Statement Creation or
Review Service, a client’s particular investment strategy
is typically jointly developed by the client and the client’s
Baird Consultant through a fact finding and analysis
process. Baird Consultants may also utilize the services
of Baird PWM’s home office investment professionals as a
part of that process. If a client does not select the
Investment Policy Statement Creation or Review Service,
the Baird Consultant will generally follow the investment
strategies set forth in the investment policy statement
provided to Baird by the client. A client is ultimately
responsible
investment policy
statement and determining the investment strategies to
be used.
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Value Strategies
Geographic Region or Country Focused Strategies
A value strategy typically invests primarily in equity
securities of value companies, which are those that the
investment manager believes are out of favor with
investors, appear underpriced by the market relative to
their earnings or intrinsic value, or have high dividend
yields. This strategy is subject to investment style risks.
Growth Strategies
Geographic region or country focused strategies primarily
invest in companies located a particular part of the world,
such as Latin America, Europe or Asia, in a group of
similarly-situated countries, such as developed or
emerging markets, or one or more specific countries.
These strategies alone generally are not intended to
satisfy a client’s entire portfolio diversification needs.
These strategies are subject to concentration risks
because they generally are not diversified or they may
invest in a limited number of securities.
Tactical and Rotation Strategies
A growth strategy typically invests primarily in equity
securities of growth companies, which are those that the
investment manager believes exhibit signs of above-
average growth relative to peers or the market, even if
the share price is high relative to earnings or intrinsic
value. This strategy is subject to investment style risks.
Income Strategies
An income strategy typically invests primarily in income-
producing securities, such as dividend-paying equity
securities and fixed income securities. This strategy may
invest in a combination of investment grade and high
yield bonds. This type of strategy may also invest in yield-
or income-producing, Non-Traditional Assets.
long-term
strategic
asset
Economic Industry or Sector Focused Strategies
Economic industry or sector focused strategies primarily
invest in companies in one or more economic industries
or sectors, such as the telecommunications, technology,
industrial, materials, or
financial sectors. These
strategies alone generally are not intended to satisfy a
client’s entire portfolio diversification needs. These
strategies are subject to concentration risks because they
generally are not diversified or they may invest in a
limited number of securities.
Tactical strategies typically tactically and actively adjust
Account allocations to different asset classes based upon
the manager’s perception of how those asset classes will
perform in the short-term. Similarly, rotation strategies
typically actively adjust Account allocations to different
market sectors based upon the manager’s perception of
how market sectors will perform in the short-term.
Tactical and rotation strategies are often driven by
technical analysis or methodologies and typically involve
underweighting and overweighting Account allocations to
certain asset classes or market sectors relative to an
applicable
allocation,
benchmark index or the market generally. These
strategies often will be focused or concentrated in one or
more asset classes or market sectors from time to time,
and it is likely that they will have limited or no exposure
to one or more asset classes or market sectors. For that
reason, tactical and rotation strategies are often subject
to concentration risk. Because the decision-making for
tactical and rotation strategies is based upon the
manager’s short-term market outlook, Accounts pursuing
these strategies often experience higher levels of trading
and portfolio turnover relative to other strategies.
International Strategies
Opportunity or Opportunistic Strategies
regions, credit
Generally, international strategies primarily invest in
securities issued by foreign companies, which may
include companies in developed and emerging markets.
International strategies may invest in companies of all
market capitalization ranges and in investments having
any credit rating, maturity or duration, or they may focus
on specific capitalization ranges, industries or sectors,
geographic
ratings, maturities or
durations.
Global Strategies
regions, credit
strategies
often
experience
Generally, global strategies invest in a mix of securities
issued by U.S. and foreign companies, which may include
companies in developed and emerging markets. Global
strategies may invest in companies of all market
capitalization ranges and in investments having any
credit rating, maturity or duration, or they may focus on
specific capitalization ranges, industries or sectors,
geographic
ratings, maturities or
durations.
Opportunity strategies will generally be invested in a
manner that seeks to provide long term growth through
capital appreciation and/or income by utilizing an active
management style that shifts the amount of investment
made in different asset classes and market sectors to
take advantage of the manager’s perception of market
pricing anomalies, those market or industry sectors
deemed favorable for investment by the manager, the
current interest rate environment and/or other macro-
economic trends identified by the manager. Opportunity
strategies often involve the use of other strategies,
particularly tactical or rotation strategies, and will have
the risks associated with those strategies. Opportunity
Strategies may also involve investment in a more-limited
number of companies compared to other strategies. As a
result, a decline in value of one or a few investments will
more adversely impact performance than if assets were
more evenly invested in a larger number of companies.
Opportunity
higher
fluctuations in annual returns and overall market value
than other strategies. The types of investments used to
implement opportunity strategies vary widely by
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
leverage and derivative
Non-Traditional
Assets,
Non-Traditional Assets,
instruments.
manager and could include equity securities, fixed income
securities,
Alternative
Investment Products and cash.
Tax Management Strategies
• Statistical Arbitrage Strategies. Statistical Arbitrage is
based on the theory that stocks have a tendency to
return to a short-term trend line. This type of strategy
typically involves the “systematic” or automated
trading of securities based upon where a security is
relative to its trend line.
• Convertible Arbitrage Strategies. Convertible arbitrage
involves the purchase and short sale of multiple
securities of the same company. The strategy is
implemented by purchasing securities believed to be
undervalued and selling short securities believed to be
overvalued. Often, the strategy involves the purchase
of a convertible bond issued by a company and selling
short that company’s common stock. This strategy may
involve the use of a wide range of derivative
instruments.
• Fixed Income Arbitrage Strategies. Fixed income
arbitrage strategies generally seek to profit from
interest rate, credit spread and other arbitrage
opportunities by investing in fixed income securities,
interest rate instruments and derivative instruments.
Tax management strategies involve buying and selling
investments in a manner intended to reduce the negative
impact of taxes. They often involve buying or selling
investments to limit taxable investment gains or to offset
taxable investment gains with investment losses or
selling investments to avoid recognition of taxable
investment gains. Tax management strategies are not
intended to, and likely will not, eliminate a client’s tax
obligations. A tax management strategy may not actually
lower a client’s tax obligations or otherwise achieve a
client’s tax goals. A tax management strategy is typically
a secondary strategy used to achieve a secondary tax
management objective and it is typically implemented
together with other primary investment strategies
designed to achieve primary investment objectives or
goals. The performance of accounts utilizing a tax
management strategy will vary from similarly-managed
accounts that do not utilize such a strategy, possibly in a
materially negative manner, and an account may not be
successful in pursuing its primary investment strategies,
objectives or goals.
Alternative Strategies and Complex Strategies
• Capital Structure Arbitrage Strategies. Capital
structure arbitrage generally involves investing in
multiple levels of a single company’s capital structure,
often taking long and short positions in a company’s
debt or equity in order to capitalize on perceived
mispricings resulting from market inefficiencies or
different pricing assumptions. This type of strategy
typically involves the use of derivatives and structured
products.
Alternative Strategies and other Complex Strategies may
invest in a wide range of investments, which may include
equity securities, fixed income securities, Non-Traditional
Assets, Alternative Investment Products and cash.
Alternative Strategies and other Complex Strategies
generally involve the use of margin, leverage, short sales
and derivative instruments. Many Alternative Strategies
and other Complex Strategies have no substantive
restrictions on the types of investments that may be
used. Examples of Alternative Strategies and other
Complex Strategies include the following.
• Absolute Return, Total Return and Real Return
Strategies. Absolute return, total return and real return
strategies generally involve the purchase of traditional
assets, such as stocks and bonds, and Non-Traditional
Assets in an attempt to generate performance that has
low correlation to the major equity markets over a
complete market cycle. They may also involve the use
of derivative instruments.
• Relative Value Strategies. Relative value strategies
generally involve the purchase of traditional assets,
such as stocks and bonds, and Non-Traditional Assets
and the use of short sales and derivative instruments
in an attempt to exploit price differences among
securities that share similar economic or financial
characteristics.
• Event-Driven Strategies. Event-driven strategies
generally involve the use of Non-Traditional Assets,
short sales and derivative instruments in an attempt to
seek arbitrage opportunities, particularly
those
triggered by corporate events (such as mergers,
restructurings, and liquidations). These strategies
typically involve the assessment of if, how and when
an announced transaction will be completed.
Assets,
leverage
and
• Long/Short Strategies. Long/short strategies generally
involve the purchase of securities believed to be
undervalued and selling short securities believed to be
overvalued. They may also involve the use of Non-
Traditional
derivative
instruments.
involved
leveraged
buy-outs,
restructurings
• Market Neutral Strategies. Market neutral strategies
generally involve the purchase of securities and selling
securities short in similar dollar amounts in an attempt
to produce returns that are independent of general
market performance. They may also involve the use of
• Merger Arbitrage/Special Situations Strategies. Merger
arbitrage strategies involve the purchase and sale of
securities of companies
in corporate
reorganizations and business combinations, such as
mergers, exchange offers, cash tender offers, spin-
offs,
and
liquidations. These strategies often involve short
selling, options trading, and the use of other derivative
instruments.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
o
• Distressed Strategies. Distressed strategies generally
involve the purchase of securities in companies that are
in financial distress, or companies that are entering
into or are already in bankruptcy. They may also
involve the use of short sales and derivative
instruments.
• Macro Strategies. Macro strategies generally involve
the purchase of traditional assets, such as stocks and
bonds, and Non-Traditional Assets and the use of short
sales and derivative instruments in an attempt to profit
from anticipated changes
in securities markets,
commodities markets, currency values, and/or interest
rates.
Private Real Estate Strategies. Private real estate
strategies invest in physical properties, such as
office buildings, apartments, retail centers, and
industrial facilities. These investments are typically
made through participation in private REITs.
Private real estate strategies may focus on specific
geographic regions, property types, or economic
sectors. Investments in private real estate can be
illiquid, meaning they may take time to sell or
refinance. Property values can fluctuate due to
market conditions, supply and demand, and other
factors. There are also risks related to tenant
vacancies, property damage, or environmental
hazards. Leverage is often used in private real
estate investments, which can increase potential
returns but also amplifies potential losses.
Infrastructure
Strategies.
o
• Discretionary and Systematic Trading Strategies.
Discretionary trading strategies generally attempt to
identify and capitalize on patterns or trends in the
markets. Systematic trading strategies generally rely
on computerized trading systems or models to identify
and capitalize on those patterns or trends. These
strategies often involve the use of Non-Traditional
Assets, short sales, derivative
instruments and
significant leverage.
• Private Investment Strategies.
in private
infrastructure
o
Private
Private
infrastructure strategies invest in infrastructure
projects and assets and may involve exposure to
a range of economic or market sectors, geographic
locations and asset
types. Examples of
infrastructure investments include, among others,
telecommunication, utilities, and transportation.
These investments are typically made through
participation
funds.
Investments in private infrastructure strategies
are often illiquid. They may focus on certain
sectors,
industries, geographic regions, size
ranges or stages of development or operations, or
on certain types and sizes of investments and may,
therefore, also lack diversification.
• Leveraged Strategies. Leveraged strategies generally
involve the use of Non-Traditional Assets, leverage,
short sales and derivative instruments in an attempt to
amplify returns or produce returns that are a multiple
of a benchmark index.
Private Equity Strategies. Private equity strategies
generally involve equity investments in companies
in private transactions. These investments are
typically made through participation in private
equity funds or funds of private equity funds.
Private equity strategies may invest in companies
of all market capitalization ranges or may focus on
any combination of specific capitalization ranges.
They may also focus on companies in one or more
economic industries or sectors or geographic
regions. Some private equity strategies focus on
companies that are newly formed, in financial
distress or already in bankruptcy. The securities
purchased are typically unregistered and illiquid.
Private equity strategies may also involve the use
of leverage.
• Inverse Strategies. Inverse strategies generally involve
the use of Non-Traditional Assets, leverage, short sales
and derivative instruments in an attempt to produce
returns that are the opposite of a benchmark index.
o
in private
are
typically made
Strategies
and
Alternative Strategies and other Complex Strategies are
not appropriate for some clients because they are subject
to special risks. See “Advisory Business—Other Service
Information—Complex
Complex
Investment Products” above and “Methods of Analysis,
Investment Strategies and Risk of Loss—Principal Risks—
Non-Traditional Assets and Alternative Strategies Risks”
below for more information.
Asset Allocation Strategies
Asset allocation strategies involve investing in one or
more of the following categories of assets:
• the equity securities asset category, which
Private Debt or Private Credit Strategies. Private
debt (also known as private credit) strategies
invest in loans or debt instruments issued by
transactions. These
companies
investments
through
participation in private debt funds or funds of
private debt funds. The investments involved are
typically unrated or rated below investment grade
and are illiquid. Oftentimes, the interest rate paid
by the companies is determined by a reference
interest rate, such as the federal funds rate, which
is periodically reset. These types of investments
are sometimes referred to as floating rate
corporate debt, floating rate loans or floating rate
bank loans. Private debt strategies often involve
the use of leverage and may involve investment in
smaller capitalization, distressed or bankrupt
companies.
is
comprised of certain asset classes, such as, equity
securities issued by: U.S. large cap growth companies;
U.S. large cap value companies; U.S. large cap core
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projections or assumptions. For more information about
Baird’s Capital Market Assumptions, a client should
contact the client’s Baird Consultant.
companies; U.S. mid cap growth companies; U.S. mid
cap value companies; U.S. mid cap core companies;
U.S. small cap growth companies; U.S. small cap value
companies; U.S. small cap core companies; foreign
companies located in developed markets; foreign
companies located in emerging markets; U.S. REITs;
and foreign REITs;
Methods of Analysis
Baird PWM home office investment professionals, and
Baird Consultants may use various forms of investment
analyses, including the following:
financial
• the fixed income securities asset category, which is
comprised of certain asset classes, such as: short-term
taxable bonds; intermediate term taxable bonds; long-
term taxable bonds; short-term tax-exempt bonds;
intermediate term tax-exempt bonds; long-term tax-
exempt bonds; high yield fixed income securities;
foreign fixed income securities; and broad fixed income
securities;
• Fundamental Analysis. Fundamental analysis involves
an approach to investing through a detailed analysis of
specific companies, such as their financial statements
and
ratios, management, competitive
advantages and markets, in an attempt to determine
the value of an investment. Fundamental analysis may
include qualitative and quantitative analyses.
• the Non-Traditional Assets category, which
is
comprised of certain asset classes, such as:
commodities and commodity-linked instruments; and
instruments, and
currencies and currency-linked
Digital Assets;
• Qualitative Analysis. Qualitative analysis involves the
use of subjective judgment to analyze factors that may
be difficult to quantify or measure objectively. As it
investment products,
pertains to managers and
qualitative analysis may
include review of the
background and experience of a manager or a mutual
fund company.
• the Alternative Investment Products category which is
comprised of certain asset classes, such as: hedge
funds, private equity funds and managed futures; and
• Quantitative Analysis. Quantitative analysis
• cash.
is a
method of evaluating securities by analyzing a large
amount of data through the use of algorithms or
models in an attempt to understand behavior, predict
market events, market prices, etc., and generate an
investment decision. As it pertains to managers and
investment products, quantitative analysis may include
review of manager performance, investment style,
style consistency, risk, and risk-adjusted performance.
• Technical Analysis. Technical analysis is a method of
analyzing past price and volume patterns and trends in
the trading markets to attempt to predict the direction
of both the overall market and specific investments.
Asset allocation strategies have varying investment
objectives, ranging from growth of capital to preservation
of capital. Asset allocation strategies also have varying
investment strategies. Some asset allocation strategies
use strategic investment strategies, which involve
investing Accounts in accordance with a predetermined
target allocation to different asset classes. Some asset
allocation strategies use tactical investing, which typically
involves
tactically and actively adjusting Account
allocations to different asset classes based upon the
manager’s perception of how those asset classes will
perform in the short-term. Some asset allocation
strategies involve the use of both strategic and tactical
investment strategies, sometimes referred to as dynamic
strategies.
• Top-Down Analysis. Top-down analysis involves a
consideration of certain macroeconomic trends, such
as general economic conditions, geographic or market
sector performance, fiscal and monetary policy, taxes,
or interest rates, to make investment decisions.
Asset allocation strategies may be implemented using a
variety of investment types, such as individual securities,
mutual funds and ETPs. The amount allocated to an asset
class or investment type varies by strategy, and some
strategies may have little or no allocation to one or more
asset classes or types of investments described above.
• Bottom-Up Analysis. Bottom-up analysis involves
consideration of factors particular to a particular
investment, such as business financials (e.g., balance
sheet strength and cash flows), financial ratios (e.g.,
price-to-earnings ratio), and business fundamentals
services
(e.g., management and product or
performance) to make investment decisions.
the
“Holdings-based
analysis”
If a client selects the Investment Due Diligence Services,
the Baird Consultant may perform a quantitative analysis
of the investment option’s performance coupled with a
investment option.
qualitative screening of
Quantitative analysis of some investments options may
be limited because a holdings-based analysis may not be
available.
determines
investment style by examining the actual securities held
in a portfolio, and is used as an alternative to returns-
Baird uses its Capital Market Assumptions in developing
its proprietary model asset allocation strategies, including
those used by some Baird Consultants. In determining its
Capital Market Assumptions, Baird conducts an analysis
of different asset classes and the different levels of risk
associated with those investments. That analysis involves
the consideration of past performance and the use of
forward-looking projections that are based upon certain
assumptions made by Baird about how markets will
perform in the future. There is no assurance that asset
classes or markets will perform in accordance with Baird’s
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
based style analysis, which is a method for determining
the style of an investment portfolio by analyzing its return
performance.
address the risks posed by AI Tools, which include
requirements that AI Tools pass a firm-level due diligence
process and that Baird associates obtain training and
independently verify AI Tool outputs. However, such
measures cannot eliminate the risks posed by AI Tools.
When providing investment advice to clients, Baird
Consultants utilize research reports and other research
material created by Baird PWM Research Groups, such as
PWM Equity Research, PWM Fixed Income Research, and
Asset Manager Research. Baird Consultants may also
utilize research reports created by Baird’s Institutional
Equities & Research Department. It should be noted that
Baird Consultants are not obligated to act in a manner
consistent with those research reports and they may act
in a manner that is contrary to those reports if they deem
it to be in the client’s best interest.
third party
When providing the Services, Baird Consultants may also
use the model portfolios or recommended or eligible
product lists (described below) made available by Baird’s
PWM Research Groups, or they may use investment
products that Baird has generally deemed to be
“available” for use in its advisory programs (“Available
Investment Products”). The level of initial and ongoing
evaluation, monitoring and review that Baird and its Baird
Consultants perform on managers and on investment
products varies. Available Investment Products generally
do not receive the same level of initial or ongoing
evaluation, monitoring or review by Baird as those
managers or products that are included in a model
portfolio or on a recommended or eligible product list. As
a result, Available Investment Products are subject to
certain risks. See “Methods of Analysis, Investment
Strategies and Risk of Loss—Principal Risks—Available
Investment Product Risks” below for more information.
to be generally
Baird PWM Research Groups and Baird Consultants use
tools when
information and
various
sources of
investment advice. The
formulating
information and tools may include, among others,
information provided or created by issuers and their
sponsors (which may include information that is reported
publicly, provided directly to Baird, or reported through
third party platforms) and information and tools provided
by third party research firms, which may include firms
affiliated with Baird. Although Baird has deemed the
information and tools provided by third party research
firms
reliable, Baird does not
independently verify or guarantee the accuracy of the
information or tools used.
list, are those which,
More specific information about Baird PWM model
portfolios, recommended lists and eligible product lists is
provided below. A client should note that investment
products recommended to the client or selected for the
client’s Account, including investment managers or
products included on a Baird PWM recommended or
eligible product
in Baird’s
professional judgment, may be appropriate to help the
client pursue the client’s financial goals. Baird and its
Baird Consultants do not represent or guarantee that
such investment managers or products are or will be the
best investment managers or products available.
Under certain circumstances when requested by a client,
Baird may allow a client to select an investment product
that is not on a Baird recommended or eligible product
list or that does not qualify as an Available Investment
Product. A client should note that Baird does not provide
any initial or ongoing evaluation, monitoring or review of
any such managers or investment products and that the
client’s decision to select such a manager or investment
product is based solely upon the client’s review of the
manager or investment product.
Baird PWM home office investment professionals and
Baird Consultants may use artificial intelligence (“AI”)
tools, such as machine learning, predictive analytics and
tools, data processing and
probabilistic modeling
automation tools, generative AI tools, visual, speech and
audio tools, specialized domain tools, and other similar
technologies and tools (collectively, “AI Tools”), in
formulating investment advice. Generally, the use of AI
Tools is limited to certain aspects of Baird’s investment-
advice process, such as assisting with drafting of
materials, automation of workflow processes, and the
compilation, reproduction, organization, summarization,
analysis and interpretation of information. The use of AI
Tools is only supportive of Baird’s investment-advice
process and does not replace the professional judgment
of Baird PWM home office investment professionals or
Baird Consultants. All AI Tool-assisted outputs used in
formulating investment advice are subject to human
review before such outputs inform recommendations or
investment decisions.
Baird Consultants may use a wide variety of investment
products to implement the client’s investment strategy,
which investments are further described under “Advisory
Business—Description of Services” above. Baird
Consultants may also engage in certain strategies and
use certain investments that involve special, sometimes
significant, risks. See “Advisory Business—Description of
Services” above for more information.
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations, deceptive
behaviors and other flaws due to the construction of their
underlying models and the composition of their training
data, which can result in outputs that seem plausible but
are in fact inaccurate, incomplete, or misleading. The use
of AI Tools creates a risk that erroneous information could
negatively influence the investment-advice process.
Baird has established policies and procedures designed to
A client should ask the client’s Baird Consultant for
additional information about the investment styles,
philosophies, strategies, analyses and techniques the
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird Consultant will use in order to meet the client’s
objectives.
in industry sector weighting. The Portfolio is intended as
a long-term investment strategy.
Certain PWM-Managed Portfolios
AQA Portfolios
Baird Recommended Portfolio
top–down
in company or
The Baird Recommended Portfolio, which is managed by
Baird’s PWM Equity Research team, seeks to outperform
the S&P 500 Index by investing in a diversified core
portfolio of 35–50 stocks. The portfolio invests primarily
in stocks with market capitalization greater than or equal
to $10 billion (large cap). The portfolio may also contain
stocks with market caps below $10 billion but these
stocks generally will not represent more than 35% of the
investment
team’s
total portfolio. The
approach begins with macroeconomic and market
outlooks from Baird’s Investment Strategy team. This
information is used to underweight or overweight
particular industry sectors compared to the S&P 500
Index. Individual stocks are selected with an emphasis on
higher quality companies that the team believes have
strong fundamental characteristics and management
teams, attractive growth prospects, and reasonable
price-appreciation expectations. Each stock selected is
assigned a weighting as a percentage of the portfolio. No
single company stock will comprise more than the greater
of 5% of the portfolio or 1.5 times the stock’s market
weight in the S&P 500 index; provided that a stock will
not be removed due to capital appreciation. Stocks can
be sold or positions reduced for a variety of reasons such
as valuation, a change
industry
fundamentals, or a change in industry sector weighting.
The Portfolio is intended as a long-term investment
strategy.
Baird Rising Dividend Portfolio
Baird makes available to clients certain Automated
Quantitative Analysis (“AQA”) Portfolios, which are
managed by Baird’s PWM Equity Research team. AQA is
an analytical tool that seeks to identify stocks of
companies that are undervalued by calculating the
intrinsic values for the stocks and comparing the
calculated values to current market prices. Focusing on a
company’s past financial performance, AQA analyzes
fundamental ratios and trends of the most recent eight-
year history of a company and each company in its peer
group, excluding estimates of future balance sheet and
income statement performance. The analysis
is
quantitative and ignores certain qualitative information
such as company-specific material news and events.
Stocks are ranked from the most undervalued to the most
overvalued based on the difference between the values
calculated by AQA and current market prices. The stocks
identified by AQA as being the most undervalued are then
selected for investment. Baird offers the following four
(4) AQA Portfolio strategies, each of which invest in
undervalued stocks identified using AQA, excluding
securities
insurance
issued by banks, REITS and
companies: (1) the AQA All Cap Strategy, which primarily
invests in stocks across market capitalizations, generally
those included in the S&P 500®, S&P MidCap 400® or
S&P SmallCap 600® Indices; (2) the AQA Large Cap
Strategy, which primarily invests in large cap stocks,
generally those included in the S&P 500® Index; (3) the
AQA Mid Cap Strategy, which primarily invests in mid cap
stocks, generally those included in the S&P MidCap 400®
Index; and (4) the AQA Small Cap Strategy, which
primarily invests in small cap stocks, generally those
included in the S&P SmallCap 600® Index.
Certain Recommended Lists
Baird’s Recommended Managers List
companies
strong
When selecting managers and their strategies (“BRM
Strategies”) for Baird’s Recommended Managers List,
Baird often seeks registered investment advisory firms
having portfolio managers with academic credentials
such as a master’s degree or participation or completion
of the Chartered Financial Analyst (“CFA”) program. Baird
also typically looks for a portfolio manager with greater
than three (3) years of investment experience focusing
on the particular investment style that is offered by the
portfolio manager. Baird generally looks for portfolio
managers that have demonstrated success, that have
performance histories showing sufficient ability to
achieve returns in excess of their respective benchmarks,
and that have investment processes, infrastructure,
personnel and other resources satisfactory to Baird. Baird
also considers other qualitative and quantitative factors.
to changes
The Baird Rising Dividend Portfolio, which is managed by
Baird’s PWM Equity Research team, seeks to provide a
core equity strategy with a portfolio yield above that of
the S&P 500 Index. The team’s top–down investment
approach begins with macroeconomic and market
outlooks from Baird’s Investment Strategy team. The 30–
50 stocks in the portfolio are primarily large cap stocks—
as defined by a market capitalization of $10 billion or
greater at the time of investment—and all are above $5
billion at the time of investment. The team looks for
quality
fundamental
with
characteristics and management, attractive dividend
yields, and the ability to increase their dividends.
Companies are screened for dividend history and
consistency, earnings growth expectations, and balance
sheet quality. Each stock selected is assigned a weighting
as a percentage of the portfolio. No single company stock
will comprise more than the greater of 5% of the portfolio
or 1.5 times the stock’s market weight in the S&P 500
index; provided that a stock will not be removed due to
capital appreciation. A position can be reduced or
removed due
in valuation, company
fundamentals or the perceived ability to continue to raise
its dividend in the future—among a variety of other
potential reasons for portfolio changes including a change
Baird’s Asset Manager Research Department is primarily
responsible for selecting and evaluating investment
managers included on Baird’s Recommended Managers
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List. In selecting investment managers, Baird’s Asset
Manager Research Department utilizes quantitative and
qualitative measures to evaluate managers based on the:
• quality and stability of their organization
• soundness and clarity of their investment philosophy
• reliability and consistency of their investment process
• competitiveness of their investment performance
Baird’s Asset Manager Research Department may also
employ the use of computers and third party software to
more readily display information and assist with the
evaluation and analysis.
factors: stability of the
Baird’s initial screening process begins with a proprietary,
multi-factor model that evaluates managers on different
factors including risk-adjusted performance, consistency
of returns and downside protection. These factors are
scored over various time periods and relative to a specific
peer group universe, narrowing the pool of managers for
further evaluation. Baird’s Asset Manager Research
Department then performs a more in-depth evaluation of
managers that are identified through the initial screening
process, which generally includes a review of the
following
firm/team, the
robustness and repeatability of the investment process,
the portfolio’s past returns pattern and tax-efficiency,
and how the manager adds value. The final determination
of Baird’s Recommended Managers List is subject to the
approval of Baird’s Investment Committee.
for
inclusion
to
select affiliated
funds
classes. When selecting funds for inclusion on the List,
Baird generally seeks funds that have investment
managers with tenure of at least three (3) years and have
underlying investments that adhere to the fund’s
market capitalization policy and are consistent with the
manager’s stated investment process and philosophy.
Baird generally looks for funds that are among the top-
performing funds in a style category in terms of risk-
adjusted returns or that are managed by individuals or
firms that have demonstrated success in other, related
asset classes; that have performance histories showing
sufficient ability to achieve returns in excess of their
respective style index; and that have investment
processes, infrastructure, personnel and other resources
satisfactory to Baird. Baird’s Asset Manager Research
Department is primarily responsible for assisting with
selecting and evaluating funds included on the List. In
selecting
funds, Baird’s Asset Manager Research
Department utilizes a quantitative and qualitative
evaluation process of the investment managers of such
funds. The process Baird uses for selecting and removing
funds for the Baird Recommended Fund List is similar to
the process Baird uses to select and remove BRM
Strategies described under “Baird’s Recommended
Managers List” above. Baird’s Investment Committee is
ultimately responsible for selecting funds included on the
List. The Baird Ultra Short Bond Fund, Baird Short-Term
Bond Fund, Baird Aggregate Bond Fund, Baird Quality
Intermediate Municipal Bond Fund, Baird Core
Intermediate Municipal Bond Fund, and Baird Mid Cap
Growth Fund, mutual funds affiliated with Baird, have
been selected by Baird
in Baird’s
Recommended Mutual Fund List. This presents a conflict
of interest. However, the criteria used by Baird in
for Baird’s
deciding
Recommended Mutual Fund List are the same as those
used for unaffiliated funds.
Baird’s Recommended Funds of Hedge Fund List
Ongoing manager evaluation generally includes quarterly
conference calls, performance attribution and periodic
onsite visits. Material adverse changes affecting a
manager may result in the manager being placed on
“watch” status. Managers on watch status are scrutinized
to see if improvement or degradation is taking place.
Potential causes for removal from Baird’s Recommended
Managers List include fundamental changes in the
operations of the manager, turnover in key personnel,
substantial changes in management or ownership, a
change in investment philosophy or style, significant drift
from stated objectives, major legal, regulatory or
compliance difficulties, impairment of financial condition,
sustained underperformance in relation to its peers, or
other adverse changes affecting the manager that in
Baird’s opinion warrants the manager’s removal.
Baird’s Recommended Funds of Hedge Fund List may
contain several types of funds of hedge funds (“FOHFs”)
that pursue various Alternative Strategies or other
Complex Strategies. Some FOHFs primarily use credit-
oriented investment strategies, which Baird classifies as
fixed income diversifiers. Some FOHFs primarily use
equity-oriented investment strategies and are classified
as equity diversifiers. Other FOHFs use a combination of
credit- and equity-oriented strategies, which Baird views
as balanced diversifiers. In certain circumstances, FOHFs
may be an appropriate substitute for part of a client’s
allocation to traditional high yield fixed income or equity
investments.
Certain SMA strategies offered by Baird Equity Asset
Management have been selected by Baird for inclusion on
Baird’s Recommended Managers List. This presents a
conflict of interest. However, the criteria used by Baird in
deciding to select Associated SMA Strategies for Baird’s
Recommended Managers List are the same as those used
for unassociated SMA strategies.
Baird’s Recommended Mutual Fund List
To be added to Baird’s Recommended FOHF List, a FOHF
must generally meet the following requirements: the
investment advisor to the FOHF is registered as an
Investment Adviser under Advisers Act; the fund has
stable
to growing assets under management as
determined by Baird; principals of the fund have an
appropriate level of hedge fund management experience
and a sufficient network of contacts in the industry as
Baird’s Recommended Mutual Fund List is designed to
include mutual funds and ETFs across numerous asset
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
However, Baird will terminate a FOHF from the List if it
believes the issue is likely to be long-term and adversely
affect the FOHF’s future performance.
Baird’s Recommended Private Funds List
Private
Funds”),
including
determined by Baird; in Baird’s opinion, the fund has
adequate diversification by number of hedge funds and
type of hedge fund strategy; effective risk management
programs have been established for the fund; and service
providers to the fund (e.g., auditor, administrator, and
legal counsel) are deemed to be reputable in the
judgment of Baird. Baird also seeks FOHFs that it believes
possess one or more unique attributes that may lead to
favorable performance relative to their peers going
forward.
Baird maintains lists of recommended private Funds
(“Recommended
a
Recommended Funds of Private Equity Funds List, a
Recommended Private Debt Fund List, and a
Recommended Private Real Assets Fund List.
as
subscription
documentation,
Baird’s Recommended Funds of Private Equity Funds List
contains funds of private equity funds that pursue certain
Alternative Strategies or other Complex Strategies. These
strategies can include buyout, growth equity, venture
capital, special situations or distressed investments. The
investments are typically structured in the form of
primary funds, secondary funds or co-investments. Most
will be to “middle market” companies, many of which
have above average to high levels of leverage, or debt
relative to equity. In certain circumstances, funds of
private equity funds may be an appropriate substitute for
part of a client’s allocation to traditional equity
investments.
Before adding a prospective FOHF to the List, Baird’s
Asset Manager Research Department conducts an in-
depth due diligence process. The process begins with a
review of the FOHF’s responses to a due diligence
questionnaire and of marketing and legal documents
(such
investor
agreements, and offering memorandum, organizational
documents, and the investment advisor’s Form ADV Part
2A Brochures). This is followed by an onsite review,
where Baird meets with one or more principals and
analysts to assess how the FOHF identifies, hires,
monitors, and terminates individual hedge funds. Baird
also evaluates how the FOHF constructs its hedge fund
portfolio and manages risk. At the conclusion of the onsite
review, an investment thesis is presented to and
discussed with a Baird Investment Committee. The
Committee votes on whether to add the FOHF to Baird’s
Recommended Funds of Hedge Fund List. In making that
determination, the Committee considers the information
presented, taking into account the merits of the individual
FOHF, how that FOHF compares to other FOHFs that Baird
offers, and the level of expected demand for the
particular FOHF.
Baird’s Recommended Private Debt Fund List contains
private debt funds (also known as private credit funds)
that pursue certain Alternative Strategies or other
Complex Strategies. The private debt funds on Baird’s
Private Debt Funds List generally make first lien, second
lien and unsecured loans, primarily to middle market
companies sponsored by private equity firms. In certain
circumstances, private debt funds may be an appropriate
substitute for part of a client’s allocation to traditional
high yield fixed income or equity investments.
After a FOHF is added to Baird’s Recommended Funds of
Hedge Fund List, it is monitored each quarter, and
subsequent onsite reviews periodically take place. As part
of its quarterly monitoring, Baird evaluates a FOHF’s
assets under management and flows (subscriptions and
redemptions), organizational changes (e.g., personnel
changes or new offerings), recent changes made to the
FOHF portfolio (e.g., hedge funds added or removed),
and reasons for performance differences between the
FOHF and its benchmark. Subsequent onsite reviews are
similar in nature and scope to the initial on-site review.
Baird’s Recommended Private Real Assets Fund List
contains private real estate and private infrastructure
funds that pursue certain Alternative Strategies or other
Complex Strategies. These strategies invest in different
real assets and may involve exposure to a range of
economic or market sectors, geographic locations and
asset types. Examples of investments may include,
among others, real estate, telecommunication, utilities,
and transportation. The investments may be structured
in the form of asset ownership or leasing or include direct
investment in or joint ventures with companies that
control infrastructure assets. In certain circumstances,
private real assets funds may be an appropriate
substitute for part of a client’s allocation to traditional
fixed income or equity investments.
To be added to a Baird Recommended Private Fund List,
a fund must generally meet the following requirements:
the investment advisor to the fund is registered under the
Advisers Act ; the fund has stable to growing assets under
management as determined by Baird; principals of the
fund have an appropriate level of applicable experience
and a sufficient network of contacts in the industry as
determined by Baird; effective risk management
Baird may place a FOHF on “Watch” status if it has
experienced a material event that, in Baird’s opinion, may
negatively affect the FOHF’s performance going forward
or possibly lead to the departure of an important
member(s) of the FOHF. Examples include a large decline
in assets under management, high rate of redemptions,
notable change in the investment or compliance teams,
weakening performance, or regulatory problems. Any
firm that is placed on “watch” status is evaluated more
closely to determine if the problem is likely to be
temporary or long-term, and whether it can be remedied.
Baird will remove a FOHF from “watch” status and return
it to active status if, in Baird’s opinion, the problem has
been or is in process of being adequately addressed.
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to
fund
Private Fund List if it believes the issue is likely to be long-
term and adversely affect the fund’s future performance.
Certain Eligible Product Lists
Certain Eligible Product Lists
Baird’s ETF Focus List
programs have been established for the fund; and the
service providers
(e.g., auditor,
the
administrator, and legal counsel) are deemed to be
reputable in the judgment of Baird. Baird also seeks funds
that it believes possess one or more unique attributes
that may lead to favorable performance relative to their
peers going forward.
fund makes
Baird’s ETF Focus List is designed to encompass
numerous asset classes and varied
investment
objectives. Baird generally seeks to include ETPs,
primarily ETFs, with transparent, experienced sponsors
that have stable or growing assets under management
and have demonstrated consistent strategy performance
over time. Baird tends to favor ETPs that have well-
known, diversified benchmark indices, lower fees and
tracking errors, and higher trading liquidity relative to
other ETPs. Inclusion on or exclusion from the Baird ETF
Focus List
is not meant to be a buy or sell
recommendation. Rather, the List is a collection of ETPs
that may be appropriate to meet particular client
investment goals.
PWM Stock Opportunities List
Before adding a prospective fund to a Recommended
Private Fund List, Baird’s Asset Manager Research
Department conducts an in-depth due diligence process.
The process begins with a review of the fund’s responses
to a due diligence questionnaire (known as a DDQ or RFI)
and of marketing and legal documents (such as,
investor agreements,
subscription documentation,
offering memorandum, organizational documents, and
the investment advisor’s Form ADV Part 2A Brochures).
This is followed by an onsite review, where Baird meets
with one or more principals and analysts to assess how
investment decisions. Baird also
the
evaluates how the fund constructs its portfolio and
manages risk. In addition, Baird may undertake a brief
review of the fund’s third-party service providers. At the
conclusion of the onsite review, an investment thesis is
presented to and discussed with a Baird Investment
Committee. The Committee votes on whether to add the
fund to a Baird Recommended Private Fund List. In
making that determination, the Committee considers the
information presented, taking into account the merits of
the individual fund, how that fund compares to other
similar funds that Baird offers, and the level of expected
demand for that particular fund.
The PWM Stock Opportunities List is comprised of stocks
that Baird’s PWM Equity Research team believes offer
timely investment opportunities based on market, sector,
and fundamental analysis. Stocks on the list must be
covered by Baird, Evercore ISI, or Morningstar and are
screened to curb near-term fundamental risk. The List
focuses on large cap and mid/small cap companies,
investments with yield, and speculative investment
opportunities.
Structured Products
When determining whether to make a structured product
available to Baird clients, Baird reviews the offering
documents for the structured product and considers: the
size of the issuer and issuer’s credit rating, the maturity
of the product, how interest is calculated, the underlying
asset category (e.g., a basket of securities or currencies
or a market index), applicable caps, barriers, and
participation rate, and whether the structured product
has principal protection.
After a fund is added to a Baird Recommended Private
Fund List, it is monitored each quarter, and subsequent
onsite reviews periodically take place. As part of its
quarterly monitoring, Baird evaluates a fund’s assets
under management and fund flows (subscriptions and
redemptions), organizational changes (e.g., personnel
changes or new offerings), recent changes made to the
portfolio, and reasons for performance differences
between the fund and its benchmark. Subsequent onsite
reviews are similar in nature and scope to the initial on-
site review.
Baird tends to favor larger-sized issuers of structured
products over smaller-sized issuers and also tends to
favor structured products that have shorter maturities,
less complex payout structures, underlying assets that
are more liquid or transparent, and offer full or partial
principal protection. If a product does not offer full
principal protection, Baird also considers how much
principal is exposed to loss, whether, in Baird’s judgment,
there is reasonable risk/reward trade-off for that
exposure, as well as the events that could trigger loss of
principal and Baird’s belief as to the likelihood of the
occurrence of such events.
Baird’s Investment Solutions Department is primarily
responsible for selecting and evaluating structured
products made available to clients under the Services.
Baird may place a Recommended Private Fund on “watch”
status if it has experienced a material event that, in
Baird’s opinion, may negatively affect the
fund’s
performance going forward or possibly lead to the
departure of an important member(s) of the fund’s
investment team. Examples include a large decline in
assets under management, high rate of redemptions,
notable change in the investment or compliance teams,
weakening performance, or regulatory problems. Any
fund that is placed on “watch” status is evaluated more
closely to determine if the problem is likely to be
temporary or long-term, and whether it can be remedied.
Baird will remove a fund from “watch” status and return
it to active status if, in Baird’s opinion, the problem has
been or is in process of being adequately addressed.
However, Baird will remove a fund from a Recommended
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Activities and Affiliations—Certain Relationships and
Arrangements—Baird and Associated Parties” below.
Baird Trust Strategies
Baird’s Alternative
Investment Committee, which
includes members of Baird’s Investment Solutions, Asset
Manager Research, Compliance, Legal, and Risk
Management Departments, ultimately determines
whether to make a structured product available to Baird
clients.
Available Hedge Funds
Baird makes available to clients five (5) portfolio
strategies developed and maintained by Baird Trust
(“Baird Trust Strategies”) described below. The Baird
Trust Strategies invest in a mix of equity securities and
ETFs.
(1)
The Baird Trust Large Cap Equity strategy
invests in a fairly concentrated portfolio of large cap
equity securities. This strategy is intended for clients
seeking investment in large cap companies as one part of
their overall asset allocation. This strategy is generally
not intended to be a complete investment program.
Baird makes hedge funds available to clients in certain
Programs sponsored by, affiliated with or offered by
Capital Integration Systems LLC or CAIS Capital LLC
(“CAIS”). An independent third-party research firm
provides research and due diligence materials to Baird on
the hedge funds available on the CAIS platform
(“Available Hedge Funds”). Clients interested in an
Available Hedge Fund or invested in an Available Hedge
Fund may obtain additional information from Baird upon
request. Clients should note that Baird solely relies upon
the independent third-party research firm to provide an
independent analysis of each Available Hedge Fund, Baird
does not conduct its own research or due diligence on any
Available Hedge Fund, and Baird does not verify the
accuracy of the information contained in the research and
due diligence materials.
(2)
The Baird Trust Core + Satellite 100 strategy is
a diversified portfolio with a 100% target equity
allocation. The strategy uses the Baird Trust Large Cap
Equity strategy as the core allocation of the portfolio
while providing exposure to satellite asset classes (such
as mid cap and small cap companies) through the use of
ETFs that principally invest in equity securities. This
model does not include fixed income.
Available Private Funds
(3)
The Baird Trust Core + Satellite 70/30 strategy
utilizes the Baird Trust Large Cap Equity strategy as the
core allocation of the portfolio while providing exposure
to satellite asset classes (such as mid cap and small cap
companies) and fixed income securities through the use
of ETFs that principally invest in equity securities and
fixed income securities. This strategy has a target
allocation of 70% of its assets to equity securities and
30% of its assets to fixed income securities.
(4)
The Baird Trust Core + Satellite 50/50 strategy
utilizes the Baird Trust Large Cap Equity strategy as the
core allocation portion of the portfolio while providing
exposure to satellite asset classes (such as mid cap and
small cap companies) and fixed income securities through
the use of ETFs that principally invest in equity securities
and fixed income securities. This strategy has a target
allocation of 50% of its assets to equity securities and
50% of its assets to fixed income securities.
In addition to Recommended Private Funds, Baird makes
available to clients in certain Programs other private
funds sponsored by, affiliated with, or offered by CAIS
(“Available Private Funds”), including Available Private
Equity Funds, Available Private Debt Funds, Available
Private REITs and Available Private Infrastructure Funds.
When determining whether to make a fund an Available
Private Fund, Baird utilizes the services of an independent
third-party research firm that provides research and due
diligence materials to Baird on the private funds available
on the CAIS platform. Clients interested in an Available
Private Fund or invested in an Available Private Fund may
obtain those research and due diligence materials from
Baird upon request. Clients should note that Baird solely
relies upon the independent third-party research firm to
provide an independent analysis of each Available Private
Fund, Baird does not conduct its own research or due
diligence on any Available Private Fund, and Baird does
not verify the accuracy of the information contained in
the research and due diligence materials.
Affiliated Private Equity Funds
(5)
The Baird Trust Equity Income strategy primarily
invests in dividend paying companies that Baird Trust
believes have the ability to consistently grow their
dividend at attractive rates over the long‑term.
In addition to Recommended Funds of Private Equity
Funds and Available Private Equity Funds, Baird makes
available to clients private equity funds that are affiliated
with Baird (“Affiliated Private Equity Funds”). Baird does
not subject Affiliated Private Equity Funds to the criteria
imposed upon Recommended Funds of Private Equity
Funds or Available Private Equity Funds described above
when making them available to clients, and Baird does
not perform any evaluation, monitoring or review of
Affiliated Private Equity Funds. This presents a potential
conflict of interest. See “Other Financial Industry
Principal Risks
Risk is inherent in any investment product and Baird does
not guarantee any level of return on a client’s
investments. There is no assurance that a client’s
investment objectives will be achieved, and a client could
lose all or a portion of the amount invested. Baird’s
recommendations are based in part upon the use of
forward-looking projections, which in turn are based upon
certain assumptions about how markets will perform in
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horizon and risk tolerance. A client should inform the
client’s Baird Consultant of these considerations so the
Baird Consultant can assist in determining the client’s
investment objectives and asset allocation strategies.
investment style or strategy, and
Conflicts of Interest Risks. Issuers, advisors or other
sponsors of investment products or their affiliates may
engage in business practices that conflict with the
interests of investors. Among other things, these
business practices can have a negative impact on the
market price of the investment product. Clients are
encouraged to review the prospectus or other disclosure
document for the investment product and also discuss
with their Baird Consultant the conflicts of interest risks
that may apply to them.
the future. There can be no guarantee that markets will
perform in the manner assumed and the actual
performance of markets and a client’s Account could
differ materially from those assumptions. Also, a client’s
Account value may fluctuate, sometimes dramatically,
depending upon the nature of the client’s investments,
market conditions and other factors. By investing, a client
may be subject to certain risks, including, but not limited
to the risks described below. The risks discussed below
the
vary by
investments in the client’s Account, and each risk may or
may not apply to a client. Clients should not pursue a
strategy or invest in an investment product unless they
are prepared to accept the associated risks. Clients are
encouraged to discuss with their Baird Consultant the
risks that apply to them. A client should also review the
prospectus or other disclosure document for any security
or other investment product in which the client invests,
as it will contain important information about the risks
associated with investing in such security or other
investment product.
Stock Market Risks. Equity security prices vary and
may
fall, thus reducing the value of a client’s
investments. Certain stocks selected for a client’s
Account may decline in value more than the overall stock
market.
Investment Risk Information
General risks of investing include the following:
Equity Securities Risks. Equity securities may
experience sudden, unpredictable drops in value or long
periods of decline in value. This may occur because of
factors that affect the securities markets in general, such
as adverse changes in economic conditions, the general
outlook for corporate earnings, interest rates or investor
sentiment. Equity securities may also lose value because
of factors affecting an entire industry or sector, such as
increases in production costs, or factors directly related
to a specific company, such as decisions made by its
management.
Market Risks. A client’s Account may change in value
due to overall market fluctuations. General economic
conditions, political developments, international events
and other factors may cause the overall market to
decline, which in turn may reduce the value of the client’s
Account regardless of the relative strength of the
securities held in the Account. Securities prices often vary
for reasons unrelated to matters directly affecting the
issuers of the securities.
Management and Securities Selection Risks. A
client’s Account may fluctuate in value differently than,
or in the opposite direction as, the overall market or
applicable benchmark because of the selection of
individual securities for the Account. The judgments
made by the persons managing client Accounts about the
attractiveness, value and potential appreciation of
particular securities may prove to be incorrect. For
example, while the stock markets may experience
increases in value, the client’s Account may experience a
decline in value due to the underperformance of the
stocks selected for investment in the client’s Account.
Common Stock Risks. Common stocks are susceptible
to general stock market fluctuations and to volatile
increases and decreases in value as market confidence in
and perceptions of their issuers change. These investor
perceptions are based on various and unpredictable
factors including: expectations regarding government,
economic, monetary and fiscal policies; inflation and
interest rates; economic expansion or contraction; and
global or regional political, economic and banking crises.
Holders of common stocks are generally subject to
greater risk than holders of preferred stocks and debt
obligations of the same
issuer because common
stockholders generally have inferior rights to receive
payments from issuers in comparison with the rights of
preferred stockholders, bondholders and other creditors.
Fixed-Income Security Risks. Fixed income securities
are subject to certain risks, including interest rate risk,
credit risk and liquidity risk. In addition, they are subject
to maturity risk. Generally, the longer a bond’s maturity,
the greater the interest rate risk and the higher its yield.
Conversely, the shorter a bond’s maturity, the lower the
interest rate risk and the lower its yield. Non-rated, split-
rated, below
investment grade, and asset-backed
securities, including mortgage-backed securities and
CMOs, have additional, special risks.
Investment Objective and Asset Allocation Risks. A
investment objective and asset allocation
client’s
strategies involve the risk that certain asset classes
selected for the client’s Account may not perform as well
as other asset classes during varying periods. In addition,
clients who pursue more aggressive
investment
objectives and asset allocation strategies, while hoping to
achieve high returns, may face greater risk of loss than
clients with more conservative objectives and strategies.
In developing investment objectives and asset allocation
strategies, clients should carefully consider their financial
situation and needs, investment goals, investment time
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Interest Rate Risk. The value of some investment
products, particularly fixed income securities, is affected
significantly by changes in interest rates. Generally, when
interest rates rise, the product’s market value declines
and when interest rates decline, its market value rises.
In addition, a rise in interest rates may have a negative
impact on the issuer, which, in turn, could have a
negative impact on the market value of the investment
product.
overall transaction costs. In addition, fluctuations in the
U.S. dollar’s value versus other currencies may enhance,
erode, reverse gains or widen losses from investments
denominated in foreign currencies. For instance, foreign
governments may limit or prevent investors from
transferring their capital out of a country. This may affect
the value of a client’s investment in the country that
adopts such currency controls. Exchange rate fluctuations
also may impair an issuer’s ability to repay U.S. dollar
denominated debt, thereby increasing the credit risk of
such debt. In addition, there may be less publicly
available information about a foreign company than
about a domestic company. Foreign companies generally
are not subject to uniform accounting, auditing and
financial reporting standards comparable to those
applicable to domestic companies. With respect to certain
foreign countries, there is a possibility of expropriation or
confiscatory taxation, or diplomatic developments, which
could affect investment in those countries.
political
stability, market
Emerging Markets Risks. Investments in emerging
markets can involve risks in addition to and greater than
those generally associated with investing in more
developed foreign markets. The extent of economic
depth,
development,
infrastructure, capitalization, and regulatory oversight
can be less than in more developed markets. Emerging
market economies can be subject to greater social,
economic, regulatory, and political uncertainties. All of
these factors can make emerging market securities more
volatile and potentially less liquid than securities issued
in more developed markets.
Security,
Cybersecurity
Credit Risk. The value of some investment products,
particularly fixed income securities, is affected by
changes in the product’s credit quality rating or the
issuer’s financial condition. If the credit quality rating or
the issuer’s financial condition declines, so may the value
of the investment product. Issuers may experience
unanticipated financial problems and may be unable to
meet its payment obligations. Municipal obligations in
particular may be adversely affected by political and
economic conditions and developments (for example,
legislation reducing state aid to local governments.)
Bonds receiving the lowest investment grade rating or a
non-investment grade rating may have speculative
characteristics and, compared to higher grade debt
obligations, may have a weakened capacity to make
principal and interest payments due to changes in
economic conditions or other adverse circumstances.
Ratings agencies such as Moody’s, Fitch and S&P provide
ratings on bonds based on their analyses of information
they deem relevant. Ratings are essentially opinions or
judgments of the credit quality of an issuer and may
prove to be inaccurate. In addition, there may be a delay
between events or circumstances adversely affecting the
ability of an issuer to pay interest and/or repay principal
and an agency’s decision to downgrade a security.
incidents
technology‑related
could
compromise
impact on the
Capitalization Size Risks. A client may be invested in
small and mid cap stocks, which are often more volatile
and less liquid than investments in larger companies. The
frequency and volume of trading in securities of such
companies may be substantially less than is typical of
larger companies. Therefore, the securities of such
companies may be subject to greater and more abrupt
price fluctuations. In addition, small- and mid-size
companies may lack the management experience,
financial resources and product diversification of larger
companies, making them more susceptible to market
pressures and business failure.
in
financial
losses, business
Information
and
Technology-Related Risks. As issuers and their service
providers increasingly rely on digital technologies, such
as the Internet, cloud computing, and AI‑enabled
systems, they face heightened information security,
risks,
cybersecurity, and other
the
that
including
confidentiality, integrity, or availability of their systems,
data, or technology infrastructure. Technology-related
incidents may result from deliberate adversarial actions
(such as cyber attacks) or unintentional events (such as
systems or human error) and could have a materially
adverse
issuer’s performance and
operations. Such incidents may involve unauthorized
access, disclosure, use, corruption, degradation, or
destruction of systems or data (such as through hacking,
malware, social engineering or theft of digital devices);
or the disruption of systems access to authorized users
(such as through denial of service attacks). Such events
can impede critical functions, compromise sensitive
business and protected customer information, and may
interruptions,
result
impediments to the ability to process transactions,
breaches of applicable privacy, data protection, or other
laws, regulatory fines or penalties, reputational harm,
reimbursement or other remediation costs, and increased
compliance or operational expenses. Substantial costs
may be incurred to prevent, detect, investigate, or
Foreign Issuer and Investment Risks. Securities of
foreign
issuers, ADRs, Global Depositary Receipts
(“GDRs”) and European Depositary Receipts (“EDRs”),
and investments in foreign markets generally, are subject
to certain inherent risks, such as political or economic
instability of the country of issue, the difficulty of
predicting international trade patterns and the possibility
of imposition of exchange controls. Such securities may
also be subject to greater fluctuations in price than
securities of domestic corporations. Investors in foreign
markets may face delayed settlements, currency controls
and adverse economic developments as well as higher
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
rise
Public
concerns
regarding
protected
to
information, potentially giving
intellectual property infringement claims and substantial
damages.
fairness,
transparency, and responsible use of AI may reduce
demand for an issuer’s products or services. Failure to
use AI responsibly may harm an issuer’s reputation and
competitive position.
brokers-dealers,
banks,
remediate future technology related incidents. Issuers’
increasing use of AI systems introduces additional risks
discussed in the section titled “Artificial Intelligence
Risks” below. Issuers may also rely on third party or cloud
based platforms that present their own information
security, cybersecurity, and other technology‑related
risks. Similar adverse consequences may arise from
technology related incidents affecting governmental
authorities, regulatory bodies, financial market systems,
insurance
exchanges,
companies, plan providers, recordkeepers and other
custodians, or other market participants. Although
issuers and their service providers may adopt business
continuity plans, information security controls, and risk
management programs designed to prevent or mitigate
such incidents, these measures are subject to inherent
limitations, including the possibility that certain risks may
not be identified or fully addressed. As a result, client
Accounts and investments may be negatively affected.
Government Obligation Risks. Client assets may be
invested in securities issued, sponsored or guaranteed by
the U.S. Government, its agencies and instrumentalities.
However, no assurance can be given that the U.S.
Government will provide financial support to U.S.
Government-sponsored agencies or instrumentalities
where it is not obligated to do so by law. For instance,
securities issued by the Government National Mortgage
Association (“Ginnie Mae”) are supported by the full faith
and credit of the United States. Securities issued by the
Federal National Mortgage Association (“Fannie Mae”)
and the Federal Home Loan Mortgage Corporation
(“Freddie Mac”) have historically been supported only by
the discretionary authority of the U.S. Government. While
the U.S. Government provides financial support to
various U.S. Government-sponsored agencies and
listed above, no
instrumentalities, such as those
assurance can be given that it will always do so.
involve
Artificial Intelligence Risks. Issuers of investments
increasingly use AI systems in various aspects of their
business operations, creating competitive market
pressures to increase the development and use of AI
systems. Failure to effectively develop or use AI systems
may place an issuer at a competitive disadvantage. At the
same time, AI systems present significant risks that could
materially affect an issuer’s business and financial
performance. AI Tools rely on complex models, large
datasets, and evolving algorithms. AI Tools are highly-
useful but complex and fallible systems that can exhibit
bias, hallucinations, deceptive behaviors and other flaws
due to the construction of their underlying models and
the composition of their training data, which can result in
outputs that seem plausible but are in fact inaccurate,
incomplete, or misleading. The use of erroneous outputs
can undermine customer trust and expose issuers to
litigation, regulatory scrutiny, substantial remediation
costs, and reputational harm. AI tools require timely
access to high‑quality, compliant data, and any disruption
in data availability can impair or disable AI Tool
functionality. Issuers often rely on third-party AI
systems, infrastructure, and data, which can create
vendor dependency, limit visibility into and validation of
AI model performance, and increase the risk of disruption
in data availability. The regulatory environment for AI is
rapidly evolving and may
inconsistent or
conflicting requirements across jurisdictions. Compliance
may require significant investment, changes to AI
systems, or the discontinuation of certain AI‑enabled
features. Non‑compliance may lead to fines, enforcement
actions, or operational constraints. AI systems are
vulnerable to cyberattacks or other adversarial actions
that can impair system performance and integrity and
compromise sensitive business and protected customer
information. The impairment of AI systems or the
unauthorized disclosure of sensitive business or protected
information can result in material disruption and damage
to business operations, significant legal and regulatory
liabilities, substantial
remediation expenses, and
reputational harm. AI systems may inadvertently use
Money Market Fund Risks. A money market fund is a
type of mutual fund that generally invests in short-term
debt instruments. Many investors use money market
funds to store cash. There are three primary types of
money market funds: (1) government money market
funds (funds that invest nearly all assets in cash,
government securities, and/or repurchase agreements
collateralized by cash or government securities); (2)
retail money market funds (funds that have policies and
procedures reasonably designed to limit beneficial
ownership to natural persons); and (3) institutional
money market funds (funds that permit beneficial
ownership by institutions and natural persons). The rules
governing money market funds vary based on the type of
money market fund. Government and retail money
market funds generally try to keep their net asset value
(NAV) at a stable $1.00 per share using special pricing
and valuation conventions. Institutional money market
funds are required to calculate their NAV in a manner
such that the NAV will vary based upon the market value
of assets and liabilities of the fund (also known as a
“floating NAV”). An investment in a money market fund
is not insured or guaranteed by the FDIC or any other
government agency. Although some money market funds
seek to preserve the value of an investment at $1.00 per
share, there can be no assurance that will occur, and it is
possible to lose money should the fund value per share
fall. In some circumstances, money market funds may be
forced to cease operations when the value of a fund
drops. In that event, the fund's holdings may be
liquidated and distributed to the fund's shareholders. This
liquidation process could take time to complete. During
that time, the amounts a client has invested in the money
market fund would not be available for purchases or
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redemption gates)
in
return of the portfolio. High portfolio turnover may also
cause a client to experience adverse tax consequences
due to the fact that the client may have increased
instances of realized gains and losses and such gains and
losses may commonly be characterized as short term
gains and losses under applicable tax law.
it will
withdrawals. In addition, retail and institutional money
market funds are required to impose redemption fees
(also known as liquidity fees) and suspend redemptions
certain
(also known as
circumstances. Government money market funds may
also impose redemption fees and suspend redemptions in
those same circumstances. More specific information
about how a money market fund calculates its NAV and
the circumstances under which
impose a
redemption fee or suspend redemptions is set forth in the
prospectus for that money market fund.
regulatory changes applicable
to
Asset-Backed
Asset-backed
Securities Risks.
securities are securities secured or backed by mortgage
loans, student loans, automobile loans, installment sale
contracts, credit card receivables or other assets and are
issued by entities such as commercial banks, trusts,
financial companies, finance subsidiaries of industrial
companies, savings and loan associations, mortgage
banks and investment banks. These securities represent
interests in pools of assets in which periodic payments of
interest or principal on the securities are made, thus, in
effect passing through periodic payments made by the
individual borrowers on the assets that underlie the
securities, net of any fees paid to the issuer or guarantor
of the securities. Asset-backed securities are issued in
multiple classes (or tranches) and their relative payment
rights may be structured in many ways. Asset-backed
securities may be subject to greater risk of default during
periods of economic downturn than other instruments.
Asset-backed securities also can be more sensitive to
interest rate risk than other types of fixed income
securities. Modest movements in interest rates (both
increases and decreases) may quickly and significantly
reduce the value of certain types of these securities.
Asset-backed securities are subject to a number of other
risks, including, but not limited to, market and valuation
risks, liquidity risk, and prepayment risk.
Illiquid Securities and Liquidity Risks. Liquidity risk
is the risk that certain investments may be difficult or
impossible to sell at the time and price that a client would
like to sell. Clients may have to lower the price, sell other
investments or forego an investment opportunity, any of
which may have a negative effect on the management or
performance of client Accounts. The liquidity of a
particular investment depends on the strength of demand
for the investment, which is generally related to the
willingness of broker-dealers to make a market for the
investment as well as the interest of other investors to
buy the
investment. During periods of economic
uncertainty, significant economic and market downturns
and periods in which financial services firms are unable
to commit capital to make a market in, or otherwise buy,
certain investments, a client may experience challenges
in selling such investments at optimal prices. In addition,
financial
recent
intermediaries that make markets in debt securities have
restricted or made it less desirable for those financial
intermediaries to hold large inventories of debt securities.
Because market makers provide stability to a market
through their intermediary services, a reduction in dealer
inventories may lead to decreased liquidity and increased
volatility in the fixed income markets.
Concentration Risks. A client’s Account may consist of
a portfolio of securities that is concentrated in an issuer
or group of issuers, an industry or economic sector or
group of related industries or sectors, or concentrated in
limited asset classes. Client Accounts with concentrated
positions are susceptible to greater volatility and
increased risk of loss than an Account that is diversified
across several issuers and industries or sectors and asset
classes. A client should not engage in strategies using
concentration unless the client is prepared to experience
significant losses in the value of the client’s Account.
Non-Rated, Split-Rated, and Below Investment
Grade Securities (High Yield or “Junk” Bonds)
Risks. Investing in securities or other investment
products that are not rated, split-rated or are below
investment grade (also known as high yield or “junk”
bonds) involve significant, special risks. As a result, they
may not be suitable for some clients. The risks associated
with these investments include, but not limited to, price
volatility risk, credit risk, default risk, and liquidity risk.
Clients investing in securities or other investment
products that are not rated, split-rated or are below
investment grade should have a high tolerance for risk,
including the willingness and ability to accept significant
price volatility, potential lack of liquidity and potential
loss of their investment.
Frequent Trading and Portfolio Turnover Risks.
Some of the investment strategies offered to clients in
this Brochure may involve frequent or active trading for
client Accounts, which could result in high portfolio
turnover. Strategies that involve frequent or active
trading increase the management and securities selection
risks because the persons managing the Accounts are
making more trading decisions, which may prove to be
incorrect. A portfolio with a high turnover rate will also
incur more transaction costs than one with a lower rate.
Higher transaction costs may negatively impact the
Mutual Fund Risks. Mutual funds can have many
different investment objectives and strategies, including
equity, fixed income, balanced, international, and global
strategies, and strategies that focus on a particular
investment style, economic
market capitalization,
industry or sector, or geographic region. Mutual funds
have risks, which may include market risk, management
and securities selection risk, investment objective and
asset allocation risk, stock market risk, equity securities
risk, common stock risk, fixed income securities risk,
interest rate risk, credit risk, capitalization risk,
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risk, foreign issuer and investment risk, and emerging
market risk. Certain ETFs pursue Complex Strategies,
which are subject to special risks. The degree of these
and other risks will vary depending on the type of ETF
selected.
investment style risk, foreign issuer and investment risk,
and emerging market risk. Certain mutual funds pursue
Complex Strategies, which are subject to special risks.
The degree of these and other risks will vary depending
on the type of mutual fund selected. Also, investment
return and principal value will fluctuate, and shares, when
redeemed, may be worth more or less than their original
cost.
inspection by
Collective Investment Trust Risks. Collective
investment trusts (CITs) are pooled investment vehicles
similar to mutual funds available to qualified investors,
typically through retirement plans. Like mutual funds,
CITs can have many different investment objectives and
strategies that present similar risks, which may include
market risk, management and securities selection risk,
investment objective and asset allocation risk, stock
market risk, equity securities risk, common stock risk,
fixed income securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign issuer
and investment risk, and emerging market risk. Certain
UITs may pursue Complex Strategies, which are subject
to special risks. The degree of these and other risks will
vary depending on the type of CIT selected. Also,
investment return and principal value will fluctuate, and
shares, when redeemed, may be worth more or less than
their original cost. CITs are not subject to the Investment
Company Act of 1940, as amended, and are not subject
to
the Securities and Exchange
Commission. CITs do not trade on an exchange and
provide less transparency when compared with mutual
funds.
Closed-End Fund Risks. Unlike mutual funds which
continuously offer and redeem their shares on a daily
basis at net asset value, closed-end funds typically raise
money by selling a fixed number of shares of common
stock in a single, one-time offering, much the way a
company issues stock in an initial public offering. Closed-
end funds can have many different investment objectives
and strategies, including equity, fixed income, balanced,
international, and global strategies, and strategies that
focus on a particular market capitalization, investment
style, economic industry or sector, or geographic region.
Closed-end fund shares are not redeemable, meaning
that investors cannot require closed-end funds to buy
back their shares, although closed-end fund shares are
listed and traded on an exchange. For many reasons,
closed-end fund shares often trade at a discount to their
net asset value and the market prices of closed end fund
shares often fall below their public offering prices. Clients
are therefore cautioned about buying shares of a closed-
end fund in its initial public offering. Closed-end funds
often engage in leverage to raise additional capital for
purposes of making investments through borrowings and
issuances of senior securities (such as preferred stock).
Such leverage may present the opportunity to enhance
potential returns but also involve the risk of exacerbating
losses and depreciation in the value of the underlying
securities. Closed-end funds have other risks, which may
include market risk, management and securities selection
risk, investment objective and asset allocation risk, stock
market risk, equity securities risk, common stock risk,
fixed income securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign issuer
and investment risk, and emerging market risk. Certain
closed-end funds pursue Complex Strategies, which are
subject to special risks. Some closed-end funds are
organized as interval funds, which differ from traditional
closed-end funds in that their shares do not trade on the
secondary market, but instead their shares are subject to
repurchase offers from the fund. Closed-end funds
structured as an interval fund will, therefore be relatively
less liquid. Interval funds also often impose a redemption
fee when shares are sold back to the fund. The degree of
these and other risks will vary depending on the type of
close-end fund selected.
income, balanced,
Exchange Traded Fund Risks. An ETF is different from
a mutual fund in that an ETF does not sell its shares
directly to public investors and does not redeem shares
from public investors. Rather, shares of an ETF are
commonly purchased or sold in the secondary market on
a securities exchange, like common stocks. An ETF
maintains a net asset value but, based on demand and
other factors, the market price of shares of an ETF may
vary from its net asset value. ETFs invest in and hold
securities and other assets, such as stocks, bonds,
commodities and currencies, and have stated investment
objectives and principal strategies. ETFs can have many
different investment objectives and strategies, including
equity, fixed income, balanced, international, and global
strategies, and strategies that focus on a particular
market capitalization,
investment style, economic
industry or sector, or geographic region. Many ETFs seek
to track the performance of an index or other underlying
benchmark. Passively managed ETFs will not be able to
replicate exactly the performance of the indices the ETFs
track because the total return generated by the securities
will be reduced by management fees, transaction costs
and other expenses incurred by the ETF. ETFs have other
risks, which may include market risk, management and
securities selection risk, investment objective and asset
allocation risk, stock market risk, equity securities risk,
common stock risk, fixed income securities risk, interest
rate risk, credit risk, capitalization risk, investment style
Unit Investment Trust Risks. A UIT is a pooled
investment vehicle in which a portfolio of securities is
selected by the sponsor and deposited into the trust for
a specified period of time. The portfolio of a UIT is
designed to follow an investment objective over a
specified time period, although there is no guarantee that
the objective will be met. UITs can have many different
investment objectives and strategies, including equity,
fixed
international, and global
strategies, and strategies that focus on a particular
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
broader market may not agree with the manager’s
assessment of, or recognize, the investments’ intrinsic
value.
ESG Considerations Risk. Consideration of ESG factors
in the investment process may cause an advisor or
manager to forgo opportunities to recommend or invest
in certain companies or to gain exposure to certain
industries or regions. Therefore, there is a risk that,
under certain market conditions, an Account pursuing
strategies that consider ESG factors may underperform
accounts that do not consider such factors. There are not
universally accepted ESG factors and advisors and
managers typically consider them in their discretion.
market capitalization,
investment style, economic
industry or sector, or geographic region. UITs are
passively managed and follow a “buy and hold” strategy,
meaning that UITs buy a fixed portfolio of securities and
hold on to that portfolio until their termination date at
which time the portfolio is liquidated with the net
proceeds paid to investors. UITs, thus, generally have a
relatively higher risk of loss than other funds in the event
of adverse changes in market or economic conditions.
UITs have other risks, which may include management
and securities selection risk, investment objective and
asset allocation risk, stock market risk, equity securities
risk, common stock risk, fixed income securities risk,
interest rate risk, credit risk, capitalization risk,
investment style risk, foreign issuer and investment risk,
and emerging market risk. Certain UITs pursue Complex
Strategies, which are subject to special risks. The degree
of these and other risks will vary depending on the type
of UIT selected. Also, investment return and principal
value will fluctuate, and units, if and when redeemed,
may be worth more or less than their original cost.
investment
Quantitative Strategy Risks. Some
investment
employ quantitative
managers may
methodologies or processes
investment
to make
decisions. The success of the quantitative investment
methodologies and processes used by
investment
managers depends on the analyses and assessments that
were used in developing such methodologies and
processes, as well as on the accuracy and reliability of
models and data provided by third parties. Incorrect
analyses and assessments or inaccurate or incomplete
models and data would adversely affect performance.
Additionally, an investment manager’s methodologies
and processes are predictive in nature, based on
historical outcomes and trends. Certain low-probability
events or factors that are assigned little weight may occur
or prove to be more likely or may have more relevance
than expected, for short or extended periods of time,
which may adversely affect the portfolios generated by
the investment manager’s quantitative methodologies
and processes. It is also possible that prices of securities
may move in directions that were not predicted by the
investment manager’s quantitative methodologies and
processes or may fail to move as much as predicted, for
reasons that were not expected. There can be no
assurance that these methodologies will enable a client
to achieve the client’s objective.
Risks Common to All Funds; Purchase and
Redemption Risks. Funds are generally subject to the
same risks as the securities or other assets in which they
invest. In addition, from time to time Baird, a Baird
Consultant, or an investment manager may decide to add
or remove a Fund to or from an investment strategy or
program. In addition, they may decide to increase or
decrease their clients’ Account allocations to a Fund. In
general, they will place transactions for all affected
accounts at one time, which may cause the Fund to
experience relatively large purchases or redemptions.
Significant purchases and redemptions may adversely
affect the Fund in question and consequently, a client’s
investment. A Fund receiving large purchase orders may
have difficulty investing the cash, which may have a
negative impact on the Fund’s performance. A Fund
experiencing large redemption orders may have to sell
impact
portfolio securities, which may negatively
performance and which may have negative
tax
consequences. Large redemptions could also reduce
liquidity as the Fund may suspend or delay redemptions.
These risks are more pronounced with respect to newer
Funds and those with smaller asset sizes.
Risks Associated with Certain Investment
Strategies
In order
for
Technical Strategy Risks. Some investment managers
and Financial Advisors may employ technical analysis or
investment methodologies to make investment decisions
or recommendations. The primary risk of using technical
analysis is that past price and volume patterns and trends
in the trading markets cannot predict future prices,
volume patterns or trends. There is no guarantee that
investment methods used are designed
technical
properly, are updated with new data as it becomes
available, or can accurately predict future market or
investment performance.
technical
investment methods to work, there must be sufficient
data about the markets available so that trends can be
identified and predictions can be made. A technical
method may fail to identify trends or be able to accurately
predict future prices if a market does not have sufficient
data or trends or if the market behaves erratically.
Growth and Value Investment Style Risks.
Investment styles or strategies that focus on growth
stocks may perform better or worse than styles or
strategies that focus on value stocks or that are broader
or more diversified. Similarly, investment styles or
strategies that focus on value stocks may perform better
or worse than styles or strategies that focus on growth
stocks or that are broader or more diversified. A
particular style of investing may go out of favor at times
and for extended periods. Growth stocks are often
characterized by high price-to-earnings ratios and may
be more volatile than stocks with lower price-to-earnings
ratios. Value stocks are subject to the risk that the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Other Strategy Risks. The risks associated with other
types of investment strategies are described under the
heading “Methods of Analysis, Investment Strategies and
Risk of Loss—Investment Strategies” above.
Non-Traditional Assets and Complex Strategies
Risks
Leverage and Margin Risks. Leveraging strategies may
amplify the impact of any decrease in the value of
underlying securities in the client’s Account, thereby
increasing a client’s risk of loss. The use of leverage may
also increase an Account’s volatility. Strategies involving
margin can cause a client to lose more money than
deposited in the client’s margin account. A client should
not engage in strategies involving leverage or margin
unless the client is prepared to experience significant
losses in the value of the client’s Account.
Non-Traditional Assets Risks. Non-Traditional Assets,
such as commodities, currencies, securities indices,
interest rates, credit spreads, private companies, and
Digital Assets, are subject to risks that are different from,
and in some instances, greater than, other assets like
stocks and bonds. Some Non-Traditional Assets are less
transparent and more sensitive to domestic and foreign
political and economic conditions than more traditional
investments. Non-traditional assets are also generally
more difficult to value, less liquid, and subject to greater
volatility compared to stocks and bonds.
investments
Short Sales Risks. Short selling runs the risk of loss if
the price of the securities sold short does not decline
below the price at which they were originally sold. This
risk of loss is theoretically unlimited, as there is no cap
on the amount that the price of a security may
appreciate. In addition, a lender may request, or market
conditions may dictate, that securities sold short be
returned to the lender on short notice, which may result
having to buy the securities sold short at an unfavorable
price. A client should not engage in short sales unless the
client is prepared to experience significant losses in the
client’s Account.
than
investments
in
trading activities
Commodities Risks. Investments
in commodities
markets or a particular sector of the commodities
markets, and
in securities or other
instruments denominated in or indexed or linked to
commodities, are subject to certain risks. Those
investments generally will subject a client Account to
greater volatility
traditional
securities. The commodities markets are impacted by a
variety of factors, including changes in overall market
movements, domestic and foreign political and economic
conditions, interest rates, inflation rates and investment
and
in commodities. Prices of
commodities may also be affected by factors such as
drought, floods, weather, livestock disease, embargoes,
tariffs and other regulatory developments. The prices of
commodities can also fluctuate widely due to supply and
demand disruptions in major producing or consuming
regions. Certain commodities may be produced in a
limited number of countries and may be controlled by a
small number of producers or groups of producers. As a
result, political, economic and supply related events in
such countries could have a disproportionate impact on
the prices of such commodities. No active trading market
may exist for certain commodities investments, which
may impair the value of the investments.
Derivative Instrument Risks. The values of options,
convertible securities, futures, swaps, forward contracts
and other derivative instruments is derived from an
underlying asset, such as a security, commodity,
currency, or index. Derivative instruments often have
risks similar to the underlying asset, however, in certain
cases, those risks are greater than the risks presented by
instruments may
the underlying asset. Derivative
experience dramatic price changes and
imperfect
correlations between the price of the derivative and the
increase volatility.
underlying asset, which may
Derivatives generally create leverage, and as a result, a
small movement in the underlying asset's value can
result in large change in the value of the derivative
instrument. Derivatives are also subject to liquidity risk,
interest rate risk, market risk, credit risk, management
risk and counterparty risk. The use of these instruments
is not appropriate for some clients because they involve
special risks. A client should not invest in these
instruments unless the client is prepared to experience
volatility and significant losses in the client’s Account.
securities or other
Options Risks. In purchasing a put or call option, the
purchaser faces the risk of loss of the premium paid for
the option if the market price moves in a direction
opposite to what the purchaser had expected. In selling
or writing an option, the seller faces significantly more
risk. A seller of a call option faces the risk of significant
loss if the prevailing market price of the underlying
security or index increases above the strike price, and a
seller of a put option faces the risk of significant loss if
the prevailing market price of the underlying security or
index decreased below the strike price.
in currencies, and
Currency Risks. Investments
investments
instruments
in
denominated in or indexed or linked to currencies, are
subject to certain risks. Those investments are subject to
all of the risks associated with foreign investing generally.
In addition, currency markets generally are not as
regulated as securities markets. Also, changes in
currency exchange rates could adversely impact the
investment. Devaluation of a currency by a country will
also have a significant negative impact on the value of
any investment denominated in that currency. Currency
investments may also be positively or negatively affected
by a country’s strategies intended to make its currency
stronger or weaker relative to other currencies.
Hedging Risks. When a derivative instrument is used as
a hedge against an opposite position, any loss on the
derivative instrument should be substantially offset by
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
gains on the hedged investment, and vice versa.
Although hedging can be an effective way to reduce the
investment risk, it may not always perfectly offset one
position with another. As a result, there is no assurance
that hedging transactions will be effective.
leverage, derivative
investments and are generally subject to a higher risk of
volatility. Investing in hedge funds and funds of hedge
funds involves other special risks, including, but not
limited to, risks associated with Non-Traditional Assets,
short sales,
instruments, and
Complex Strategies. Other risks may include: market
risk, management and securities selection
risk,
investment objective and asset allocation risk, stock
market risk, equity securities risk, common stock risk,
fixed income securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign issuer
and investment risk, and emerging market risk. Hedge
funds and funds of hedge funds are complex investments
that have significant, special risks. As a result, they may
not be suitable for some clients. Clients investing in
hedge funds or funds of hedge funds should have a high
tolerance for risk, including the willingness and ability to
accept significant price volatility, potential lack of liquidity
and potential loss of their investment.
invest primarily
flow. Private equity
Digital Assets Risks. Digital Assets are not appropriate
for some clients because they involve substantial risk of
loss including special risks not present in traditional
financial markets. Digital Assets derive value primarily
from the demand for such assets in the marketplace and
their association with decentralized networks and other
technology. Digital Assets may lack an intrinsic value and
markets for Digital Assets are susceptible to extreme and
sudden price movements and fragmented liquidity.
Markets for Digital Assets continue to evolve, but lack
certainty regarding the status of regulation and investor
protections. The use and custody of Digital Assets involve
technological and cybersecurity risks, including the
potential for system outages, protocol flaws, operational
disruptions, hacking incidents, or failures of third-party
platforms and service providers that support trading,
settlement, and storage infrastructure. Many Digital
Assets depend on external validators, miners, or protocol
developers whose actions or inaction can impact network
stability or asset functionality and affect value. Market
structure risks—such as reliance on a limited number of
trading venues or counterparties—may impair the ability
to transact or liquidate positions during periods of market
stress. A client should not invest in these instruments
unless the client is prepared to experience extreme
volatility and significant losses in the client’s Account.
Complex Investment Product Risks
fee,
Private Equity Funds and Funds of Private Equity
Funds Risks. Private equity funds are pools of actively
managed capital that
in private
companies with the intent of creating value in the
companies in which they invest by improving operations,
reducing costs, selling non-core assets and maximizing
cash
funds usually have an
investment objective or strategy that may focus on
companies in certain sectors, industries, geographic
regions, size ranges or stages of development or
operations, or on certain types and sizes of investments.
Funds of private equity funds typically invest substantially
all of their assets in other private equity funds. Private
equity funds and funds of private equity funds have
unique tax characteristics. A client should consult with a
tax advisor before investing in those funds. Private equity
funds and funds of private equity funds are subject to
limited regulation and offer limited disclosure and
transparency. Also, the costs of private equity funds and
funds of private equity funds are typically higher than
other types of funds. Investment advisers or managers
for those funds often receive a management fee plus an
incentive fee or carried interest. Private equity funds and
funds of private equity fund are also generally subject to
fees and portfolio company
administrative service
transaction fees. Because of the existence of a carried
interest, fund managers may be motivated to make
riskier investments that have the potential for significant
growth in value. Investments in private equity funds and
funds of private equity funds also have reduced liquidity
compared to other investments. Investors should not
expect to receive distributions from a fund for a number
of years. Private equity investing is very risky. Many
investments made in portfolio companies are not
profitable. In addition, investments made by private
equity funds and funds of private equity funds may be
concentrated in one or more economic industries or
sectors, geographic regions, stages of development or
operation, or sizes of companies. Investing in private
equity funds and funds of private equity funds involves
other special risks, including, but not limited to,
Hedge Funds and Funds of Hedge Fund Risks. Hedge
funds typically engage
in one or more Complex
Strategies, including the use of Non-Traditional Assets,
short sales, leverage and other derivative instruments.
Funds of hedge funds typically invest substantially all of
their assets in other hedge funds. Hedge funds and funds
of hedge funds have unique tax characteristics. A client
should consult with a tax advisor before investing in those
funds. Some hedge funds and funds of hedge funds are
subject to limited regulation and offer limited disclosure
and transparency. Also, the costs of hedge funds and
funds of hedge funds are typically higher than other types
of funds. Investment advisers or managers for those
funds often receive a management fee plus an incentive
or performance-based fee. Because of the existence of a
fund managers may be
performance-based
motivated to make riskier investments that have the
potential for significant growth in value. Hedge funds and
funds of hedge funds are also subject to a higher risk of
incorrect valuations. Many hedge funds hold investments
for which market quotations are not readily available,
which necessitates the use of “fair value” pricing. Fair
value pricing is an inherently subjective process and may
not accurately reflect the prices that can actually be
obtained upon sale of the assets for which fair values are
used. Investments in hedge funds and funds of hedge
funds also have reduced liquidity compared to other
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
dependence upon key personnel and conflicts of interest
risks. Other risks may include: market risk, management
and securities selection risk, investment objective and
asset allocation risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign issuer
and investment risk, and emerging market risk. Private
equity funds and funds of private equity funds are
complex investments that have significant, special risks.
As a result, they may not be suitable for some clients.
Clients investing in private equity funds and funds of
private equity funds should have a high tolerance for risk,
including the willingness and ability to accept lack of
liquidity and potential loss of their investment.
concentrated in one or more economic industries or
sectors, geographic regions, stages of development or
operation, or sizes. Investing in private debt funds and
funds of private debt funds involves special risks,
including, but not limited to, dependence upon key
personnel, conflicts of interest risks, market risk,
management and securities selection risk, investment
objective and asset allocation risk, interest rate risk,
credit risk, capitalization risk, investment style risk,
foreign issuer and investment risk, emerging market risk,
illiquid securities and liquidity risks, concentration risks,
investment fund risks, currency risks and leveraging
risks. Private debt funds and funds of private debt funds
are complex investments that have significant, special
risks. As a result, they may not be suitable for some
clients. Clients investing in private debt funds and funds
of private debt funds should have a high tolerance for
risk, including the willingness and ability to accept lack of
liquidity and potential loss of their investment.
telecommunications
facilities,
funds have unique
portfolio
risk
(including
Private Debt Funds (or Private Credit Funds) and
Funds of Private Debt Funds. Private debt funds (also
known as private credit funds) are pools of actively
managed capital that invest primarily in loans or debt
instruments issued by companies in private transactions.
Sometimes, repayment of the loan is secured by assets
of the companies obtaining the loans. However, the
companies often have low or no credit ratings. Thus,
investments held by private debt funds generally are
subject the same risks as below investment grade or
“junk” bonds. Trading markets for the investments held
by those funds are also limited and their investments may
be illiquid. Oftentimes, the interest rate paid by the
companies is determined by a reference interest rate,
such as the federal funds rate, which is periodically reset.
These types of investments are sometimes referred to as
floating rate corporate debt, floating rate loans or floating
rate bank loans. Private debt funds usually have an
investment objective or strategy that may focus on
companies in certain sectors, industries, geographic
regions, size ranges or stages of development or
operations, or on certain types and sizes, including
focusing investments on smaller capitalization, distressed
or bankrupt companies. Private debt funds commonly use
borrowings or leverage to make investments. Funds of
private debt funds typically invest substantially all of their
assets in other private debt funds. Private debt funds and
funds of private debt
tax
characteristics. A client should consult with a tax advisor
before investing in those funds. Private debt funds and
funds of private debt funds are subject to limited
regulation and offer limited disclosure and transparency.
Also, the costs of private debt funds and funds of private
debt funds are typically higher than other types of funds.
Investment advisers or managers for those funds often
receive a management fee plus a performance fee.
Private debt funds and funds of private debt fund are also
generally subject to operational expenses and transaction
fees. Because of the existence of a performance fee, fund
managers may be motivated to make riskier investments
that have the potential for significant growth in value.
Investments in private debt funds and funds of private
debt funds also have reduced liquidity compared to other
investments. Investors should not expect to receive
distributions from a fund for a number of years. Private
debt investing is very risky. Investments made by private
debt funds and funds of private debt funds may be
Real Estate Investment Trusts (“REITs”) and
Private REIT Risks. A REIT is a corporation, trust or
association that owns and typically operates income-
producing real estate or real estate-related assets. The
income-producing real estate assets owned by a REIT
may include office buildings, shopping malls, multi-family
housing, student housing, hotels, resorts, hospitals and
health care facilities, self-storage facilities, data centers,
warehouses,
and
mortgages or loans. Many REITs are registered with the
SEC and their common stock and preferred stock are
publicly traded on a stock exchange. These are known as
publicly-traded REITs. Others may be registered with the
SEC but are not publicly traded. These are known as
private REITs (also known as non-traded or non-
exchange traded REITs). There is no public trading
market for private REITs and the sole method for
disposing of the shares may be limited to a periodic offer
to redeem the shares by the issuer, if the issuer offers a
redemption program. Private REITs are generally subject
to limited regulation and offer limited disclosure and
transparency. The shareholders of a REIT are responsible
for paying taxes on the dividends that they receive and
on any capital gains associated with their investment in
the REIT. Dividends paid by REITs generally are treated
as ordinary income and are not entitled to the reduced
tax rates on other types of corporate dividends. Prices of
REIT securities and trading volumes may be more volatile
that other investments. Many REITs focus on a particular
sector of the real estate market, such as apartments,
student housing, hotels and hospitality, health care,
office buildings, shopping malls, warehouses, self-
storage facilities and the like. Those REITs are subject to
risks associated with sectors in which they are focused.
Additionally, many REITs may own properties that are
concentrated in a particular geographic region or regions,
which subject them to the risk of deteriorating economic
conditions in those areas. Investing in REITs involves
other special risks, including, but not limited to, real
estate
development,
environmental, competition, occupancy and maintenance
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
funds are complex
risk), liquidity risk, leverage risk, distribution risk, capital
markets access risk, growth risk, counterparty risk,
conflicts of interest risk, dependence upon key personnel
risk, and regulatory risk. Other risks may include: market
risk, management and securities selection
risk,
investment objective and asset allocation risk, stock
market risk, equity securities risk, interest rate risk,
credit risk, foreign issuer and investment risk, and
emerging market risk. REITs involve significant, special
risks and may not be suitable for some clients. Clients
investing in REITs should have a high tolerance for risk,
including the willingness and ability to accept significant
price volatility and volatility of regular distribution
amounts, potential lack of liquidity and potential loss of
their investment.
operation, or sizes. Investing in private real estate funds
and funds of private real estate funds involves special
risks, including, but not limited to, dependence upon key
personnel, conflicts of interest risks, market risk,
management and securities selection risk, investment
objective and asset allocation risk, interest rate risk,
credit risk, capitalization risk, investment style risk,
foreign issuer and investment risk, emerging market risk,
illiquid securities and liquidity risks, concentration risks,
investment fund risks, currency risks and leveraging
risks. Private real estate funds and funds of private real
estate
investments that have
significant, special risks. As a result, they may not be
suitable for some clients. Clients investing in private real
estate funds and funds of private real estate funds should
have a high tolerance for risk, including the willingness
and ability to accept lack of liquidity and potential loss of
their investment.
types and sizes of
liquidity compared to other
Private Real Estate Funds and Private Real Estate
Fund of Funds. Private real estate funds are pools of
actively managed capital that directly invest primarily in
investments in real estate and real estate-related
investments. Private real estate funds may invest in any
number of types of real estate, such as office, apartment,
retail, lodging, industrial and other real estate and real
estate-related investments. Some may focus investment
in properties involved in certain sectors or industries,
located in certain geographic regions or that have certain
sizes of operations or investment requirements. Some
may focus investment on properties the manager or
sponsor believes are undervalued or undercapitalized or
that require repositioning, redevelopment, improved
management or additional capital to reach their full value.
Private real estate funds commonly use borrowings or
leverage to make investments. Trading markets for
investments held by those funds are limited and their
investments may be illiquid. Funds of private real estate
funds typically invest substantially all of their assets in
other private real estate funds. Private real estate funds
and funds of private real estate funds have unique tax
characteristics. A client should consult with a tax advisor
before investing in those funds. Private real estate funds
and funds of private real estate funds are subject to
limited regulation and offer limited disclosure and
transparency. Also, the costs of private real estate funds
and funds of private real estate funds are typically higher
than other types of funds. Investment advisers or
managers for those funds often receive a management
fee plus a performance fee. Private real estate funds and
funds of private real estate fund are also generally
subject to operational expenses and transaction fees.
Because of the existence of a performance fee, fund
managers may be motivated to make riskier investments
that have the potential for significant growth in value.
Investments in private real estate funds and funds of
private real estate funds also have reduced liquidity
compared to other investments. Investors should not
expect to receive distributions from a fund for a number
of years. Private real estate investing is very risky.
Investments made by private real estate funds and funds
of private real estate funds may be concentrated in
properties involved in one or more economic industries or
sectors, geographic regions, stages of development or
Private
Infrastructure Funds Risks.
Private
infrastructure funds are pools of actively managed capital
that invest primarily in infrastructure projects and assets
and may involve exposure to a range of economic or
market sectors, geographic locations and asset types.
Examples of infrastructure investments may include,
among others,
telecommunication, utilities, and
transportation. Private infrastructure funds usually have
an investment objective or strategy that may focus on
certain sectors, industries, geographic regions, size
ranges or stages of development or operations, or on
certain
investments. Private
infrastructure funds have unique tax characteristics. A
client should consult with a tax advisor before investing
in those funds. Private infrastructure funds are subject to
limited regulation and offer limited disclosure and
transparency. Also, the costs of private infrastructure
funds are typically higher than other types of funds.
Investment advisers or managers for those funds often
receive a management fee plus an incentive fee. Private
infrastructure funds are also generally subject to
administrative service fees and investment transaction
fees. Because of the existence of incentive fees, fund
managers may be motivated to make riskier investments
that have the potential for significant growth in value.
Investments in private infrastructure funds also have
reduced
investments.
Investors should not expect to receive distributions from
a fund for a number of years. Private infrastructure
investing is very risky. Many investments are not
profitable. In addition, investments made by private
infrastructure funds may be concentrated in one or more
economic industries or sectors, geographic regions,
stages of development or operation, or sizes of
companies. Investing in private infrastructure funds
involves other special risks, including, but not limited to,
dependence upon key personnel and conflicts of interest
risks. Other risks may include: market risk, management
and securities selection risk, investment objective and
asset allocation risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign issuer
and investment risk, and emerging market risk. Private
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
interest rates, and
infrastructure funds are complex investments that have
significant, special risks. As a result, they may not be
suitable for some clients. Clients investing in private
infrastructure funds should have a high tolerance for risk,
including the willingness and ability to accept lack of
liquidity and potential loss of their investment.
derivative
instruments,
potential for significant growth in value. Managed futures
may seek exposure to different asset classes, such as
equity securities, fixed income securities, commodities
(such as metals, agricultural products, and energy
products), currencies,
indices.
Managed futures often obtain this exposure through
derivative instruments, which may be traded on U.S. or
foreign exchanges or markets. Managed futures often
employ computerized, systematic and often proprietary
trading models and systems. Investing in managed
futures involves special risks, including, but not limited
to, liquidity risks and risks associated with commodities,
currencies, and other Non-Traditional Assets, leverage,
derivative instruments and Complex Strategies. Other
risks may include: market risk, management and
securities selection risk, investment objective and asset
allocation risk, stock market risk, equity securities risk,
common stock risk, fixed income securities risk, interest
rate risk, credit risk, foreign issuer and investment risk,
and emerging market risk. Managed futures can be
speculative
investments because of the types of
investments they make and they involve significant,
special risks. As a result, they may not be suitable for
some clients. Clients investing in these funds should have
a high tolerance for risk, including the willingness and
ability to accept significant price volatility, potential lack
of liquidity and potential loss of their investment.
investments and
Exchange Traded Notes Risks. An ETN is a type of debt
security that trades on an exchange and provides a return
linked to the performance of an underlying benchmark.
The underlying benchmark can be a particular security,
bond, commodity, currency, or other non-traditional
asset type, a group or basket of companies, securities,
commodities, currencies, derivative instruments, non-
traditional asset investments or other assets, or an index
or other benchmark linked to stocks, market volatility,
bonds, interest rates, Treasury yields, yield curves and
spreads,
strategies,
commodities, currencies or other assets. ETNs trade on
exchanges throughout the day at prices determined by
the market. Unlike ETFs, issuers of ETNs do not buy or
hold assets to replicate or approximate the performance
of the underlying benchmark. Also in contrast to ETFs,
ETNs also do not calculate their net asset value, are
generally not redeemable on a daily basis, and are not
registered under the Investment Company Act of 1940.
Issuers may also have the right and option to redeem
ETNs. Redemptions are made at the ETN’s “indicative
value” or “closing indicative value”. An ETN's closing
indicative value is computed by the issuer and is distinct
from an ETN's market price, which is the price at which
an ETN trades in the secondary market. Issuers of ETNs
may also issue and redeem notes as a means to keep the
ETN’s market price in line with its indicative value, which
have caused significant fluctuations in ETN prices.
Investing in ETNs involves special risks, including, but not
limited to, risks associated with Non-Traditional Assets
and derivative instruments and the risk that the actual
market price for an ETN may vary significantly from the
indicative value computed by the issuer. Other risks may
include: market risk, management and securities
selection risk, investment objective and asset allocation
risk, stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest rate risk,
credit risk, capitalization risk, investment style risk,
foreign issuer and investment risk, and emerging market
risk. ETNs are complex
involve
significant, special risks. As a result, ETNs may not be
suitable for some clients.
Leveraged Fund and Inverse Fund Risks. Leveraged
funds and inverse funds may be structured as ETNs, ETFs
or open-end mutual funds. Leveraged funds seek to
deliver multiples of the performance of the index or
benchmark they track. Inverse funds seek to deliver the
opposite of the performance of the index or benchmark
they track. Leveraged inverse funds seek to achieve a
return that is a multiple of the inverse performance of the
underlying index. Most leveraged and inverse funds
“reset” daily, meaning that they are designed to achieve
their stated objectives on a daily basis. Because of the
effects of compounding, volatility and the fund expenses,
the returns of a leveraged or inverse fund over longer
periods of time can differ significantly
from the
performance (or inverse of the performance) of their
underlying index or benchmark during the same period of
time. To achieve their objectives, leveraged and inverse
funds typically employ aggressive investment techniques,
such as the use of leverage, short sales, swap contracts,
futures, options and other derivative instruments.
Investing in leveraged funds and inverse funds involves
special risks, including, but not limited to, risks
associated with Non-Traditional Assets, short sales,
leverage, and derivative instruments. Other risks may
include: market risk, management and securities
selection risk, investment objective and asset allocation
risk, stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest rate risk,
credit risk, foreign issuer and investment risk, and
emerging market risk. Leveraged funds and inverse funds
are complex investments that have an increased risk of
loss compared to other funds and they involve significant,
special risks. As a result, they may not be suitable for
Managed Futures Risks. Managed
futures are
commodity pools (typically structured as investment
partnerships) managed by a futures trading adviser that
trade speculatively in various derivative instruments and
other investments. There are significantly higher fees and
expenses associated with investments in managed
futures than other types of funds. Sponsors or managers
for these pools often receive a management fee plus
incentive or performance-based fee. Because of the
existence of a performance-based fee, managers may be
motivated to make riskier investments that have the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
some clients. A client should not invest in these securities
unless the client is prepared to experience significant
losses in the value of the client’s Account.
investments they make and involve significant, special
risks. As a result, BDC investments may not be suitable
for some clients. Clients investing in BDCs should have a
high tolerance for risk, including the willingness and
ability to accept significant price volatility, potential lack
of liquidity and potential loss of their investment.
Structured Products Risks. Structured products are a
hybrid between two asset classes (typically issued in the
form of a CD or note) but instead of having a pre-
determined rate of interest, the return is linked to the
performance of an underlying asset class, such as single
security or basket or index of securities; a commodity or
basket or index of commodities, including futures; and a
foreign currency or basket of
foreign currencies.
Investing in structured products involves special risks,
including, but not limited to, risks associated with
derivative instruments. Other risks may include: market
risk, management and securities selection
risk,
investment objective and asset allocation risk, stock
market risk, equity securities risk, common stock risk,
fixed income securities risk, interest rate risk, credit risk,
foreign issuer and investment risk, emerging market risk,
commodities risk and currency risk. Structured products
are complex investments and involve special risks. As a
result, they may not be suitable for some clients.
Master Limited Partnership Risks. An MLP is a form of
publicly-traded partnership that is taxed as a partnership.
MLPs have unique tax characteristics. A client should
consult with a tax advisor before investing in MLPs. An
MLP must generally earn at least 90% of its income from
certain qualifying sources, which includes income and
gains from certain activities involving natural resources
such as oil, natural gas, natural gas liquids, refined
petroleum products, coal, carbon dioxide and biofuels. An
MLP is generally structured as a limited partnership or
limited liability company and managed and operated by a
general partner or manager. Owners of an MLP are called
“limited partners” or “unit holders”. Unit holders own
interests or units in the MLP (“units”) that are traded on
a stock exchange. MLPs make distributions to unit holders
of their available cash flows. Many MLPs focus on a
particular sector or industry. Those MLPs are subject to
risks associated with sectors or industries in which they
are focused. The value of an investment in an MLP and
the amount of distributions it makes may depend on the
prices of the underlying commodity, such as oil or natural
gas. Many MLPs are sensitive to changes in the prevailing
level of commodity prices. MLPs have also shown
sensitivity to interest rate movements. Investing in MLPs
involves other special risks, including, but not limited to,
macroeconomic risk, interest rate risk, liquidity risk,
operating risk, capital markets access risk, growth risk,
distribution risk, conflicts of interest risk, and regulatory
risk. MLPs are complex investments that have significant,
special risks. As a result, MLPs may not be suitable for
some clients. Clients investing in MLPs should have a high
tolerance for risk, including the willingness and ability to
accept potential lack of liquidity and potential loss of their
investment.
Additional information about certain Complex Investment
Products and other investments pursuing Complex
Strategies, including the risks associated with those
investments,
is available on Baird’s website at
bairdwealth.com/retailinvestor. A client is encouraged to
read the disclosure documents included on those
websites carefully before investing.
Available Investment Product Risks
to
risks compared
investment
products.
Business Development Company Risks. A BDC is
typically a domestic, closed-end investment company
that is operated for the purpose of making equity and
debt investments in small and developing businesses, as
well as financially troubled businesses. As a result,
investments made by BDCs tend to be risky and
speculative. Investment advisers or managers for BDCs
often receive a management fee plus incentive or
performance-based fee. Because of the existence of a
performance-based fee, managers may be motivated to
make riskier investments that have the potential for
significant growth
in value. BDCs commonly use
borrowings or leverage to make investments in portfolio
companies. Adverse
interest rate movements can
negatively impact a BDC’s ability to make investments.
Investments made by BDCs are typically illiquid, and
valuing such investments is challenging. It is possible
that valuations on investments used are materially
different from the values that BDCs will ultimately receive
upon disposition of those investments. Changing market
and economic conditions affecting a BDC’s investments
may cause significant volatility in the BDC’s net asset
value and stock price. Due to the nature of BDCs’
investments, securities issued by BDCs are subject to
greater liquidity risk than other investments. A debt
security or preferred stock issued by a BDC, in many
cases, is non-rated or is rated below investment grade,
which can carry its own risks. Investing in BDCs involves
other special risks, including, but not limited to, portfolio
company credit and investment risk, leverage risk, capital
markets access risk, dependence upon key personnel
risk, and regulatory risk. Other risks may include: market
risk, management and securities selection
risk,
investment objective and asset allocation risk, stock
market risk, equity securities risk, common stock risk,
fixed income securities risk, and interest rate risk. BDCs
can be speculative investments because of the types of
The use of Available Investment Products are subject to
the use of Baird
additional
recommended
Available
Investment Products are investment products that
generally do not meet the qualifications and standards
that Baird establishes for its recommended product lists.
As a result, there is a higher likelihood that some
Investment Products will have poor
Available
significantly underperform
performance and will
compared to an applicable benchmark index or peer
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Product
experiences
Rapid advancements in artificial intelligence (AI) and
automation are increasingly influencing global economic
trends, corporate decision making, and financial market
dynamics. Expanding investment in these technologies is
contributing to shifts in how industries operate, compete,
and allocate resources. The fast pace of technological
change, potential disruptions to existing business
models, and evolving regulatory responses introduce
additional uncertainty and may contribute to market
volatility.
to a heightened
Taken together, these developments may have a
impact upon global economic
significant negative
conditions and contribute
risk
environment. As a result, fluctuations in asset prices may
increase, and such volatility could adversely affect the
value of a client’s Account.
group. Available Investment Products are also subject to
significantly less rigorous review by Baird compared to
recommended investment products. Thus, if an Available
Investment Product experiences significant performance
problems or if the manager or sponsor of an Available
Investment
significant
management, organizational, operational, compliance,
legal, regulatory or other problems, there is a higher risk
that the Available Investment Product will be made
available (and will continue to be made available) to
clients by Baird. An investment by a client in an Available
Investment Product that experiences the occurrence of
any such event could negatively impact the client’s
Account. Available Investment Products should only be
used by a client if the client wishes to take more
responsibility for monitoring and managing the assets in
the client’s Account, the list of recommended products
does not contain an investment product that meets the
client’s particular needs, and the client understands the
risks of doing so.
Recent Events
relationships, and evolving
Global financial markets have continued to experience
periods of elevated volatility, driven by a combination of
economic, political, and broader macroeconomic
developments. Conditions across major economies have
been influenced by shifting policy priorities, changes in
geopolitical
investor
expectations.
reduction
remains a central
focus
Disciplinary Information
In April 2016, Baird, without admitting or denying the
findings, consented to the sanctions and findings of
FINRA that it violated NASD Conduct Rule 3010, FINRA
Rule 3110, and FINRA Rule 2010, by failing to establish
and maintain a supervisory system and procedures
reasonably designed to ensure that customers who
purchased mutual fund shares received the benefit of
applicable sales charge waivers. In May 2015, Baird
began a review to determine whether Baird had provided
available sales charge waivers to eligible customers.
Based on this review, in May 2015, Baird self-reported to
FINRA that various eligible customers had not received
available sales charge waivers. Baird was found to have
disadvantaged certain retirement plan and charitable
organization customers that were eligible to purchase
Class A shares in certain mutual funds without a front-
end sales charge. The findings also stated that these
customers were instead sold Class A shares with a front-
end sales charge or Class B or C shares with higher
ongoing fees and the potential application of a contingent
deferred sales charge. Baird was censured and required
to pay restitution to affected customers estimated to be
approximately $2.1 million including interest.
Within the United States, the current U.S. administration
has demonstrated intent on implementing policy changes
through executive orders and legislation, contributing to
a less certain policy environment. Potential adjustments
to federal programs, regulatory initiatives, and legislative
priorities create additional factors for markets to assess,
which may cause meaningful market uncertainty. While
inflation
for
policymakers, achieving the U.S. Federal Reserve Board’s
long term inflation target of 2% continues to prove
challenging. Although annual price increases have
generally moderated, the price of many goods and
services remains elevated compared to levels from a few
years ago. Leadership changes at the Federal Reserve
and political divisions and discord add further uncertainty
to the economic outlook.
Internationally, geopolitical risks have increased as the
U.S. and Israel are engaged in a military conflict with
Iran. The conflict has disrupted global trade and caused
an increase in the price of oil. The continuation or
escalation of military strikes could lead to a lengthy
period of military conflict, and Iran’s military attacks and
other hostile actions against other countries present a
risk of widening the conflict. In addition, the war between
Ukraine and Russia is now passing its fourth anniversary,
instability in parts of the Middle East persist, and relations
between the U.S. and other countries are strained.
In July 2016, Baird, without admitting or denying the
findings, consented to the sanctions and to the entry of
findings of FINRA that the firm and a firm supervisor
within its Private Wealth Management business did not
reasonably supervise a former Financial Advisor who
misused a customer’s funds. The findings stated that the
supervisor did not reasonably follow-up on red flags
associated with a trade correction request submitted by
the Financial Advisor that should have alerted him to the
Financial Advisor's misuse of a customer’s funds. The
supervisor also did not follow certain of Baird’s written
supervisory procedures (“WSPs”) relating to trade
corrections. After the supervisor realized that the
Financial Advisor misused the customer’s funds, Baird
reimbursed the customer for the loss. The findings also
included that Baird did not establish and maintain a
supervisory system, including WSPs, for correcting trade
to ensure
errors
that was
reasonably designed
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
compliance with applicable securities laws, regulations
and rules. Baird was censured and fined $200,000.
reporting and consenting to the order, Baird agreed to a
censure and to cease and desist from committing or
causing any violations and future violations of Sections
206(2) and 207 of the Advisers Act. Baird also agreed to
establish a distribution fund and to deposit into that fund
the improperly disclosed 12b-1 fees received by Baird
plus prejudgment interest, which will be paid to affected
advisory clients. More information about the order is
contained in Baird’s Form ADV, which is available on the
SEC’s Investment Advisory Public Disclosure website at
https://www.adviserinfo.sec.gov/IAPD/Default.aspx or in
the SEC’s press release about the SCSD Initiative at
https://www.sec.gov/news/press-release/2019-28.
In June 2019, Baird, without admitting or denying the
findings, consented to the sanctions and to the entry of
findings of FINRA that between late April 2013 and early
July 2013 it published 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 and that the failure to disclose the research
analyst’s employment discussions with the issuer in the
research reports made those reports misleading. Baird
was censured and fined $150,000.
In September 2016, the SEC announced that 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. Baird also was ordered to cease and desist
committing or causing any violations and any future
violations of Section 206(4) of the Advisers Act and Rule
206(4)-7 thereunder and pay a civil money penalty in the
amount of $250,000.
In September 2022, Baird, without admitting or denying
the findings, consented to the entry of findings of FINRA,
which found that it charged certain brokerage customers
an unfair commission when it charged its published
minimum commission amount of $100 on 7,277 retail
equity trades and failed to establish and maintain a
supervisory system reasonably designed to prevent
charging a customer a commission that is unreasonable
or unfair in violation of FINRA Rules 3110, 2121, and
2010. Baird also consented to a censure, a fine in the
amount of $150,000, and the payment of restitution of
$266,481 plus interest. The findings related to FINRA’s
routine examination of Baird in 2020. Following that
examination, Baird modified its minimum commission
schedule and supervisory procedures. Baird also took
steps to make payments to the affected customers, which
on average amounted 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.
its
In March 2019, Baird, without admitting or denying the
findings, consented to an order of the SEC, which found
that it violated Sections 206(2) and 207 of the Advisers
Act for making inadequate disclosures to advisory clients
about mutual fund share classes. The order was part of a
voluntary self-reporting program initiated by the SEC
called the “Share Class Selection Disclosure (or SCSD)
Initiative.” Under the program, 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 settlement terms imposed by the SEC,
including returning money to affected
investment
advisory clients. The central issue identified by the SEC
was that, in many cases, investment advisory firms
bought for or recommended to their investment advisory
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 advisory clients, and the
investment advisory firms did not adequately disclose
their receipt of 12b-1 fees and/or the conflict of interest
associated with those 12b-1 paying share classes. Baird
and many other firms self-reported under the program
and entered into substantially identical orders. By self-
In September 2023, Baird entered into an Offer of
Settlement with the SEC, 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
business-related
associates’
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
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Baird ICS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
representatives and associated persons of Baird to the
extent necessary or appropriate to perform their job
responsibilities.
Certain Relationships and Arrangements
Baird and Associated Parties
that
certain Baird
including
the amount of
the
financial
Baird PWM has relationships or arrangements with other
Baird businesses units and the Associated Parties
described below, including referral programs that pay
special compensation to Baird Consultants for eligible
referrals. Additional information about those referral
programs,
referral
compensation,
is disclosed on Baird’s website at
bairdwealth.com/retailinvestor. These relationships or
arrangements present a conflict of interest because they
provide a
incentive to Baird and Baird
Consultants to use, select or recommend the investment
products and services of Baird and Associated Parties
over those of unassociated parties and those that pay the
greatest level of compensation. Baird addresses this
potential conflict through disclosure in this Brochure.
Further, when acting as fiduciaries, Baird and Baird
Consultants are required to select or recommend
investment products only when they determine it to be in
the client’s best interest to do so.
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. While Baird had policies and procedures
in place prohibiting such off-channel communications, it
was discovered
supervisors
communicated off-channel using non-Baird approved
methods on their personal devices about Baird’s broker-
dealer and investment adviser businesses, and the
findings were reported to the SEC. Baird took steps prior
to and after the SEC’s review, including implementing a
new communication tool designed for Baird associates’
personal devices, conducting training, and periodically
requiring requisite associates to provide an attestation
relating to their business-related communications. 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.
Baird Asset Management
located
Baird’s Asset Management business, Baird Advisors,
Baird Equity Asset Management, and Chautauqua Capital
Management (“CCM”), part of Baird Equity Asset
Management, provide investment management services
to institutional clients and Investment Funds. Baird
Consultants who refer clients to Baird Asset Management
are eligible for referral compensation to be paid by Baird.
Baird Consultants, therefore, have a financial incentive to
favor the services provided by Baird Asset Management
over those provided by other managers.
Baird Funds
In March 2026, Baird entered into an Offer of Settlement
with the Massachusetts Securities Division to settle a
regulatory matter relating to the timing of state
investment adviser representative registration approvals
for two of Baird’s Financial Advisors
in
Massachusetts. The Division alleged that, for a limited
period in early 2025, the two individuals provided
investment advisory services before their Massachusetts
registrations were completed as a form was missing from
their application materials. 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.
on
SEC’s
website
Additional information about Baird’s disciplinary history is
available
at
the
www.adviserinfo.sec.gov.
Baird is the investment adviser and principal underwriter
for Baird Funds, Inc. (the “Baird Funds”). Baird Advisors
provides investment management, administrative, and
other services to certain Baird Funds investing primarily
in fixed income securities (the “Baird Bond Funds”). Baird
Equity Asset Management and CCM provide investment
management and other services to certain Baird Funds
investing primarily in equity securities (the “Baird Equity
Funds”), and Greenhouse Funds LLLP, a party related to
Baird, is the investment subadvisor to one of those
Funds, the Baird Equity Opportunity Fund. In certain
instances, Baird Consultants who refer clients to the Baird
Funds are eligible for referral compensation to be paid by
Baird. Due to the amount of referral compensation, Baird
Consultants have a financial incentive to favor the Baird
Equity Funds over the Baird Bond Funds.
Baird Trust
Other Financial Industry Activities and
Affiliations
Baird’s Broker-Dealer Activities
Baird PWM offers brokerage accounts and related
services to its clients. Baird is also engaged in a broad
range of broker-dealer activities through other business
units, including its Global Investment Banking, Fixed
Income Capital Markets (including Public Finance) and
Institutional Equities and Research Departments. Certain
Baird associates, including Baird Consultants, and certain
management persons of Baird are registered, or have an
registered
application pending
to
register,
as
Baird is affiliated, and may be deemed to be under
common control, with Baird Trust, a Kentucky-chartered
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Sagard
trust company, because both entities are indirectly wholly
owned by BFG. Baird and Baird Consultants receive
compensation from Baird Trust for referring clients and
providing ongoing relationship management services to
clients engaging Baird Trust for trust administration
services as described under the heading “Advisory
Business—Additional Service Information—Trust Services
Arrangements” above.
Baird Capital
Baird is engaged in a global private equity business
through Baird Capital (“Baird Capital”). Baird and Baird
Consultants may refer clients to Baird Capital. Baird
Consultants who assist in obtaining a client’s investment
in a private equity fund offered through Baird Capital are
eligible for referral compensation.
information
Baird’s direct parent corporation, BFC, has a minority
ownership interest (about 5%) in Sagard Holdings
Management, Inc. (“Sagard”) and the right to appoint a
member to Sagard’s board of directors, which is currently
a management person of Baird. Baird has agreed to use
best efforts, to the extent consistent with its fiduciary
duties, best interest obligations, and other regulatory
responsibilities, to offer to clients investment products
managed by affiliates of Sagard. Baird has an incentive
to do so because not reaching minimum thresholds would
give Sagard a right to redeem BFC’s ownership interest
in Sagard and reaching significant thresholds would give
BFC the right to increase its ownership interest. Baird
Consultants do not receive any additional compensation
for recommending Sagard-affiliated investment products.
Additional
identifying Sagard-affiliated
investment products will be provided to clients prior to
investment.
55ip
Baird has a financial incentive to the extent it would
recommend that a client invest in a portfolio company
owned by a Baird Capital private equity fund. A list of the
portfolio companies held by Baird Capital private equity
funds is located on Baird Capital’s website located at
https://www.bairdcapital.com/portfolio/baird-capital-
portfolio.aspx.
55I, LLC (d/b/a 55ip, “55ip”) uses research and other
services from Riverfront, an affiliate of Baird, in the
development of its portfolios under certain Baird wrap fee
programs, and Riverfront receives compensation from
55ip with respect to those portfolios. Due to its affiliation
with Riverfront, Baird has a financial incentive to favor
55ip portfolios that use Riverfront services.
Baird Global Investment Banking
Baird Institutional Equities and Research
Baird Public Finance
Associated Investment Products and Services
Baird and Baird Consultants may select or recommend
Associated Investment Products and Services, including
the Associated Funds and Associated SMA Strategies,
listed in Appendix A to this Brochure.
Through its Global Investment Banking, Public Finance
and Institutional Equities and Research Businesses, Baird
provides
investment banking, municipal advisory,
securities underwriting, stock buyback and related
services to various corporate, municipal, and other
issuers of securities. Baird receives compensation from
such issuers in connection with the services it provides,
and the success of its services generally depends upon
Baird’s ability to sell the securities of such issuers. Baird
may, therefore, have an incentive to favor the securities
of issuers for which Baird provides such services over the
securities of issuers for which Baird does not provide such
services.
Certain Associated Parties are associated with Baird
because BFC, Baird’s parent corporation, owns some or
all of the Associated Parties’ voting securities. BFC’s
(and Baird’s ultimate parent
parent corporation
corporation), BFG, may be deemed to indirectly own or
control such voting securities. Baird is deemed to be
under common control and “affiliated” with an Associated
Party when BFG indirectly owns or controls 25% or more
of such Associated Party’s voting securities (or of an
entity deemed to control such Associated Party). Baird
considers itself “related” to an Associated Party when BFG
indirectly owns or controls at least 10% but less than
25% of such Associated Party’s voting securities (or of an
entity deemed to control such Associated Party). Baird
considers itself “associated” with an Associated Party
when certain other relationships or other arrangements
exist between Baird and such Associated Party that might
present a conflict of interest with clients.
A Baird Consultant who refers a client to Baird Global
Investment Banking for a possible transaction in which
Baird Global Investment Banking earns a financial
advisory or underwriting fee receives a portion of such
fee. A Baird Consultant who refers a client to Baird Public
Finance
for a municipal advisory or underwriting
opportunity receives a portion of the compensation
earned by Baird Public Finance on that opportunity. Baird
and Baird Consultants thus have an incentive to
recommend the securities issued in those offerings. A
Baird Consultant who refers a corporation to Baird’s
Institutional Equities and Research business for a stock
buy-back program receives a portion of the commissions
earned by Baird’s Institutional Equities and Research
business. Baird and its Baird Consultants may, therefore,
have an incentive to buy, and to recommend that clients
sell, the securities of issuers that are part of Baird’s
buyback services.
An Associated Party receives fees or other compensation
for investment advisory or other services that it provides
to an Associated Fund. The amount of fees and other
compensation paid by an Associated Fund to an
Associated Party is disclosed in the Associated Fund’s
prospectus or other offering document. An Associated
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Baird ICS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Party also receives fees from a client for services that it
provides related to the client’s Associated SMA Strategy.
Information about the amount of fees paid to an
Associated Party with respect to an SMA Strategy is
contained in the applicable Baird Form ADV Part 2A
Brochure, the applicable account schedule, or in some
instances, the client’s contract with the Associated Party.
by Baird clients. These transactions may include trading
in securities in a manner that differs from, or is
inconsistent with, the advice given to Baird clients, and
the transactions may occur at or about the same time
that such securities are recommended to or are
purchased or sold for client accounts. This creates a
potential for a conflict between the interest of clients and
the interests of Baird and its affiliates and associates.
indirect ownership
Baird and Baird Consultants have a financial incentive to
use, select or recommend Associated Investment
Products and Services because Baird and BFG benefit
financially if a client utilizes those investment products
and services rather than unassociated
investment
products and services, and Baird Consultants benefit
financially from the overall success of Baird and BFG.
Similarly, Baird and Baird Consultants also generally have
a financial incentive to favor the investment products and
services of Baird over Associated Parties and to favor
those of Associated Parties in which BFG has a materially
interest over those of
greater
Associated Parties in which BFG has a materially lesser
indirect ownership interest. Baird addresses this potential
conflict through disclosure in this Brochure. Further,
when acting as fiduciaries, Baird and its Baird Consultants
are required to select or recommend investment products
only when they determine it to be in the client’s best
interest to do so. The criteria used by them in deciding to
select or recommend Associated Investment Products are
generally the same as those used for unassociated
investment products.
To address the potential for conflicts of interest, Baird has
adopted a Code of Ethics (the “Code”) that applies to its
associates that provide investment advisory services to
clients, including Baird Consultants, their supervisors,
and certain associates who have access to non-public
information relating to advisory client accounts (“Access
Persons”). The Code prohibits Access Persons from using
knowledge about advisory client account transactions to
profit personally, directly, or indirectly, by trading in his
or her personal accounts. The Code also generally
prohibits Access Persons from executing a security
transaction for their personal accounts during a blackout
period one business day before or after the date that a
client transaction in that same security is executed. The
Code provides for certain exceptions deemed appropriate
by Baird management or by Baird’s Compliance
Department. In addition, orders for the accounts of
Access Persons and other Baird associates that are under
discretionary management by Baird may be aggregated
with orders for other Baird client accounts, so long as the
order is executed as part of a block transaction with client
orders. A copy of the Code is available to clients or
prospective clients upon request.
Baird has also
implemented certain policies and
procedures relating to Baird’s and its associates’ trading
activities that are designed to prevent them from
improperly benefiting from the trading activities of Baird’s
advisory clients.
In addition, Baird’s Compliance
Department monitors the personal trading activities of all
of Baird’s associates providing advisory-related services
to clients.
Participation or Interest in Client Transactions
Investment Advisory Accounts
Relationships and Arrangements with Investment
Managers
Investment managers, including those participating in
the Baird wrap fee programs, may select Baird, in its
capacity as a broker-dealer, to execute portfolio trades
for their clients, including for Investment Funds they
advise and in which Baird clients invest. Investment
managers may also select Baird to provide custody,
research or other services. Baird receives compensation
for those services. This may create an incentive for Baird
to favor the investment products and services of such
investment managers. However, Baird is a fiduciary that
is required to act in the best interest of advisory clients
when selecting or recommending investment managers
or their investment products and services to such clients.
Baird addresses this potential conflict through disclosure
in this Brochure. Baird does not consider the extent to
which an investment manager directs or is expected to
direct trading, custody or research services to Baird when
considering the eligibility of an investment manager or its
investment products or services for the Services.
Asset-based Advisory Fee arrangements create an
incentive for Baird and Baird Consultants to set the
applicable fee rate at a high level and to encourage clients
to add more money into their accounts. Baird and Baird
Consultants also have an incentive to recommend an
investment advisory account to a client rather than a
brokerage account if the client has, or is expected to
have, lower levels of trading activity in the client’s
Account. Select clients may pay a fixed dollar fee, which
presents a conflict in that such fee does not give the Baird
Consultant an incentive to make recommendations that
could benefit the client’s Account, or a performance or
incentive fee, which presents a conflict because it gives
the Baird Consultant an incentive to recommend riskier
investments in order to achieve the level of performance
in the Account that would result in payment of the fee.
Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
Code of Ethics
Subject to the restrictions described below, Baird and its
affiliates and associates may engage in securities
transactions for their own accounts, including the same
or related securities that are recommended to or owned
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Accounts and Investments Provide Different Levels of
Compensation
The types of accounts and investment products offered to
clients provide Baird and Baird Consultants different
levels of compensation. Baird and Baird Consultants have
an incentive to generate revenues from client accounts
by selecting and recommending account types and
investment products that will provide them the greatest
level of compensation.
Recommendations of Associated Investment Products
and Services
Baird and Baird Consultants have an incentive to use,
select or recommend the investment products and
services of Associated Parties because they will benefit
financially. See “Other Financial Industry Activities and
Affiliations—Certain Relationships and Arrangements—
Associated Investment Products and Services” above and
“Certain Parties Associated with Baird” on Baird’s website
at bairdwealth.com/retailinvestor.
Baird also generally receives marketing support related
to the sale of units of UITs. Sponsors of UITs typically
make marketing or concession payments to the firms that
sell their UITs, including Baird. These payments are
typically calculated as a percentage of the total volume
of sales of the sponsor’s UITs made by the firm during a
particular period. That percentage typically increases as
higher sales volume levels are achieved. Descriptions of
these additional payments are provided in a UIT’s
prospectus. UIT sponsors that have paid volume
concessions to Baird over the past two calendar years
include Advisors Asset Management (AAM), First Trust
Portfolios and Guggenheim Investments. Receipt of
marketing support payments
from sponsors and
investment advisers of mutual funds and UITs provides
Baird an incentive to use, select and recommend such
mutual funds and UITs and to favor mutual funds and
UITs with sponsors or investment advisers that make the
greatest levels of such payments. Baird does not share
these payments with Baird Consultants. Please see
“Revenue Sharing/Marketing Support and Other Third
Party Payments” at bairdwealth.com/retailinvestor for
more information.
Referral Compensation Paid to Baird Consultants
Baird Conference Sponsorships
Baird hosts a number of seminars and conferences for
Baird Consultants in any given year, including Baird’s
PWM Symposium, which gives sponsors of investment
products, such as mutual funds, the opportunity to make
presentations at, and contribute money toward the cost
of, such seminars and conferences. This presents a
conflict of interest in that it gives Baird an incentive to
promote or market the sponsors’ investment products in
order to persuade them to continue supporting Baird
seminars and conferences. Please see “Revenue
Sharing/Marketing Support and Other Third Party
Payments” at bairdwealth.com/retailinvestor for more
information.
on
Baird’s
website
Baird Consultants receive additional compensation for
referring clients to certain Associated Parties described
above. See “Other Financial Industry Activities and
Affiliations—Certain Relationships and Arrangements—
Baird and Associated Parties” above. Baird Consultants
also receive additional compensation for referring clients
to unaffiliated banks that make loans to clients under
Baird’s Securities-Based Lending Program. See “Advisory
Business—Additional Service Information—Securities-
Based Lending Program” above. Such compensation
gives Baird Consultants an incentive to recommend or
refer clients to those Associated Parties and to
recommend that a client participate in the Securities-
Based Lending Program. For more information about
referral compensation paid to Baird Consultants and
related conflicts of interest, please see “Baird Referral
at
Programs”
bairdwealth.com/retailinvestor.
Baird Consultants Receive Benefits from Product
Providers
Consultants
receive
Marketing Support and Revenue Sharing from Mutual
Fund and UIT Sponsors
Baird receives marketing support or revenue sharing
payments (“marketing support”) from the sponsors and
investment advisers of certain mutual funds. These
payments, which are based on sales of, or client assets
invested in, such funds, are intended to compensate
Baird for providing marketing, distribution and other
services for the mutual funds. Marketing support is not
paid by sponsors or investment advisers of mutual funds
on mutual fund assets held in investment advisory
Retirement Accounts to the extent prohibited by
law. Baird received marketing support
applicable
payments over the past two calendar years from the
sponsors or investment advisers of Alliance Bernstein
Funds, American Funds, Franklin Templeton Funds,
Goldman Sachs Funds, Hartford Funds, Invesco Funds,
John Hancock Funds, JPMorgan Funds, Lord Abbett
Funds, MFS Funds, PIMCO Funds and Principal Funds.
Baird
non-cash
generally
compensation and other benefits from Baird and from
sponsors of investment products with which Baird does
business. Such non-cash compensation and other
benefits may include invitations to attend conferences or
educational seminars, payment of related travel, lodging
and meal expenses, and
receipt of gifts and
entertainment. For example, Baird Consultants are
invited to educational conferences hosted by sponsors of
mutual funds, annuities and other investment products,
with the costs associated with such conference (including
travel and lodging) paid by the sponsors. In addition,
Baird Consultants hold client events with some or all of
the costs of such events paid by sponsors of investment
products. Product sponsors may also provide gifts and
entertainment in connection with those or other events.
These benefits present a conflict of interest in that they
give Baird Consultants an incentive to use, select or
recommend investment products and their sponsors that
provide the greatest levels of such benefits. Please see
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Baird ICS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
“Revenue Sharing/Marketing Support and Other Third
Party Payments” at bairdwealth.com/retailinvestor for
more information.
Trust Services Arrangements
likely
to maintain
joint accounts, 529 plan accounts and UGMA/UTMA
accounts, because if a client has different types of
accounts with Baird, the client brings more of the client’s
investable assets to Baird, on which fees can be
generated, thereby increasing Baird’s revenues and the
client’s Baird Consultant’s compensation. Also, if a client
has more account types with Baird, the client is
statistically more
the client’s
relationship with Baird and the client’s Baird Consultant
for longer periods of time.
Baird Stock Ownership
Baird and Baird Consultants have an incentive to
recommend that a client retain Baird Trust for the client’s
trust services needs rather than an unassociated firm and
to recommend arrangements that involve Baird and the
Baird Consultant providing investment advisory services
to the client and Baird Trust only providing trust
administration services because it is more profitable for
them. Please see “Advisory Business—Additional Service
Information—Trust Services Arrangements” above for
more detailed information.
Investment Advisory and Brokerage Account and
Service Recommendations
to a
client even
though
Most Baird Consultants own common stock of BFG,
Baird’s ultimate parent, and when offered the opportunity
to buy BFG stock they usually do so. The amount of BFG
stock that a Baird Consultant may purchase is based in
part on the Baird Consultant’s total production level. A
client’s Baird Consultant thus has an incentive to make
recommendations that increase the Baird Consultant’s
total production on the client’s accounts with Baird.
Moreover, revenues from Baird’s PWM department, in
which Baird Consultants operate, contribute substantially
to BFG’s overall revenues and profitability, and the
performance of BFG’s stock price is largely due to the
profitability of Baird’s PWM department. As a result, a
client’s Baird Consultant’s ownership of BFG stock creates
a financial incentive to make recommendations to the
client that increase the amount of revenues generated
from the client’s accounts with Baird, even if those
recommendations will not increase the Baird Consultant’s
production, so as to
increase the revenues and
profitability of Baird’s PWM department and thus of BFG,
which will serve to grow the value of the BFG stock. For
example, ownership of BFG stock, the performance of
which is impacted by the success of Associated Parties,
provides a client’s Baird Consultant an incentive to use,
select or recommend Associated Investment Products
and Services
such
recommendation does not increase the client’s Baird
Consultant’s production.
Other Client Relationships
Baird and Baird Consultants generally have a financial
incentive to recommend investment advisory accounts to
clients rather than brokerage accounts because Advisory
Fee revenue is recurring, more predictable and typically
greater than the revenues Baird earns, and the
compensation Baird Consultants receive, from brokerage
accounts. In addition, because Advisory Fees are paid by
a client regardless of the trade activity in the client’s
advisory account, Baird will receive greater revenue, and
the client’s Baird Consultant will receive greater
compensation, from a low trade-activity advisory account
than from a low trade-activity brokerage account. Baird
and Baird Consultants thus have an incentive to
recommend an investment advisory account to a client
rather than a brokerage account if the client has, or is
expected to have, lower levels of trading activity in the
client’s Account. However, because Baird’s revenues and
the compensation paid to Baird Consultants from
brokerage accounts increase as the level of trading
increases, Baird and Baird Consultants have an incentive
to recommend a brokerage account to a client rather than
an investment advisory account if the client has, or is
expected to have, significant trading activity in the
client’s Account. Baird Consultants also have a financial
incentive to recommend certain wealth management
services, such as financial planning. Please see “Fees and
Compensation—Advisory Fees—Advisory Fee Payments
to Baird and Baird Consultants” above for more detailed
information.
Certain client accounts overseen by Baird and Baird
Consultants may have similar investment objectives and
strategies but may be subject to different fee schedules
or commission rates. Thus, Baird and
its Baird
Consultants have an incentive to favor client accounts
that generate a higher level of compensation.
Account Transfers and New Accounts
Relationships with Issuers of Securities
Baird and a client’s Baird Consultant have an incentive to
recommend that the client transfer the client’s Accounts
to Baird and establish new accounts with Baird (including
IRA rollovers) because doing so will result in increased
revenues to Baird and compensation for the Baird
Consultant.
Recommendations to Open Different Types of Accounts
From time to time, Baird may have proprietary
investments in companies or issuers whose securities are
offered and sold to clients, a Baird Consultant or another
Baird associate may have significant investments in
companies or issuers whose securities are offered and
sold to clients, or a Baird Consultant or another other
Baird associate (or their spouses, partners or family
members) may have a position as an officer or director
of a company or issuer whose securities are offered and
sold to clients. In such cases, Baird and/or a client’s Baird
Baird and Baird Consultants have an incentive to
recommend that a client open different types of accounts
with Baird, such as individual accounts, IRA rollovers,
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
law or agreements
Consultant will have an incentive to recommend that the
client invest in those companies.
Baird Consultants Transferring to Baird
prohibited by applicable
from
disclosing such information to clients or acting upon such
information with respect to any client Account. Baird’s
other activities thus present a potential conflict of interest
because such activities may limit Baird’s ability to advise
or manage client Accounts.
Other Conflicts of Interest
A Baird Consultant joining Baird from another firm has an
incentive to recommend that a client to transfer the
client’s accounts from such firm to Baird because doing
so will increase the Baird Consultant’s compensation.
Please see “Fees and Compensation—Advisory Fees—
Advisory Fee Payments to Baird, Baird Consultants and
Investment Managers” above
for more detailed
information.
Baird Underwritten Offerings
Baird offers to clients other investment products and
services not described in this Brochure. These investment
products and services provide different
levels of
compensation to Baird and its Baird Consultants. Baird
and its Baird Consultants have an incentive to favor those
investment products and services that generate a higher
level of compensation than those that generate a lower
level of compensation. For more information about the
other investment products and services offered by Baird,
clients should contact Baird or a Baird Consultant.
Baird and Baird Consultants have an incentive to
recommend that clients purchase securities in offerings
underwritten by Baird because
the underwriting
compensation that Baird and Baird Consultants will earn
on those offerings tends to be higher than the
compensation they would normally receive if clients were
to buy them in the secondary market, and because the
profitability of underwritten offerings to Baird depends
upon Baird’s ability to sell the securities allocated to Baird
in the offering.
Baird’s Other Broker-Dealer and Related Activities
Other sections of this Brochure also describe instances
when Baird and its Baird Consultants may recommend to
clients, and may buy and sell for client’s Account,
securities in which Baird and its Associated Parties and
associates have a material financial interest or practices
that present a conflict of interest. For more information,
please see “Advisory Business—Advisory Fees—Advisory
Fee Payments to Baird and Baird Consultants” and “Other
Financial Industry Activities and Affiliations” above, and
“Client Referrals and Other Compensation” below.
Addressing Conflicts
The investment advice provided to a client may be based
on the research opinions of Baird’s research departments.
Baird does, and seeks to do, business with companies
covered by those research departments and as a result,
Baird may have a conflict of interest that could affect the
content of its research reports.
in
this Brochure,
The foregoing activities could create a conflict of interest
with clients. In addition to the measures described above,
Baird addresses conflicts posed by those activities
through disclosure
the client’s
agreements with Baird, the Client Relationship Booklet
and prospectuses, offering documents or other disclosure
documents provided or made available to clients. Baird
has also adopted a Code of Ethics and other internal
policies and procedures for Baird and its associates that:
• require them to provide investment advice that is
the
for advisory clients (based upon
Baird and its Associated Parties and associates may buy
or sell investments that are recommended to or owned
by a client for their own accounts, or they may act as
broker or agent for other clients buying or selling those
investments. Those transactions may include buying or
selling investments in a manner that differs from, or is
inconsistent with, the advice given to a client, and those
transactions may occur at or about the same time that
such investments are recommended to or are purchased
or sold for a client’s account.
suitable
information provided by such clients);
• address Baird’s and its associates’ trading activities
and are designed to prevent them from improperly
benefiting from the trading activities of Baird’s advisory
clients; and
• address and limit cash and non-cash benefits provided
to Baird Consultants by third parties in an attempt to
avoid any question of propriety or any conduct
inconsistent with Baird’s high standards of ethics.
Baird and Baird Consultants have an incentive to favor
the securities of issuers for which Baird’s Global
Investment Banking, Fixed Income Capital Markets
(including Baird Public Finance) and Institutional Equities
and Research Departments provide services due to the
compensation received by Baird and Baird Financial
Advisors. See “Other Financial Industry Activities and
Affiliations—Certain Relationships and Arrangements—
Baird and Associated Parties” above.
Duration Compensation Will Be Received
Baird and its associates, by reason of Baird’s broker-
dealer, investment banking or other activities, may from
time to time acquire information deemed confidential,
material and non-public, about corporations or other
entities and their securities. Baird and its associates are
If a client holds any of the investment products described
above, Baird, its Associated Parties and associates will
receive the fees and payments described above for the
duration of the client’s advisory relationship with Baird.
In some circumstances, the receipt of such compensation
42
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
may extend beyond a client’s advisory relationship with
Baird if the client continues to hold those assets at Baird.
circumstances, Baird may agree to provide such services
and serve as custodian under a separate agreement. A
client should consult with the client’s Baird Consultant or
review Baird’s Form ADV Part 2A Brochure and
agreement for the other advisory program or service for
more information.
If Baird, or an Associated Party or associate of Baird,
receives any compensation or benefit described in this
Brochure from or related to a client’s investment, they
will generally retain the compensation or benefit. Except
as otherwise described above, Baird generally does not
rebate these amounts to a client’s Account or credit the
amount against the Advisory Fees payable by a client
unless such compensation may not be retained under
applicable law or regulation.
Investment Discretion
Baird and Baird Consultants do not have discretionary
authority to buy or sell securities for client Accounts or
otherwise act for client Accounts in connection with the
Services. A client retains full discretionary authority over
client’s accounts with respect to purchasing, holding,
exchanging, converting, selling or otherwise transacting
in securities or other assets for client’s accounts.
Brokerage Practices
Baird does not recommend or select broker-dealers to
effect transactions for client Accounts as part of the
Services.
Voting Client Securities
Baird does not have authority to vote proxies with respect
to the securities held in the client’s Account or otherwise
act for client Accounts in connection with the Services. A
client retains the right to vote proxies with respect to the
securities held in such Accounts and is solely responsible
for voting any such proxies.
Review of Accounts
The nature and frequency of client Account reviews
performed by Baird Consultants and the reports provided
to clients varies by the particular needs of each client and
will be set forth in the client’s Consulting Agreement.
However, Baird Consultants generally review client
Accounts at least annually. A client receives reports on a
periodic basis with such frequency as the client and Baird
agree in the client’s agreement. ICS clients currently
receive those reports on an annual, semi-annual or
quarterly basis. Such reports show asset performance
compared to benchmarks within the same asset class.
Financial Information
Baird does not require or solicit prepayment of more than
$1,200 in fees per client six months or more in advance
and, thus, has not included a balance sheet of its most
recent fiscal year. Baird is not aware of any financial
condition that is reasonably likely to impair its ability to
meet its contractual commitments to clients, nor has it
been the subject of a bankruptcy petition at any time
during the past ten years.
in some
instances. When applicable,
Client Referrals and Other Compensation
Baird may provide compensation to individuals who refer
clients
the
compensation paid is a percentage of the client’s fee
payments or the value of the client’s Account. The
amount of compensation will vary, with the specific level
determined based upon consideration of various factors
including, but not limited to, the individual’s role in
developing the client relationship and the assets under
management. Baird may pay these fees to registered
representatives of Baird and its Associated Parties as well
as to unassociated solicitors that have entered into a
written agreement with Baird.
Baird and its Associated Parties and associates may
receive certain economic benefits in connection with
providing advisory services to clients, which are
described in the sections entitled “Other Financial
Industry Activities and Affiliations” and “Code of Ethics,
Participation or Interest in Client Transactions and
Personal Trading” above.
Custody
Baird does not have custody of client assets as part of the
Services. However, some clients may elect to establish a
brokerage account or participate in other advisory
programs or services provided by Baird to implement the
advice provided by Baird Consultants. Under those
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Appendix A
Associated Investment Products and Services
Entity Type
Name
Relationship
Baird Advisors1
Baird Department
Baird Equity Asset Management1
Baird Department
Chautauqua Capital Management1
Baird Department
55I, LLC (d/b/a 55ip, “55ip”)
Associated
Investment Advisor
GAMMA Investing, LLC
Affiliated
Greenhouse Fund GP LLC
Related
Greenhouse Funds LLLP
Related
LoCorr Fund Management, LLC
Related
Reinhart Partners, LLC
Affiliated
Riverfront Investment Group, LLC
Affiliated
Dual Registrant2
Strategas Securities, LLC
Affiliated
Trust Company
Baird Trust Company1
Affiliated
Baird Funds, Inc.1
Affiliated
Bridge Builder Trust (Baird series)
Affiliated
Mutual Fund
Financial Investors Trust (Riverfront series)
Affiliated
LoCorr Investment Trust
Related
Managed Portfolio Series Trust (Reinhart series)
Affiliated
Pace® Select Advisors Trust (Baird Series)
Affiliated
Advisors’ Inner Circle Fund III (Strategas series)
Affiliated
ETF
ALPS ETF Trust (Riverfront Series)
Affiliated
First Trust Exchange-Traded Fund III (Riverfront series)
Affiliated
Automated Quantitative Analysis (AQA®) Portfolio Series
Affiliated
UIT
Dividend Income Trust (DIT) Series
Affiliated
Strategas Trust, Series 1-1
Affiliated
CIT
Reliance Trust Institutional Retirement Trust (Baird/Chautauqua series)
Affiliated
Greenhouse Master Fund LP
Related
Hedge Fund
Greenhouse Onshore Fund LP
Related
Greenhouse Overseas Fund Ltd.
Related
Chautauqua Global Growth Equity QP Fund, LP
Affiliated
Private Fund
Chautauqua International Growth Equity QP Fund, LP
Affiliated
Chautauqua Series Fund, LLC
Affiliated
Appendix A - 1
Baird ICS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Venture Partners Management Company III, LLC
Baird Venture Partners III Limited Partnership
Affiliated
BVP III Affiliates Fund Limited Partnership
BVP III Special Affiliates Limited Partnership
Baird Venture Partners Management Company IV, LLC
Baird Venture Partners IV Limited Partnership
Affiliated
BVP IV Affiliates Fund Limited Partnership
BVP IV Special Affiliates Limited Partnership
Baird Venture Partners Management Company V, LLC
Baird Venture Partners V Limited Partnership
Affiliated
BVP V Affiliates Fund Limited Partnership
BVP V Special Affiliates Fund Limited Partnership
Baird Capital Partners Management Company V, LLC
Baird Capital1,3
Baird Capital Partners V Limited Partnership
Affiliated
Investment Advisor
BCP V Affiliates Fund Limited Partnership
Private Equity Fund
BCP V Special Affiliates Limited Partnership
Baird Capital Management Company, LLC
Baird Venture Partners GP VI, LLC
Baird Venture Partners VI LP
Affiliated
BVP VI Affiliates Fund LP
BVP VI Special Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management I LP
Baird Capital Global Fund I LP
Affiliated
Baird Capital Global Fund I-DE LP
BCGF I Special Affiliates LP
BCGF I Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management II LLC
Baird Capital Global Fund II Limited Partnership
Affiliated
BCGF II Affiliates Fund Limited Partnership
BCGF II Special Affiliates Limited Partnership
Appendix A - 2
Baird ICS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Capital Management Company, LLC
Baird Capital Global GP III LLC
Baird Capital Global Fund III LP
Affiliated
Baird Capital1,3
BCGF III Affiliates Fund LP
Investment Advisor
BCGF III Special Affiliates LP
Private Equity Fund
Baird Capital Partners Europe Limited4
Baird Capital Partners Europe II LP
Affiliated
Baird Capital Partners Europe II Special Affiliates LP
The Growth Fund
Baird Principal Group Management Company I, LLC
Baird Principal Group5
Baird Principal Group Partners Fund I Limited Partnership
Investment Advisor
Baird Principal Group Management Company II, LLC
Affiliated
Private Equity Fund
Baird Principal Group Partners Fund II Limited Partnership
Baird Principal Group Management Company, LLC
Baird Principal Group Partners Fund III, LP
Holding Company
Sagard Holdings Management, Inc.6
Associated
1. Participates in a Baird PWM Referral Program that pays compensation to Baird Consultants for eligible referrals.
2. Registered with the SEC as a broker-dealer and investment advisor.
3. Baird Capital, Baird’s private equity business.
4. Baird Capital Partners Europe Limited, an English limited company, is regulated and authorized by the Financial Conduct
Authority.
5. Baird Principal Group, a group within Baird that has private equity funds only available to Baird employees.
6. Baird has a contractual relationship with and a small minority investment in Sagard Holdings Management, Inc., a
holding company for various financial services businesses whose investment products are made available to clients under
the Services. See “Other Financial Industry Activities and Affiliations—Certain Relationships and Arrangements—Baird and
Associated Parties” above for more information.
Appendix A - 3
Baird ICS Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Additional Brochure: BAIRD INSTITUTIONAL EQUITY RESEARCH SERVICES (2026-03-27)
View Document Text
Baird Institutional Equities and Research
Form ADV Part 2A Brochure
March 27, 2026
Institutional Equity Research Services
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue
Milwaukee, WI 53202
IER-HD@rwbaird.com
rwbaird.com
Member FINRA & SIPC
SEC File No. 801-7571
This brochure (“Brochure”) provides information about the qualifications and business practices of
Robert W. Baird & Co. Incorporated (“Baird”) and its Institutional Equities and Research Department’s
Institutional Equity Research Services. Clients should carefully consider this information before
becoming a client of Baird. If you have any questions about the contents of this Brochure, please
contact us at the email address listed above. The information contained in this Brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any state
securities authority. Additional information about Baird is available on the SEC’s website at
www.adviserinfo.sec.gov.
Material Changes
Robert W. Baird & Co. Incorporated (“Baird”) updated the Form ADV Part 2A brochure for its Institutional Equities and
Research Department (the “Brochure”) on March 27, 2026. The following summary discusses the material changes that
Baird has made to the Brochure since March 21, 2025, the date of the last annual update to the Brochure.
• Baird updated information about Baird’s regulatory assets under management. See the Section of the Brochure
entitled “Advisory Business—Robert W. Baird & Co. Incorporated” for more information.
• Baird updated its disclosures about the information and tools used by research analysts when formulating
investment advice, which may include the use of artificial intelligence (“AI”) tools, and the related risks. See the
Section of the Brochure entitled “Methods of Analysis, Investment Strategies and Risk of Loss” for more
information.
• Baird updated information about Baird’s affiliates. See the Section of the Brochure entitled “Other Financial Industry
Activities and Affiliations” for more information.
A client should note that the foregoing summary only discusses material changes made to the Brochure since March 21,
2025. The updated Brochure contains changes that are not listed above.
ii
Baird IER Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Table of Contents1
Advisory Business .......................................................................................................... 1
Robert W. Baird & Co. Incorporated .............................................................................. 1
Description of Research Services ................................................................................... 1
Additional Service Information ...................................................................................... 1
Fees and Compensation ................................................................................................. 2
Fees for Research Services ........................................................................................... 2
Other Fees and Expenses ............................................................................................. 2
Other Compensation Received by Baird ......................................................................... 2
Performance-Based Fees and Side-By-Side Management ............................................... 2
Types of Clients .............................................................................................................. 2
Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 2
Research Services Risks ............................................................................................... 4
Investment Risks ........................................................................................................ 4
Disciplinary Information ................................................................................................ 4
Other Financial Industry Activities and Affiliations ........................................................ 6
Baird’s Broker-Dealer Activities ..................................................................................... 6
Certain Associated Parties ............................................................................................ 6
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading........................................................................................................ 6
Code of Ethics ............................................................................................................ 6
Participation or Interest in Client Transactions ................................................................ 7
Brokerage Practices ....................................................................................................... 8
Review of Accounts ........................................................................................................ 8
Client Referrals and Other Compensation ....................................................................... 8
Custody .......................................................................................................................... 8
Investment Discretion .................................................................................................... 8
Voting Client Securities .................................................................................................. 8
Financial Information ..................................................................................................... 8
1 The SEC requires all investment advisers to organize their Form ADV Part 2A Brochure according to specific categories of
information, even though some categories of information may not apply to the business of certain investment advisers.
Where a required category is not relevant to its business, Baird Institutional Equities and Research has listed the category
below and stated that it does not apply to its business.
iii
Baird IER Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Advisory Business
This Brochure describes the Institutional Research
Services that the Institutional Equities and Research
division of Robert W. Baird & Co. Incorporated (“Baird”)
offers to its clients. Baird is registered with the Securities
and Exchange Commission (“SEC”) as an investment
adviser under the Investment Advisers Act of 1940, as
amended (the “Advisers Act”).
research
analysts,
other
The information contained in this Brochure is current as
of the date above and is subject to change at Baird’s
discretion. Please retain this Brochure for your records.
Robert W. Baird & Co. Incorporated
Baird
is a privately-held, employee-owned global
investment and wealth management firm formed in the
State of Wisconsin in 1919.
Description of Research Services
Baird offers the equity research services described in this
Brochure (the “Research Services”) to institutional clients
through its Institutional Equities and Research (“IER”)
division. The Research Services made available to clients
include equities-based research reports, surveys and
analyses about companies, industries, sectors, markets
and macro-economic developments produced by Baird
research-related
IER
communications from IER research analysts, and access
to research analysts including via attendance at industry
conferences. Some of the Research Services may also be
provided by other Baird IER representatives in selected
circumstances as requested by a client and agreed upon
by Baird. The specific Research Services provided to a
particular client vary based upon the client’s needs and
will be set forth in the client’s agreement with Baird (the
“Agreement”).
Baird is owned indirectly by its associates through several
holding companies. Baird is owned directly by Baird
Financial Corporation (“BFC”). BFC is, in turn, owned by
Baird Financial Group, Inc. (“BFG”), which is the ultimate
parent company of Baird. Associates of Baird own
substantially all of the outstanding stock of BFG.
Baird’s investment advisory relationship with a client is
strictly limited to Research Services provided to the client
in exchange for a cash fee. To the extent a client receives
research or other advice incidental to brokerage services
such as in consideration of commissions or other trading-
related compensation, the client should note that such
research or advice is not an investment advisory service.
See “Additional Service Information – Brokerage and
Other Services” below for more information.
strategies;
research,
analysis
the specific
its services separately or
Baird research analysts provide Research Services with
respect to over 700 individual companies or securities
categorized within
five broad market sectors: (i)
Consumer and Retail, (ii) Financial Services, (iii)
Healthcare and Life Sciences, (iv) Industrial, (v) Real
Estate, and (vi) Technology and Services. In connection
with its provision of the Research Services, Baird does not
tailor such services to the individual needs of specific
clients and the Research Services are not customized to
meet
investment objectives, goals,
strategies, financial needs or risk profile of any client who
receives the Research Services (nor any customers of
such clients).
Through its Private Wealth Management and Asset
Management divisions, Baird offers various investment
advisory services to retail and institutional clients,
including services not described in this Brochure. These
investment advisory services Baird offers
include:
portfolio management and analysis; analysis and
regarding asset allocation and
recommendations
investment
and
recommendations regarding investment managers and
individual securities; investment consulting; financial
planning; investment policy development; and account
performance monitoring. Baird also offers clients
execution of brokerage transactions and administrative
services, including maintaining custody of account
assets. Clients may also negotiate other services with
Baird. Baird offers
in
combination with other services.
Additional Service Information
Brokerage and Other Services
Baird participates in wrap fee programs not described in
this Brochure and it provides portfolio management
services in connection with those programs. Baird
receives a portion of the wrap fee paid by clients for
providing portfolio management services under those
wrap fee programs.
billion
in
regulatory
assets
As of December 31, 2025, Baird had approximately
$394.0688
under
management, approximately $289.4898 billion of which
was managed on a discretionary basis and approximately
$104.5790 billion of which was managed on a non-
discretionary basis.
Baird is dually registered as an investment adviser and a
broker-dealer and offers both investment advisory and
brokerage services. Although Baird acts as investment
adviser when it provides the Research Services for a cash
fee, the investment advisory relationship does not extend
to other services we or our affiliates provide or other
arrangements we or our affiliates have with clients.
These non-advisory services may include invitations to
industry conferences and other corporate access
services, custody, trade execution or other brokerage
services, the provision of investment advice solely
incidental to brokerage services, including market color,
analysis, perspectives, opinions, commentaries or ideas
provided by IER representatives or affiliates of Baird.
Baird’s investment advisory relationship with a client is
1
Baird IER Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
strictly limited to Research Services provided to the client
in exchange for a cash fee.
Services. See “Participation in Client Transactions –
Research Activities” below for more information.
A client has the option to obtain execution of trades,
including the purchase of investment products that Baird
may recommend, through broker-dealers and other
brokers or agents that are not affiliated with Baird.
fees)
Specifically, where Baird provides research or other
advice in consideration of commissions or other trading-
related compensation, Baird is acting in its capacity as a
broker-dealer and not an investment adviser. Brokerage
services are regulated under different standards than
those that apply to investment advisory services and
differ in terms of the types of investment assistance
provided, fees charged and the rights and obligations of
the parties involved. Any securities transactions or
orders that may be executed, routed or otherwise
processed through Baird will be handled by Baird solely
in its capacity as broker-dealer.
Performance-Based Fees and Side-By-Side
Management
Baird does not charge any fees or maintain other
arrangements involving the payment of fees based upon
the capital gains or capital appreciation of a client’s assets
in connection with
(i.e., performance-based
provision of the Research Services.
Other divisions of Baird do, however, advise client
accounts that are subject to performance-based fee
arrangements.
Fees and Compensation
Fees for Research Services
Fees for provision of the Research Services are separately
negotiated with each client based upon the nature of the
services provided and other factors. Fees are payable as
agreed upon by the parties, typically in arrears. Baird
generally does not solicit or accept pre-paid fees for
provision of the Research Services unless requested by
the client. The specific fee and terms of payment will be
set forth in the client’s Agreement.
Types of Clients
Baird offers the Research Services to institutional clients
including but not limited to investment advisers, pension
and retirement plans, corporations and other entities,
mutual funds, insurance companies, hedge funds, private
equity funds, trusts and banks. Clients are not required
to open or maintain a trading account with Baird or an
affiliated broker-dealer to receive the Research Services.
Other Fees and Expenses
The fees paid to Baird by the client only cover the
Research Services provided by Baird. A client may also
pay for other services, such as securities trade execution
and custody, separately when effecting securities trades.
Methods of Analysis, Investment Strategies
and Risk of Loss
The Research Services consist of impersonal investment
advisory services that analyze a broad range of securities
and companies. When analyzing a specific company (i.e.,
“fundamental research”), written research reports will
generally contain one of the three investment ratings
detailed below with respect to the subject company:
• O-Outperform. An “Outperform” rating means, in the
research analyst’s opinion, the subject company is
expected to outperform, on a total return, risk-
adjusted basis, the broader U.S. equity market over
the next 12 months.
• N – Neutral. A “Neutral” rating means, in the research
analyst’s opinion, the subject company is Expected to
perform in line with the broader U.S. equity market
over the next 12 months.
Other Compensation Received by Baird
Baird is registered as a broker-dealer under the Securities
Exchange Act of 1934, as amended (the “Exchange Act”),
and in such capacity, Baird provides brokerage and
related services to clients, including the purchase and
sale of individual stocks, bonds, mutual funds, private
investment funds, and other securities, and sales of life
insurance policies and annuities. Baird
receives
compensation based upon the sale of such securities and
other investment products, including asset-based sales
charges and service fees on the sale of mutual funds.
Should a client use Baird or an affiliated broker-dealer to
execute trades, the client will incur transaction costs such
as commissions, mark-ups or mark-downs and spreads
payable to Baird or the affiliated broker-dealer. Such
costs are exclusive to and in addition to the fee for the
Research Services.
• U – Underperform. An “Underperform” rating means, in
the research analyst’s opinion, the subject company is
Expected to underperform on a total return, risk-
adjusted basis, the broader U.S. equity market over
the next 12 months.
The compensation received by Baird or an affiliate of
Baird presents a conflict of interest because it gives Baird
an incentive to recommend investment products based
upon the compensation received rather than on a client’s
needs. Baird addresses the conflict through disclosure in
this Brochure. In addition, IER research analysts are not
compensated based upon the sale of any security,
including those that are the subject of the Research
2
Baird IER Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
In addition, written research reports will generally assign
one of the four Risk Ratings detailed below with respect
to the subject company:
• Fundamental Analysis. Fundamental analysis involves
a detailed analysis of specific companies using financial
statements and financial ratios, information regarding
management, competitive advantages and markets, in
an attempt to determine the value or develop an
opinion regarding the expected value of a security.
Fundamental analysis may include qualitative and
quantitative analyses.
• L-Lower Risk. A Lower Risk rating means, in the
research analyst’s opinion, the covered company
represents a higher-quality company for investors
seeking capital appreciation or income with an
emphasis on safety. Company characteristics may
include: stable earnings, conservative balance sheets,
and an established history of revenue and earnings.
• Qualitative Analysis. Qualitative analysis involves the
use of subjective judgment to analyze factors that may
be difficult to quantify or measure objectively.
• Quantitative Analysis. Quantitative analysis
is a
method of evaluating securities by analyzing a large
amount of data through the use of algorithms or
models.
• A- Average Risk. An Average risk rating means, in the
research analyst’s opinion, the covered company
represents a growth situation for investors seeking
capital appreciation with an emphasis on safety.
Company characteristics may
include: moderate
volatility, modest balance-sheet leverage, and stable
patterns of revenue and earnings.
• Technical Analysis. Technical analysis is a method of
analyzing past price and volume patterns and trends in
the trading markets or an individual security to attempt
to predict the direction of both the overall market and
specific investments.
• H-Higher Risk. A Higher Risk rating means, in the
research analyst’s opinion, the covered company
represents a higher-growth situation appropriate for
the
investors seeking capital appreciation with
acceptance of risk. Company characteristics may
include: higher balance-sheet
leverage, dynamic
business environments, and higher levels of earnings
and price volatility.
investment decision.
• S- Speculative Risk. A Speculative Risk rating means,
in the research analyst’s opinion, the covered company
represents a high-growth situation appropriate only for
investors willing to accept a high degree of volatility
include:
and risk. Company characteristics may
unpredictable earnings, small capitalization, aggressive
growth strategies, rapidly changing market dynamics,
high leverage, extreme price volatility and unknown
competitive challenges.
All Risk or Investment ratings are determined without
regard to any client’s particular situation, needs or
objectives.
Research reports and research analyst commentaries
may be modified from time to time without notice and
may express opinions or provide investment perspectives
that are inconsistent with prior opinions or perspectives
of the research analyst preparing the report or opinions
or perspectives of other Baird representatives. Clients
must consider their particular circumstances and needs
and make their own independent investigation before
Baird expressly
making an
for the completeness,
disclaims any responsibility
accuracy or timeliness of the Research Services provided
and Baird is under no duty to update or revise the
Research Services, the contents thereof or analyses,
recommendations or opinions expressed
therein.
Nothing contained in this paragraph or elsewhere in this
document shall constitute a waiver by clients of any of
their legal rights under applicable U.S. federal securities
laws or any other laws whose applicability is not
permitted to be waived.
Any risk or investment rating assigned in a report is
based solely on the analyst’s evaluation of the merits of
investing in the security without regard to other factors.
Any such recommendation does not consider a client’s
particular circumstances or needs.
Baird may rely on third-party sources for information that
it believes to be reliable in providing the Research
Services, but it does not guarantee the quality, accuracy
or completeness of any third party information or any
information or data. Baird makes no express or implied
warranties with respect to the Research Services or any
other information or data.
Research analysts perform analysis based on publicly-
available economic, industry, market and company data,
which include financial statements and financial ratios as
well as information regarding a company’s products and
services, market and management.
In providing the Research Services, research analysts or
others may use various forms of security analyses,
including the following:
Research analysts may use artificial intelligence (“AI”)
tools, such as machine learning, predictive analytics and
probabilistic modeling
tools, data processing and
automation tools, generative AI tools, visual, speech and
audio tools, specialized domain tools, and other similar
technologies and tools (collectively, “AI Tools”), in
formulating Research Services. Generally, the use of AI
Tools is limited to certain aspects of Baird’s investment-
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
factors including: expectations regarding government,
economic, monetary and fiscal policies; inflation and
interest rates; economic expansion or contraction; and
global or regional political events, such as economic and
banking crises. Holders of common stocks are generally
subject to greater risk than holders of preferred stocks
and debt obligations of the same issuer because common
stockholders generally have inferior rights to receive
payments from issuers in comparison with the rights of
preferred stockholders, bondholders and other creditors.
advice process, such as assisting with drafting of
materials, automation of workflow processes, and the
compilation, reproduction, organization, summarization,
analysis and interpretation of information. The use of AI
Tools is only supportive of Baird’s investment-advice
process and does not replace the professional judgment
of research analysts. All AI Tool-assisted outputs used in
formulating investment advice are subject to human
review before such outputs inform the Research Services.
In addition, research analysts are required to certify that
their research reports accurately reflect their personal
views.
Industry/Sector Risks. An investment in one or more
securities operating in an individual industry or sector are
subject to industry-specific risks. Any factors detrimental
to the performance of such industries as a whole will
disproportionately impact investment returns of these
securities. Investments focused in a particular industry
are subject to greater risk and a more impacted by
volatility than less concentrated investments.
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations, deceptive
behaviors and other flaws due to the construction of their
underlying models and the composition of their training
data, which can result in outputs that seem plausible but
are in fact inaccurate, incomplete, or misleading. The use
of AI Tools creates a risk that erroneous information could
negatively influence the investment-advice process.
Baird has established policies and procedures designed to
address the risks posed by AI Tools, which include
requirements that AI Tools pass a firm-level due diligence
process and that Baird associates obtain training and
independently verify AI Tool outputs.
financial
resources
and
Capitalization Size Risks. Small and mid cap stocks,
are often more volatile and less liquid than investments
in larger companies. The frequency and volume of trading
in securities of such companies may be substantially less
than is typical of larger companies. Therefore, the
securities of such companies may be subject to greater
and more abrupt price fluctuations. In addition, small-
and mid-size companies may lack the management
experience,
product
diversification of larger companies, making them more
susceptible to market pressures and business failure.
Research Services Risks
The analyses, perspectives, opinions and commentaries
included in the Research Services reflect the good faith,
personal views of the research analysts and others
providing the Research Services at the time such services
are provided and are based upon information available to
them. It is possible that such analyses, perspectives,
opinions and commentaries, predictions or beliefs about
future outcomes may prove to be incorrect.
Investment Risks
Risk of loss is inherent in any investment in securities that
clients should be prepared to bear. Clients should be
aware of the following risks associated with respect to an
investment in equity securities:
Short Sales Risks. Short selling runs the risk of loss if
the price of the securities sold short does not decline
below the price at which they were originally sold. This
risk of loss is theoretically unlimited, as there is no cap
on the amount that the price of a security may
appreciate. In addition, a lender may request, or market
conditions may dictate, that securities sold short be
returned to the lender on short notice, which may result
having to buy the securities sold short at an unfavorable
price. A client should not engage in short sales unless the
client is prepared and able to sustain significant losses.
Equity Securities Risks. Equity securities may
experience sudden, unpredictable drops in value or long
periods of decline in value. This may occur because of
factors that affect the securities markets in general, such
as adverse changes in economic conditions, the general
outlook for corporate earnings, interest rates or investor
sentiment. Equity securities may also lose value because
of factors affecting an entire industry or sector, such as
increases in production costs, or factors directly related
to a specific company, such as decisions made by its
management.
Disciplinary Information
In April 2016, Baird, without admitting or denying the
findings, consented to the sanctions and findings of
FINRA that it violated NASD Conduct Rule 3010, FINRA
Rule 3110, and FINRA Rule 2010, by failing to establish
and maintain a supervisory system and procedures
reasonably designed to ensure that customers who
purchased mutual fund shares received the benefit of
applicable sales charge waivers. In May 2015, Baird
began a review to determine whether Baird had provided
available sales charge waivers to eligible customers.
Based on this review, in May 2015, Baird self-reported to
FINRA that various eligible customers had not received
available sales charge waivers. Baird was found to have
disadvantaged certain retirement plan and charitable
organization customers that were eligible to purchase
Common Stock Risks. Common stocks are susceptible
to general stock market fluctuations and to volatile
increases and decreases in value as market confidence in
and perceptions of their issuers change. These investor
perceptions are based on various and unpredictable
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
206(4)-7 thereunder and pay a civil money penalty in the
amount of $250,000.
Class A shares in certain mutual funds without a front-
end sales charge. The findings also stated that these
customers were instead sold Class A shares with a front-
end sales charge or Class B or C shares with higher
ongoing fees and the potential application of a contingent
deferred sales charge. Baird was censured and required
to pay restitution to affected customers estimated to be
approximately $2.1 million including interest.
that was
reasonably designed
In July 2016, Baird, without admitting or denying the
findings, consented to the sanctions and to the entry of
findings of FINRA that the firm and a firm supervisor
within its Private Wealth Management business did not
reasonably supervise a former Financial Advisor who
misused a customer’s funds. The findings stated that the
supervisor did not reasonably follow-up on red flags
associated with a trade correction request submitted by
the Financial Advisor that should have alerted him to the
Financial Advisor's misuse of a customer’s funds. The
supervisor also did not follow certain of Baird’s written
supervisory procedures (“WSPs”) relating to trade
corrections. After the supervisor realized that the
Financial Advisor misused the customer’s funds, Baird
reimbursed the customer for the loss. The findings also
included that Baird did not establish and maintain a
supervisory system, including WSPs, for correcting trade
errors
to ensure
compliance with applicable securities laws, regulations
and rules. Baird was censured and fined $200,000.
In March 2019, Baird, without admitting or denying the
findings, consented to an order of the SEC, which found
that it violated Sections 206(2) and 207 of the Advisers
Act for making inadequate disclosures to advisory clients
about mutual fund share classes. The order was part of a
voluntary self-reporting program initiated by the SEC
called the “Share Class Selection Disclosure (or SCSD)
Initiative.” Under the program, 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 settlement terms imposed by the SEC,
including returning money to affected
investment
advisory clients. The central issue identified by the SEC
was that, in many cases, investment advisory firms
bought for or recommended to their investment advisory
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 advisory clients, and the
investment advisory firms did not adequately disclose
their receipt of 12b-1 fees and/or the conflict of interest
associated with those 12b-1 paying share classes. Baird
and many other firms self-reported under the program
and entered into substantially identical orders. By self-
reporting and consenting to the order, Baird agreed to a
censure and to cease and desist from committing or
causing any violations and future violations of Sections
206(2) and 207 of the Advisers Act. Baird also agreed to
establish a distribution fund and to deposit into that fund
the improperly disclosed 12b-1 fees received by Baird
plus prejudgment interest, which will be paid to affected
advisory clients. More information about the order is
contained in Baird’s Form ADV, which is available on the
SEC’s Investment Advisory Public Disclosure website at
https://www.adviserinfo.sec.gov/IAPD/Default.aspx or in
the SEC’s press release about the SCSD Initiative at
https://www.sec.gov/news/press-release/2019-28.
In June 2019, Baird, without admitting or denying the
findings, consented to the sanctions and to the entry of
findings of FINRA that between late April 2013 and early
July 2013 it published 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 and that the failure to disclose the research
analyst’s employment discussions with the issuer in the
research reports made those reports misleading. Baird
was censured and fined $150,000.
In September 2016, the SEC announced that 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. Baird also was ordered to cease and desist
committing or causing any violations and any future
violations of Section 206(4) of the Advisers Act and Rule
In September 2023, Baird entered into an Offer of
Settlement with the SEC, 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
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
its
have an application pending to register, as registered
representatives and associated persons of Baird to the
extent necessary or appropriate to perform their job
responsibilities.
Certain Associated Parties
Affiliated Broker-Dealers
Baird is affiliated, and may be deemed to be under
common control, with Strategas Securities, LLC
(“Strategas Securities”), which is registered with the SEC
as a broker-dealer and investment adviser, by virtue of
their common indirect ownership by BFG.
Affiliated Investment Advisers
that
certain Baird
Baird is affiliated, and may be deemed to be under
common control, with Strategas Asset Management, LLC
(“Strategas”), by virtue of their common indirect
ownership by BFG.
Other Affiliated Financial Services Firms and
Associated Parties
ADV
Part
1A
available
Baird is affiliated with other investment advisors, broker-
dealers, a trust company and other financial services
firms that offer their own investment products and
services. A list of Baird’s affiliates is available in Baird’s
Form
at
https://adviserinfo.sec.gov. Additional Associated Parties
are also identified under the “Other Useful Information”
tab of bairdwealth.com/retailinvestor. Baird IER does not
use or recommend those investment products and
services when providing the Research Services.
devices (“off-channel communications”) and for failing to
supervise
business-related
associates’
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. While Baird had policies and procedures
in place prohibiting such off-channel communications, it
supervisors
was discovered
communicated off-channel using non-Baird approved
methods on their personal devices about Baird’s broker-
dealer and investment adviser businesses, and the
findings were reported to the SEC. Baird took steps prior
to and after the SEC’s review, including implementing a
new communication tool designed for Baird associates’
personal devices, conducting training, and periodically
requiring requisite associates to provide an attestation
relating to their business-related communications. 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.
on
SEC’s
website
Additional information about Baird’s disciplinary history is
available
at
the
www.adviserinfo.sec.gov.
Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
Code of Ethics
Subject to the restrictions described below, Baird and its
affiliates and associates may engage in securities
transactions for their own accounts, including in the same
or related securities that are the subject of the Research
Services. These transactions may include trading in
securities in a manner that differs from, or is inconsistent
with, the advice given to Baird clients, and the
transactions may occur at or about the same time that
such securities are the subject of the Research Services.
This creates a potential for a conflict between the interest
of clients and the interests of Baird and its affiliates and
associates.
Other Financial Industry Activities and
Affiliations
Baird is registered with the SEC as a broker-dealer under
the Exchange Act and as an investment adviser under the
Advisers Act. Baird is also affiliated with, related to or
otherwise associated with certain broker-dealers,
investment advisors, other financial services firms and
investment products (collectively, “Associated Parties”)
including those that are identified and discussed below.
Certain Baird associates and certain management
persons of Baird may invest in investment products
managed or sponsored by Associated Parties.
Baird’s Broker-Dealer Activities
Baird IER offers brokerage accounts and related services
to its clients. Baird is also engaged in a broad range of
broker-dealer activities through its other business units,
including its Private Wealth Management, Investment
Banking, Public Finance and Institutional Equities
Services Departments. Certain Baird associates and
certain management persons of Baird are registered, or
To address the potential for conflicts of interest, Baird has
adopted a Code of Ethics (the “Code”) that applies to its
associates that provide the Research Services, their
supervisors, and certain associates who have access to
non-public information relating to the Research Services
(“Access Persons”). The Code prohibits Access Persons
from using knowledge about the Research Services to
profit personally, directly, or indirectly, by trading in his
or her personal accounts. In addition, an Access Person
must generally pre-clear his or her trades or obtain prior
authorization from his or her supervisor or Baird’s
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Compliance Department before executing a trade. The
Code provides for certain exceptions deemed appropriate
by Baird management or by Baird’s Compliance
Department. A copy of the Code is available to clients or
prospective clients upon request.
in securities and receives and retains compensation for
such services. In such capacity, Baird may act as agent
or principal in executing trades for client accounts, some
of whom may be clients who receive the Research
Services. Those securities trades and market making
activities involve buying or selling securities that are the
same as those discussed in reports and commentaries
included in the Research Services. However, Baird does
not intentionally buy or sell securities as a result of any
discussions about them in the Research Services and the
personnel providing such services do not receive copies
or drafts of research reports or commentaries before they
are delivered to clients.
Baird has also
implemented certain policies and
procedures relating to Baird’s and its associates’ trading
activities that are designed to prevent them from
improperly benefiting from the Research Services. In
addition, Baird’s Compliance Department monitors the
personal trading activities of all of Baird’s associates
providing the Research Services.
Participation or Interest in Client Transactions
Research Activities
In connection with the provision of the Research Services,
Baird does not have discretion over client accounts and
does not recommend or select the use of any particular
broker‐dealer to implement research recommendations,
although Baird in its capacity as a broker‐dealer seeks to
provide brokerage services to clients. Clients are not
required nor expected to use Baird or any other affiliate
to implement recommendations received or otherwise to
place orders for securities transactions.
Baird does, and seeks to do, business with companies
covered by Baird research analysts. Employees of Baird
or its affiliates may serve as officers of directors of
companies covered by research analysts. In addition,
Baird or its affiliates may hold securities of covered
companies in the ordinary course of their business such
as in connection with market making activities. As a
result of the foregoing, Baird will have a conflict of
interest in certain instances that could affect the content
of its research reports. Baird addresses this potential
conflict of interest through disclosure in this Brochure,
disclosure on research reports and by ensuring that
research analyst compensation does not take into
account these factors.
between
research
Baird and its associates, by reason of its broker-dealer or
other activities, may
from time to time acquire
information deemed confidential, material and non-
public, about corporations or other entities and their
securities. Baird and its associates are prohibited by
applicable law or agreements from disclosing such
information to clients or acting upon such information.
Baird’s other activities thus present a potential conflict of
interest because such activities may limit Baird’s ability
to provide the Research Services.
Other Conflicts of Interest
Baird offers to clients other investment products and
services, including asset management and other products
and services that are investment advisory in nature, not
described in this Brochure. These investment products
and services provide different levels of compensation to
Baird. However, it is not a condition or a requirement for
clients who pay for the Research Services to accept such
services from Baird or any affiliate.
Addressing Conflicts
The foregoing activities could create a conflict of interest
with clients. In addition to the measures described above,
Baird addresses conflicts posed by those activities
through disclosure in this Brochure, via the Research
Services, including disclosure on research reports, and in
the client’s agreements with Baird. Baird has also
adopted a Code of Ethics and other internal policies and
procedures for Baird and its associates that:
Research analyst compensation is based on: (1) the
correlation
analyst's
the
recommendations and stock price performance; (2)
ratings and direct feedback from investing clients,
institutional and retail sales force (as applicable) and
from independent rating services, but independent of
Baird’s investment banking department; (3) the research
analyst's productivity, including the quality of such
analyst's research and such analyst's contribution to the
growth and development of our overall research effort;
(4) compliance with all of Baird’s internal policies and
procedures; and (5) other considerations, such as Baird’s
assessment of the prevailing market rates for talent in
the sector the research analyst covers, but excluding the
analyst’s contributions to Baird’s investment banking
services activities. This compensation criteria and actual
compensation is reviewed and approved on an annual
basis by Baird's Research Oversight Committee. Analyst
compensation is derived from all revenue sources of the
firm, including revenues from investment banking, sales
and trading. Baird does not compensate research
analysts based on specific trading activity, specific
investment banking transactions, or their contributions to
Baird's investment banking services activities.
•
Baird’s Other Broker-Dealer and Related Activities
As a registered broker-dealer, Baird may buy or sell
securities for its own account in the ordinary course of its
market making activities. Baird also effects transactions
require them to provide the Research Services in a
manner that reflects the analyst’s personal views
about the companies or securities to which they
apply, to confirm that no part of his or her
compensation was, is or will be directly or indirectly
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
related to the specific recommendations or views
contained in any research report and to certify the
same on written research reports;
•
prohibit research analysts from owning stock in
companies covered by the analyst; and
•
address and limit cash and non-cash benefits
provided to research analysts by third parties in an
attempt to avoid any question of propriety or any
conduct inconsistent with Baird’s high standards of
ethics.
Brokerage Practices
Baird does not recommend or select broker-dealers to
effect transactions for client accounts as part of the
Research Services.
Review of Accounts
Provision of the Research Services does not require a
client establish an account with Baird. Accordingly, Baird
does not review client accounts.
Client Referrals and Other Compensation
Neither Baird nor its employees or supervised persons
receive any additional economic benefit (including, for
example, sales awards or other prizes) from any non-
client for providing the Research Services to clients.
Baird does not enter into any agreements or other
understanding under which Baird pays, directly or
indirectly, any compensation to third parties for client
referrals with respect to the Research Services.
Custody
Baird does not maintain custody of client funds or
securities in connection with the Research Services.
Investment Discretion
Baird does not have discretionary authority to buy or sell
securities for client accounts or otherwise act for client
accounts in connection with the Research Services.
Voting Client Securities
Baird does not have authority to vote proxies with respect
to the securities held in the client’s account or otherwise
act for client accounts in connection with the Research
Services.
Financial Information
Baird is not aware of any financial condition that is
reasonably likely to impair its ability to meet its
contractual commitments to clients, nor has it been the
subject of a bankruptcy petition at any time during the
past ten years.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Additional Brochure: BAIRD PRIVATE ASSET MANAGEMENT (2026-03-27)
View Document Text
Baird Private Asset Management
Brochure
March 27, 2026
Baird Private Asset Management
777 East Wisconsin Avenue
Milwaukee, Wisconsin 53202
Toll Free: 888-596-1592
www.rwbaird.com
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue
Milwaukee, WI 53202
1-800-792-2473
rwbaird.com
Member FINRA & SIPC
SEC File No. 801-7571
This brochure (“Brochure”) provides information about the qualifications and business practices of
Robert W. Baird & Co. Incorporated (“Baird”) and Baird Private Asset Management (“PAM”), part of
Baird’s Private Wealth Management department. Clients should carefully consider this information
before becoming a client of PAM. If you have any questions about the contents of this Brochure,
please contact PAM at the toll-free phone number listed above. The information contained in this
Brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority. Additional information about Baird is available on
the SEC’s website at www.adviserinfo.sec.gov.
Material Changes
Baird Private Asset Management (“PAM”), part of the Private Wealth Management department of Robert W.
Baird & Co. Incorporated (“Baird”), updated its Form ADV Part 2A brochure (the “Brochure”) on March 27,
2026. The following summary discusses the material changes that PAM has made to the Brochure since
March 21, 2025, the date of the last annual update to the Brochure.
• In January 2026, Baird’s direct parent corporation, Baird Financial Corporation (“BFC”), made a
significant minority investment in Reinhart Partners, LLC (“Reinhart”), an investment advisor that offers
investment products and services through the Programs. As a result of the investment transaction, Baird
and Reinhart are affiliated, providing Baird a financial incentive to use, select or recommend Reinhart
investment products and services.
• In September 2025, Baird entered into a strategic partnership with Sagard Holdings Management, Inc.
(“Sagard”). Baird’s direct parent corporation, BFC, acquired a minority ownership interest in Sagard and
the right to appoint a member to Sagard’s board of directors. Baird agreed to use best efforts,
consistent with its fiduciary duties and other regulatory responsibilities, to offer investment products
managed or sponsored by affiliates of Sagard deemed suitable by Baird for its PWM clients, providing
Baird a financial incentive to recommend such investment products. See the Section of the Brochure
entitled “Other Financial Industry Activities and Affiliations—Certain Relationships and Arrangements—
Baird and Associated Parties” for more information.
• Baird updated information about Baird’s regulatory assets under management. See the Section of the
Brochure entitled “Advisory Business” for more information.
• Baird updated its description of the DC Program. The DC Program is designed to accommodate a client
who wishes to independently select an investment manager not available in the PAM Recommended
Managers Service or BSN Program to manage the assets in the client’s Account. The Program is also
designed for a client that wants to independently select a manager and negotiate the manager’s
Portfolio Fee rate directly with the manager. Certain managers offer lower Portfolio Fee rates to clients
through the DC Program compared to the BAM, PAM Recommended Managers, or BSN Programs. A
client considering an SMA Strategy should discuss with client’s PAM Consultant SMA Strategy availability
and the different Portfolio Fee rates, costs, and the types and levels of service provided in connection
with the different Programs. If a client has decided to participate in the DC Program, upon the client’s
request, the client’s PAM Consultant may assist the client with the client’s negotiation with the manager
of the Portfolio Fee rate for the applicable SMA Strategy. The Portfolio Fee negotiated by the client could
be higher or lower than the Portfolio Fee that applies to the same SMA Strategy that is available through
other Programs. The client is ultimately responsible for understanding the differences between the SMA
Programs, deciding to participate in the DC Program, selecting the SMA Strategy, and negotiating and
agreeing to the Portfolio Fee rate.
• Baird updated information about tax management and direct indexing strategies, including the
associated limitations and risks. See the Sections of the Brochure entitled “Advisory Business—
Additional Service Information—Tax Management Services” and “Methods of Analysis, Investment
Strategies and Risk of Loss—Investment Strategies” for more information.
• Baird provided additional information about possible tax consequences of a client’s investment activities.
See the Section of the Brochure entitled “Advisory Business—Additional Service Information—Legal and
Tax Considerations” for more information.
• Baird updated the rates of Portfolio Fees charged by managers under the Services. See the Section of
the Brochure entitled “Fees and Compensation—Advisory Fees” for more information.
• Baird updated its disclosures about the research, information and tools used by Baird PWM home office
investment professionals and PAM Consultants when formulating investment advice, which may include
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the use of artificial intelligence (“AI”) tools, and the related risks. See the Section of the Brochure
entitled “Methods of Analysis, Investment Strategies and Risk of Loss—Methods of Analysis” for more
information.
• Baird included a description of the PWM Stock Opportunities List. See the Section of the Brochure
entitled “Methods of Analysis, Investment Strategies and Risk of Loss—Methods of Analysis—Certain
Eligible Product Lists” for more information.
• Baird updated investment risk information related to information security, cybersecurity, and other
technology‑related events, issuers’ use of AI, investments in digital assets, such as cryptocurrencies,
and those associated with recent events, such as those associated with the U.S. administration’s policy
initiatives, inflation, conflicts in Iran and the Middle East, the war between Ukraine and Russia, and the
strain in relationships between the U.S. and other countries. See the Section of the Brochure entitled
“Methods of Analysis, Investment Strategies and Risk of Loss—Principal Risks” for more specific
information.
• In March 2026, Baird entered into an Offer of Settlement with the Massachusetts Securities Division to
settle a regulatory matter relating to the timing of state investment adviser representative registration
approvals for two of Baird’s Financial Advisors located in Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals provided investment advisory services before their
Massachusetts registrations were completed as a form was missing from their application materials. 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.
• Baird updated information about firms affiliated with, related to, or otherwise associated with Baird. See
the Section of the Brochure entitled “Other Financial Industry Activities and Affiliations” and Appendix A
to the Brochure for more information.
A client should note that the foregoing summary only discusses material changes made to the Brochure
since March 21, 2025. The updated Brochure contains changes that are not listed above.
iii
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Table of Contents
Advisory Business ........................................................................................... 1
Robert W. Baird & Co. Incorporated ................................................................ 1
The Client-Baird Fiduciary Relationship ............................................................ 1
Summary of PAM’s Services ........................................................................... 2
Consulting Services ...................................................................................... 5
Discretionary Services ................................................................................... 6
PAM Investment Management Service ....................................................... 6
SMA Services ............................................................................................... 7
PAM Recommended Managers Service ....................................................... 7
Baird SMA Network Program .................................................................... 9
Dual Contract Program .......................................................................... 11
Other SMA Strategy Information ............................................................. 12
Additional Service Information ..................................................................... 13
Conversion, Exchange or Sale of Certain Investments ............................... 13
Complex Strategies and Complex Investment Products .............................. 13
Permitted Investments .......................................................................... 16
Unsupervised Assets ............................................................................. 17
Special Considerations for the Services .................................................... 18
Household Management ......................................................................... 18
Tax Management Services ..................................................................... 19
Investment Objectives ........................................................................... 21
Mutual Fund Share Class Policy ............................................................... 22
Custody Services .................................................................................. 23
Cash Sweep Program ............................................................................ 23
Trust Services Arrangements .................................................................. 25
Margin Loans ........................................................................................ 26
Securities-Based Lending Program .......................................................... 26
Other Non-Advisory Services .................................................................. 27
Client Responsibilities ............................................................................ 27
Retirement Accounts ............................................................................. 27
Legal and Tax Considerations ................................................................. 27
Account Requirements ........................................................................... 28
Fees and Compensation ................................................................................ 32
Advisory Fees ............................................................................................ 32
Fee Options and Fee Schedules............................................................... 32
Service Account Minimums ..................................................................... 34
Calculation and Payment of Advisory Fees ................................................ 34
Obtaining Services Separately: Brokerage or Advisory? Factors
to Consider ...................................................................................... 38
Advisory Fee Payments to Baird, PAM Consultants and
Investment Managers ........................................................................ 39
Other Fees and Expenses ............................................................................ 41
Cost and Expense Information for Certain Investment Products .................. 41
Additional Account Fees and Charges ...................................................... 41
Other Fees and Charges ........................................................................ 41
Other Compensation Received by PAM and Baird ............................................ 42
iv
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Performance-Based Fees and Side-By-Side Management .............................. 43
Types of Clients............................................................................................. 43
Methods of Analysis, Investment Strategies and Risk of Loss ....................... 43
Investment Strategies ................................................................................. 43
Equity Strategies .................................................................................. 43
Fixed Income or Bond Strategies ............................................................ 43
Balanced Strategies .............................................................................. 44
Value Strategies ................................................................................... 44
Growth Strategies ................................................................................. 44
Income Strategies ................................................................................. 44
Economic Industry or Sector Focused Strategies ....................................... 44
International Strategies ......................................................................... 44
Global Strategies .................................................................................. 44
Geographic Region or Country Focused Strategies ..................................... 44
Tactical and Rotation Strategies .............................................................. 45
Opportunity or Opportunistic Strategies ................................................... 45
Tax Management Strategies ................................................................... 45
Direct Indexing Strategies ...................................................................... 46
Alternative Strategies and Complex Strategies ......................................... 46
Asset Allocation Strategies ..................................................................... 49
Important Information about Implementation of Investment
Objectives and Investment Strategies ................................................. 51
Methods of Analysis .................................................................................... 51
Certain PWM-Managed Portfolios ............................................................. 53
Certain Recommended Lists ................................................................... 54
Certain Eligible Product Lists .................................................................. 58
Baird Trust Strategies ............................................................................ 59
The PAM Investment Process .................................................................. 60
Service Information .................................................................................... 61
PAM Investment Management Service ..................................................... 61
PAM Recommended Managers Service ..................................................... 62
Baird SMA Network and Dual Contract Programs ....................................... 63
Portfolio Management by PAM, Baird and Associated Managers ........................ 64
Principal Risks ............................................................................................ 64
Investment Risk Information .................................................................. 65
Risks Associated with Certain Investment Strategies ................................. 72
Non-Traditional Assets and Complex Strategies Risks ................................ 72
Complex Investment Product Risks ......................................................... 74
Risks Associated with Certain Investment Objectives and Asset
Allocation Strategies ......................................................................... 81
Available Investment Product Risks ......................................................... 83
Recent Events ...................................................................................... 83
Disciplinary Information ............................................................................... 84
Other Financial Industry Activities and Affiliations ....................................... 86
Baird’s Broker-Dealer Activities .................................................................... 86
Certain Relationships and Arrangements ....................................................... 86
Baird and Associated Parties................................................................... 86
v
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Associated Investment Products and Services ........................................... 87
Relationships and Arrangements with Investment Managers ............................ 88
Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading ................................................................................ 88
Code of Ethics ............................................................................................ 88
Participation or Interest in Client Transactions ............................................... 89
Investment Advisory Accounts ................................................................ 89
Accounts and Investments Provide Different Levels of
Compensation .................................................................................. 89
Recommendations of Associated Investment Products and
Services .......................................................................................... 89
Referral Compensation Paid to PAM Consultants ....................................... 89
Ongoing Product Fees ............................................................................ 90
Marketing Support and Revenue Sharing from Mutual Fund and
UIT Sponsors ................................................................................... 90
Schwab Clearing Arrangement ................................................................ 91
Baird Conference Sponsorships ............................................................... 91
PAM Consultants Receive Benefits from Product Providers .......................... 91
Cash Sweep Program ............................................................................ 91
Trust Services Arrangements .................................................................. 92
Margin Loans ........................................................................................ 92
Securities-Based Lending Program .......................................................... 92
Investment Advisory and Brokerage Account and Service
Recommendations............................................................................. 92
Account Transfers and New Accounts ...................................................... 92
Recommendations to Open Different Types of Accounts ............................. 92
Baird Stock Ownership .......................................................................... 93
Other Client Relationships ...................................................................... 93
Relationships with Issuers of Securities ................................................... 93
PAM Consultants Transferring to Baird ..................................................... 93
Principal Trading ................................................................................... 93
Baird Underwritten Offerings .................................................................. 93
Allocations of IPOs and Other Public Offerings .......................................... 94
Trade Error Correction ........................................................................... 94
Baird’s Other Broker-Dealer and Related Activities .................................... 94
Other Conflicts of Interest ...................................................................... 95
Addressing Conflicts .............................................................................. 95
Duration Compensation Will Be Received ................................................. 95
Brokerage Practices ...................................................................................... 95
PAM’s and Baird’s Trading Practices .............................................................. 95
Broker-Dealer Selection ......................................................................... 95
Trade Aggregation, Allocation and Rotation Practices ................................. 96
Directed Brokerage Arrangements........................................................... 97
Cross Trading Involving Advisory Accounts ............................................... 97
Trade Error Correction ........................................................................... 98
Soft Dollar Benefits ............................................................................... 98
Trading Practices of Investment Managers ..................................................... 98
vi
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Trade Execution Services Performed by Baird ................................................. 99
Agency Cross Transactions ..................................................................... 99
Principal Transactions ........................................................................... 100
Review of Accounts ..................................................................................... 101
Client Account Review ................................................................................ 101
Account Statements and Performance Reports .............................................. 101
Client Referrals and Other Compensation ................................................... 102
Custody ....................................................................................................... 103
Investment Discretion ................................................................................ 103
Investment Selection and Trading Authorizations .......................................... 103
Client Investment Restrictions ..................................................................... 105
Associated Investment Products .................................................................. 105
Investment Policy Statements ..................................................................... 106
Conversion, Exchange or Sale of Certain Investments .................................... 106
Voting Client Securities ............................................................................... 106
Non-Discretionary Accounts ........................................................................ 106
Separately Managed Accounts ..................................................................... 106
Discretionary Services ................................................................................ 106
Other Proxy Voting Information ................................................................... 108
Providing Baird Voting Instructions .............................................................. 108
Legal Proceedings and Corporate Actions ...................................................... 108
Financial Information.................................................................................. 108
Special Considerations for Retirement Accounts ......................................... 108
Associated Investment Products and Services ............................. Appendix A-1
vii
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Robert W. Baird & Co. Incorporated
Baird is privately-held, employee-owned global
investment and wealth management firm formed
in the State of Wisconsin in 1919.
Baird is owned indirectly by its associates through
several holding companies. Baird
is owned
directly by Baird Financial Corporation (“BFC”).
BFC is, in turn, owned by Baird Financial Group,
Inc. (“BFG”), which
is the ultimate parent
company of Baird. Associates of Baird own
substantially all of the outstanding stock of BFG.
analysis
and
research,
analysis
and
planning;
investment
and
account
transactions
and
retirement
accounts, which
Baird offers various investment advisory services
to clients, including services not described in this
Brochure. The investment advisory services Baird
include: portfolio management and
offers
recommendations
analysis;
investment
regarding asset allocation and
strategies;
and
recommendations regarding investment managers
and individual securities; investment consulting;
policy
financial
development;
performance
monitoring. Baird also offers clients execution of
administrative
brokerage
services, including maintaining custody of account
assets. Clients may also negotiate other services
with Baird. Baird offers its services separately or
in combination with other services.
(“IRC”)
(collectively,
Baird participates in wrap fee programs, including
programs not described in this Brochure and it
provides portfolio management services
in
connection with those programs. Baird receives a
portion of the wrap fee paid by clients for
providing portfolio management services under
those wrap fee programs.
under management,
including
Advisory Business
This Brochure describes some of the investment
advisory services that Robert W. Baird & Co.
Incorporated (“Baird”) offers to its clients through
Private Asset Management (“PAM”), a team of
Baird Financial Advisors (“PAM Consultants”)
within Baird’s Private Wealth Management
(“PWM”) department. Baird and PAM offer other
investment advisory services not described in this
Brochure. Separate brochures describe those
other investment advisory services and discuss
the terms and conditions, fees and costs and
potential conflicts of interest associated with
those services. This Brochure also references
other documents that contain additional important
information about Baird. Those documents
describe the types of investment products and
services that Baird makes available to clients,
including the terms, conditions, fees, costs, risks,
and conflicts of interest applicable to those
investment products
services. Those
documents are available on Baird’s website at
bairdwealth.com/retailinvestor. Included on that
website is Baird’s Client Relationship Booklet,
contains Baird’s Form CRS Client
which
and Baird’s Client
Relationship Summary
Relationship Details document. The Client
Relationship Booklet also contains an important
disclosure document for retirement investors that
have
include
employee pension benefit plan accounts that are
subject to the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”) and
individual retirement accounts (“IRAs”) that are
subject to the Internal Revenue Code of 1986, as
“Retirement
amended
Accounts”). A client of Baird should have already
received a copy of the Client Relationship Booklet.
A client or prospective client who wishes to obtain
a brochure for another investment advisory
service provided by Baird, or a paper copy of any
of the other documents referenced
in this
Brochure,
the Client Relationship
Booklet, should contact a PAM Consultant or call
Baird toll-free at 1-800-792-2473.
As of December 31, 2025, Baird had
approximately $394.0688 billion in regulatory
assets
approximately
$289.4898 billion of which was managed on a
discretionary basis and approximately $104.5790
billion of which was managed on a non-
discretionary basis.
The information contained in this Brochure is
current as of the date above and is subject to
change at Baird’s discretion. Please retain this
Brochure for your records.
The Client-Baird Fiduciary Relationship
is registered with the Securities and
Baird
Exchange Commission (“SEC”) as an investment
adviser under the Investment Advisers Act of
1940, as amended (the “Advisers Act”). PAM and
Baird are deemed to have a fiduciary relationship
with a client when providing the investment
1
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• discretionary services, whereby a client gives
PAM or Baird (including Baird PWM’s home
office investment professionals or the client’s
PAM Consultant) full discretionary authority to
manage the client’s Account (“Discretionary
Services”);
provide
investment
advice
client’s
Account
• non-discretionary services, whereby PAM or
Baird
and
recommendations but the client retains full
authority with respect to the management of
the
(“Non-Discretionary
Services”); and
contain
information about
• separately managed account (“SMA”) programs
and services, whereby an investment manager
manages the client’s Account according to a
strategy (each, an “SMA Strategy”) with full
discretionary authority, and PAM and Baird
provide additional consulting services to the
client (collectively, “SMA Services”).
Depending on their particular needs or objectives,
clients may use one or more of these Services.
advisory services that are described in this
Brochure. That means that PAM and Baird are
required to act in the best interest of the client
when providing investment advisory services.
From time to time PAM and Baird may engage in
certain business practices or may
receive
compensation or other benefits that create a
potential for conflict between the interests of
clients and the interests of PAM and Baird. PAM
and Baird generally address potential conflicts of
interest by disclosing them to clients through
documents provided to clients, including, without
limitation, this Brochure, Brochure supplements
that
individuals
providing investment advice to clients and the
services they provide, and the agreements clients
enter into with PAM and Baird. In addition, Baird
has adopted internal policies and procedures for
PAM and Baird that require them to: provide
investment advice that is suitable for advisory
clients (based upon the information provided by
such clients); make full disclosure of all potential,
material conflicts of interest; act with utmost care
and good faith in dealings with advisory clients;
and seek to obtain “best execution” of advisory
client transactions. The specific business practices
that create potential conflicts of interest with
clients and additional measures used by PAM and
Baird to address them are discussed in other
sections of this Brochure.
A client should note that registration as an
investment adviser does not imply a certain level
of skill or training.
The Consulting Services include: assisting a client
with the development of an investment policy
statement; asset allocation reporting; investment
manager search, investment manager interviews,
performance reviews, performance monitoring,
asset allocation and funding requirement analysis;
asset liability modeling; and annuity modeling. In
certain instances, PAM may also provide clients
with asset allocation and funding requirement
analysis and asset
liability modeling. The
Discretionary Services include: PAM Investment
Management. The SMA Services include: PAM
Recommended Managers; Baird SMA Network
(“BSN”); and Dual Contract (“DC”).
advisory
account
advised by
reporting and
Summary of PAM’s Services
This Brochure describes certain
investment
advisory programs and services that PAM and
Baird offer to clients (“Services”) and applies to
PAM
each
(“Account”). The investment advisory services
offered under the Services generally include
investment advice and consulting services,
performance
related account
services, which are provided by Baird PWM’s
home office investment professionals or PAM,
and, depending upon the Service that a client
selects,
include portfolio
the Service may
management. The Services consist of:
consulting
services
(“Consulting
• certain
Services”);
The SMA Services are generally offered under a
“single contract” arrangement. Under a single
contract arrangement, a client enters into an
advisory agreement with PAM and Baird, and
Baird, in turn, enters into a subadvisory or similar
agreement with the investment manager on the
client’s behalf. This type of arrangement is
frequently referred to as a single contract
arrangement because there is only one contract
between the client and PAM and Baird; the client
does not have an agreement directly with the
client’s investment manager. Under the Dual
Contract Program, a client has a “dual contract”
two
arrangement, meaning
the client has
2
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
contracts; one contract with PAM and Baird and
another contract with the client’s investment
manager.
standard brokerage services. However, trade
execution services, whether provided by Baird or
another firm, are not included in the advisory fee
the client pays for the Services (“Advisory Fee”).
A client should note that the client will incur costs
in addition to the Advisory Fee. See “Fees and
Compensation—Other Fees and Expenses” below
for more information.
Certain Programs may allow a client to invest in
groups of mutual funds and ETFs (referred to as
“sleeves”) and other model portfolios of securities
managed by Baird PWM (such sleeves and model
portfolios collectively, “PWM-Managed Portfolios”).
The SMA Programs allow a client to select among
a variety of SMA Strategies offered by third party
investment managers (“Other Managers”), which
may include Other Managers affiliated with,
related to, or otherwise associated with Baird
(“Associated Managers”), or Baird to manage the
client’s Account.
tend
PAM and Baird tailor advisory services to the
individual needs of clients. Each Service is
designed to address different investment needs of
clients. All of the Services discussed in this
Brochure may not be appropriate for every client.
For example, the Services may not be appropriate
for clients who have low or no trading activity,
who desire to pay transaction-based fees, who
maintain their accounts invested in high levels of
cash or other concentrated positions, who do not
want ongoing professional investment advice or
account monitoring, who
to execute
transactions without the recommendation or
advice of an advisor, which are commonly
referred to as “unsolicited” transactions, or who
intend to utilize an investment strategy, product
or solution that is not available in a Service.
and bonds
(collectively,
Manager,
and
investment products
Baird has engaged an overlay management firm,
Envestnet Asset Management, Inc. (the “Overlay
Manager”) to provide certain subadvisory services
to clients that participate in certain SMA Services.
The SMA Services make available two types of
SMA Strategies: (1) manager-traded strategies,
whereby the manager itself manages a client’s
Account and conducts the trading to implement
the SMA Strategy selected by the client (a
“Manager-Traded Strategy”); and (2) model-
traded strategies, whereby the manager does not
manage a client’s Account (a “Model Provider”)
but instead provides a model portfolio (“Model
Portfolio”) to an overlay management firm, which
may include the Overlay Manager, Baird or other
third party
firm (each, an “Implementation
Manager”), that in turn manages a client’s
Account and conducts the trading to implement
the SMA Strategy selected by the client (a
“Model-Traded Strategy”). If a client selects a
Model-Traded Strategy, the Model Provider will
provide the Model Portfolio and updates to the
Implementation
the
Implementation Manager will manage the client’s
Account with full discretionary authority according
to the strategy selected by the client. Otherwise,
if the client selects a Manager-Traded Strategy,
the investment manager will directly manage the
client’s Account with full discretionary authority as
more fully described below.
Some Services offer clients the ability to pursue
alternative investment strategies (“Alternative
Strategies”) or other non-traditional or complex
investment strategies that involve special risks
not apparent in more traditional investments like
stocks
“Complex
Strategies”). Similarly, some Programs offer
clients the ability to invest in non-traditional or
real assets (“Non-Traditional Assets”). Some
Programs also offer the ability to invest in
investment products
that pursue Alternative
Strategies (“Alternative Investment Products”) or
other Complex Strategies (collectively, “Complex
these
Investment Products”). The use of
strategies and
involves
special risks, and a client should not engage in a
strategy or purchase an investment product
unless the client understands the related risks.
See “Additional Service Information—Complex
Strategies and Complex Investment Products”
and “Methods of Analysis, Investment Strategies
and Risk of Loss—Principal Risks” below for more
information.
Baird is also registered with the SEC as a broker-
dealer under Securities Exchange Act of 1934, as
amended (the “Exchange Act”). Baird, in its
capacity as broker-dealer, may also provide
clients with trade execution, custody and other
Certain Services make available asset allocation
investment strategies. Asset allocation strategies
involve investing in one or more categories of
assets, such as equity securities, fixed income
3
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
allocation
strategies
have
and PAM Consultants may use, select or
recommend Associated Investment Products and
Services. This may present a conflict of interest. A
client is free at any time to select investment
products and services that are not associated with
Baird. For specific information about Associated
Parties and Associated Investment Products and
Services, see “Other Financial Industry Activities
and Affiliations” below.
include
a
client’s
age,
the
A client’s PAM Consultant will offer or recommend
appropriate Services, investment strategies, and
investment products and services based upon a
client’s
investment profile and an Account’s
investment objective, which establishes an
Account’s investment return objective and risk
tolerance. A client’s
investment profile will
other
generally
investments, financial situation and needs, tax
status, investment goals, investment experience,
investment time horizon, liquidity needs, risk
tolerance and other relevant information provided
by a client and updated from time to time.
Although a PAM Consultant may offer or
recommend appropriate options, a client will
ultimately select
investment objective,
Services, investment strategies, and investment
products and services for an Account.
securities, Non-Traditional Assets, Alternative
Investment Products and cash, and one or more
subcategories of assets, called asset classes.
varying
Asset
investment objectives and investment strategies.
Some asset allocation strategies use strategic
investment strategies, which involve investing
accounts in accordance with a predetermined
target allocation to different asset classes. Some
asset allocation strategies use tactical investing,
which typically involves tactically and actively
adjusting account allocations to different asset
classes based upon the manager’s perception of
how those asset classes will perform in the short-
term. Some asset allocation strategies involve the
use of both strategic and tactical investment
strategies, sometimes referred to as dynamic
strategies. Asset allocation strategies may be
implemented using a variety of investment types,
such as individual securities, mutual funds and
exchange traded products (“ETPs”), including
exchange traded funds (“ETFs”) and exchange
traded notes (“ETNs”). The amount allocated to
an asset class or investment type varies by
strategy, and some strategies may have little or
no allocation to one or more asset classes or
investments described above. See
types of
“Methods of Analysis, Investment Strategies and
Risk of
Loss—Investment Strategies—Asset
Allocation Strategies” below for more information.
funds, ETFs, unit
Service
A client that wishes to participate in a Service will
enter into a client relationship agreement or other
investment advisory agreement with PAM and
Baird
client’s
(“advisory agreement”). The
advisory agreement will contain the specific terms
applicable to the services selected by the client,
fees payable by the client, and other terms
applicable to the client’s advisory relationship with
PAM and Baird. A client should note that the
client’s advisory relationship with PAM and Baird
does not begin until they enter into the applicable
advisory agreement with the client, which occurs
when Baird PWM’s Home Office has accepted the
client’s advisory agreement and determined that
all of the client’s paperwork is in order. See
Information—Account
“Additional
Requirements” below for more information.
Subject to the agreement of PAM, a client may
impose reasonable restrictions on the securities or
types of securities to be held in the client’s
Account. Please see “Investment Discretion”
below for more information. Clients may negotiate
with PAM to provide other investment advisory
services.
The Services make available many different
investment products and services offered by third
parties that are not associated with Baird, such as
mutual
investment trusts
(“UITs”), collective investment trusts (“CITs”),
private equity funds, hedge funds, private funds
and other investment pools (collectively “Funds”).
However, certain
investment products and
services managed, advised or sponsored by Baird
or other parties affiliated with, related to, or
otherwise associated with Baird,
including
Associated Managers (“Associated Parties”), have
been selected for inclusion in certain Services or
are made available to clients through Service
Accounts (“Associated Investment Products and
Services”). Associated Investment Products and
Services generally consist Funds managed,
advised or sponsored by Baird or Associated
Parties (“Associated Funds”) and other investment
products managed, advised or sponsored by Baird
or Associated Parties (collectively, “Associated
Investment Products”), and SMA Strategies
managed or advised by Baird or Associated
Managers (“Associated SMA Strategies”). Baird
4
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment objectives, policies, constraints, and
risk profile.
for
determining whether
into account by PAM
Asset Allocation Report. PAM provides to a client
or its fiduciaries an Asset Allocation Report which
identifies one or more investment portfolios for
the client (in terms of risk and return) based on
information requested by PAM and
certain
provided by the client. The client is solely
the
responsible
information taken
in
formulating an Asset Allocation Report is accurate
and complete.
As mentioned above, Baird, in its capacity as
broker-dealer, may also provide PAM clients with
trade execution, custody and other standard
brokerage services. For this reason, a client may
also enter into a client relationship agreement or
other account agreement with PAM and Baird
(“account agreement”) if the client has not
already done so. The client’s account agreement
authorizes PAM and Baird to execute trades for,
and perform related brokerage and custody
services to, the client’s Account. Baird generally
does not permit a client to include assets in the
client’s Account that are held by a third party
custodian or that are otherwise held outside of a
Baird account (“Held-Away Assets”), although
PAM will provide Consulting Services on Held-
Away Assets when requested by a client and
agreed to by PAM.
Service
has
different
for any
and
ongoing
research,
Each
structures,
administration, types and levels of service, and
fees and expenses. In particular, a client should
note that the
investment advisory services
provided by PAM and Baird, including the depth of
initial
evaluation,
monitoring and review of the investments in a
client’s Account, varies by Service and the
investments selected for the Account.
Investment Manager Search Report. PAM provides
to a client an Investment Manager Search Report
that lists investment managers with investment
philosophies and investment strategies believed
to be consistent with the client’s investment
objectives, policies, constraints, and risk profile,
as specified by the client to PAM. PAM does not
assume responsibility for the client’s choice of any
investment
investment manager or
manager’s performance when providing
this
service to the client, nor is PAM responsible for an
unaffiliated
investment manager’s compliance
with applicable law or for matters beyond PAM’s
reasonable control. Investment Manager Search
Interviews. PAM coordinates client interviews with
a select number of investment managers listed on
the Investment Manager Search Report. The
interviews enable the client to gain additional
information regarding such investment managers’
respective investment philosophies, policies and
business operations.
The foregoing discussion of the Services is only a
summary. More specific information about the
Services and the particular investment advisory
services that PAM and Baird provide in connection
with each Service are further described below and
in the client’s advisory agreement. Clients are
encouraged to review this Brochure and their
advisory agreement carefully.
Consulting Services
PAM offers the following Consulting Services.
compares
various
aspects
of
in preparing an
the client’s
Past Performance Reviews. PAM provides to a
client a Past Performance Review which, based on
information supplied by the client, includes the
historical performance of the client’s portfolios
and
such
performance to one or more benchmark indices.
Account data will be derived from information
provided by the client or its agent(s) for the
agreed upon time period. PAM is not responsible
for verifying information supplied by the client or
its agent(s).
the
Investment Policy Statement. PAM will assist a
Investment Policy
client
investment
Statement reflecting
objectives, policies, constraints, and risk profile.
The Investment Policy Statement is designed to
provide guidance to the client’s
investment
manager(s). The Investment Policy Statement is
a product of information and data provided by the
client; therefore, the client is responsible for
review and final approval of the Investment Policy
Statement. The client is solely responsible for
Investment Policy
determining whether
client’s
Statement
accurately
reflects
the
5
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
provide
a
Discretionary Services
PAM Investment Management Service
Under the PAM Investment Management Service,
a client grants full discretionary authority and
management of the client’s Account to Baird and
the client’s PAM Consultant.
Performance Monitoring Reports. PAM will
periodically
client written
to
Performance Monitoring Reports which include
calculations of the performance of the client’s
Account(s) over various
time periods and
compare various aspects of such performance to
one or more benchmark indices.
PAM offers the following consulting services to
clients only in special arrangements:
Asset
Allocation
and
reviews
the client’s
Annual
Funding
the
Requirements. Annually, PAM evaluates
adequacy of the client’s current and target asset
allocation to meet projected liabilities. The client
provides actuarial data that PAM relies upon as
accurate and complete. PAM’s analysis assesses
the long term funding risks associated with the
client’s current asset allocation, and if necessary,
PAM recommends a rebalancing plan which
supports the transition to, and maintenance of,
the client’s target asset allocation.
In the PAM Investment Management Service, a
client’s PAM Consultant seeks to meet the client’s
particular investment needs by developing a
customized
investment strategy based upon
guidelines that are jointly established by the client
and
the
the client’s PAM Consultant. At
commencement of services, the client’s PAM
Consultant
investment
objectives and risk tolerance. Based upon that
review and other information provided by the
client, the PAM Consultant makes a subsequent
recommendation to the client as to which
investment style the PAM Consultant believes is
best suited for the client. A client makes the final
decision as to which investment style is chosen
for the client’s Account. More specific information
as to how the client’s PAM Consultant will manage
the client’s Account is provided to the client in
connection with the opening of the Account.
to, equity securities,
fixed
Asset Liability Modeling. As a client’s actuarial
inputs, economic situations, and/or
liabilities
change, the client’s current asset allocation
should be altered. PAM provides a liability model
to help the client determine the appropriate time
to alter the asset mix, as well as the proper
assets to draw down in the proper sequence.
Actuarial assumptions used to forecast the size of
the future liability stream are provided by the
client or the client’s agent, and PAM relies upon
such information as accurate and complete. As
the client’s liabilities come due, the client works
with PAM to determine the order and amount of
each segment of the portfolio(s) to withdraw from
in order to minimize transition costs. This service
is typically performed annually.
“Additional
Service
Investments” below.
PAM
about
Investment
appropriate
given
annual
changes
A PAM Consultant may make investments in
various types of securities, including, but not
limited
income
securities, mutual funds, ETFs, Non-Traditional
Assets and
Investment
certain Alternative
Products. All or a portion of the assets in a client’s
Account may be held in cash or cash equivalents,
including securities issued by money market
mutual funds, or may be deposited in interest-
bearing bank accounts. Additional information
about the types of investments a PAM Consultant
may use for client accounts is contained under the
Information—
heading
For more
Permitted
information
Investment
the
Management Service, see “Methods of Analysis,
Investment Strategies and Risk of Loss—Service
Information—PAM
Management
Service” below.
Annual Annuity Modeling. Annually,
PAM
recommends changes to the client’s asset/liability
projection model. PAM assists the client model
projected liabilities under various assumptions to
contribution
project
requirements
liability
in
projections, actuarial assumptions, the current
level of assets held and the current expected
asset growth assumptions. PAM maintains and
refines the calculation models.
Baird may remove any PAM Consultant or
strategy from the Service at any time and
transfer day-to-day management responsibility of
a client’s Account to another PAM Consultant or
Baird Financial Advisor at any time without
providing prior notice to, or obtaining the consent
of, a client.
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Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
PAM Recommended Managers have varying
investment objectives, styles and strategies, and
they may invest a client’s Account in various
types of securities, which will be chosen by the
PAM Recommended Manager and which may
include mutual funds, ETFs or other investment
products associated with the manager or Baird.
investments
are urged
review
the
information
about
products.
See
“Additional
the
Important Information about PAM Investment
Management Service Accounts. A client should
note that PAM Consultants may engage
in
strategies that involve concentrated and less
diversified portfolios of securities, leverage or
margin. In addition, PAM Consultants may invest
client accounts in illiquid securities and Complex
Investment Products. These types of strategies
involve special, sometimes
and
significant, risks and are not appropriate for all
clients. A client should understand those risks
before engaging in those strategies or investing in
Service
those
Information—Complex Strategies and Complex
Investment Products” and “Methods of Analysis,
Investment Strategies and Risk of Loss—Principal
Risks” below for more information.
Clients
PAM
to
Recommended Manager’s Form ADV Part 2A
contain additional
Brochure, which
should
important
PAM
the
Recommended Manager, including information
about
PAM Recommended Manager’s
strategies, the types of investments the PAM
Recommended Manager may use for a client’s
Account, and the risks associated with investing in
a PAM RM Strategy. Such brochures are available
upon request.
Associated Investment Products are available to
clients under the PAM Investment Management
Service. This presents a conflict of interest. For
more information, see “Other Financial Industry
Activities and Affiliations” below.
initially selects
SMA Services
PAM Recommended Managers Service
Some of the services provided under the PAM
Recommended Managers Service will be provided
to a client by a PAM Consultant assigned to the
client’s Account. A client, typically working with a
PAM Consultant,
the PAM
Recommended Manager and PAM RM Strategy for
the client’s Account. Thereafter, whenever Baird
or the client’s PAM Consultant deems it necessary,
Baird or the client’s PAM Consultant will replace a
PAM Recommended Manager or PAM RM Strategy
with another PAM Recommended Manager or PAM
RM Strategy for the client’s Account.
The PAM Recommended Managers Service is a
program whereby a client provides Baird and the
client’s PAM Consultant with discretionary
authority to appoint investment managers to
manage the client’s Account with full discretionary
authority and to terminate or replace investment
managers for the client’s Account. The PAM
Recommended Managers Service is designed for a
client who wishes to have the client’s Account
managed by
investment managers that are
monitored by PAM and Baird on an ongoing basis.
the
full discretionary authority
If a client participates in the PAM Recommended
Managers Service, the client authorizes and
to appoint PAM
directs PAM and Baird
Recommended Managers to serve as sub-adviser
to the client’s Account and to otherwise manage
the client’s Account in accordance with the terms
of the PAM Recommended Managers Service. The
client also authorizes and directs the PAM
Recommended Managers to manage the client’s
Account with
in
accordance with the PAM RM Strategy selected.
Under the PAM Recommended Managers Service,
investment
PAM and Baird determine
managers (“PAM Recommended Managers”) and
their strategies (“PAM RM Strategies”) eligible to
participate in the Service through an initial and
ongoing evaluation process.
RM
Strategies
offered
of
Certain PAM RM Strategies are only made
available through Implementation Managers. The
PAM
through
Implementation Managers consist of Manager-
Traded Strategies and Model-Traded Strategies. If
a PAM RM Strategy offered
through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs PAM
and Baird to appoint the Implementation Manager
For more specific information about the managers
and SMA Strategies made available through the
PAM Recommended Managers Service and the
level of initial and ongoing research, evaluation,
monitoring and review performed by Baird on
those managers and SMA Strategies, see
“Methods of Analysis, Investment Strategies and
Information—PAM
Loss—Service
Risk
Recommended Managers Service” below.
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Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the client should understand
the discretionary
full discretionary authority
recommendation or
full discretionary authority
to serve as sub-adviser to the client’s Account. If
a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to manage the client’s
Account with
in
accordance with the selected PAM RM Strategy. If
a Manager-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to appoint the applicable
PAM Recommended Manager as sub-adviser, and
the client also authorizes and directs such PAM
Recommended Manager to manage the client’s
Account with
in
accordance with the selected PAM RM Strategy.
If a client’s Account is managed by an Other
Manager under the PAM Recommended Managers
that,
Service,
authority
notwithstanding
granted to Baird and the client’s PAM Consultant
under the Service: Baird and the client’s PAM
Consultant do not manage the Account and do not
otherwise have any influence over the Other
investment decisions or securities
Manager’s
selections, and therefore, Baird and the client’s
PAM Consultant are not responsible for the
decisions made by the Other Manager; and Baird
and the client’s PAM Consultant do not provide
any
investment advice
regarding the purchase or sale of investment
products made for the client’s Account.
from
the
the
implement
the direction of
the
client’s Account,
the prior manager and
From time to time, PAM or Baird may remove
investment managers
PAM
Recommended Managers Service, and PAM or
Baird may select a replacement manager to
manage the client’s Account. In such event, PAM
or Baird, at
the client’s
replacement manager, or the client’s replacement
manager may sell all or a portion of the securities
or other investments in the Account that were
the
managed by
replacement manager will reinvest the cash
proceeds of those sales. Sales of securities or
other investments could result in adverse tax
consequences for the client.
faithfully
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Implementation Manager will
Account,
typically
the Model Portfolio as
proposed by the Model Provider. However, since
the Implementation Manager has discretionary
authority over
the
Implementation Manager may implement the
Model Portfolio differently than proposed by the
Model Provider if the Implementation Manager
determines such action to be necessary and in the
client’s best interest. A client should note that
PAM and Baird do not monitor or ascertain
whether a third party Implementation Manager is
fully and
implementing the Model
Portfolio on a continuous basis. The client should
periodically discuss the Account’s performance
with the client’s PAM Consultant.
in
If PAM or Baird terminates an
investment
manager from the PAM Recommended Managers
Service, a client authorizes PAM and Baird to
invest, with full discretionary authority, the assets
in the client’s Account previously managed by the
terminated
other
investment manager
securities, including, but not limited to, mutual
funds and ETPs. PAM’s and Baird’s discretionary
authority to make such other investments will
continue until a replacement investment manager
is selected or alternative arrangements are made
for the management of the client’s assets.
below
Certain managers of Model-Traded Strategies
offered
through the Overlay Manager have
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a PAM client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of other
those Model
client accounts managed by
Providers. See “Additional Service Information—
Trading for Client Accounts—Trading Practices of
Investment Managers”
for more
information.
A client who prefers to continue using an
investment manager that has been removed from
the PAM Recommended Managers Service, or who
directs or otherwise requests that a particular
investment manager not recommended by PAM
be selected to manage the client’s Account, will
need to move to another Service, such as the
BSN Program. See “Baird SMA Network Program”
below for more information. Clients who elect to
do so will no longer receive the same level of
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Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the
rigorous ongoing monitoring, evaluation, or
review of that investment manager from PAM or
Baird.
not contain an SMA Strategy that meets the
client’s particular needs, and
client
understands the risks of doing so.
have
varying
departments
of Baird,
Industry
Activities
BSN Managers
investment
objectives, styles and strategies, and they may
invest a client’s Account in various types of
securities, which will be chosen by the BSN
Manager and which may include mutual funds,
ETFs or other investment products associated with
the manager or Baird. Certain managers offer
strategies that exclusively invest in Funds (“Fund
Strategist Portfolios”).
Important
Information about Affiliated
Managers. The PAM Recommended Managers
Service makes available to clients investment
services that are offered by Baird Advisors and
investment
Baird Equity Asset Management,
management
and
Riverfront, an affiliate of Baird. This presents a
conflict of interest. For more information, see
and
Financial
“Other
Affiliations” below.
Baird SMA Network Program
a
is designed
client who wishes
Clients are urged to review the BSN Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the BSN
Manager, including information about the BSN
Manager’s strategies, the types of investments
the BSN Manager may use for a client’s Account,
and the risks associated with investing in a BSN
Strategy. Such brochures are available upon
request.
The BSN Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
client. The BSN Program
to
to
accommodate
independently select an investment manager not
available in the PAM Recommended Managers
Program to manage the assets in the client’s
Account.
Some of the services provided under the BSN
Program may be provided to a client by a PAM
Consultant assigned to the client’s Account, and
the client’s PAM Consultant may provide his or her
own advice and recommendations about BSN
Managers.
(“BSN
Strategies”)
eligible
If a client participates in the BSN Program, the
client authorizes and directs PAM and Baird to
appoint the BSN Manager selected by the client to
serve as sub-adviser to the client’s Account. The
client also authorizes and directs the BSN
Manager to manage client’s Account with full
discretionary authority in accordance with the
BSN Strategy selected by the client.
Under the BSN Program, Baird determines the
investment managers (“BSN Managers”) and their
strategies
to
participate in the Program through a significantly
less rigorous evaluation process compared to the
PAM Recommended Managers Service. However,
a client should note that PAM and Baird do not
make any recommendation to clients regarding
any BSN Strategy or any
representations
regarding a BSN Manager’s qualifications as an
investment adviser or abilities to manage client
assets.
For more specific information about the managers
and SMA Strategies made available through the
BSN Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those managers and SMA
Strategies, if any, see “Methods of Analysis,
Investment Strategies and Risk of Loss—Service
Information—Baird SMA Network and Dual
Contract Programs” below.
Certain BSN Strategies are only made available
through the Overlay Manager. The BSN Strategies
offered through the Overlay Manager consist of
Manager-Traded Strategies and Model-Traded
Strategies. If a client selects a BSN Strategy
offered through the Overlay Manager for the
client’s Account, the client authorizes and directs
PAM and Baird to appoint the Overlay Manager to
serve as sub-adviser to the client’s Account. If a
client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to manage the client’s Account
with full discretionary authority in accordance
A client should only participate in the BSN
Program if the client wishes to take more
responsibility for monitoring the client’s Account,
the PAM Recommended Managers Program does
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Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
reviewing
the
with the BSN Strategy selected by the client. If a
client selects a Manager-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to appoint the applicable BSN
Manager as sub-adviser, and the client also
authorizes and directs such BSN Manager to
manage the client’s Account with full discretionary
authority in accordance with the BSN Strategy
selected by the client.
investment advice regarding the purchase or sale
of investment products made for the client’s
Account; and PAM and Baird only provide the
client with certain consulting services, which may
include the client’s PAM Consultant’s assistance
with determining the client’s financial needs,
investment goals and investment restrictions and
periodically
manager’s
performance. PAM and Baird do not undertake to
provide any other consulting or
investment
advisory services under the BSN Program unless
PAM and Baird agree to do so in writing.
the Account and
its
regarding
If a client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the Overlay Manager will typically
implement the Model Portfolio as proposed by the
Model Provider. However, since the Overlay
Manager has discretionary authority over the
client’s Account, the Overlay Manager may
implement the Model Portfolio differently than
proposed by the Model Provider if the Overlay
Manager determines such action to be necessary
and in the client’s best interest. A client should
note that PAM and Baird do not monitor or
ascertain whether the Overlay Manager is fully
and faithfully implementing the Model Portfolio on
a continuous basis. The client should periodically
discuss the Account’s performance with the
client’s PAM Consultant.
A client that participates in the BSN Program is
strongly encouraged to contact the client’s PAM
Consultant or BSN Manager on a periodic basis to
discuss:
investment
performance; the BSN Manager’s investment
philosophy and style (to determine if the BSN
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information
the BSN Manager,
described on the manager’s Form ADV, which is
available on the SEC's website at www.adviser
info.sec.gov.
Information—Trading
Certain managers of Model-Traded Strategies
through the Overlay Manager have
offered
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a PAM client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by those Model Providers. See
“Additional Service
for
Client Accounts—Trading Practices of Investment
Managers” below for more information.
The BSN Strategies and BSN Managers made
available under the BSN Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the BSN Program,
PAM and Baird cannot appoint a replacement
manager or otherwise manage a client’s Account
assets. Given the terms of the BSN Program,
upon the withdrawal or removal of an investment
manager from the BSN Program, a client’s BSN
Program Account will be automatically removed
from the BSN Program and the Account will
become an unmanaged brokerage account, unless
the client provides contrary instructions to PAM.
See “Methods of Analysis, Investment Strategies
and Risk of Loss—Service Information—Baird SMA
Network and Dual Contract Programs” below for
further information.
influence over
If a client’s Account is managed by an Other
Manager under the BSN Program, the client
should understand that: PAM and Baird do not
manage the Account and do not otherwise have
any
the Other Manager’s
investment decisions or securities selections, and
therefore, PAM and Baird are not responsible for
the decisions made by the Other Manager; PAM
and Baird do not provide any recommendation or
Important Information about
the BSN
Program. Portfolios managed by 55I, LLC (d/b/a
55ip, “55ip”) are made available under the BSN
Program. 55ip uses research and other services
from Riverfront, an affiliate of Baird, in the
development of certain of those portfolios, and
Riverfront receives compensation from 55ip with
respect to those portfolios. This presents a conflict
10
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
of interest. For more information, see “Other
Financial Industry Activities and Affiliations”
below.
any DC Strategy or any representations regarding
a DC Manager’s qualifications as an investment
adviser or abilities to manage client assets.
appointment
For more specific information about the managers
and SMA Strategies made available through the
DC Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those managers and SMA
Strategies, if any, see “Methods of Analysis,
Investment Strategies and Risk of Loss—Service
Information—Baird SMA Network and Dual
Contract Programs” below.
in managing
the client’s Account
A client should only participate in the DC Program
if the client wishes to take more responsibility for
the PAM
the client’s Account,
monitoring
Recommended Managers Program does not
contain an SMA Strategy that meets the client’s
particular needs, and the client understands the
risks of doing so.
the
foregoing when deciding
DC Managers have varying investment objectives,
styles and strategies, and they may invest a
client’s Account in various types of securities,
which will be chosen by the DC Manager and
which may include mutual funds, ETFs or other
investment products associated with the manager
or Baird.
The BSN Program is designed to accommodate a
client who wishes to independently select an
investment manager that is not available in the
PAM Recommended Managers Service to manage
the client’s Account. The client assumes ultimate
responsibility for monitoring the client’s BSN
the BSN Manager’s
Program Account and
performance. A
and
client’s
continued retention of a BSN Manager to manage
the client’s Account are based ultimately upon the
client’s independent review of the BSN Manager
and the BSN Manager’s services. The client
ultimately determines that the BSN Strategy to be
is
used
consistent with the client’s stated investment
objectives and financial needs and risk tolerance.
Once retained by the client, a BSN Manager will
only be removed from managing the client’s BSN
Program Account upon the manager’s withdrawal,
removal from the BSN Program, or the client’s
direction to do so. A client should carefully
consider
to
participate in the BSN Program and also consider
whether another Service, such as the PAM
Recommended Managers Service, may be more
appropriate for the client.
Dual Contract Program
a
is designed
client who wishes
Clients are urged to review the DC Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the DC
Manager, including information about the DC
Manager’s strategies, the types of investments
the DC Manager may use for a client’s Account,
and the risks associated with investing in a DC
Strategy. Such brochures are available upon
request.
The DC Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
to
client. The DC Program
accommodate
to
independently select an investment manager not
available in the PAM Recommended Managers
Service or BSN Program to manage the assets in
the client’s Account. The Program is also designed
for a client that wants to independently select a
manager and negotiate the manager’s Portfolio
Fee rate directly with the manager.
Some of the services provided under the DC
Program may be provided to a client by a PAM
Consultant assigned to the client’s Account, and
the client’s PAM Consultant may provide his or her
own advice and recommendations about DC
Managers.
Under the DC Program, Baird determines the
investment managers (“DC Managers”) and their
strategies (“DC Strategies”) eligible to participate
in the Program through a significantly less
rigorous evaluation process compared to the PAM
Recommended Managers Service. However, a
client should note that PAM and Baird do not
make any recommendation to clients regarding
Under the DC Program, DC Managers are offered
to clients through a dual contract arrangement,
and a client will need to enter into a separate
agreement with the DC Manager in addition to the
advisory agreement the client enters into with
PAM and Baird. A client participating in the DC
Program is solely responsible for negotiating the
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client’s agreement with the client’s DC Manager,
and neither PAM nor Baird will participate or
advise a client regarding the terms of such an
agreement, the advisability of entering into such
an agreement, or the retention of the client’s DC
Manager unless PAM and Baird agree to do so in
writing.
from the DC Program and the Account will
become an unmanaged brokerage account, unless
the client provides contrary instructions to PAM.
See “Methods of Analysis, Investment Strategies
and Risk of Loss—Service Information—Baird SMA
Network and Dual Contract Programs” below for
more information.
Information about
“Other Financial
the DC
Important
Program. Other
investment management
departments of Baird and Associated Managers
are available to clients under the DC Program.
This presents a conflict of interest. For more
information,
Industry
see
Activities and Affiliations” below.
appointment
reviewing
the
in managing
the client’s Account
If a client’s Account is managed by an Other
Manager under the DC Program, the client should
understand that: PAM and Baird do not manage
the Account and do not otherwise have any
influence over the Other Manager’s investment
decisions or securities selections, and therefore,
PAM and Baird are not responsible for the
decisions made by the Other Manager; PAM and
Baird do not provide any recommendation or
investment advice regarding the purchase or sale
of investment products made for the client’s
Account; and PAM and Baird only provide the
client with certain consulting services, which may
include the client’s PAM Consultant’s assistance
with determining the client’s financial needs,
investment goals and investment restrictions and
periodically
manager’s
performance. PAM and Baird do not undertake to
investment
provide any other consulting or
advisory services under the DC Program unless
PAM and Baird agree to do so in writing.
the Account and
its
the DC Manager’s
the
foregoing when deciding
The DC Program is designed to accommodate a
client who wishes to independently select an
investment manager. The client assumes ultimate
for monitoring the client’s DC
responsibility
the DC Manager’s
Program Account and
and
client’s
performance. A
continued retention of a DC Manager to manage
the client’s Account are based ultimately upon the
client’s independent review of the DC Manager
and the DC Manager’s services. The client
ultimately determines that the DC Strategy to be
used
is
consistent with the client’s stated investment
objectives and financial needs and risk tolerance.
Once retained by the client, a DC Manager will
only be removed from managing the client’s DC
Program Account upon the manager’s withdrawal,
removal from the DC Program, or the client’s
direction to do so. A client should carefully
to
consider
participate in the DC Program and also consider
whether another Service, such as the PAM
Recommended Managers Service, may be more
appropriate for the client.
Other SMA Strategy Information
A client that participates in the DC Program is
strongly encouraged to contact the client’s PAM
Consultant or DC Manager on a periodic basis to
investment
discuss:
performance;
investment
philosophy and style (to determine if the DC
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information regarding the DC Manager, described
on the manager’s Form ADV, which is available on
the SEC's website at www.adviserinfo.sec.gov.
to
Certain SMA Strategies are available through
multiple Services. The overall cost of an SMA
Strategy and the types and levels of service
provided to a client in connection with an SMA
Strategy will vary depending upon the particular
Service selected by the client. Certain managers
offer lower Portfolio Fee rates to clients through
the DC Program compared
the PWM
Recommended Managers or BSN Programs. A
client considering an SMA Strategy should discuss
with client’s PAM Consultant SMA Strategy
availability and the different Portfolio Fee rates,
The DC Strategies and DC Managers made
available under the DC Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the DC Program,
PAM and Baird cannot appoint a replacement
manager or otherwise manage a client’s Account
assets. Given the terms of the DC Program, upon
the withdrawal or removal of an investment
manager from the DC Program, a client’s DC
Program Account will be automatically removed
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
is contained under
“Methods of Analysis,
costs, and the types and levels of service
provided in connection with the different Services.
A client is solely responsible for selecting the SMA
Strategy and the Service in which the client’s
Account will participate.
and Risk
of
invested
in concentrated and
one or more Complex Strategies. Additional
information about Alternative Strategies and
Complex Strategies
the
Investment
heading
Strategies
Loss—Investment
Strategies—Alternative Strategies and Complex
Strategies” below. Additional information about
Complex Strategies and Complex Investment
Products, generally, is provided below.
Non-Traditional Assets
information about
currencies,
securities
A client should note that certain SMA Strategies
less
may be
diversified portfolios of securities and may involve
the use of leverage, margin, and options. A client
should discuss with the client’s PAM Consultant
the specific strategies and investments used by a
the
manager. Additional
strategies and investments used by a manager
are available in a manager’s Form ADV Part 2A
Brochure.
tokens
investment
Additional Service Information
Conversion, Exchange or Sale of Certain
Investments
“Investment
By participating in a Service, a client authorizes
PAM and Baird to convert or exchange any shares
of Funds, such as mutual funds, ETFs, closed-end
funds, UITs, Complex Investment Products, and
other similar investment pools, held in the client’s
Account to a class of shares of the same fund.
See
Discretion—Conversion,
Exchange or Sale of Certain Investments” below
for more information.
Non-Traditional Assets, such as investments in
indices,
commodities,
interest rates, credit spreads, private companies,
and digital assets, such as cryptocurrencies, non-
stablecoins, and
fungible
(“NFTs”),
products (collectively,
tokenized
“Digital Assets”) may be used for diversification
purposes. They may also be used to try to reduce
market and inflation risk. The performance of
Non-Traditional Assets may not correspond to the
performance of the stock markets generally, and
investments
in Non-Traditional Assets will
generally impact an account’s returns differently
than more traditional investments like stocks or
bonds. Non-Traditional Assets are subject to risks
that are different from, and in some instances,
greater than, other assets like stocks and bonds.
Non-Traditional Assets are generally more difficult
to value, less liquid, and subject to greater
volatility compared to stocks and bonds.
Complex Strategies and Complex Investment
Products
Margin and Leverage
Margin
or
including by
investing
in
and
venture
capital
and
such
as
options,
Margin involves borrowing money from a firm,
such as Baird, to buy securities or other property.
It is generally PAM’s practice to not use margin as
part of an investment strategy, although a client’s
investment manager may do so. If a client wishes
to pay for securities by borrowing part of the
purchase price from Baird, a client must open a
margin account with Baird, and Baird may provide
the client with a margin loan. Securities held in a
client’s margin account are used as Baird’s
collateral for the margin loan. The value of the
collateral
the margin account must be
maintained at a certain level relative to the
margin loan for the duration of the loan. If the
securities in the margin account decline in value,
so does the value of the collateral supporting the
margin loan, and as a result, Baird may take
action, such as issue a margin call and sell
securities in the account.
Some Services offer clients the ability to pursue
Alternative Strategies
other Complex
Strategies that involve special risks not apparent
in more traditional investments like stocks and
bonds. Complex Strategies may be pursued in
multiple ways,
in
alternative mutual funds, ETFs, hedge funds,
managed futures, private equity funds and SMAs
third party managers. Some
managed by
Complex Strategies
in Non-Traditional
invest
Assets, such as real estate, commodities (which
include metals, mining, energy and
may
agricultural products), currencies, movements in
securities indices, credit spreads and interest
rates,
buyout
investments in private companies. Some Complex
Strategies engage in the use of margin or
leverage or selling securities short (“short sales”).
Some Complex Strategies invest in derivative
instruments
convertible
securities, futures, swaps, or forward contracts.
Complex Investment Products generally engage in
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Leverage
than,
the
instruments. While
returns,
traditional
investments.
Investing
involves
Leverage generally attempts to obtain investment
exposure in excess of available assets through the
use of borrowings, short sales and other
leverage can
derivative
potentially enhance
can also
it
exacerbate losses if changes in the markets, or
the values of the investments subject to the
leverage, are adverse to the strategy being
pursued. The use of leverage may also increase
an Account’s volatility.
be used to try to hedge or reduce exposure to
other risks. They may also be used to make
speculative investments on the movement of the
value of an underlying asset. The use of
derivative instruments involves risks different
from, or possibly greater
risks
associated with investing directly in securities and
other
in
leverage.
derivatives also generally
Derivatives are also generally less liquid, and
subject to greater volatility compared to stocks
and bonds.
Short Sales
Options
to benefit
Options transactions may involve the buying or
writing of puts or calls on securities. In some
cases, Baird may require clients to open a margin
account to engage in options trading.
security or
With a call option, the purchaser has the right to
buy, and the seller (writer) the obligation to sell,
index at a
the underlying
predetermined price (i.e., the exercise or strike
price) prior to expiration of the option. The
premium paid to the seller (writer) for the option
is in consideration for the underlying obligations
imposed on the seller should the option be
exercised. With a put option, the purchaser has
the right to sell, and the seller has the obligation
to buy, the underlying security or index at the
exercise price prior to expiration of the option.
Short selling attempts
from an
anticipated decline in the market value of a
security. To affect a short sale, a client sells a
security the client does not own. When a client
sells a security short, Baird borrows the security
from a lender and makes delivery to the buyer on
the client’s behalf. Because short sales involve an
extension of credit from Baird to the client, a
client must use a margin account. A client must
also eventually purchase the same shares sold
short and return them back to the lender. It is
possible that the prices of securities that a client
sells short may increase in value, in which case
the client may lose money on the short position.
Short selling thus runs the risk of loss if the price
of the securities sold short does not decline below
the price at which they were originally sold. This
risk of loss is theoretically unlimited, as there is
no cap on the amount that the price of a security
may appreciate.
Clients should note that investment managers
managing a client’s Account or
investment
products in the client’s Account may also engage
in short sales. Thus, a client’s Account will be
subject to short sales risks if the investment
manager managing the client’s Account or an
investment product
the client’s Account
in
engages in short sales.
Options and Other Derivative Instruments
Derivative Instruments
instruments,
securities,
futures,
In buying a call option, the purchaser expects
that the market value of the underlying security
or index will appreciate, which would enable the
purchaser of a call to buy the underlying security
or index at a strike price lower than the prevailing
market price. The purchaser of the call option
makes a profit if the prevailing market price is
greater than the sum of the strike price plus the
premium paid for the option. The seller of a call
option earns income in the form of the premium
received from the purchaser for the option and
expects that the market value of the underlying
security or index will depreciate such that the
option will expire without being exercised. The
seller of a call option makes a profit if the
prevailing market price of the underlying security
or index is less than the sum of the strike price
plus the premium received.
such as options,
Derivatives
convertible
swaps, and
forward contracts are financial contracts that
derive value based upon the value of an
underlying asset, such as a security, commodity,
currency, or index. Derivative instruments may be
used as a substitute for taking a position in the
underlying asset. Derivative instruments may also
In buying a put option, the purchaser expects that
the market value of the underlying security or
index will depreciate, which would enable the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
companies (“BDCs”), real estate investment trusts
(“REITs”), and master
limited partnerships
(“MLPs”).
thereby making
website
purchaser of a put to sell the underlying security
or index at a strike price higher than the
prevailing market price. The purchaser of the put
option makes a profit if the prevailing market
price is less than the sum of the strike price and
the premium paid for the option. The seller of a
put option earns income in the form of the
premium received from the purchaser for the
option and expects that the market value of the
underlying security or index will appreciate such
that
the option will expire without being
exercised. The seller of a put option makes a
profit if the prevailing market price of the
underlying security or index is greater than the
difference between the strike price and the
premium.
In addition, a client should be aware that more
traditional investments, such as mutual funds,
ETFs, UITs and variable annuities may also pursue
them
Complex Strategies,
Complex Investment Products. A client should
carefully review the prospectus or other offering
document for each investment and understand
the strategy being pursued before deciding to
invest. More detailed information about mutual
funds, ETFs, UITs and variable annuities is
available
at
Baird’s
on
bairdwealth.com/retailinvestor.
Additional Important Information
losses
in
In purchasing a put or call option, the purchaser
faces the risk of loss of the premium paid for the
option if the market price moves in a direction
opposite to what the purchaser had expected. In
selling or writing an option, the seller faces
significantly more risk. A seller of a call option
faces the risk of significant loss if the prevailing
market price of the underlying security or index
increases above the strike price, and a seller of a
put option faces the risk of significant loss if the
prevailing market price of the underlying security
or index decreased below the strike price.
and
any
Clients should note that investment managers
managing a client’s Account or
investment
products in the client’s Account may also engage
in options transactions. Thus, a client’s Account
will be subject to options risks if the investment
manager managing the client’s Account or an
investment product
the client’s Account
in
engages in options transactions.
Complex Investment Products
The use of Complex Strategies or Complex
Investment Products is not appropriate for some
clients because they involve special risks. A client
should not engage in those strategies or invest in
those products unless the client is prepared to
experience significant
the client’s
Account. This is especially true for short selling,
which can result in unlimited losses as there is no
limit to the amount borrowed securities can rise in
value. See “Methods of Analysis, Investment
Strategies and Risk of Loss—Principal Risks”
below for more information. Before using those
types of strategies or products, a client is strongly
urged to discuss them with the client’s PAM
Consultant
investment manager
managing the client’s Account. A client should
also carefully review the client’s agreements with
Baird and related disclosure documents, which the
client should have received when opening the
Account. Additional information about Complex
Strategies and Complex Investment Products is
provided under the heading “Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment Strategies—Alternative Strategies and
Complex Strategies” below and on Baird’s website
at bairdwealth.com/retailinvestor.
Products
include
futures, but also
for notifying
and
any
Complex Investment Products typically invest
primarily in Non-Traditional Assets or engage in
one or more Complex Strategies. Complex
Alternative
Investment
Investment Products, such as hedge funds, funds
of hedge funds, private equity funds, funds of
private equity funds, private debt funds, and
managed
include other
pursuing Complex Strategies,
investments
including but not limited to, exchange or swap
funds, leveraged funds, inverse funds, and other
special situation funds, structured certificates of
(“structured
deposit and
structured notes
development
products”),
ETNs,
business
A client assumes responsibility for engaging in
Complex Strategies and investing in Complex
Investment Products. If a client determines that
the client no longer wants to engage in those
strategies or invest in those products, the client is
the client’s PAM
responsible
Consultant
investment manager
managing the client’s Account. PAM and Baird are
not responsible for any losses resulting from any
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Other Manager’s failure or delay in implementing
any such instructions.
In certain limited instances, Baird may allow a
client to hold an investment in an Account that is
an Unpermitted Investment.
PAM
Investment Management Service.
Permitted Investments for the PAM Investment
Management Service generally include, but are
not limited to, the following types of investments:
Complex
Strategies
or
• equity securities, including, but not limited to,
common stocks, American Depositary Receipts
(“ADRs”), and ordinary shares,
including
whether exchange-traded, or over-the-counter
traded;
The use of Complex Strategies or Complex
Investment Products has a unique impact upon
the calculation of a client’s asset-based Advisory
Fee. See “Fees and Compensation—Calculation
and Payment of Advisory Fees” below for more
information. A client should also understand that
Baird and the client’s PAM Consultant have a
financial incentive to use, select or recommend
certain
Complex
Investment Products, including margin and short
sales. See “Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
stocks,
As a creditor, Baird may have interests that are
adverse to a client. Neither PAM nor Baird will act
as investment adviser to a client with respect to
the liquidation of securities held in an Account to
meet a call on a margin loan. Any such sale of
assets will be executed in Baird’s capacity as
broker-dealer and creditor and may, as permitted
by law, result in executions on a principal basis.
Permitted Investments
• fixed income securities, including but not limited
to, debt securities issued by domestic and
corporations and other entities;
foreign
preferred
securities
asset-backed
(including mortgage-backed securities and
collateralized mortgage obligations (“CMOs”));
convertible debt securities; obligations issued
by U.S., state, or foreign governments or their
agencies, instrumentalities, or authorities, such
as securities issued by the U.S. Treasury,
federal
federal government agencies or
government-sponsored enterprises
(“Agency
securities”), or foreign governments; municipal
securities; money market mutual
funds;
certificates of deposit (“CDs”) (primary or
secondary); commercial paper;
• rights or warrants on equity securities and
Investments”).
written covered call equity options;
load-waived, or
for purchase; shares
“Methods
of Analysis,
Under the Discretionary and Non-Discretionary
Services, Baird determines the asset categories
and investment products that clients may access
for investment (“Permitted Investments”) and
those that are not permitted in Program Accounts
(“Unpermitted
Permitted
Investments vary by Service. Although Baird
determines the Permitted Investments under
those Services, the level of initial and ongoing
evaluation, monitoring and review that PAM and
Baird perform on Permitted Investments varies.
For more information, see the descriptions of each
Service under “Advisory Business” above and
under
Investment
Strategies and Risk of Loss—Service Information”
below.
PAM or Baird may add Permitted Investments or
restrict client access to a Permitted Investment at
any time in their sole discretion.
• open-end mutual funds shares that Baird has
selected for use in the Service, which generally
includes only those funds with which Baird has a
selling agreement and only those funds that are
institutional are
no-load,
allowed
that were
originally purchased
in a Baird brokerage
account and not sold when transitioned to an
advisory account will held in the account as
non-billable assets when the original purchase
was subject to a
front-end sales charge
(typically 36 months) or until the Contingent
Deferred Sales Charge (CDSC) expires (typically
13 months) if subject to a back-end sales
charge after which time they will be converted
to the appropriate advisory share class and
become billable assets;
Service
Some Permitted Investments contain restrictions
that limit their use, and clients will not be
permitted to purchase or hold such investments
outside of an Account. See “Advisory Business—
Information—Account
Additional
Requirements” below for more information.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
for use
in
client’s PAM Consultant which assets will be
purchased for the client’s Account.
• closed-end funds, ETFs, and UITs that have cost
structures designed
fee-based
investment advisory programs; UITs originally
purchased in a brokerage account and not sold
when transitioned to an advisory account will be
held as non-billable assets until the UIT
termination date at which time they will be
liquidated and the proceeds are billable;
• BDCs, publicly-traded REITs, certain non
publicly-traded (or private) REITs, and MLPs
(which may be organized as limited liability
companies (“LLCs”));
SMA Services. Investment products under the
SMA Services are selected solely by
the
investment manager providing services to the
client. The investment products used by an
investment manager may include products that
Baird does not permit to be used in connection
with the PAM Investment Management Service
described above. A client should review the
investment manager’s Form ADV Part 2A
Brochure for more information.
leveraged
Unsupervised Assets
• ETNs,
funds, and other special
situation mutual funds, and exchange or swap
funds;
or
supervised
by
them
• certain hedge funds, funds of hedge funds,
private equity funds, funds of private equity
funds, reinsurance funds, structured products,
private debt funds and managed futures that
Baird has selected for use in the Services; and
• cash and cash equivalents.
The types of investments that are not permitted
for the PAM Investment Management Service
generally include, but are not limited to:
If
a
client
holds
• Class B or Class C shares offered by mutual
funds or any other class of mutual fund shares
that impose a contingent deferred or level sales
charge (back-end or level load);
• inverse funds;
• UITs that impose an initial or deferred sales
charge (load);
• put options;
• all annuities and insurance products;
or
options
on
• commodities,
futures
commodities, and commodity pools; and
investment
funds
• private
and Complex
Investment Products that Baird has not selected
for use in the Services.
If a client has selected a commission-based fee
arrangement, the client should discuss with the
Under certain circumstances, Baird, in its sole
discretion, may accept a client request to hold an
asset in an Account that is not included in the
investment advisory services provided by Baird or
a PAM Consultant or otherwise monitored,
overseen
(an
“Unsupervised Asset”). For example, if Baird
permits a client
to hold an Unpermitted
Investment in an Account, the asset is typically
also considered an Unsupervised Asset. Baird, in
its sole discretion, may also designate an asset
that is otherwise a Permitted Investment as an
Unsupervised Asset under certain circumstances,
such as when a client acquires the asset in an
unsolicited transaction, transfers the asset from
firm or Baird
an account held at another
brokerage account, or continues to hold the asset
against Baird’s or the client’s PAM Consultant’s
recommendation.
an
Unsupervised Asset in an Account, the client
should understand that the Unsupervised Asset
may not be included in performance reports
provided to the client and that Baird and PAM
Consultants do not manage, provide investment
advice, or otherwise act as an investment adviser
with respect to the Unsupervised Asset, even if
the Unsupervised Asset is included in account
statements or performance reports provided to
the client. Because Baird and PAM Consultants do
not manage or provide investment advisory
services regarding Unsupervised Assets, no asset-
based Advisory Fee is charged on Unsupervised
Assets. While Unsupervised Assets are not subject
to the asset-based Advisory Fee, Baird may
impose additional fees upon Accounts holding
Unsupervised Assets. See “Other Fees and
Expenses” below for more information. A client
should also understand
that holding an
Unsupervised Asset in an Account may increase
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
is contained under
the risk of trade errors, overinvestment, and
negative Account performance. A client should
consult the client’s PAM Consultant for further
information.
Special Considerations for the Services
with Growth; (5) Conservative Income; and (6)
Capital Preservation. A description of those
objectives
the heading
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of
Loss—Investment Strategies—Asset
Allocation Strategies” below.
Third Party Information
(a
is
When providing services to a client, PAM and
Baird rely on information provided by third parties
and other external sources believed to be reliable,
including, but not limited to, information provided
by investment managers. PAM and Baird assume
that all such information is accurate, complete
and current. PAM and Baird do not conduct an in-
depth review of, or verify, such information, and
they do not guarantee the accuracy of the
information used. See “Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis” below for more information.
Household Management
Unless otherwise specified in writing, clients that
are part of the same household will include their
eligible Advisory Accounts in the same household
for management purposes
“Household
the client’s sole
Management Plan”). It
responsibility to notify PAM that the client should
be excluded from a household so that PAM is
aware that the client’s Advisory Accounts are to
be managed independently. It is also the client’s
sole responsibility to notify PAM whenever the
client ceases to be part of a household if an
account is part of a Household Management Plan.
Failure to do so could have a materially negative
impact on applicable accounts.
the
household
level
is
part
An account will be removed from a Household
Management Plan: (1) upon request or consent of
the client, (2) if the Account ceases to be an
eligible Advisory Account, (3) in the event the
Account
another Household
of
Management Plan, if the client notifies PAM that
the client ceases to be a member of the applicable
household, or (4) upon written notice from Baird
that it is no longer able to manage the Account
according to the Household Management Plan.
included
Unless otherwise specified in writing, PAM and
Baird manage client Advisory Accounts together
at
(“Household
Management”). Household Management provides
that the client’s Advisory Accounts are managed
together toward a single, overall investment
objective selected by the client with the flexibility
of using multiple, eligible Advisory Accounts
(“Household Management Accounts”) that may
have different investment strategies or objectives.
Household Management Accounts, taken together,
will be managed or advised by Baird and client’s
PAM Consultant in such a way so as to seek to
achieve a single, overall goal or investment
objective (“Household Management Objective”)
chosen by the client. Each individual Account
included in Household Management will also be
managed or advised by Baird and client’s PAM
Consultant in accordance with the terms of the
applicable Advisory Program or Service and any
investment strategy or objective applicable to the
Account. However, each
individual account
included in Household Management may be
managed or advised in any manner believed by
Baird or the client’s PAM Consultant to be
necessary or appropriate
for the Household
Management Accounts, taken together, to seek to
achieve the Household Management Objective.
Given the nature of Household Management, a
client should understand that each Account
enrolled in a Household Management Plan may
not be invested in a manner such that the
individual Account alone would be able to achieve
the Household Management Objective. It is likely
that one or more Accounts
in a
Household Management Plan, taken alone, will be
managed or advised differently and will be subject
to greater or enhanced risks than would be the
case if the Account alone had the same objective
as the Household Management Objective. Such
enhanced risks include, without limitation, market
risks, investment objective and asset allocation
risks, capitalization risks, investment style risks,
illiquid securities and liquidity risks, concentration
risks, frequent trading and portfolio turnover
risks, Non-Traditional Assets and Complex
Strategies risks, and Complex Investment Product
risks.
The Household Management Objectives that Baird
makes available to clients as part of Household
Management include: (1) All Growth; (2) Capital
Growth; (3) Growth with Income; (4) Income
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Robert W. Baird & Co. Incorporated
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Plan will
for
tax
purposes
in
Information—Legal
and
effectiveness of tax managed strategies and
services may be negatively
impacted by
applicable tax rules, such as the IRS wash sales
rules and straddle rules, which will disallow, limit
or defer a client’s ability to recognize losses in an
Account
specified
circumstances. Tax management strategies and
services also involve special risks. See “Additional
Tax
Service
Considerations” and
“Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment
Management
Strategies—Tax
Strategies” below for more information.
A client should note that: if an Account is
removed from a Household Management Plan for
any reason, including if the client ceases to be a
member of the same household, the Service and
strategy for the Account removed from the
Household Management
remain
unchanged unless a change is requested by the
client; further, the Account removed from the
Household Management Plan will not be allocated
assets from other Accounts included in the
Household Management Plan unless the client and
all other applicable clients, if any, consent and
direct Baird to do so and then only to the extent
permitted by applicable law; and PAM and Baird
will have no liability for implementing a Household
Management Plan unless a client requests, in
writing, that an Advisory Account be excluded
from the Household Management Plan.
Tax Management Services
A client should understand the terms of the tax
management services that will be implemented,
including the associated limitations, risks and
additional costs, if any, before enrolling an
Account in a Service or selecting a manager for
that Account. A client is strongly urged to consult
with the client’s tax advisor about potential tax
implications before enrolling an Account in a
Service or selecting a manager for that Account. A
client is also encouraged to discuss the client’s tax
management needs with
the client’s PAM
Consultant.
Many Services and managers make available tax
management strategies and services that are
intended to reduce the negative impact of U.S.
federal income taxes on an Account and enhance
Account performance by selectively
trading
investments in the Account to recognize or avoid
investment gains and losses.
PAM Tax Management Strategies
the PAM
Certain Services and managers
include tax
management services as a default feature of the
Services or the manager’s services. A client that
wishes to opt an Account out of participation in a
tax management service should contact the
client’s PAM Consultant.
implementation of
Certain PAM Consultants offer tax management
investment strategies (“PAM TM Strategies”),
described below, to non-Retirement Accounts
enrolled in PAM Consultant-directed Services,
including
Investment Management
Service. A client is encouraged to ask the client’s
PAM Consultant if PAM TM Strategies will be used
if the Account is enrolled in a Service. PAM
Consultants who offer PAM TM Strategies will
generally implement such strategies for Accounts
they manage on a discretionary basis unless a
client opts out by contacting the client’s PAM
Consultant. The Baird PWM Home Office will assist
with
the PAM TM
the
Strategies.
Tax management services are provided solely
based upon
information
the direction and
provided by a
client. The offering and
performance of tax management services to a
client’s Account does not constitute tax advice. A
client is ultimately responsible for all tax-related
consequences resulting from the client’s decision
to enroll in a Service or select a manager that
utilizes tax management services.
investment strategies
Each PAM TM Strategy is a secondary investment
strategy designed
to achieve a secondary
objective of an Account to reduce the negative
impact of U.S. federal income taxes and each
such strategy is implemented together with the
other primary
for the
Account that are designed to achieve the client’s
primary investment objectives or goals.
Tax management strategies are not intended to,
and likely will not, eliminate a client’s U.S. federal
income tax obligations relating to investments in
an Account. Like all investment strategies, there
is no guarantee that the implementation of a tax
management strategy will be successful. A client’s
use of a tax management strategy may not
actually
lower a client’s tax obligations or
otherwise achieve a client’s tax goals. The
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
The PAM TM Strategies features are not available
to Retirement Accounts.
Tax Harvesting Strategy
identified as part of
periodically, but at least annually, monitors the
issuers of investments held in the Account for
capital gains distributions announcements and
capital gains avoidance opportunities. When an
opportunity is identified, the Baird PWM Home
Office or the PAM Consultant, as applicable, sells
(or recommends the sale of) such securities in the
client’s Account
the
monitoring process in order for the Account to
avoid a capital gain distribution made by the
issuer. The Baird PWM Home Office or the PAM
Consultant will then reinvest (or recommend the
reinvestment of) the proceeds of such sale in cash
until the capital gain distribution has been paid by
the issuer, and then the securities will be
purchased again. If the securities are sold at a
loss, then Baird PWM or the PAM Consultant may
employ (or recommend the employment of) the
tax harvesting strategy described above.
Generally, the capital gains avoidance strategy is
limited to open end mutual fund positions in a
client Account, and a mutual fund position will be
included in the implementation of the strategy
only if the potential net U.S. federal income tax
benefit to the Account related to such position is
estimated by Baird to be $1,000 or more. For
purposes of calculating the $1,000 threshold, the
Account’s current unrealized gain or loss in each
mutual fund position is analyzed in light of the
applicable amount of capital gains distribution
announced by the mutual fund company.
Additional Important Information about PAM’s Tax
Management Strategies.
implementation of a
A tax harvesting strategy seeks to improve the
value of an Account, on a post U.S. federal
income tax basis, by offsetting capital losses in
the Account with capital gains. This strategy is
oftentimes referred to a “tax harvesting” or “tax
loss harvesting”. When
implementing a tax
harvesting strategy, the Baird PWM Home Office
or the PAM Consultant, as applicable, periodically,
but at least annually, conducts an assessment of
the Account to identify capital losses for tax
harvesting opportunities. When an opportunity is
identified, the Baird PWM Home Office or the PAM
Consultant, as applicable, sells (or recommends
the sale of) certain securities in the client’s
Account in order for the Account to recognize the
unrealized capital losses identified as part of the
assessment process. The Baird PWM Home Office
or the PAM Consultant will then reinvest (or
recommend the reinvestment of) the proceeds of
such sale in one or more replacement securities
that
the PAM Consultant believes are not
“substantially identical” for purposes of the IRS
wash sales rules. Replacement securities may
include, without limitation, ETFs, cash, cash
equivalents or other securities. Unless the client
instructs otherwise, investment in replacement
securities will be made on a temporary basis and
generally only for the duration of any applicable
IRS wash sale rule period, currently 30 days after
the sale, and within a reasonable time thereafter,
the proceeds will be reinvested in a manner
consistent with the way the Account was invested
prior to the employment of the tax harvesting
strategy.
the
implementation of
the
tax
Generally,
harvesting strategy is limited to open end mutual
fund and ETF positions with unrealized capital
losses over $1,000 for U.S. federal income tax
purposes, unless Baird and the client otherwise
agree.
The
tax management
strategy is based upon Baird’s or the PAM
Consultant’s, as applicable, estimates of capital
gains and losses associated with investments in
client’s Account and information provided to them
by third parties, such as issuers of securities.
Capital losses will remain in an Account following
the implementation of a tax harvesting strategy,
and the Account will realize capital gains following
the implementation of a capital gains avoidance
strategy,
the extent such estimates or
to
information are incorrect.
Capital Gains Avoidance Strategy
The implementation of the tax harvesting strategy
and capital gains avoidance strategy (or the
recommendation to implement a strategy) is done
in the sole discretion of the Baird PWM Home
Office or PAM Consultant, as applicable, and
securities may be excluded from implementation
A capital gains avoidance strategy seeks to avoid
capital gains attributable to an investment in the
Account for U.S. federal income tax purposes by
selling the investment before the capital gain is
distributed by the issuer. When implementing a
capital gains avoidance strategy, the Baird PWM
Home Office or the PAM Consultant, as applicable,
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
limit the Services, investment products and
services that will be made available to the
Account.
of such strategies for a number of reasons,
including without limitation, the length of time the
security has been in the Account, the lack of a
replacement security acceptable to Baird or the
PAM Consultant, withdrawal and deposit activity
in
the Account, market conditions deemed
unfavorable by Baird or the PAM Consultant, or if
doing so would, in Baird’s or the PAM Consultant’s
judgment, negatively impact management of the
Account.
All Growth. An All Growth investment objective
typically seeks to provide growth of capital.
Typically, an Account pursuing an All Growth
investment objective will experience high
fluctuations in annual returns and overall market
value. Under normal market conditions, such an
Account generally invests nearly all of its assets in
equity securities. Such an Account may also hold
other types of investments.
The tax harvesting and capital gains avoidance
strategies are provided by Baird and PAM
Consultants on an Account-by-Account basis.
When employing such strategies for a client
Account, Baird does not monitor or consider the
trading activity in any other client account,
including any Account held at Baird or another
firm.
A client should also note that when normal
for the client’s
is resumed
trading activity
Account, such activity could generate taxable
gains or losses.
Capital Growth. A Capital Growth investment
objective typically seeks to provide growth of
capital. Typically, an Account pursuing a Capital
Growth
investment objective will experience
moderately high fluctuations in annual returns
and overall market value. Generally, under
normal market conditions, such an Account will
primarily invest in a mix of equity securities and
fixed income securities, with a significantly higher
allocation to equity securities. Such an Account
may also hold other types of investments.
Third Party Manager Tax Management
Services
review
the
Some investment managers participating in the
SMA Services offer tax management services and
others do not. A client should consult the client’s
investment
PAM Consultant or
manager’s Form ADV Part 2A Brochure for specific
information.
Client-Directed Tax Management Strategies
Growth with Income. A Growth with Income
investment objective typically seeks to provide
moderate growth of capital and some current
income. Typically, an Account pursuing a Growth
with Income investment objective will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of equity securities and fixed
income securities, with a bias towards equity
securities. Such an Account may also hold other
types of investments.
A client may direct PAM and Baird, and PAM and
Baird may agree, to implement an investment
strategy designed by the client or client’s tax
advisors for the client’s specific tax purposes (a
“client-designed strategy”). PAM and Baird do not
undertake any responsibility for the development,
evaluation or efficacy of any client-designed
strategy.
Investment Objectives
for an Account based upon
Income with Growth. An Income with Growth
investment objective typically seeks to provide
current income and some growth of capital.
Typically, an Account pursuing an Income with
Growth
investment objective will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of fixed income securities and
equity securities, with a bias towards fixed income
securities. Such an Account may also hold other
types of investments.
responsible
for
selecting
for
Generally, every Account will have one of the
investment objectives described below. Although
a PAM Consultant may recommend an investment
objective
the
information provided by a client, the client is
ultimately
the
investment objective
the Account. The
investment objective will determine, in part, and
Conservative Income. A Conservative Income
investment objective typically seeks to provide
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
index or
locations or market sectors relative to an
applicable long-term strategic asset allocation,
benchmark
the market generally.
Accounts with a tactical investment objective may
have investments focused or concentrated in
certain asset classes, geographic locations or
market sectors and they often experience higher
levels of trading and portfolio turnover relative to
accounts with other investment objectives.
current income. Typically, an Account pursuing a
Conservative Income investment objective will
experience relatively small fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, such an Account
will primarily invest in a mix of fixed income
securities, cash and equity securities, with a
significantly higher allocation to fixed income
securities. Such an Account may also hold other
types of investments.
A
Tax-Managed
indicates
that
the
account
investment
Tax-Managed.
objective
is
transitioning from one investment strategy to
another using one or more tax management
strategies or tax management considerations. The
primary investment strategy or consideration for
Accounts with a Tax-Managed
investment
objective will involve tax management, and such
accounts may not be successful in pursuing any
other investment strategies, objectives or goals.
Capital Preservation. A Capital Preservation
investment objective typically seeks to preserve
capital while generating current income. Typically,
an Account pursuing a Capital Preservation
investment objective will experience relatively
small fluctuations in annual returns and overall
market value. Under normal market conditions,
such an Account generally invests nearly all of its
assets in a mix of fixed income securities and
cash. Such an Account may also hold other types
of investments.
Goal. A Goal investment objective indicates that
the Account is a Goal Management Account that is
part of a Goal Management Plan and the Account
will be managed or advised in accordance with
the applicable Goal Management Objective.
Investment Objectives
For information about the risks associated with
the investment objectives described above, see
the section of the Brochure entitled “Methods of
Analysis, Investment Strategies and Risk of
Loss—Principal Risks—Risks Associated with
Certain
and Asset
Allocation Strategies” below.
for
a
client’s
specific
Mutual Fund Share Class Policy
investment
objective
Opportunistic. An Opportunistic
investment
objective typically seeks to provide long term
growth
through capital appreciation and/or
income by utilizing an active management style
that shifts the percentage of assets held in
various investment categories to take advantage
of the manager’s perception of market pricing
anomalies, market sectors deemed favorable for
investment by the manager, the current interest
rate environment or other macro-economic trends
identified by the manager to achieve growth while
accounting
short,
intermediate and long term investment and/or
cash flow needs. Depending upon the investment
strategy used, an Account pursuing an
Opportunistic
could
experience high fluctuations in annual returns and
overall market value. The types of investments in
which such an Account may invest will also vary
widely, depending upon the particular investment
strategy used.
long-term growth by
investments based upon
in
to
implement a
typically
objective
and
overweighting
Most mutual funds offer different share classes.
While each share class of a given mutual fund has
the same underlying investments, those share
classes have different fees, costs and investment
minimums, and they provide different levels of
compensation to Baird. In an effort to provide
clients with appropriate low cost mutual fund
investment options for their fee-based investment
advisory accounts, Baird has established a mutual
fund share class policy (“Share Class Policy”) for
certain PAM-directed Services, including PAM
Investment Management (the “Share Class Policy
Services”). Typically, only one share class of a
given mutual fund family will be made available
for purchase by clients in the Share Class Policy
Services pursuant to the Share Class Policy (the
“Approved Share Class”). When selecting the
Approved Share Class for a mutual fund family,
Tactical. A tactical investment objective seeks to
provide
tactically and
actively adjusting account allocations to different
the
categories of
manager’s perception of how those investment
the short-term.
categories will perform
tactical
Strategies used
involve
investment
account
underweighting
allocations to certain asset classes, geographic
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Interest
purchased by clients. Because the compensation
that Baird receives from certain mutual funds is
based upon share class purchased by clients,
Baird has a financial incentive to make available
to clients those share classes that provide Baird
greater compensation, which, in many instances,
would cause clients investing in those share
classes to incur higher ongoing costs relative to
other share classes made available by the fund
families. This presents a conflict of interest. Baird
addresses this conflict through the Share Class
Policy described above and through disclosure in
this Brochure. For more information about the
compensation that Baird receives from mutual
funds, see “Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading—Participation or
in Client
Transactions—Investment Product Selling and
Servicing—Mutual Funds” below.
Shares of mutual funds held in client Accounts
that do not meet the requirements of the Share
Class Policy will generally be converted to the
applicable Approved Share Class subject to
certain restrictions. The Share Class Policy is
subject to change at Baird’s discretion without
notice to clients. Additional information about the
Share Class Policy is available on Baird’s website
at bairdwealth.com/retailinvestor.
The Share Class Policy does not apply to the
portion of a UAS Account managed by third party
managers. Third party managers are responsible
for establishing their own criteria for selecting
investments, including mutual funds, if any.
Custody Services
Baird may provide custody services in connection
with the Services. See “Custody” below for more
specific information.
Cash Sweep Program
Baird endeavors to select the share class with the
lowest expense ratio, based upon the average
expense ratio of the class across all mutual funds
in the mutual fund family, that are widely
available for trading on the mutual fund trading
platform of Charles Schwab & Co.,
Inc.
(“Schwab”). In selecting the share class for a
mutual fund family to be made available for
purchase by clients in the Share Class Policy
Services, Baird considers a number of factors,
including the number of funds within the fund
family that offer the share class, client positions
funds, and the
for those
in and demand
availability of the share classes and funds for
purchase on the Schwab mutual fund trading
platform. Generally, share classes designed for
retirement plans and those that pay a distribution
(12b-1) fee to Baird will not be permitted in those
Services, or, if such share classes are permitted
and the client’s Account is subject to an asset-
based fee arrangement, Baird will either: (1)
rebate the distribution (12b-1) fees to a client if
the client is paying an asset-based Advisory Fee
on such investment; or (2) exclude such fund
shares from the calculation of the client’s asset-
based Advisory Fee (sometimes referred to as
“unbillable assets”) for such period of time that
Baird collects and retains the distribution (12b-1)
fee as further described under the heading “Code
of Ethics, Participation or Interest in Client
Transactions and Personal Trading—Participation
or Interest in Client Transactions—Investment
Product Selling or Servicing—Mutual Funds”
below. Clients should note that the Approved
Share Class for a mutual fund family is based
upon the average expense ratio for the class
across all mutual funds in the fund family and not
on a fund-by-fund basis. Further, the expenses of
every mutual fund can and will vary over time.
Therefore, while Baird has endeavored to select
the lowest cost share classes as described above,
in some instances, the Approved Share Class is
not the least expensive share class for a particular
mutual fund. Clients may be able to obtain a less
expensive share class in other Programs or at
another firm.
payments,
revenue
sharing
Baird maintains a Cash Sweep Program that is
intended for clients who want to earn interest and
receive FDIC insurance protection on their cash
over short periods of
time while awaiting
investment. If a client participates in Baird’s Cash
Sweep Program, uninvested cash in the client’s
accounts will be automatically deposited or swept,
on a daily basis, into one or more FDIC-insured
deposit accounts at participating banks (the “Bank
Sweep Feature”) or, under certain conditions, will
be automatically invested in shares of a money
market mutual fund that Baird makes available in
Baird receives certain compensation from mutual
fund families in the form of distribution (12b-1)
fees, shareholder servicing fees, transfer agency
fees, networking fees, accounting fees, marketing
support
and
administration fees. The amount of compensation
paid to Baird generally varies based upon the
fund
share class of
the applicable mutual
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
to provide FDIC
bank will be aggregated with the client’s cash
balances deposited with the bank under the Cash
Sweep Program for purposes of calculating the
$250,000 FDIC insurance limit. Total deposits
exceeding $250,000 at a bank may not be fully
insured by the FDIC. A client is responsible for
monitoring the total amount of other deposits that
the client has with a bank outside the Cash Sweep
Program in order to determine the extent of
deposit insurance coverage available. Baird is not
responsible for any insured or uninsured portion
of a client’s deposits at a bank. Cash invested in a
money market mutual fund under the Money
Market Fund Feature is not FDIC insured, but is
protected by Securities
Investor Protection
Corporation (“SIPC”) coverage up to applicable
limits.
is
available
Each
receives
compensation
for
the program (the “Money Market Fund Feature”),
subject to the terms and conditions of the
program. By using multiple participating banks as
opposed to a single bank, the Bank Sweep
Feature seeks
insurance
protection for a client’s cash balances of up to an
aggregate deposit limit determined under the
program (currently, $2,500,000 for most account
types and $5,000,000 for joint accounts). A client
receives interest on cash balances in deposit
accounts under the Bank Sweep Feature at tiered
rates that are based on the aggregate value of
the accounts within the client’s household. The
applicable client household tier values are: less
than $1 million; at least $1 million but less than
$2 million; at least $2 million but less than $5
million; and $5 million are more. Current rate
at
information
rwbaird.com/cashsweeps.
deposit
account at a bank constitutes a direct obligation
of the bank and is not directly or indirectly Baird’s
obligation.
account
values
of
less. For
Any aggregate cash balances held by a client in
excess of the applicable aggregate deposit limit
are automatically invested in shares of a money
market mutual fund that Baird makes available in
the Money Market Fund feature of the program.
Cash held in employee benefit plan accounts,
employee health and welfare plan accounts, donor
advised fund accounts, and SEP and SIMPLE IRAs
will be automatically invested or swept into a
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the program In addition, clients with aggregate
cash balances of $5 million or more across all of
their accounts with Baird within the same
household may opt out of the Bank Sweep
Feature and instead have all of their cash
balances automatically swept into an institutional
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the program. More information about the Money
Market Fund Feature of Baird’s Cash Sweep
Program is available at rwbaird.com/cashsweeps.
The Bank Sweep Feature seeks to provide FDIC
insurance protection for a client’s cash balances
up to an aggregate deposit limit determined
under the program. Any deposits, including CDs,
that a client maintains, directly or indirectly
through an intermediary (such as us or another
broker), with a bank participating in the Cash
Sweep Program in the same capacity with the
Baird
the
administrative, accounting and other services that
Baird provides under the program, which is paid
out of the aggregate interest that is paid by the
participating banks on the aggregate client
balances in the deposit accounts participating in
the Bank Sweep Feature. Baird’s annual rate of
compensation may be up to 3.60% of the
for clients with
aggregate client balances
household
than
less
$1,000,000, 2.45% for clients with household
account values of $1,000,000 but less than
$2,000,000, 2.00% for clients with household
account values of $2,000,000 but less than
$5,000,000, and 1.75% for clients with household
account values of $5,000,000 or more. In a lower
interest rate environment Baird’s annual rate of
fee-based
compensation will be
investment advisory IRA accounts participating in
the Bank Sweep Feature, Baird’s compensation is
a monthly per account fee (which is the same
regardless of client balances in bank deposit
accounts). The per account fee for these advisory
IRA accounts is generally paid out of the interest
that the banks pay on aggregate client balances
in the deposit accounts, and the per account fee
varies based on the applicable Fed Funds Target
Rate but in no event will it exceed $19.00 per
month. Baird also receives an annual rate of
compensation of up to 0.50% of the aggregate
client balances automatically invested into money
market mutual funds under the Money Market
Fund Feature. A client should note that the client
will be charged the asset-based Advisory Fee on
the value of all of the assets in the client’s
Accounts, including cash that is swept into a bank
deposit account or invested into a money market
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
trust administration
trust administration, custody,
related
to
those assets, and
its
mutual fund under the Cash Sweep Program. As a
result, Baird receives two layers of fees on a
client’s assets swept or invested in the Cash
the Advisory Fee, which
Sweep Program:
compensates Baird for the investment advice,
trading and custody services provided to the
client
the
compensation paid by the banks or money market
funds related to those assets, which compensates
Baird for the services Baird provides to the banks
and funds and for Baird’s efforts in maintaining
the Cash Sweep Program. The compensation that
Baird receives from the Cash Sweep Program
gives Baird a financial incentive to recommend
that a client participate in the Cash Sweep
Program and maintain high levels of uninvested
cash balances in the client’s accounts.
any
trust
financial
incentive
to
As an alternative to the Cash Sweep Program,
Baird makes available other money market
mutual funds and other cash alternatives in which
a client may invest, often at a higher yield,
although these investments do not have an
automatic sweep feature. In addition, instead of
maintaining cash balances in an advisory Account,
a client has the option to maintain such cash
balances in a brokerage account that is not
subject to an asset-based Advisory Fee.
it
including Baird Trust Company (“Baird Trust”),
services,
that provide
including
tax
reporting and recordkeeping. PAM Consultants at
times refer clients seeking trust services to
institutions that are members of the alliance.
Subject to
fiduciary duties, the trustee
oftentimes retains Baird to provide investment
advisory services to the client trust. A client
should understand that any such referral for trust
services under the Trust Alliance Program made
by Baird and its PAM Consultants is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
services
such
oversee
arrangement. Baird has a financial incentive to
recommend that clients use Baird Trust, an
affiliate, over other non-affiliated trust companies.
As a result of this affiliation, Baird Trust also has
a financial incentive to retain Baird to provide
investment advisory or other services on behalf of
the client. In addition, Baird and PAM Consultants
have a
recommend
arrangements that involve Baird and the PAM
Consultant providing investment advisory services
to the client and the trust company only providing
trust administration services compared to an
arrangement whereby a trust company would
investment advisory and trust
provide both
administration services because
is more
profitable to Baird and the PAM Consultant.
in connection with
A client should understand that the Cash Sweep
Program is an ancillary account service and it is
not nor is it part of any advisory program or
investment advisory service. PAM and Baird do
not act as investment adviser or a fiduciary to a
client
the Cash Sweep
Program. However, a client should note that the
amount of the client’s advisory Account dedicated
to cash and cash equivalents is part of the overall
investment allocation advice provided to the client
and thus the amount of such cash and cash
equivalents included in the calculation of the
Advisory Fee for the client’s advisory Account.
ongoing
Baird
Trust
generally
on
website
More detailed information about the Cash Sweep
Program and the compensation Baird receives is
available
at
Baird’s
www.rwbaird.com/cashsweeps. A
client also
receives information about the compensation
Baird receives from the Cash Sweep Program
through a client’s account statements.
Trust Services Arrangements
Baird maintains an alliance with
certain
institutions, both non-affiliated and affiliated,
In addition, outside of the Trust Alliance Program,
PAM Consultants may refer a client to Baird Trust
to provide investment management and trust
administration services to the client. If a client
enters into such a relationship with Baird Trust,
Baird and the client’s PAM Consultant typically
relationship management
provide
services.
provides
compensation to Baird and the client’s PAM
Consultant for the referral and providing ongoing
services, which may be up to 50% of the ongoing
fees that a client pays to Baird Trust, and which is
credited to the client’s PAM Consultant
for
purposes of determining the PAM Consultant’s
compensation. The compensation paid to Baird
and a client’s PAM Consultant does not increase
the fees that the client pays to Baird Trust. Due to
Baird’s affiliation with Baird Trust and the
compensation paid to Baird and PAM Consultants,
Baird and PAM Consultants have a financial
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Baird PAM F+C Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
incentive to favor Baird Trust over other trust
companies.
Margin Loans
A client should note that Baird’s margin loan
program is generally intended to be used to fund
additional purchases of securities. or short-term
liquidity needs. If a client wishes to obtain a loan
for some other purpose, a client should instead
consider whether the client is eligible for Baird’s
Securities-Based Lending Program, which involves
clients obtaining loans from third-party lenders for
general use purposes. Baird and PAM Consultants
have a conflict to the extent they would
recommend that a client use the Baird margin
loan program instead of the Securities-Based
Lending Program because a client pays interest
and other fees to Baird instead of a third-party
lender.
visit
Additional important information about margin,
including the risks and margin interest rates that
apply, is set forth in the “Margin” section of
Baird’s website at bairdwealth.com/retailinvestor.
contact
website
a
Securities-Based Lending Program
loan, Baird has an
incentive
that any margin balance
(i.e.,
the
loan or
Margin involves borrowing money from Baird
using eligible securities as collateral, including for
the purpose of buying securities. If a client uses
margin, the client will pay Baird interest on the
amount the client borrows. The rate of interest
that a client pays on a margin loan will be at a
base rate determined by Baird plus or minus a
specified percentage that varies based on the
outstanding debit balance of the margin loan and
the client’s household account value. Interest
rates are lower for larger debit balances and
those with higher household account balances. As
a result, rates will vary. To determine the actual
interest rate that may apply to a client’s margin
at
Baird’s
loan,
rwbaird.com/loanrates
PAM
or
Consultant. Because a client will pay interest to
Baird on the outstanding balance of the client’s
margin
to
recommend to the client investment products and
services that involve the use of margin. Baird and
PAM Consultants also have an incentive to
recommend investment products and services
that involve the use of margin, because a margin
loan allows a client to make larger securities
purchases and retain assets
in the client’s
that pay an ongoing asset-based
Accounts
Advisory Fee instead of liquidating them to fund a
cash need, which increases the asset-based fees
Baird earns on a client’s Accounts. A client should
note
the
outstanding amounts of the margin loan the client
owes to Baird) in the client’s advisory Accounts
will not be applied to reduce the client’s billable
account value in calculating the client’s asset-
based Advisory Fee, which gives Baird and PAM
Consultants further incentive to recommend client
use of margin instead of liquidating assets to fund
a cash need. Because the interest Baird receives
and fees Baird earns on a client’s Accounts
increase as the amount of the client’s margin loan
increases, Baird and PAM Consultants also have
an
incentive to recommend that the client
continue to maintain a margin loan balance with
Baird at high levels. Baird has the right to lend
the securities a client pledges as collateral for the
client’s margin loan, and Baird receives additional
compensation for lending those securities, which
provides Baird a further incentive to recommend
margin to a client.
Baird offers clients an opportunity to borrow
money from a third party lender under Baird’s
Securities-Based Lending Program. These loans, if
made, can be used for any personal or business
purpose other than to purchase, carry or trade
securities, or to repay margin debt. These loans
are secured by the investments and other assets
in the client’s accounts with Baird. A client will
pay interest on the outstanding balance of the
client’s loan. The rates of interest charged by the
bank depends on many factors, such as the
prevailing interest rate environment, the amount
line of credit, a client’s
of
creditworthiness, and the aggregate assets in a
client’s Baird accounts in the client’s household
(“relationship size”). The interest rates are based
on a benchmark
rate, plus an applicable
percentage that varies based on the approved
loan amount and the relationship size. Rates are
generally higher for smaller loans and relationship
sizes and lower for larger loans and relationship
sizes. The interest rate that will apply to a client’s
loan will be set forth in the loan agreement the
client enters into with the bank. Baird receives an
ongoing administrative fee from the bank, at an
annual rate of up to 2.50% of the outstanding
balance under a client’s loan, which is paid by the
bank out of the interest the client pays to the
bank. A client’s PAM Consultant typically receives
an ongoing referral fee at an annual rate of up to
0.25% of the outstanding balance of the client’s
loan, which is paid out of Baird’s administrative
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Client Responsibilities
financial
incentive
A client is responsible for providing information to
Baird and the client’s PAM Consultant reasonably
requested by them in order to provide the
services selected by the client. Baird, the client’s
PAM Consultant and investment managers, if any,
will rely on this information when providing
services to the client. A client is also responsible
for promptly informing the client’s PAM Consultant
of any significant life changes (e.g., change in
marital status, significant health issue, or change
in employment) or if there is any change to the
client’s investment objectives, risk tolerance,
financial circumstances, investment needs, or
other circumstances that may affect the manner
in which the client’s assets are invested. None of
the client’s PAM Consultant or any
Baird,
investment manager managing a client’s Account
is responsible
for any adverse consequence
arising out of the client’s failure to promptly
inform the client’s PAM Consultant of any such
changes. Since investment goals and financial
circumstances change over time, a client should
review the client’s participation in a Service with
the client’s PAM Consultant at least annually.
of
website
Retirement Accounts
fee. A client should note that Baird and PAM
Consultants will continue to receive compensation
on assets held in the client’s accounts that serve
as collateral for the client’s loans, including
Advisory Fees. Because Baird
receives an
administrative fee and PAM Consultants receive a
referral fee if a client obtains a loan from a third
party
lender under Baird’s Securities-Based
Lending Program, Baird and PAM Consultants
have an incentive to recommend that a client
obtain loans under that program. Baird and PAM
Consultants will continue to receive compensation
on assets held in a client’s accounts that are
collateral for such loans, including Advisory Fees
on such assets if those assets are in the client’s
advisory Account. As a result, Baird and PAM
Consultants have a
to
recommend that a client obtain a loan under the
program to provide for the client’s needs instead
of liquidating assets in the client’s accounts with
Baird because a decline in the amounts the client
has in the client’s accounts will result in lower
revenues to Baird and compensation paid to the
client’s PAM Consultant. Additional important
information about securities-based lending is set
forth in the “Securities-Based Lending Program”
at
Baird’s
section
bairdwealth.com/retailinvestor.
A client should understand that any referral made
the
by Baird and PAM Consultants under
Securities-Based Lending Program is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
oversee any such lending arrangement.
Other Non-Advisory Services
Additional laws, regulations and other conditions
apply to Retirement Accounts. Each owner,
trustee, plan
sponsor, adopting employer,
responsible plan fiduciary, named fiduciary, or
other fiduciary acting on behalf of a Retirement
Account (“Retirement Account Fiduciary”) should
understand that PAM and Baird do not provide
legal advice regarding Retirement Accounts. A
Retirement Account Fiduciary is urged to consult
with his or her own legal advisor about the laws
and regulations that may apply to Retirement
Accounts. ERISA and the IRC prohibit PAM and
Baird from offering certain types of investment
products and services to Retirement Accounts.
Legal and Tax Considerations
A client’s investment activities may have legal
and tax consequences to the client.
purchases,
sales,
The investment strategies used for a client’s
Account and transactions in a client’s Account,
liquidations,
including
redemptions, and rebalancing transactions, may
cause the client to realize gains or losses for
income
tax purposes. Funds often make
distributions of income and capital gains to
Certain Baird associates from time to time may
provide clients with tax return preparation, bill
pay or related services. In some instances, the
fee for those services may be bundled with the
Advisory Fee. A client should understand that the
provision of such services is separate from, and
not related to, the Services offered under this
Brochure and will be governed by an agreement
separate from the client’s advisory agreement
with Baird. A client should understand that Baird
and its associates do not act as investment
advisor or fiduciary to the client when providing
tax return preparation, bill pay or related non-
advisory services to the client.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investors, which may cause the client to realize
income for tax purposes.
for any tax‑related effects or obligations resulting
from the investments or transactions in a client’s
Account.
Account Requirements
Opening an Account
Certain investment products, such as Alternative
Investments and Complex Investments, are
classified as partnerships. Clients invested in such
investment products will be treated as partners
for U.S. federal income tax purposes, which has
tax implications different from other types of
investments, including Schedule K-1 reporting.
A client that wishes to engage PAM will enter into
an advisory agreement with PAM and Baird. The
client’s advisory agreement will contain the
specific terms applicable to the services selected
by the client, Advisory Fees payable by the client,
and other terms applicable to the client’s advisory
relationship with PAM and Baird.
taxable
Clients with tax-exempt Accounts, such as certain
Retirement Accounts or charitable or religious
organization Accounts, should be aware that some
investments, such as some Non-Traditional
Assets, Alternative Investments and Complex
income,
Investments, may produce
referred to as unrelated business taxable income
(“UBTI”). In such circumstances, such clients will
be required to pay tax on the UBTI produced by
the tax-exempt Accounts.
is a brokerage agreement
In addition to the investment advisory services
that PAM and Baird provide in connection with
each Service, Baird, in its capacity as broker-
dealer, may provide clients with trade execution,
custody and other standard brokerage services.
For this reason, a client may also enter into a
client account agreement with Baird if the client
has not already done so. The client account
agreement
that
authorizes Baird to execute trades for, and
perform related brokerage and custody services
to, the client’s Account.
Baird generally requires that assets in a client’s
Account be held in a Baird account, for which
Baird acts as custodian. However, in certain
limited circumstances when requested by a client,
Baird may permit a client to include Held-Away
Assets in the client’s Account.
A client’s ability to recognize losses in an Account
for tax purposes may be disallowed, limited or
deferred by applicable tax rules. For example, IRS
wash sales rules will disallow a client’s tax
deductions for a loss in an Account related to the
sale of an investment if the client purchases
(whether through Baird or another firm) a
“substantially identical” investment within the
wash sale period (currently 30 days before or 30
days after the date of the sale). Similarly, IRS
straddle rules limit and defer a client’s ability to
claim tax deductions related to the loss on a sale
of an investment in an Account if the client holds
an offsetting position in any account held at Baird
or another firm.
the Services,
the
tax
implications of
to
PAM and Baird do not offer legal or tax advice to
clients. The information, recommendations, and
services provided by PAM and Baird to clients
through
including, without
limitation, tax management strategies, do not
constitute tax advice. A client is responsible for
the
understanding
investment activities in the client’s accounts
(whether held at Baird or another firm) and
complying with applicable tax rules. A client is
strongly urged to consult with the client’s tax
advisor about potential tax implications before
making investment or trading decisions. PAM and
Baird do not undertake any responsibility to
monitor or verify a client’s compliance with
applicable tax rules, and they are not responsible
After a client has signed and delivered an
advisory agreement to Baird, the agreement is
subject to review and acceptance by the client’s
PAM Consultant, his or her Market Director or
PWM Supervision department supervisor (or his or
her respective designee), and Baird PWM’s Home
Office. The agreement and Baird’s advisory
relationship with a client will become effective
when the client’s paperwork is accepted by Baird
PWM’s Home Office and following such acceptance
Baird has delivered
the client written
confirmation of the Account’s enrollment in the
applicable Service. A client should understand
that the advisory agreement will not become
effective, and Baird will not provide any advisory
services to the client, until such time that Baird
has accepted the advisory agreement. Baird may
delay acceptance of the advisory agreement and
the provision of advisory services to the client for
various reasons, including deficiencies in the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
client’s paperwork. Once it has become effective,
the agreement shall continue until it is terminated
in accordance with the terms described in the
advisory agreement.
certain
retain
those documents
for
The terms of a client’s agreements and this
Brochure apply to all Accounts that a client
establishes with PAM, including any Accounts that
a client may open with Baird in the future. Some
of the information in those documents may not
apply to a client now, but may apply in the future
if a client changes services or establishes other
Accounts with PAM. PAM will generally not provide
a client another copy of the agreements or this
Brochure when a client changes services or
establishes new Accounts unless
the client
requests a copy from PAM. Therefore, a client
future
should
reference as they contain important information if
a client changes services or establishes other
Accounts with PAM.
Certain Account Requirements
Minimum Account Size
is sometimes referred to dollar cost averaging
(“DCA”). The goal of this method of investment is
to reduce the risk of making large purchases of
securities at an inopportune time or price. The
Overlay Manager
investment
and
managers also offer an optional DCA service for
Accounts they manage. Additional information will
be provided to a client if the client enrolls in a
DCA service. A client should note that, if dollar
cost averaging is used to invest cash in the
client’s Account, the returns for the Account
could, depending upon market and other
conditions, be lower than the returns that could
have been obtained had all the cash in the
Account been fully invested upon contribution to
the Account. In addition, a client should note that,
when dollar cost averaging is used, the amount of
cash in the client’s Account will be included in the
value of the Account for fee calculation purposes.
Whenever assets are contributed to an Account, a
client should discuss with the client’s PAM
Consultant the timing of when the assets will be
invested. If DCA will be used to invest the assets,
a client should ask for more specific information
about how the assets will be invested and the
associated timing for investing.
that
Each Service has a minimum account size and
may have a minimum Advisory Fee, which are
described in the section entitled “Fees and
Compensation—Advisory Fees” below. PAM or
Baird may remove an Account from a Service and
immediately terminate the advisory agreement
with respect to an Account upon written notice to
the client if the client fails to maintain the
required minimum asset levels in an Account or if
the client fails to otherwise abide by the terms of
a Service as determined by PAM or Baird in their
sole discretion.
Account Contributions and Withdrawals
in
investment manager until
sale
could
in adverse
A client may fund an Account with cash and with
securities that PAM, Baird and the client’s
if any, deem
investment manager,
to be
acceptable
their sole discretion. Funds
deposited or transferred to a client’s SMAs from
another Baird account and funds deposited or
transferred to a client’s SMAs from outside of
Baird will not be available for investment by the
client’s
the next
business day and therefore the investment of
such funds, at the discretion of the manager, will
occur no earlier than the next business day.
When a client funds an Account with securities,
including when a client changes Services for an
Account or changes investment managers for an
Account within the same Service, the client should
understand that PAM’s, Baird’s or the client’s
investment manager’s review of securities used to
fund the Account may delay
investing. In
addition, PAM, Baird or the client’s investment
the
if any, may determine
manager,
securities contributed to the Account may not be
appropriate for the client’s strategy, and PAM,
Baird or the investment manager, if any, may
sell, or recommend the sale of, such securities.
Further, an investment manager may be removed
from the management of a client’s Account and a
replacement
investment manager may be
appointed. In such event, Baird, at the direction
of the client’s replacement manager, or the
client’s replacement manager may sell all or a
portion of the securities or other investments in
the Account that were managed by the prior
manager and the replacement manager will
reinvest the cash proceeds of those sales. Any
such
tax
result
consequences for the client. A client should note
that securities transferred into an Account may be
subject to the Advisory Fee immediately upon its
transfer into the Account, even if the client paid a
Some PAM Consultants will invest, or recommend
investing, cash contributions made to an Account
over a period of time. This method of investment
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
such sale of assets held in an Account. Any such
sale of assets will be executed in Baird’s capacity
as broker-dealer and creditor and may, as
permitted by law, result in executions on a
principal basis. Such sales could have adverse tax
consequences, disrupt a client’s
investment
strategy, and have an adverse impact on the
Account’s performance. A client should review the
client’s agreements for more information.
commission or front-end sales charge on the
security prior to its transfer into the Account. In
addition, if the securities are subject to deferred
sales charges or redemption fees, the client will
be responsible for paying those charges and fees.
To the extent permitted by applicable law, certain
funding transactions may be handled by Baird on
a principal basis, and such transactions are not
considered investment advisory services of PAM,
Baird or the client’s investment manager.
All of the assets in a client’s Account must be free
and clear from any security interest, lien, charge
or other encumbrance (other than a security
interest, lien, charge or other encumbrance in
favor of Baird) and must remain so for the
duration of the client’s relationship with Baird,
unless Baird otherwise specifically agrees in
writing.
Business—Additional
If an asset transferred to an Account is an
Unpermitted Investment under the terms of the
applicable Service, PAM, Baird or the client’s
investment manager may sell the asset or
transfer it into a separate brokerage account.
Alternatively, they may designate such asset as
an Unsupervised Asset as further described under
“Advisory
Service
Information—Unsupervised Assets” above.
If a client wishes to obtain loans secured by
assets in the client’s Account (commonly referred
to as “securities-based lending”) and PAM and
Baird agree to the arrangement, the client should
understand that the lender may exercise certain
rights and powers over the assets in the Account,
including the disposition and sale of any and all
assets pledged as collateral for the loan to meet a
collateral call, which may occur without prior
notice to the client. A collateral call could have
adverse tax consequences, disrupt a client’s
investment strategy, and have an adverse impact
on the Account’s performance. A client should be
aware of these and other potential adverse effects
of securities-based lending and collateralizing
Accounts before deciding to do so.
A client is responsible for notifying PAM and any
investment manager managing
the client’s
Account of any contributions made into the
Account and instructing PAM and any investment
manager to liquidate positions in the event the
from the
client wishes to withdraw assets
Account. PAM and Baird have no responsibility to
invest cash deposits (other than complying with a
client’s cash sweep instructions) or liquidate
positions with respect to an Account managed by
an Other Manager, and they are not responsible
for any losses that may result from a client’s
failure to notify PAM and any investment manager
managing the client’s Account regarding deposits
or withdrawals.
A client may also incur additional expenses and
liabilities, including tax related liabilities, when
transferring assets out of an Account or Baird’s
custody. See “Termination of Accounts” below.
A client is required to disclose the terms of the
client’s agreements with Baird to any lender
seeking to use Account assets as collateral. A
client must promptly notify PAM and Baird of any
default or similar event under the client’s
collateral arrangements.
Liens and Use of Account Assets as Collateral
A client should understand that neither PAM nor
Baird will provide advice on or oversee a
securities-based lending or collateral arrangement
and they will not act as investment adviser or a
fiduciary to the client with respect to the
liquidation of securities held in the client’s
Account to meet a collateral call. Any such
liquidation will be executed in Baird’s capacity as
broker-dealer and may, as permitted by law,
result in executions on a principal basis.
As security for the full and complete payment
when due of any debts and other obligations that
a client owes to PAM and Baird, and to the extent
permitted by applicable law or regulation, all
assets in a client’s Account held at Baird will be
subject to a first priority security interest, lien and
right of setoff in favor of Baird. Baird may sell
assets in an Account to satisfy the lien. As a
secured party, Baird may have interests that are
adverse to a client. Neither PAM nor Baird will act
as investment adviser to a client with respect to
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
“Additional
In some instances, Baird and PAM Consultants
may refer a client to a third party lender under
Baird’s Securities-Based Lending Program that
certain
pays Baird and PAM Consultants
compensation.
Service
See
Information—Securities-Based Lending Program”
above for more information.
exclusive
responsibility
to
Business—Additional
in
writing,
other
investment manager managing such
Account, shall have no obligation to act as
investment adviser to such Account. If such
Account is custodied at Baird, the Account shall
be converted to and designated as a brokerage
account. PAM, Baird, and, if relevant, any other
investment manager managing such Account,
shall be under no obligation to recommend any
action with regard to, or to liquidate the securities
or other investments in, such Account. After an
Account is removed from a Service, it is the
issue
client’s
the
regarding
instructions,
management of any assets in such Account.
Securities purchased on margin are used as
Baird’s collateral for the margin loan. Clients that
have a margin account should review the section
“Advisory
Service
Information—Complex Strategies and Complex
Investment Products” above
for additional
information.
Electronic Delivery of Documents
By signing an advisory agreement, a client
consents to the electronic delivery of documents
that PAM or Baird may deliver to the client. The
term of the consent to electronic delivery is
indefinite but a client may revoke the consent at
any time by notifying PAM.
Termination of Accounts
If a client directs Baird to liquidate assets in
connection with a closure of an Account, the client
should understand that Baird acts as broker-
dealer, and not
investment adviser, when
processing such a liquidation request and that the
client will generally be charged commissions,
sales charges, sales “loads”, or other applicable
transaction-based fees in accordance with the
applicable Baird fee schedule or other third-party
transaction-based fee schedule for the particular
investment then in effect. Additional information
about the compensation that a client pays to
Baird for effecting brokerage transactions is
contained in Baird’s Client Relationship Details
document, available on Baird’s website at
bairdwealth.com/retailinvestor.
A client may incur significant expenses and
liabilities, including tax-related liabilities for which
the client will be solely liable, if the client closes
an Account, terminates an advisory agreement, or
transfers assets out of Baird’s custody. PAM and
Baird will not be liable to a client in any way with
respect to the termination, closure, transfer or
liquidation of the client’s Accounts.
The client’s advisory agreement will survive any
event that causes the client’s PAM Consultant to
be unable to provide services to the client (either
on a temporary or permanent basis), including if
the client’s PAM Consultant ceases
to be
employed by Baird. In any such event, Baird will
endeavor to continue to provide services to the
client and will as promptly as practicable assign
another PAM Consultant or Baird Financial Advisor
to the client’s Accounts (either on a temporary or
permanent basis) and the client will be notified of
any such change or, if Baird determines that it is
unable to continue to provide advisory services to
the client, Baird may remove the applicable
Account from a Service or Program and convert
the Account to a brokerage account upon notice
to the client.
PAM or Baird may remove an Account from a
Service and immediately close an Account upon
written notice to a client if the client fails to abide
by the terms of the Service. PAM or Baird may
also remove an Account from a Service at any
time upon written notice to a client if the client
fails to maintain the required minimum asset
levels in such Account.
Upon the termination of an Account’s enrollment
in a Service, PAM, Baird and, if relevant, any
Some of the investments offered in connection
with the Services contain restrictions that limit
their use, and such
investments may be
unavailable for purchase or holding outside of an
Account. For example, certain mutual funds, ETFs
or other Funds held in an Account may only be
available to a client through a PAM Service or may
not be held at another firm. If such restrictions
apply and the client terminates a Service or closes
an Account, the Client will be required to sell or
redeem such Funds or exchange them for other
Funds that may be more costly to the client or
have poorer performance. A client should consider
restrictions applicable to investments carefully
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Baird PAM F+C Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
to how Account
before participating in a Service. A client should
contact the client’s PAM Consultant for specific
information as
closure,
termination of an agreement, or asset transfers
might impact the assets in the client’s Accounts.
Fees and Compensation
Advisory Fees
Fee Options and Fee Schedules
advice fee (“Advice Fee”) and, for some Services,
an additional portfolio fee (“Portfolio Fee”). The
Advice Fee covers certain investment advisory
and custody services provided by PAM and Baird.
The Portfolio Fee covers portfolio management
and other services provided by Baird and the
manager to the client’s Account, which may
include departments or affiliates of Baird. If a
client has a Unified Advice Fee Arrangement, the
client’s Advisory Fee rate will be equal to the sum
of the applicable Advice Fee rate and the
applicable Portfolio Fee rate, if any.
Clients with a Unified Advice Fee Arrangement
generally choose a breakpoint fee schedule for the
Advice Fee portion of the Advisory Fee.
fee
arrangement,
A client’s advisory agreement will set forth the
actual compensation the client will pay to Baird.
In most instances, a client pays an ongoing
Advisory Fee based upon the value of assets in
the client’s Account (an “asset-based
fee”),
although other options, such as a flat fee or a
commission-based
are
available.
Breakpoint Advice Fee Schedules
Asset-Based Fee Arrangement
fee
PAM generally offers one asset-based
arrangement: a breakpoint fee schedule.
All Services Except Consulting Services. The
following fee schedule sets forth the maximum
breakpoint Advice Fee rates for the Services
(other than Consulting Services) provided by
PAM.
Unified Advice Fee Arrangement
Breakpoint Advice Fee Schedule
Services (Other Than Consulting Services
Value of Assets
Annual Fee Rate
Under a breakpoint fee schedule, the asset-based
fee is determined by reference to the market
value of the client’s Account assets, with the fee
rate being lower for accounts with higher levels of
assets. The breakpoint fee, once determined, is
then applied to all of the assets in the client’s
Account.
$0 to $249,999
3.00%
$250,000 to $499,999
2.50%
$500,000 to $999,999
2.25%
$1,000,000 to $1,999,999
2.00%
$2,000,000 to $4,999,999
1.75%
The asset-based fee may be a fixed percentage
across all asset categories or
investment
strategies or may be a percentage that varies by
investment strategy. For
asset category or
example, an Account pursuing an equity strategy
may pay a higher fee rate than an Account
pursuing a fixed income strategy.
$5,000,000 and above
1.50%
Consulting Services. The following fee schedule
sets forth the maximum breakpoint Advice Fee
rates for the Consulting Services provided by
PAM.
The typical asset-based fee varies depending
upon the Service and the fee option selected by
the client. Fee options and rates may also differ
among different Accounts held by the same client,
for an
depending on the services selected
Account.
Unified Advice Fee Arrangement
Breakpoint Advice Fee Schedule
Consulting Services
All new client Accounts paying an asset-based fee
are generally subject to a unified advice fee
arrangement (“Unified Advice Fee Arrangement”),
which is described below.
Value of Assets
Annual Fee Rate
Unified Advice Fee Arrangement
Up to $10 million
0.50%
$10 million - $25 million
0.45%
Under a Unified Advice Fee Arrangement, the
asset-based Advisory Fee is comprised of an
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Unified Advice Fee Arrangement
Breakpoint Advice Fee Schedule
Consulting Services
Value of Assets
Annual Fee Rate
The Portfolio Fee rates are current as of the date
of this Brochure. A client’s actual Portfolio Fees
could be higher or lower than the amounts shown
above if Baird adds new investment managers to
the Services with higher or lower fees or if Baird
and a manager renegotiate the amount of the
subadvisory fee.
$25,000,001 - 50 million
0.35%
Above $50 million
Negotiable
Portfolio Fee Schedule
The Advice Fee and Portfolio Fee rates do not
reflect the internal fees and expenses of any
Funds or other investment products used in
connection with a strategy, the costs of which are
borne by a client in addition to the Advisory Fee.
See “Other Fees and Expenses” below.
following
fee schedule sets
forth
The Portfolio Fee
rate varies by Service,
investment vehicle, and the type of investment
strategy or style being pursued by the Account.
The
the
maximum Portfolio Fee rates or range of rates for
the Services.
Portfolio Fee Schedule
Service
Annual Fee Rate
or Range of Rates
PAM Investment Management
0.00%
titled
“Administrative
PAM Recommended Managers
0.20% - 0.75%
Equity SMA Strategies
In some instances, Baird provides operational and
administrative services to third party managers in
connection with their management of client
Accounts. As compensation for those services,
Baird receives a portion of the Portfolio Fee at an
annual rate of up to 0.02% of the value of the
Account. Additional information is contained in the
document
Servicing,
Revenue Sharing, and Other Third Party
Payments” available on Baird’s website at
bairdwealth.com/retailinvestor.
0.20% - 0.52%
Balanced SMA Strategies
0.25% - 0.40%
Fixed Income SMA Strategies
0.25% - 0.70%
Global and International SMA
Strategies
0.35% - 0.60%
For more specific information about the fee that
applies to an existing Account, a client should
refer to the paperwork the client received when
opening the Account or the client may contact the
client’s PAM Consultant.
Alternative SMA Strategies
0.10%
Tax Managed Strategies
0.09%
Index SMA Strategies
Baird SMA Network (BSN)
0.22% - 0.77%
Equity SMA Strategies
0.22% - 0.52%
Balanced SMA Strategies
0.10% - 0.27%
Fixed Income SMA Strategies
0.27% - 0.52%
Global and International SMA
Strategies
0.37% - 0.77%
Alternative SMA Strategies
—1
Dual Contract (DC)
Certain managers offer lower Portfolio Fee rates
for SMA Strategies to clients through the DC
Program compared to the PAM Recommended
Managers or BSN Programs. If a client has
decided to participate in the DC Program, upon
the client’s request, the client’s PAM Consultant
may assist the client with the client’s negotiation
with the manager of the Portfolio Fee rate for the
applicable SMA Strategy. The Portfolio Fee
negotiated by the client could be higher or lower
than the Portfolio Fee that applies to the same
SMA Strategy that is available through other
Services. The client is ultimately responsible for
understanding the differences between the SMA
Programs, deciding to participate in the DC
the SMA Strategy, and
Program, selecting
negotiating and agreeing to the Portfolio Fee rate.
Flat Fee Arrangement
1 Fees charged by managers under the DC Program are
negotiated by each client pursuant to a separate
agreement that does not include Baird. Baird, therefore,
does not have the necessary information to provide a
definitive range of fees paid to managers under the DC
Program.
Under a flat fee arrangement, the applicable fee
may be determined according to a fixed asset-
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Additional Advisory Services
Account Minimums
Service
Asset Level
PAM Investment Management
$100,000
PAM Recommended Managers
$100,000(1)
based fee rate or may be a fixed dollar amount.
Specific services may each have their own,
separately-stated, flat fee, or several services
may be grouped together under a single flat fee.
Some services may entail a flat fee per usage.
Flat fees are negotiable and vary by client. The
details of flat fee arrangements, including fee
amounts, the billing schedule, and the services
covered, will be included in the client’s advisory
agreement.
Commission-Based Fee Arrangement
commission-based
(1) BSN Fund Strategist Portfolios have a minimum
account requirement of $10,000. Other SMA
Strategies typically have an account minimum of
$100,000. However, each investment manager sets
its own minimum account size requirements, which
can range from $25,000 to more than $1,000,000.
As a result, some investment managers may not be
available to clients with smaller accounts.
A client’s Account may also be subject to a
minimum quarterly Advisory Fee that will be set
forth in the client’s advisory agreement regardless
of the value of the assets in the client’s Account.
The minimum annual Advice Fee
for PAM
Investment Management Accounts is generally
$3,000 for equity or balanced Accounts and
$1,250 for fixed income Accounts. In addition, if a
third party custodian has custody of the client’s
Account assets, Baird may
impose Account
requirements different than those set forth above,
including but not limited to higher minimums, and
it may impose additional fees due to the increase
in resources needed to administer the Account.
A client is encouraged to periodically review with
the client’s PAM Consultant the client’s Advisory
Fee and the services provided to determine if the
services and fees continue to meet the client’s
needs.
Advisory
Calculation and Payment of Advisory Fees
fee
PAM also offers a
arrangement. In contrast to the asset-based fee
arrangements described above, a client who
selects a commission-based fee arrangement
pays PAM and Baird commissions and other costs
and expenses of the transactions that are effected
for the client’s Account (“Transaction Fees”).
These commissions and other transaction charges
compensate PAM and Baird for the combination of
investment advice and brokerage services they
provide. Depending upon a client’s selection, a
client’s Account may be subject to a commission-
based fee arrangement or may be subject to both
a commission-based fee arrangement and asset-
based fee arrangement. For example, if a client’s
Account is managed by an investment manager
other than PAM, a client electing a commission-
based fee arrangement may pay Transaction Fees
to PAM for the trades placed by the investment
manager and an asset-based fee to PAM and the
client’s investment manager. If a client selects a
commission-based fee arrangement, the client’s
advisory agreement will set
forth how the
compensation the client will pay to PAM and Baird
will be determined. See “Calculation and Payment
of
Fee
Fees—Commission-Based
Arrangements” below for more information.
Asset-Based Fee Arrangements
Service Account Minimums
The minimum asset value to open an Account in a
Service is set forth in the table below.
Additional Advisory Services
Account Minimums
Service
Asset Level
Consulting Services
Negotiable
Baird SMA Network
$100,000(1)
Dual Contract
$100,000(1)
Baird will calculate a client’s Advisory Fee by
applying the applicable fee rate to the value of all
of the assets in the client’s Accounts, including
cash and its equivalent and including all Held-
Away Assets, unless otherwise agreed to in
writing. Liabilities held in a client's Accounts,
including the value of margin debit balances, open
short sale positions and open options positions
with a negative market value will be excluded
from the calculation of a client's Advisory Fee. The
value of cash balances held in a client’s Account
will be excluded from the calculation of a client's
Advisory Fees in an amount equal to the value of
any open short sale positions and options
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
positions with a negative market value held in the
margin account.
custodian other than Baird, Baird may also use
valuation information provided by the client’s
third party custodian in determining the value of
the assets in the client’s Account.
is unreliable. Valuation data
If requested by a client and approved by Baird, a
client’s Advisory Fee may be determined by also
including the aggregate value of assets in certain
other Advisory accounts held by a client and
certain members of the client’s household or
family (a “household fee arrangement”). A client
should note that Retirement Accounts may not be
included in a household fee arrangement to the
extent a prohibited transaction under ERISA or
the IRC may result. The terms of any such
household fee arrangement will be set forth in the
client’s advisory agreement.
third party pricing services,
Neither PAM nor Baird conducts a review of
valuation information provided by third party
pricing services, issuers, sponsors, or custodians,
and they do not verify or guarantee the accuracy
of such information. PAM and Baird do not accept
responsibility for valuations provided by third
parties that are inaccurate unless they have a
reason to believe that the source of such
valuations
for
investments, particularly annuities and Complex
Investment Products, may not be provided to
Baird in a timely manner, resulting in valuations
that are not current. The prices obtained by Baird
from
issuers,
sponsors and custodians may differ from prices
that could be obtained from other sources.
Values used for fee-calculation purposes may vary
from prices received in actual transactions and
are not firm bids, offers or guarantees of any type
with respect to the value of assets in an Account,
and the Advisory Fee for some securities may be
calculated based on values that are greater than
the amount a client would receive if the securities
were actually sold from the client’s Account.
While PAM and Baird may perform an analysis as
to whether any client Accounts may be eligible for
a household fee arrangement, a client should note
that it is client’s sole responsibility to inform the
client’s PAM Consultant that client’s household or
family has two or more Advisory accounts that
are eligible for a household fee arrangement. PAM
and Baird do not undertake any obligation to
ensure client Accounts are eligible for a household
fee arrangement. By agreeing to a household fee
to such
arrangement, each client subject
household fee arrangement consents to PAM and
Baird providing to each other client subject to
such household fee arrangement, in PAM’s or
Baird’s sole discretion, information about the
aggregate level, or range, of household assets
used for fee calculation purposes. As a result,
each such client should understand that the other
clients included in the household fee arrangement
may be able to ascertain the amount of the
client’s assets at Baird.
As mentioned above, Baird will include cash and
cash equivalent balances in a client’s Account
when calculating a client’s asset-based Advisory
Fee. Baird has adopted internal policies that
monitor the percentage of an Account swept into
cash under the Cash Sweep Program. These
internal policies are designed to inform PAM
Consultants and their clients who hold large cash
sweep balances in their Accounts for sustained
periods that those Accounts are holding large
cash sweep balances and that there may be other
investment or account options for their cash and
that Baird receives direct compensation
in
addition to the Advisory Fee from client balances
in the Cash Sweep Program.
If a client maintains a debit balance in the client’s
margin account with Baird, such balance has no
bearing on the asset-based Advisory Fees charged
on client’s Account. In other words, the margin
balance (i.e., the outstanding amounts of the
margin loan a client owes to Baird) in client’s
Account will not be applied to reduce the client’s
For purposes of calculating a client’s asset-based
Advisory Fee, the value of a client’s assets is
generally determined by Baird. Baird generally
relies upon third party sources, such as third
party pricing services when valuing Account
assets. In some instances, such as when Baird is
unable to obtain a price for an asset from a
pricing service, Baird may obtain a price from its
trading desk or it may elect to not price the asset.
Obtaining a price from its trading desk may
present a conflict of interest. In some cases, Baird
obtains prices from the issuers or sponsors of
investment products in the client’s Account when
prices are not otherwise readily available. This
frequently occurs with respect to the valuation of
annuities and Complex Investment Products. If
the assets in the client’s Account are held by a
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
billable Account value in calculating the Advisory
Fee.
If a client’s Account is subject to direct billing, the
client is required to pay each bill within 30 days of
the date of the invoice. PAM and Baird may
automatically deduct a client’s Advisory Fees and
other charges from the client’s Account as
described above in the event that Baird does not
receive payment from the client within 30 days of
the date of the invoice. PAM or Baird may rescind
a direct billing arrangement with a client at any
time. Direct billing may not be available for
Retirement Accounts.
The Account value used for the Advisory Fee
calculation may differ from that shown on a
client’s Account statement or performance report
due to a variety of factors, including the client’s
use of margin, options, short sales, and other
considerations. If a client has assets held by a
third party custodian, the prices shown on a
client’s Account statements provided by the
custodian could be different from the prices
shown on statements and reports provided by
Baird. See “Advisory Services” above and
“Custody” below for more information.
To the extent permitted by applicable law, PAM or
Baird may increase a client’s existing fees and
other charges or add additional fees or charges by
providing the client with 30 days’ prior written
notice.
the
A client’s Advisory Fees are payable in accordance
with the terms of the client’s advisory agreement.
Typically, Advisory Fees are payable on a calendar
quarterly basis, in advance. The initial billing
period begins when
client’s advisory
agreement is accepted by Baird and the Account
is opened by Baird (the “Opening Date”). The
initial Advisory Fee payment will be adjusted for
the number of days remaining in the then current
quarter. The initial Advisory Fee will be based on
the value of assets in the client’s Account on the
Opening Date. The period which such payment
covers shall run from the Opening Date through
the last business day of the then current calendar
quarterly billing period. Thereafter, the quarterly
Advisory Fees shall be calculated based upon the
Account’s asset value on the last business day of
the prior calendar quarter and shall become
payable on the first business day of the then
current calendar quarter.
If PAM, Baird or the client terminates the client’s
advisory agreement or the client’s participation in
a Service, a pro-rated refund from the date of
termination through the end of the applicable
billing period will generally be made to the client
in the client’s affected Accounts. PAM and Baird
will not implement a decrease in the client’s fee
rate during a billing period or otherwise reimburse
or adjust Advisory Fees during any such period for
asset value appreciation or depreciation in a
client’s Account during such period. For example,
if a client’s Account is subject to a tiered or
breakpoint fee schedule and the asset levels of
the Account move into a new tier or cross a
breakpoint during such period, no rebate or fee
adjustment will be made. However, PAM and
Baird, in their sole discretion, may make fee
adjustments in response to asset fluctuations in a
client’s Account occurring during a billing period
that result from contributions to, or withdrawals
from, the client’s Account.
Each Service may have a minimum asset value in
order to open an Account, and a minimum
Advisory Fee may be assessed against a client’s
Account as further described under “Advisory
Fee—Fee Schedules” above. The minimum
Advisory Fee will be described in the client’s
advisory agreement. PAM may waive
the
minimum asset value or minimum Advisory Fee at
its discretion. The minimum Advisory Fee is
subject to change upon notice to the client.
the
client’s Account may
The Advisory Fee and minimum account value are
negotiable in certain instances and may vary
based upon a number of factors, including but not
A client’s Advisory Fees and other charges will be
automatically deducted from the client’s Account,
unless the client requests, and PAM and Baird
agree, to an alternate arrangement, such as
having Baird issue the client an invoice for the
Advisory Fees (“direct billing”). A client should
understand that the client’s Advisory Fees and
other charges relating to the client’s Account may
be satisfied from free credit balances and other
assets in the client’s Account. If free credit
balances in a client’s Account are insufficient to
pay the Advisory Fees or other charges when due,
investment manager
PAM, Baird and any
managing
sell
investments from the client’s Account to the
extent they deem necessary and appropriate, in
their sole discretion, to pay the client’s Advisory
Fees and other charges.
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Baird PAM F+C Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
varies depending upon the aggregate value of the
transaction.
sales
charges
and
limited to the size and nature of the assets in the
client’s Account, the client’s particular investment
strategy or objective, and any particular services
requested by the client. In some instances, clients
may pay a higher fee than indicated in the fee
schedules above. The fees paid by a client may
differ from the fees paid by other clients based on
a number of factors, including but not limited to
the factors identified above.
For other investment products, such as mutual
funds, UITs, annuities and Alternative Investment
Products, a client generally will pay
the
commissions,
other
transaction-based compensation disclosed in the
prospectus or other offering documents for the
applicable investment product. For certain types
of investments, a client will also indirectly pay
Baird and the client’s PAM Consultant ongoing or
trail commissions or fees (“trail fees”) described
in the prospectus or offering document for the
investment. Additional information about these
forms of compensation is provided on Baird’s
website at bairdwealth.com/retailinvestor.
The fee schedules set forth above are the current
fee schedules for the Services. Each Service has
had other fee schedules in effect, which may
reflect fees that are lower or higher, as the case
may be, than those shown above. As new fee
schedules are put into effect, they are made
applicable only to new clients, and fee schedules
applicable to existing clients may not be affected.
Therefore, some clients may pay different fees
than those shown above.
Commission-Based Fee Arrangements
For equity securities, ETFs, bond and no-load
mutual fund transactions, a client is subject to
Baird’s minimum commission charge then in
effect, unless otherwise stated in the client’s
agreement. The minimum commission charge
may change from time to time without notice to
the client and can be found on Baird’s website at
bairdwealth.com/retailinvestor or by contacting a
PAM Consultant.
the cost of
the
trade and,
A client’s advisory agreement will set forth how
the compensation the client will pay to PAM and
Baird will be determined. Instead of an asset-
based fee, clients who select a commission-based
fee arrangement pay
to PAM and Baird
Transaction Fees for each transaction effected for
their Accounts, similar to the compensation that a
client would pay if the Account was a brokerage
account.
The Transaction Fees and charges will be included
in
therefore,
automatically deducted from the client’s Account
or from the investment amount. Other fees and
charges, if applicable, will also be deducted from
the client’s Account.
to Baird’s
standard
To the extent permitted by applicable law, Baird
may modify a client’s existing fees, including
Transaction Fees, and other charges or add
additional fees or charges by providing the client
with 30 days’ prior written notice.
A client account may also be subject to a
minimum quarterly fee that will be set forth in the
client’s advisory agreement regardless of the
values of the assets in the client’s Account.
For equity securities and ETPs, such as ETFs, the
Transaction Fees generally will be determined
commission
according
schedule then in effect, unless otherwise stated in
the client’s advisory agreement. The commission
rates may be negotiated by the client. Baird’s
standard commission schedule considers the
share price or principal amount and the number of
shares traded
in determining the applicable
commission. Baird may change its standard
commission schedule at any time without notice
to the client. The transaction confirmation sent to
the client will disclose the amount of the
commission charged by PAM or Baird for that
transaction. Clients are encouraged to discuss
commission rates with their PAM Consultant.
The minimum account size is set forth above. This
minimum may be waived in PAM’s discretion.
For fixed income securities, such as bonds, a
client typically pays a fixed dollar amount per
security bought or sold for the client’s Accounts,
or the client may pay a certain dollar amount that
The Transaction Fees and minimum Account value
are negotiable in certain instances and may vary
based upon a number of factors, including but not
limited to the size and nature of the assets in the
client’s Account, the client’s particular investment
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Obtaining Services Separately: Brokerage or
Advisory? Factors to Consider
strategy or objective, and any particular services
requested by the client. The fees paid by a client
may differ from the fees paid by other clients
based on a number of factors, including but not
limited to the factors identified above.
in
Baird offers brokerage accounts and other
services to clients, and certain services provided
to a client in connection with a particular Service
may be available to a client outside of the Service
separately. Thus, a client’s participation in a
Service could cost the client more or less than if
the client purchased each service separately. A
number of factors bear upon the relative cost of
each Service. In comparing the Services to
brokerage accounts or other services, a client
should consider a number of factors, including,
but not limited to:
• whether a client prefers to have ongoing
monitoring, investment advice or professional
management of the client’s investments, which
are provided to Service Accounts, or whether
the client does not want or need such services;
Accordingly,
this
• whether the types of investment strategies,
products and solutions the client seeks are
available;
pay
the
greatest
levels
• whether there are limitations on the types of
securities and other investments available for
purchase and whether those limitations are
significant to the client;
the
• whether the nature and level of transaction
services, account performance reporting, or
other ancillary services the client wants are
available;
A client should note that Accounts with
commission-based fee arrangements present
some of the same conflicts of interest that
are present
traditional brokerage
accounts. The compensation received by
Baird and the client’s PAM Consultant under
is
a commission-based fee arrangement
directly related to the amount of Transaction
Fees and trail fees paid by the client and the
number of transactions effected for the
client’s Account. As
the amount of
Transaction Fees and trail fees paid by the
client and the number of transactions
effected for the client’s Account increases,
the compensation that Baird receives and
pays to the client’s PAM Consultant also
increases.
practice
presents a conflict of interest because it
gives Baird and the client’s PAM Consultant
an incentive to trade actively for the client’s
Account, recommend or select investments
that
of
compensation, recommend or select Other
Managers that trade actively, and provide
compensation
advice based upon
received rather than on a client’s needs. A
client is encouraged to review the conflicts
traditional
of
interest associated with
brokerage accounts contained
in Baird’s
Client Relationship Details document located
on Baird’s website at bairdwealth.com/
retailinvestor for more information.
• whether the client prefers to pay an ongoing
Advisory Fee for continuous advice or pay
commissions and other fees on a transaction-
by-transaction basis;
• the relative costs and expenses of a Service
Account and a brokerage account, which will
vary depending upon:
fee or commission rate
the client
o the
negotiates;
to
the contrary,
o the size of the client’s account;
o the level of trading activity and size of trade
orders;
Client Accounts with commission-based fee
arrangements also present another conflict
not associated with traditional brokerage
accounts. A client should understand that,
depending upon the Service selected by the
client, the PAM Consultant may act with
discretion with respect to the client’s
the client’s
Account and
that, absent
instructions
the PAM
Consultant will effect transactions for the
client’s Account without obtaining
the
client’s consent or providing notice to the
client.
o applicable account fees and charges;
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
o the client’s use of third party managers who
charge their own fees for managing accounts
in addition to PAM’s Advice Fee; and
As the portion of the Advisory Fee or Portfolio Fee
paid to an Other Manager increases, the portion
of the Advisory Fee or Portfolio Fee that is
retained by Baird decreases. Thus, Baird (but not
PAM) has an incentive to recommend or favor
investment managers that are paid less, because
Baird will receive a higher portion of the Advisory
Fee or Portfolio Fee.
o the amount of the client’s account invested in
investment products that have additional
internal ongoing operating fees and expenses
(e.g., Funds).
Additional important information about brokerage
accounts and facts to consider when making
account type decisions is contained in the Client
Relationship Details document, which should have
been delivered to the client and is available on
Baird’s website at bairdwealth.com/retailinvestor.
In addition, Baird has an incentive to favor
Associated SMA Strategies over other SMA
Strategies because the entire Advisory Fee is
retained by Baird and Associated Managers and
because Baird benefits from its receipt of Advisory
Fees and the overall success of Associated
Managers. For more information, see “Other
Financial Industry Activities and Affiliations”
below.
the nature of commission-based
A client should review other account types and
programs with the client’s PAM Consultant to
determine whether they are more appropriate or
should be used in addition to a Service.
Advisory Fee Payments to Baird, PAM
Consultants and Investment Managers
Given
fee
arrangements, if a client is paying Transaction
Fees, Baird and the client’s PAM Consultant have
an incentive to recommend or select investment
managers that trade frequently because such
relationships will be more profitable to Baird and
the client’s PAM Consultant.
PAM and Baird and Associated Managers benefit
from the Advisory Fees and charges that clients
pay for the services described in this Brochure.
Fee or
subadvisory
Baird retains the entire Advisory Fee paid by
clients, except as further described below. With
respect to SMA Strategies available under the
SMA Programs managed by Other Managers,
Baird pays Other Managers (including Associated
Managers and Implementation Managers, if any)
a Portfolio
fee as
compensation for the manager’s services as
further described below.
to
recognition
trips
Client Accounts are generally subject to a Unified
Advice Fee Arrangement in which the Advisory
Fee consists of an Advice Fee and a separate
Portfolio Fee. Baird pays the manager out of the
Portfolio Fee paid by the client. The Portfolio Fee
rates are set forth under “Fee Options and Fee
Schedules—Unified Advice Fee Arrangement—
Portfolio Fee” above. However, Baird, in many
instances, retains a portion of the Portfolio Fee
when a client’s Account is managed by an Other
Manager. The maximum portion of the Portfolio
Fee retained by Baird in those instances is equal
to an annual rate of 0.10% of the value of a
client’s Account. Such amounts are retained by
Baird for the services it provides.
for
achievement
of
A PAM Consultant is primarily compensated on a
monthly basis based upon a percentage of the
PAM Consultant’s total production each month,
which primarily consists of the total advisory fees
and transaction-based fees paid to Baird by the
PAM Consultant’s clients and any other fees Baird
earns on advisory and brokerage accounts held by
those clients, including trail fees paid by third
parties. The percentage of the PAM Consultant’s
total production actually paid
the PAM
Consultant will increase as the total amount of the
PAM Consultant’s production increases, meaning
that, as the total amount of the PAM Consultant’s
production increases, the rate and amount of
compensation that Baird pays to the PAM
Consultant also
increase. PAM Consultants
generally also receive deferred compensation or
bonuses based on various criteria, including net
new assets they gather, performing certain wealth
management activities, such as financial planning,
and their total production levels. PAM Consultants
who achieve certain production thresholds are
eligible for professional development conferences,
business development coaching, reimbursements,
awards and
to attractive
destinations. PAM Consultants are also eligible for
professional
bonuses
designations depending on a PAM Consultant’s
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
total production level. Thus, PAM Consultants
have a general incentive to generate financial and
other plans and charge higher fees for advisory
accounts and recommend larger investments in
advisory accounts.
include
invitations
in
the
and benefits provides
Given the structure of their compensation, they
also have an incentive to recommend that a client
transfer the client’s accounts to Baird, establish
new accounts with Baird (including IRA rollovers)
and add more money into the client’s accounts. In
addition, most PAM Consultants are shareholders
of Baird Financial Group, Inc. (“BFG”), Baird’s
ultimate parent company, and thus benefit
financially from the overall success of Baird and
its Associated Parties. The number of shares of
BFG stock that a PAM Consultant may purchase is
based in part on the PAM Consultant’s total
production
level. PAM Consultants generally
receive compensation for referrals to certain
affiliated managers and products and for referrals
to a limited number of other firms. More specific
information is provided under the headings “Other
Financial Industry Activities and Affiliations” and
“Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading—Participation
or Interest in Client Transactions” below. They
also generally receive non-cash compensation and
other benefits from Baird and from sponsors of
investment products with which Baird does
business. Such non-cash compensation and other
benefits may
to attend
conferences or educational seminars, payment of
related travel,
lodging and meal expenses,
reimbursement for branch and client events, and
receipt of gifts and entertainment. Receipt of such
compensation
PAM
Consultants an incentive to favor investment
products and their sponsors that provide the
greatest levels of compensation and benefits.
to PAM Consultants
(generally from one to three years). Installment
payments are generally contingent upon the PAM
Consultant achieving annual production or client
asset levels that exceed a significant percentage
of the PAM Consultant’s annual production for the
1-year period prior to joining Baird or the client
assets that the PAM Consultant had prior to
joining Baird. The special compensation
is
intended to compensate PAM Consultants for the
significant effort involved in transitioning their
business from the prior firm. This compensation
provides PAM Consultants who have left another
firm additional incentive to recommend that
clients of the prior firm become Baird clients and
to recommend investment products and services
that increase their production, and thus presents
a conflict of interest. The special compensation is
generally structured in the form of a forgivable
loan from Baird to the PAM Consultant. Under the
terms of the forgivable loan, Baird makes the
upfront or installment payment to the PAM
Consultant in the form of a loan, and Baird
forgives a portion of the loan made to the PAM
Consultant each month for so long as the PAM
Consultant remains Baird’s employee. Should the
PAM Consultant cease to be Baird’s employee
prior to the maturity date of the loan, the PAM
Consultant is required to repay Baird the amount
of the loan outstanding and not forgiven by Baird.
In other words, upon leaving Baird, the PAM
Consultant would be required to repay to Baird a
portion of the special compensation that the PAM
Consultant had received and that had not been
forgiven. The amount of such repayment declines
over time in proportion to the time the PAM
Consultant remains Baird’s employee. Structuring
this special compensation
form of
forgivable loans provides the PAM Consultant
added incentive to remain Baird’s employee and
to recommend that persons become and remain a
Baird client. Additional information about referral
and non-cash compensation and other financial
incentives provided
is
provided under the heading “Code of Ethics,
Participation or Interest in Client Transactions and
Personal Trading—Participation or Interest
in
Client Transactions” below.
From time to time, Baird PAM Consultants outside
of PAM may refer their clients to PAM Consultants.
In those instances, the PAM Consultant generally
shares a portion of his or her compensation with
the referring Baird Financial Advisor.
PAM Consultants generally receive recruitment
bonuses and/or special compensation from Baird
when they join Baird from another firm. The
amount of such special compensation is typically
based on the PAM Consultant’s production at the
prior firm for the 1-year period prior to joining
Baird or on the level of the PAM Consultant’s
client assets at the prior firm. All or a substantial
portion of the special compensation is paid in the
form of an upfront bonus when the PAM
Consultant joins Baird, and the remaining portion,
if any, is paid in the form of back end bonuses
generally in equal installments on an annual basis
for a certain number of years
thereafter
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Other Fees and Charges
Baird addresses the conflicts described above
through disclosure in this Brochure and by
adopting internal policies and procedures for PAM
and Baird and their associates that require them
to provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients).
In addition to the Advisory Fee described above, a
client of PAM will incur other fees and expenses.
The asset-based fee only covers investment
advice provided by PAM, and a client will pay for
other services, such as custody and trade
execution, separately in addition to the Advisory
Fee. Please see the section “Brokerage Practices”
below for more information about PAM’s trading
practices.
Other Fees and Expenses
Cost and Expense Information for Certain
Investment Products
A client is responsible for bearing or paying, in
addition to the Advisory Fee, the costs of all:
front-end or deferred sales
• commissions,
charges, redemption fees, or other charges;
• markups, markdowns, and spreads charged by
Baird in a principal transaction with a client or
charged by other broker-dealers that buy
securities from, or sell securities to, the client’s
Account (such costs are inherently reflected in
the price the client pays or receives for such
securities);
• redemption fees, surrender charges or similar
fees that an investment product or its sponsor
may impose;
• underwriting discounts, dealer concessions or
similar fees related to the public offering of
investment products;
• extra or special fees or expenses that may
result from the execution of odd lot trade orders
(i.e., “odd-lot differential”);
important
• electronic fund fees, wire transfer fees, fees for
transferring an investment between firms, and
similar fees or expenses related to account
transfers (including any such fees imposed by
Baird);
• currency conversions and transactions;
conversions,
• securities
A client should be aware that certain investment
products in which the client invests, such as
mutual funds and other Funds, annuities and
their own ongoing
other products, have
management and other operating
fees and
expenses that are deducted from the assets of the
product (or income or gains generated by the
product on its investments) and thus reduce the
value or return of the client’s investment in the
product. These fees and expenses may include
investment management fees, distribution (12b-
1) fees, shareholder servicing fees, transfer
agency fees, networking fees, accounting fees,
marketing support payments, administration fees,
fees, expense reimbursements, and
custody
expenses associated with executing securities
transactions for the investment product’s portfolio
(“ongoing operating expenses”). These ongoing
operating expenses are separate from, and in
addition to, the Advisory Fees. As a result of
making investments in these types of products, a
client should be aware that the client is paying
multiple layers of fees and expenses on the
amount of the client’s assets so invested—the
ongoing operating expenses and the Advisory
Fee. Additional
information about
ongoing fees and expenses that apply to those
types of investments is provided in Baird’s Client
Relationship Details document and Baird’s website
at bairdwealth.com/retailinvestor. A client can
find the actual ongoing fees and expenses of an
investment product that the client will pay or bear
in the product’s prospectus or offering document.
including, without
limitation, the conversion of ADRs to or from
foreign ordinary shares;
Additional Account Fees and Charges
• interest, fees and other costs related to margin
accounts, short sales and options trades;
related
to
the
• fees
website
If the client’s Account is custodied at Baird, the
client is also responsible for all applicable account
fees and service charges Baird may impose in
connection with the client’s agreements with
Baird. A schedule of fees and service charges is
available
at
Baird’s
on
bairdwealth.com/retailinvestor.
establishment,
administration or termination of Retirement
Accounts, retirement or profit sharing plans,
trusts or any other legal entity, including,
without limitation, the calculation and payment
of unrelated business income tax (“UBIT”);
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• fees imposed by the SEC or securities markets,
including transaction fees imposed by electronic
trading platforms, which fees may be imbedded
in the price the client receives for the security;
and
imposed upon or
resulting
• taxes
from
transactions effected for a client’s Account, such
as income, transfer or transaction taxes, foreign
stamp duties, or any other costs or fees
mandated by law or regulation.
client pays to PAM (“additional commissions”) if
the investment manager decides to place the
client’s trade order for execution by a firm other
than Baird. However, if a client incurs additional
commissions, at least annually, PAM attempts to
rebate the amount of such additional commissions
or offset
the amount of such additional
commissions against the commissions and fees
that the client pays to PAM. PAM may discontinue
such rebates and offsets in its discretion at any
time upon notice to the client.
Clients who have Accounts managed by PAM may
also have other accounts with Baird that are not
managed by PAM. Those accounts may be subject
to fees, commissions or other expenses that are
entirely separate from the payment of fees and
expenses for the services provided by PAM.
Clients who use a custodian other than, or in
addition to, Baird will pay the other custodian’s
fees and expenses in addition to the Advisory Fee.
In addition, if a third party custodian has custody
of the client’s Account assets, the Account is
subject to any applicable set-up, maintenance and
administrative fees established by Baird. Baird
may waive such fees in its discretion.
In addition to the Advisory Fee, a client will also
be responsible for paying the fees charged by
each investment manager selected by the client
under the Dual Contract Program. If a client
directs PAM or Baird to pay the client’s DC
Manager’s fee out of the client’s Account, and
PAM or Baird agree to do so, PAM and Baird will
not be responsible for verifying the calculation or
accuracy of such fee.
needs. However, when
If a client holds an Unsupervised Asset in the
client’s Account, the client may be charged a
commission, markup or markdown in connection
with its purchase or sale. The cash proceeds from
the sale of an Unsupervised Asset that remain in
a client’s Account are considered Permitted
Investments subject to the asset-based Advisory
Fee. If an asset becomes an Unsupervised Asset
during a quarterly billing period, that asset will be
excluded for purposes of determining the asset-
based Advisory Fee beginning at the start of the
next quarterly billing period, and no portion of the
asset-based Advisory Fee paid by a client in
advance for the quarter will be refunded or
rebated to the client. Additionally, Unsupervised
Assets in an Account are subject to any applicable
set-up, maintenance and administrative
fees
established by Baird. Baird may waive such fees
in its discretion.
specific
about
If a client selects a commission-based
fee
arrangement for an SMA, the client should note
that the client will incur commissions or related
costs in addition to the commissions that the
Other Compensation Received by PAM and
Baird
Baird is registered as a broker-dealer under the
Securities Exchange Act, and PAM Consultants are
registered broker-dealer representatives of Baird.
In such capacities, Baird and PAM Consultants
provide brokerage and related services to clients,
including the purchase and sale of individual
stocks, bonds, mutual funds, private investment
funds, and other securities, and sales of annuities.
At times, Baird and PAM Consultants provide such
brokerage and related services to clients in
connection with the Services described in this
Brochure. Baird and PAM Consultants receive
compensation based upon the sale of such
investment products,
securities and other
including asset-based sales charges and service
fees on the sale of mutual funds. This practice
presents a conflict of interest because it gives
Baird and PAM Consultants an incentive to use,
select or recommend investment products based
upon the compensation received rather than on a
client’s
providing
investment advisory services to clients, Baird and
PAM Consultants are fiduciaries and are required
to act solely in the best interest of clients. Baird
addresses this conflict through disclosure in this
Brochure and by adopting internal policies and
procedures for PAM and Baird and their associates
that require them to provide investment advice
that is suitable for advisory clients (based upon
the information provided by such clients). For
more
Baird’s
information
compensation and other benefit arrangements
and how Baird addresses the potential conflicts of
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
that all such clients receive fair and equitable
treatment over time.
interest, please see
the sections “Advisory
Business” and “Fees and Compensation” above,
and “Other Financial Industry Activities and
Affiliations” and “Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
PAM will purchase for client accounts, or will
recommend the purchase of, various investment
products, including “no load” mutual funds or
mutual funds with waived sales loads. A client has
the option to purchase investment products
through other brokers or agents that are not
affiliated with Baird.
Types of Clients
PAM offers the Services to all types of current or
prospective clients, including, but not limited to:
individuals; banks or thrift institutions; pension
trusts; estates;
and profit sharing plans;
charitable organizations; and corporations or
other business entities. Applicable requirements
for opening or maintaining an Account, such as
minimum account size, are discussed in the
“Fees and Compensation—
section entitled
Advisory Fees” above.
Performance-Based Fees and Side-By-
Side Management
PAM does not advise any client accounts that are
subject to performance-based fee arrangements.
Methods of Analysis, Investment
Strategies and Risk of Loss
Investment Strategies
The investment styles, philosophies, strategies,
techniques and methods of analysis that PAM,
investment
Baird, Baird PWM’s home office
professionals, and Other Managers use
in
formulating investment advice for clients vary
widely by Service and the person providing the
advice. A brief description of commonly used
strategies is provided below.
Equity Strategies
Act.
Performance-based
Baird advises client accounts not participating in
services described in this Brochure that are
subject to performance-based fee arrangements.
Performance-based fee arrangements involve the
payment of fees based upon the capital gains or
capital appreciation of a client’s account. Any such
fee arrangements are made in compliance with
applicable provisions of Rule 205-3 under the
Advisers
fee
arrangements present a potential conflict of
interest for Baird (but not PAM) with respect to
other client accounts that are not subject to
performance-based fee arrangements because
such arrangements give Baird an incentive to
favor client accounts subject to performance-
based fees over client accounts that are not
subject to performance-based fees.
focused,
interest
Equity strategies generally have an objective to
provide growth of capital and primarily invest in
equity securities, such as common stocks.
However, these strategies may also invest in
other types of investments, such as fixed income
securities and cash. Equity strategies may invest
in companies of all market capitalization ranges or
may
focus on any combination of specific
capitalization ranges, such as large cap, mid cap
or small cap companies. Equity strategies may be
combined with other strategies described below,
such as growth, value, income, economic industry
or sector
international, global, or
geographic region or country focused strategies.
the
arrangements
holdings
Fixed Income or Bond Strategies
inequitable
In addition to complying with its fiduciary duties
by disclosing this conflict of interest to clients
through this Brochure, Baird generally addresses
posed by
of
potential
conflicts
by
performance-based
fee
and
periodically monitoring
performance of performance-based fee accounts
and comparing them to accounts not subject to a
performance fee that are also managed using a
similar strategy in an attempt to detect any
treatment. Baird also
possible
attempts to minimize potential conflicts of interest
posed by performance-based fee arrangements
through internal trade allocation procedures that
are designed to make securities allocations to
discretionary client accounts in a manner such
Fixed income or bond strategies generally have
one or more of the following objectives: (1)
provide current income; or (2) preservation of
capital. These strategies primarily invest in fixed
income securities, such as corporate bonds,
municipal securities, mortgage-backed or asset-
backed securities, or government or agency debt
obligations. However, these strategies may also
invest in other types of investments, such as
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
invest
securities. This strategy may
in a
combination of investment grade and high yield
bonds. This type of strategy may also invest in
income-producing, Non-Traditional
yield- or
Assets.
Economic Industry or Sector Focused Strategies
region or
country
technology,
equity securities or cash. Fixed income strategies
may invest in debt obligations having any credit
rating, maturity or duration, or they may focus on
specific credit ratings, maturities or durations,
such as investment grade, non-rated, or high
yield (“junk”) bonds, or bonds having short-term,
intermediate-term or long-term maturities. Fixed
income strategies may be combined with other
strategies described below, such as economic
industry or sector focused, international, global,
or geographic
focused
strategies.
Balanced Strategies
Economic industry or sector focused strategies
primarily invest in companies in one or more
economic industries or sectors, such as the
telecommunications,
industrial,
materials, or financial sectors. These strategies
alone generally are not intended to satisfy a
client’s entire portfolio diversification needs.
These strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
International Strategies
include companies
ranges,
regions, credit
region or market
Generally, international strategies primarily invest
in securities issued by foreign companies, which
may
in developed and
emerging markets. International strategies may
invest in companies of all market capitalization
ranges and in investments having any credit
rating, maturity or duration, or they may focus on
industries or
specific capitalization
sectors, geographic
ratings,
maturities or durations.
Balanced strategies generally have one or more of
the following objectives: (1) provide current
income; (2) growth of capital/principal or income;
or (3) preservation of capital. These strategies
primarily invest in a mix of equity, fixed income
securities and cash. Balanced strategies may
invest in companies of all market capitalization
ranges and in investments having any credit
rating, maturity or duration, or they may focus on
specific capitalization ranges, credit ratings,
maturities or durations as described above.
Balanced strategies may be combined with other
strategies described below, such as economic
industry or sector focused, international, global,
or geographic
focused
strategies.
Global Strategies
Value Strategies
A value strategy typically invests primarily in
equity securities of value companies, which are
those that the investment manager believes are
out of favor with investors, appear underpriced by
the market relative to their earnings or intrinsic
value, or have high dividend yields. This strategy
is subject to investment style risks.
ranges,
regions, credit
Growth Strategies
Generally, global strategies invest in a mix of
securities issued by U.S. and foreign companies,
which may include companies in developed and
emerging markets. Global strategies may invest
in companies of all market capitalization ranges
and in investments having any credit rating,
maturity or duration, or they may focus on
industries or
specific capitalization
sectors, geographic
ratings,
maturities or durations.
Geographic Region or Country Focused Strategies
A growth strategy typically invests primarily in
equity securities of growth companies, which are
those that the investment manager believes
exhibit signs of above-average growth relative to
peers or the market, even if the share price is
high relative to earnings or intrinsic value. This
strategy is subject to investment style risks.
Income Strategies
Geographic region or country focused strategies
primarily invest in companies located a particular
part of the world, such as Latin America, Europe
or Asia, in a group of similarly-situated countries,
such as developed or emerging markets, or one
or more specific countries. These strategies alone
generally are not intended to satisfy a client’s
entire portfolio diversification needs. These
strategies are subject to concentration risks
An income strategy typically invests primarily in
income-producing securities, such as dividend-
income
paying equity securities and
fixed
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
because they generally are not diversified or they
may invest in a limited number of securities.
Tactical and Rotation Strategies
than other strategies. The
to
a few investments will more adversely impact
performance than if assets were more evenly
invested in a larger number of companies.
Opportunity strategies often experience higher
fluctuations in annual returns and overall market
value
types of
investments used
implement opportunity
strategies vary widely by manager and could
include equity securities, fixed income securities,
Non-Traditional Assets, Alternative Investment
Products and cash.
Tax Management Strategies
underweighting
and
taxable
Tax management strategies involve buying and
selling investments in a manner intended to
reduce the negative impact of U.S. federal income
taxes. They often involve buying or selling
investments to limit taxable investment gains or
to offset
investment gains with
investment losses or selling investments to avoid
recognition of taxable investment gains.
tax management strategy
is
strategies are often
subject
these
strategies
Tactical strategies typically tactically and actively
adjust account allocations to different categories
of investments, such as asset classes, geographic
locations or market sectors, based upon the
manager’s perception of how those investments
will perform in the short-term. Similarly, rotation
strategies
typically actively adjust account
allocations to different market sectors based upon
the manager’s perception of how those market
sectors will perform in the short-term. Tactical
and rotation strategies are often driven by
technical analysis or methodologies and typically
overweighting
involve
account allocations to certain asset classes,
geographic locations or market sectors relative to
an applicable long-term strategic asset allocation,
benchmark index or the market generally. These
strategies often will be focused or concentrated in
one or more asset classes, geographic locations or
market sectors from time to time, and it is likely
that they will have limited or no exposure to one
or more asset classes, geographic locations or
market sectors. For that reason, tactical and
rotation
to
concentration risk. Because the decision-making
for tactical and rotation strategies is based upon
the manager’s short-term market outlook,
accounts pursuing
often
experience higher levels of trading and portfolio
turnover relative to other strategies.
A
typically a
secondary strategy used to achieve a secondary
tax management objective and it is typically
together with other primary
implemented
investment
to achieve
strategies designed
primary investment objectives or goals. However,
managers in certain situations may use a tax
management strategy as the primary investment
strategy or tax management may be their primary
consideration when managing client Accounts,
such as when the manager is transitioning an
Account from one investment strategy to another.
Opportunity or Opportunistic Strategies
the
strategy, particularly
utilizes
strategy
Accounts pursuing a tax management strategy in
some instances will be subject to additional or
different risks of loss, which may be material. The
holdings of Accounts pursuing tax management
strategies will often differ from the holdings of
similarly-managed accounts that do not utilize
if
such a
tax
management
replacement
the performance of
securities. Therefore,
Accounts utilizing a tax management strategy will
vary from similarly-managed accounts that do not
utilize such a strategy, possibly in a materially
negative manner, and such Accounts may not be
successful in pursuing any other investment
strategies, objectives or goals.
Tax management strategies are not intended to,
and likely will not, eliminate a client’s tax
obligations relating to investments in an Account.
Opportunity strategies will generally be invested
in a manner that seeks to provide long term
growth
through capital appreciation and/or
income by utilizing an active management style
that shifts the amount of investment made in
different asset classes and market sectors to take
advantage of the manager’s perception of market
pricing anomalies, those market or industry
sectors deemed favorable for investment by the
manager, the current interest rate environment
and/or other macro-economic trends identified by
the manager. Opportunity strategies often involve
the use of other strategies, particularly tactical or
rotation strategies, and will have the risks
associated with those strategies. Opportunity
Strategies may also involve investment in a more-
limited number of companies compared to other
strategies. As a result, a decline in value of one or
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment strategies, there
resulting
from
Like all
is no
guarantee that the implementation of a tax
management strategy will be successful. A client’s
use of a tax management strategy may not
actually
lower a client’s tax obligations or
otherwise achieve a client’s tax goals.
they are not responsible for any tax‑related
effects or obligations
the
investments or transactions in a client’s Account.
A client is responsible for ensuring that the
holdings and transactions in the client’s other
accounts at Baird or another firm do not violate
appliable tax rules and bears the risk of such
violations. A client is strongly urged to consult the
client’s tax advisor prior to pursuing a tax
management strategy.
Direct Indexing Strategies
that
involve
the
The effectiveness of tax management strategies
will be reduced if a client’s ability to recognize
losses for tax purposes is disallowed, limited or
deferred under applicable tax rules, such as the
IRS wash sales rules, which disallow losses if
substantially identical securities are purchased by
a client (whether through Baird or another firm)
within 30 days before or after a sale, and IRS
straddle rules, which limit and defer a client’s
ability to claim tax deductions related to the loss
on a sale of an investment in an Account if the
client holds an offsetting position in any account
firm. Some tax
held at Baird or another
management strategies
the sale of
securities at a loss and the reinvestment of the
proceeds into a replacement security that the
manager believes
to not be “substantially
identical” for purposes of the IRS wash sales rule.
A manager’s belief may be incorrect, resulting in
a disallowance of the loss and reducing the
intended benefits of
tax management
strategy.
limitations of
Direct indexing strategies involve investing in a
basket of individual securities, such as stocks,
that seeks to track a selected benchmark index.
Direct indexing strategies may be more costly
track
investment options
than other
benchmark indices, such as mutual funds and
ETFs. Direct indexing strategies also generally
include the use of tax management strategies in
an attempt to enhance Account performance. The
use of tax management strategies will cause an
Account to deviate from the benchmark index,
which will cause the Account’s returns to vary
from that of the benchmark index. The use of tax
management strategies may not be successful
and the performance of Accounts pursuing a
direct index strategy could be materially lower
than the benchmark index. See “Tax Management
Strategies” above for more information about the
tax management
risks and
strategies.
the wash sales
resulting
losses. The
rules,
risk of
Alternative Strategies and Complex Strategies
involved
invest
Trading activity in a client’s accounts (whether at
Baird or another firm) may also inadvertently
violate
in
disallowed
inadvertent
violations increases as the number of client
increases
accounts and managers
because there is a higher chance of uncoordinated
or conflicting trading activity in those accounts.
Automatic purchases in client accounts, such as
reinvestment programs, may also
dividend
inadvertently violate wash sales rules. A client’s
investments held in other accounts at Baird or
another firm may be deemed to be offsetting
positions for purposes of the IRS straddle rules,
which will also negatively impact the client’s
ability to deduct losses and will reduce the
intended benefit of the tax management strategy.
Alternative Strategies and other Complex
Strategies may
in a wide range of
investments, which may include equity securities,
fixed income securities, Non-Traditional Assets,
Alternative
Investment Products and cash.
Alternative Strategies and other Complex
Strategies generally involve the use of margin,
leverage, short sales and derivative instruments.
Many Alternative Strategies and other Complex
Strategies have no substantive restrictions on the
types of investments that may be used. Examples
of Alternative Strategies and other Complex
Strategies include the following.
Managers do not consider the holdings or
transactions in other client accounts (whether
held at Baird or another firm) when implementing
tax management strategies. Managers do not
undertake any responsibility to monitor or verify a
client’s compliance with applicable tax rules, and
• Relative Value Strategies. Relative value
strategies generally involve the purchase of
traditional assets, such as stocks and bonds,
and Non-Traditional Assets and the use of short
sales and derivative instruments in an attempt
to exploit price differences among securities
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
financial
that share similar economic or
characteristics.
involves the use of derivatives and structured
products.
• Long/Short Strategies. Long/short strategies
generally involve the purchase of securities
believed to be undervalued and selling short
securities believed to be overvalued. They may
also involve the use of Non-Traditional Assets,
leverage and derivative instruments.
• Absolute Return, Total Return and Real Return
Strategies. Absolute return, total return and
real return strategies generally involve the
purchase of traditional assets, such as stocks
and bonds, and Non-Traditional Assets in an
attempt to generate performance that has low
correlation to the major equity markets over a
complete market cycle. They may also involve
the use of derivative instruments.
• Event-Driven
• Market Neutral Strategies. Market neutral
strategies generally involve the purchase of
securities and selling securities short in similar
dollar amounts in an attempt to produce returns
that are
independent of general market
performance. They may also involve the use of
Non-Traditional Assets, leverage and derivative
instruments.
events
(such
and
liquidations).
Event-driven
Strategies.
strategies generally involve the use of Non-
Traditional Assets, short sales and derivative
instruments in an attempt to seek arbitrage
opportunities, particularly those triggered by
as mergers,
corporate
restructurings,
These
strategies typically involve the assessment of if,
how and when an announced transaction will be
completed.
• Statistical Arbitrage Strategies. Statistical
Arbitrage is based on the theory that stocks
have a tendency to return to a short-term trend
line. This type of strategy typically involves the
“systematic” or automated trading of securities
based upon where a security is relative to its
trend line.
arbitrage
strategies
involve
in corporate
buy-outs,
restructurings
is
short
securities believed
• Merger Arbitrage/Special Situations Strategies.
the
Merger
purchase and sale of securities of companies
involved
reorganizations and
business combinations, such as mergers,
exchange offers, cash tender offers, spin-offs,
and
leveraged
liquidations. These strategies often
involve
short selling, options trading, and the use of
other derivative instruments.
• Convertible Arbitrage Strategies. Convertible
arbitrage involves the purchase and short sale
of multiple securities of the same company. The
implemented by purchasing
strategy
securities believed to be undervalued and
selling
to be
overvalued. Often, the strategy involves the
purchase of a convertible bond issued by a
company and selling short that company’s
common stock. This strategy may involve the
use of a wide range of derivative instruments.
• Fixed
• Distressed Strategies. Distressed strategies
generally involve the purchase of securities in
companies that are in financial distress, or
companies that are entering into or are already
in bankruptcy. They may also involve the use of
short sales and derivative instruments.
Income Arbitrage Strategies. Fixed
income arbitrage strategies generally seek to
profit from interest rate, credit spread and other
arbitrage opportunities by investing in fixed
income securities, interest rate instruments and
derivative instruments.
• Macro Strategies. Macro strategies generally
involve the purchase of traditional assets, such
as stocks and bonds, and Non-Traditional Assets
and the use of short sales and derivative
instruments in an attempt to profit from
anticipated changes
in securities markets,
commodities markets, currency values, and/or
interest rates.
and
Systematic
• Discretionary
• Capital Structure Arbitrage Strategies. Capital
structure arbitrage generally involves investing
in multiple levels of a single company’s capital
structure, often taking long and short positions
in a company’s debt or equity in order to
capitalize on perceived mispricings resulting
from market inefficiencies or different pricing
assumptions. This type of strategy typically
Trading
Strategies. Discretionary
trading strategies
generally attempt to identify and capitalize on
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Robert W. Baird & Co. Incorporated
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
strategies
generally
rely
patterns or trends in the markets. Systematic
trading
on
computerized trading systems or models to
identify and capitalize on those patterns or
trends. These strategies often involve the use of
Non-Traditional Assets, short sales, derivative
instruments and significant leverage.
risks
related
• Private Investment Strategies.
participation in private REITs. Private real
focus on specific
estate strategies may
geographic
types, or
regions, property
economic sectors. Investments in private real
estate can be illiquid, meaning they may take
time to sell or refinance. Property values can
fluctuate due to market conditions, supply
and demand, and other factors. There are
tenant vacancies,
to
also
property damage, or environmental hazards.
Leverage is often used in private real estate
investments, which can increase potential
returns but also amplifies potential losses.
generally
in
companies
involve
in
o Private
invest
types. Examples of
include,
These
among
utilities,
investments
o Private Equity Strategies. Private equity
strategies
equity
private
investments
transactions. These investments are typically
made through participation in private equity
funds or funds of private equity funds. Private
equity strategies may invest in companies of
all market capitalization ranges or may focus
on any combination of specific capitalization
ranges. They may also focus on companies in
one or more economic industries or sectors or
geographic regions. Some private equity
strategies focus on companies that are newly
formed, in financial distress or already in
bankruptcy. The securities purchased are
typically unregistered and illiquid. Private
equity strategies may also involve the use of
leverage.
Infrastructure Strategies. Private
infrastructure
in
strategies
infrastructure projects and assets and may
involve exposure to a range of economic or
market sectors, geographic locations and
infrastructure
asset
others,
investments
and
telecommunication,
transportation.
are
typically made through participation in private
infrastructure funds. Investments in private
infrastructure strategies are often illiquid.
They may focus on certain sectors, industries,
geographic regions, size ranges or stages of
development or operations, or on certain
types and sizes of investments and may,
therefore, also lack diversification.
typically unrated or
• Leveraged Strategies. Leveraged strategies
generally involve the use of Non-Traditional
Assets, leverage, short sales and derivative
instruments in an attempt to amplify returns or
produce returns that are a multiple of a
benchmark index.
types of
referred
to as
floating
• Inverse Strategies. Inverse strategies generally
involve the use of Non-Traditional Assets,
leverage, short sales and derivative instruments
in an attempt to produce returns that are the
opposite of a benchmark index.
in
smaller
o Private Debt or Private Credit Strategies.
Private debt (also known as private credit)
strategies invest in loans or debt instruments
issued by companies in private transactions.
These investments are typically made through
participation in private debt funds or funds of
private debt funds. The investments involved
are
rated below
investment grade and are illiquid. Oftentimes,
the interest rate paid by the companies is
determined by a reference interest rate, such
as the federal funds rate, which is periodically
investments are
reset. These
sometimes
rate
corporate debt, floating rate loans or floating
rate bank loans. Private debt strategies often
involve the use of leverage and may involve
investment
capitalization,
distressed or bankrupt companies.
limited
to,
collateralized
industrial
o Private Real Estate Strategies. Private real
estate strategies invest in physical properties,
such as office buildings, apartments, retail
facilities. These
centers, and
through
investments are
typically made
• Reinsurance Strategies. Reinsurance investment
strategies generally involve participation in the
reinsurance market through investment in a
variety of insurance-linked securities or other
instruments. Investments may include, but are
not
reinsurance
contracts, industry-loss warranties, catastrophe
bonds, mortality bonds, equity investments in
reinsurance companies, and
insurance or
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
insurance-linked swaps and other similar
derivative instruments.
such as: hedge funds, private equity funds and
managed futures; and
• cash.
allocation
strategies
have
Business—Additional
also
have
varying
Alternative Strategies and other Complex
Strategies are not appropriate for some clients
because they are subject to special risks. See
“Advisory
Service
Information—Complex Strategies and Complex
Investment Products” above and “Methods of
Analysis, Investment Strategies and Risk of
Loss—Principal Risks—Non-Traditional Assets and
Complex Strategies Risks” below
for more
information.
Asset Allocation Strategies
investing, which
and
actively
typically
adjusting
Certain Services, including the PAM Investment
Management Service, make available asset
allocation strategies. Asset allocation strategies
involve investing in one or more of the following
categories of assets:
tactical
Asset
varying
investment objectives, ranging from growth of
capital to preservation of capital. Asset allocation
strategies
investment
strategies. Some asset allocation strategies use
strategic investment strategies, which involve
investing accounts
in accordance with a
predetermined target allocation to different asset
classes. Some asset allocation strategies use
involves
tactical
tactically
account
allocations to different asset classes based upon
the manager’s perception of how those asset
classes will perform in the short-term. Some asset
allocation strategies involve the use of both
strategic and
investment strategies,
sometimes referred to as dynamic strategies.
Asset allocation strategies may be implemented
using a variety of investment types, such as
individual securities, mutual funds and ETPs. The
amount allocated to an asset class or investment
type varies by strategy, and some strategies may
have little or no allocation to one or more asset
classes or types of investments described above.
companies; U.S.
cap
located
• the equity securities asset category, which is
comprised of certain asset classes, such as,
equity securities issued by: U.S. large cap
growth companies; U.S.
large cap value
companies; U.S. large cap core companies; U.S.
mid cap growth companies; U.S. mid cap value
companies; U.S. mid cap core companies; U.S.
small cap growth companies; U.S. small cap
value
core
small
in
foreign companies
companies;
developed markets; foreign companies located
in emerging markets; U.S. REITs; and foreign
REITs;
as:
short-term
taxable
involves
that are based upon
• the fixed income securities asset category,
which is comprised of certain asset classes,
such
bonds;
intermediate term taxable bonds; long-term
taxable bonds; short-term tax-exempt bonds;
intermediate term tax-exempt bonds; long-term
tax-exempt bonds; high yield fixed income
securities; foreign fixed income securities; and
broad fixed income securities;
Baird’s
projections
Baird uses its Capital Market Assumptions in
developing its proprietary model asset allocation
strategies, including those used by some PAM
Consultants. In determining its Capital Market
Assumptions, Baird conducts an analysis of
different asset classes and the different levels of
risk associated with those investments. That
analysis
the consideration of past
performance and the use of forward-looking
projections
certain
assumptions made by Baird about how markets
will perform in the future. There is no assurance
that asset classes or markets will perform in
or
accordance with
assumptions. For more information about Baird’s
Capital Market Assumptions, a client should
contact the client’s PAM Consultant.
and
• the Non-Traditional Assets category, which is
comprised of certain asset classes, such as:
commodities
commodity-linked
instruments; and currencies and currency-
linked instruments, and Digital Assets;
Baird’s most common asset allocation strategies
are described below. A client should note that the
specific investments in an Account following a
particular asset allocation strategy could vary
• the Alternative Investment Products category
which is comprised of certain asset classes,
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
from the description below for a number of
reasons, including market conditions.
invest
income and some growth of capital. Typically, an
Income with Growth Portfolio will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, this strategy will primarily
invest in a mix of fixed income securities and
equity securities, with a bias towards fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
fixed income securities than equity securities.
All Growth Portfolio. An All Growth Portfolio
typically seeks to provide growth of capital.
Typically, an All Growth Portfolio will experience
high fluctuations in annual returns and overall
market value. Under normal market conditions,
this strategy generally invests nearly all of its
assets in equity securities. This strategy may also
invest in other asset classes, such as fixed income
securities, Non-Traditional Assets and cash. This
in Alternative
strategy may also
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
experience
relatively
Conservative Income Portfolio. A Conservative
Income Portfolio typically seeks to provide current
Income
income. Typically, a Conservative
Portfolio will
small
fluctuations in annual returns and overall market
value. Generally, under normal market conditions,
this strategy will primarily invest in a mix of fixed
income securities, cash and equity securities, with
a significantly higher allocation to fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets.
Generally, under normal market conditions, this
strategy will have a significantly higher allocation
to fixed income securities and cash than equity
securities.
Capital Growth Portfolio. A Capital Growth
Portfolio typically seeks to provide growth of
capital. Typically, a Capital Growth Portfolio will
experience moderately high fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, this strategy will
primarily invest in a mix of equity securities and
fixed income securities, with a significantly higher
allocation to equity securities. This strategy may
also invest in other asset classes, such as Non-
Traditional Assets and cash. This strategy may
also invest in Alternative Investment Products or
may involve the use of leverage, short sales and
derivative instruments. Generally, under normal
market conditions, this strategy will have a
significantly higher allocation to equity securities
than fixed income securities.
Preservation
A
Portfolio.
typically seeks
Capital
Capital
Preservation Portfolio typically seeks to preserve
capital while generating current income. Typically,
a Capital Preservation Portfolio will experience
relatively small fluctuations in annual returns and
overall market value. Under normal market
conditions, this strategy generally invests nearly
all of its assets in a mix of fixed income securities
and cash. This strategy may also invest in other
asset classes, such as equity securities and Non-
Traditional Assets.
income
investments
Growth with Income Portfolio. A Growth with
to provide
Income Portfolio
moderate growth of capital and some current
income. Typically, a Growth with Income Portfolio
will experience moderate fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, this strategy will
primarily invest in a mix of equity securities and
fixed income securities, with a bias towards equity
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
equity securities than fixed income securities.
Income with Growth Portfolio. An Income with
Growth Portfolio typically seeks to provide current
Some PAM Consultants and investment managers
use asset allocation strategies that include target
asset allocation percentages for equity and/or
fixed
in the names or
descriptions of the strategies (e.g., 80-20, 60-40,
40-60, 20-80, etc.). A client should note that
those percentages are intended to be asset
allocation targets only. There is no guarantee that
Accounts following asset allocation strategies will
be invested strictly in accordance with target
asset allocations. It is likely that the actual
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment
restrictions,
Objectives
and
investments in Accounts following those strategies
will vary, sometimes significantly, from the target
asset allocations and may include other asset
classes due to market conditions and the PAM
Consultant’s or investment manager’s assessment
of how to best invest a client’s Accounts. See
“Important Information about Implementation of
Investment
Investment
Strategies” below for more information.
For information about the risks associated with
the asset allocation strategies described above,
see the section of the Brochure entitled “Principal
Risks—Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies” below.
other circumstances, such as when the client’s
Account
is transitioning to a new Service,
investment objective or investment strategy, or
due to other factors, such as market appreciation
or depreciation of the assets in the client’s
Account, deposits and withdrawals made by the
client, and
if any,
imposed by the client. A client’s Account may not
be able to achieve its investment objectives
during any such period of time and the Account
may be subject to different or enhanced risks
than would be the case had the Account been
invested in a manner wholly consistent with the
investment objective or
investment strategy
selected by the client. Clients are encouraged to
discuss with their PAM Consultant on a regular
basis how the Account is being managed or
advised and whether any such conditions exist.
Important Information about Implementation of
Investment Objectives and Investment Strategies
Methods of Analysis
Baird, its home office investment professionals,
and PAM Consultants may use various forms of
investment analyses, including the following:
• Fundamental Analysis. Fundamental analysis
involves an approach to investing through a
detailed analysis of specific companies, such as
their financial statements and financial ratios,
management, competitive advantages and
markets, in an attempt to determine the value
of an investment. Fundamental analysis may
include qualitative and quantitative analyses.
A client should note that, to implement an
investment strategy, a client’s PAM Consultant or
investment manager may use or recommend
mutual funds, ETPs or other Funds that primarily
invest in particular types of securities instead of
direct investment in those types of securities. A
client should also note that the client’s PAM
Consultant or investment manager may use a
strategy not described above or they may use a
strategy with the same or similar name that is
implemented differently. A client should ask the
client’s PAM Consultant or investment manager
for more specific information about the strategy
being used for the client’s Account.
Analysis. Qualitative
• Qualitative
A client’s Account
is subject to the risks
associated with the Account’s particular strategies
and investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
analysis
involves the use of subjective judgment to
analyze factors that may be difficult to quantify
or measure objectively. As it pertains to
managers and investment products, qualitative
analysis may include review of the background
and experience of a manager or a mutual fund
company.
in an attempt
• Quantitative Analysis. Quantitative analysis is a
method of evaluating securities by analyzing a
large amount of data through the use of
algorithms or models
to
understand behavior, predict market events,
market prices, etc., and generate an investment
decision. As it pertains to managers and
investment products, quantitative analysis may
include
review of manager performance,
investment style, style consistency, risk, and
risk-adjusted performance.
From time to time, the client’s PAM Consultant or
investment manager will
invest the client’s
Account, or recommend that the client invest the
Account, in a manner that is inconsistent with the
investment strategy or
investment objective
selected by the client for the Account when the
client’s PAM Consultant or investment manager
determines that it is appropriate to do so, such as
using defensive strategies in response to adverse
market or other conditions or engaging in tax
management. Similarly, a client’s Account may be
invested in a manner inconsistent with the
investment strategy or
investment objective
selected by the client for the Account in certain
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• Technical Analysis. Technical analysis is a
method of analyzing past price and volume
patterns and trends in the trading markets to
attempt to predict the direction of both the
overall market and specific investments.
details, fees, investment philosophy, ownership
and legal history. Although Baird has deemed the
information and tools provided by third party
research firms to be generally reliable, Baird does
not
the
independently verify or guarantee
accuracy of the information or tools used.
(“AI”)
• Top-Down Analysis. Top-down analysis involves
a consideration of certain macroeconomic
trends, such as general economic conditions,
geographic or market sector performance, fiscal
and monetary policy, taxes, or interest rates, to
make investment decisions.
Analysis. Bottom-up
• Bottom-Up
in
formulating
investment,
analysis
involves consideration of factors particular to a
particular
such as business
financials (e.g., balance sheet strength and
cash flows), financial ratios (e.g., price-to-
earnings ratio), and business fundamentals
(e.g., management and product or services
performance) to make investment decisions.
Baird PWM home office investment professionals
and PAM Consultants may use artificial
intelligence
tools, such as machine
learning, predictive analytics and probabilistic
modeling tools, data processing and automation
tools, generative AI tools, visual, speech and
audio tools, specialized domain tools, and other
similar technologies and tools (collectively, “AI
Tools”),
investment advice.
Generally, the use of AI Tools is limited to certain
aspects of Baird’s investment-advice process,
such as assisting with drafting of materials,
automation of workflow processes, and the
compilation,
organization,
reproduction,
summarization, analysis and interpretation of
information. The use of AI Tools is only supportive
of Baird’s investment-advice process and does not
replace the professional judgment of Baird PWM
home office investment professionals or PAM
Consultants. All AI Tool-assisted outputs used in
formulating investment advice are subject to
human
inform
review before such outputs
recommendations or investment decisions.
When providing investment advice to clients, PAM
Consultants utilize research reports and other
research material created by Baird PWM Research
Groups, such as PWM Equity Research, PWM Fixed
Income Research, and Asset Manager Research.
PAM Consultants may also utilize research reports
created by Baird’s
Institutional Equities &
Research Department. It should be noted that
PAM Consultants are not obligated to act in a
manner consistent with those research reports
and they may act in a manner that is contrary to
those reports if they deem it to be in the client’s
best interest.
could negatively
influence
their
sponsors
(which may
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations,
deceptive behaviors and other flaws due to the
construction of their underlying models and the
composition of their training data, which can
result in outputs that seem plausible but are in
fact inaccurate, incomplete, or misleading. The
use of AI Tools creates a risk that erroneous
the
information
investment-advice process. Baird has established
policies and procedures designed to address the
risks posed by AI Tools, which
include
requirements that AI Tools pass a firm-level due
diligence process and that Baird associates obtain
training and independently verify AI Tool outputs.
However, such measures cannot eliminate the
risks posed by AI Tools.
conditions,
investment
Baird PWM Research Groups and PAM Consultants
use various third party information and tools
when formulating investment advice. The sources
of information and tools may include, among
others, information provided or created by issuers
and
include
information that is reported publicly, provided
directly to Baird, or reported through third party
platforms) and information and tools provided by
third party research firms, which may include
firms affiliated with Baird. PAM relies on both
affiliated and independent, third-party research
and information when analyzing market trends
and
manager
performance, and asset class characteristics and
performance. PAM has built and maintains a
proprietary database of manager characteristics,
personnel
including historical
performance,
When providing investment advice to clients, PAM
Consultants may also use the model portfolios or
recommended or eligible product lists (described
below) made available by Baird’s PWM Research
Groups, or they may use investment products
that Baird has generally deemed to be “available”
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investment
approach
risks. See
for use in its advisory programs (“Available
Investment Products”). The level of initial and
ongoing evaluation, monitoring and review that
PAM and Baird perform on managers and on
investment products varies. Available Investment
Products generally do not receive the same level
of initial or ongoing evaluation, monitoring or
review by Baird as those managers or products
that are included in a model portfolio or on a
recommended or eligible product list. As a result,
Available Investment Products are subject to
certain
“Methods of Analysis,
Investment Strategies and Risk of Loss—Principal
Risks—Available Investment Product Risks” below
for more information.
but these stocks generally will not represent more
than 35% of the total portfolio. The team’s top–
down
begins with
macroeconomic and market outlooks from Baird’s
Investment Strategy team. This information is
used to underweight or overweight particular
industry sectors compared to the S&P 500 Index.
Individual stocks are selected with an emphasis
on higher quality companies that the team
believes have strong fundamental characteristics
teams, attractive growth
and management
prospects, and
reasonable price-appreciation
expectations. Each stock selected is assigned a
weighting as a percentage of the portfolio. No
single company stock will comprise more than the
greater of 5% of the portfolio or 1.5 times the
stock’s market weight in the S&P 500 index;
provided that a stock will not be removed due to
capital appreciation. Stocks can be sold or
positions reduced for a variety of reasons such as
valuation, a change in company or industry
fundamentals, or a change in industry sector
weighting. The Portfolio is intended as a long-
term investment strategy.
Baird Rising Dividend Portfolio
More specific information about Baird PWM model
portfolios, recommended lists and eligible product
lists is provided below. A client should note that
investment products recommended to the client
or selected for the client’s Account, including
investment managers or products included on a
Baird PWM recommended or eligible product list,
are those which, in Baird’s professional judgment,
may be appropriate to help the client pursue the
client’s financial goals. PAM and Baird do not
represent or guarantee that such investment
managers or products are or will be the best
investment managers or products available.
Under certain circumstances when requested by a
client, PAM and Baird may allow a client to
transfer from another firm or select an investment
product that is not on a Baird recommended or
eligible product list or that does not qualify as an
Available Investment Product. A client should note
that, unless PAM and Baird otherwise agree in
writing, PAM and Baird do not provide any initial
or ongoing evaluation, monitoring or review of
any such investment product and that the client’s
decision to transfer or select such investment
product is based solely upon the client’s review of
the investment product.
Certain PWM-Managed Portfolios
Baird Recommended Portfolio
The Baird Rising Dividend Portfolio, which is
managed by Baird’s PWM Equity Research team,
seeks to provide a core equity strategy with a
portfolio yield above that of the S&P 500 Index.
The team’s top–down investment approach begins
with macroeconomic and market outlooks from
Baird’s Investment Strategy team. The 30–50
stocks in the portfolio are primarily large cap
stocks—as defined by a market capitalization of
$10 billion or greater at the time of investment—
and all are above $5 billion at the time of
investment. The team looks for quality companies
with strong
fundamental characteristics and
management, attractive dividend yields, and the
ability to increase their dividends. Companies are
screened for dividend history and consistency,
earnings growth expectations, and balance sheet
quality. Each stock selected
is assigned a
weighting as a percentage of the portfolio. No
single company stock will comprise more than the
greater of 5% of the portfolio or 1.5 times the
stock’s market weight in the S&P 500 index;
provided that a stock will not be removed due to
capital appreciation. A position can be reduced or
removed due to changes in valuation, company
fundamentals or the perceived ability to continue
to raise its dividend in the future—among a
variety of other potential reasons for portfolio
The Baird Recommended Portfolio, which
is
managed by Baird’s PWM Equity Research team,
seeks to outperform the S&P 500 Index by
investing in a diversified core portfolio of 35–50
stocks. The portfolio invests primarily in stocks
with market capitalization greater than or equal to
$10 billion (large cap). The portfolio may also
contain stocks with market caps below $10 billion
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
changes including a change in industry sector
weighting. The Portfolio is intended as a long-
term investment strategy.
AQA Portfolios
to
clients
Analysis
years of investment experience focusing on the
particular investment style that is offered by the
portfolio manager. Baird generally looks for
that have demonstrated
portfolio managers
success, that have performance histories showing
sufficient ability to achieve returns in excess of
their respective benchmarks, and that have
investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird
also considers other qualitative and quantitative
factors.
performance.
The
analysis
Baird’s Asset Manager Research Department is
primarily responsible for selecting and evaluating
included on Baird’s
investment managers
Recommended Managers List.
selecting
In
investment managers, Baird’s Asset Manager
Research Department utilizes quantitative and
qualitative measures to evaluate managers based
on the:
• quality and stability of their organization
• soundness and clarity of their investment
philosophy
• reliability and consistency of their investment
process
• competitiveness of their investment
performance
Baird’s Asset Manager Research Department may
also employ the use of computers and third party
software to more readily display information and
assist with the evaluation and analysis.
certain
Baird makes available
Automated Quantitative
(“AQA”)
Portfolios, which are managed by Baird’s PWM
Equity Research team. AQA is an analytical tool
that seeks to identify stocks of companies that
are undervalued by calculating the intrinsic values
for the stocks and comparing the calculated
values to current market prices. Focusing on a
company’s past
financial performance, AQA
analyzes fundamental ratios and trends of the
most recent eight-year history of a company and
each company in its peer group, excluding
estimates of future balance sheet and income
statement
is
quantitative and
ignores certain qualitative
information such as company-specific material
news and events. Stocks are ranked from the
most undervalued to the most overvalued based
on the difference between the values calculated
by AQA and current market prices. The stocks
identified by AQA as being the most undervalued
are then selected for investment. Baird offers the
following four (4) AQA Portfolio strategies, each of
which invest in undervalued stocks identified
using AQA, excluding securities issued by banks,
REITS and insurance companies: (1) the AQA All
Cap Strategy, which primarily invests in stocks
across market capitalizations, generally those
included in the S&P 500®, S&P MidCap 400® or
S&P SmallCap 600® Indices; (2) the AQA Large
Cap Strategy, which primarily invests in large cap
stocks, generally those included in the S&P 500®
Index; (3) the AQA Mid Cap Strategy, which
primarily invests in mid cap stocks, generally
those included in the S&P MidCap 400® Index;
and (4) the AQA Small Cap Strategy, which
primarily invests in small cap stocks, generally
those included in the S&P SmallCap 600® Index.
Certain Recommended Lists
Baird’s Recommended Managers List
Baird’s initial screening process begins with a
proprietary, multi-factor model that evaluates
managers on different factors including risk-
adjusted performance, consistency of returns and
downside protection. These factors are scored
over various time periods and relative to a
specific peer group universe, narrowing the pool
of managers for further evaluation. Baird’s Asset
Manager Research Department then performs a
more in-depth evaluation of managers that are
identified through the initial screening process,
which generally includes a review of the following
factors: stability of the firm/team, the robustness
and repeatability of the investment process, the
portfolio’s past returns pattern and tax-efficiency,
and how the manager adds value. The final
determination of Baird’s Recommended Managers
List
is subject to the approval of Baird’s
Investment Committee.
When selecting managers and BRM Strategies for
Baird’s Recommended Managers List, Baird often
seeks registered investment advisory firms having
portfolio managers with academic credentials
such as a master’s degree or participation or
completion of the Chartered Financial Analyst
(“CFA”) program. Baird also typically looks for a
portfolio manager with greater than three (3)
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird’s Recommended Mutual Fund List
conference
calls,
for
removal
that
to
the
change
Ongoing manager evaluation generally includes
quarterly
performance
attribution and periodic onsite visits. Material
adverse changes affecting a manager may result
in the manager being placed on “watch” status.
Managers on “watch” status are scrutinized to see
if improvement or degradation is taking place.
Potential causes
from Baird’s
Recommended Managers List include fundamental
changes in the operations of the manager,
turnover in key personnel, substantial changes in
management or ownership, a
in
investment philosophy or style, significant drift
from stated objectives, major legal, regulatory or
compliance difficulties, impairment of financial
condition, sustained underperformance in relation
to its peers, or other adverse changes affecting
the manager that in Baird’s opinion warrants the
manager’s removal.
Baird’s
Asset Manager
Investment Committee
its discretion, decides
inclusion
If a Model-Traded BRM Strategy is selected for a
client’s Account, it is important to note that
Baird’s selection and ongoing evaluation of a BRM
Strategy is based upon an assumption that the
Recommended Manager’s Model Portfolio will be
fully and faithfully implemented by the Overlay
Manager or Implementation Manager on a
continuous basis. A client should understand that
the Overlay Manager or Implementation Manager
has discretion over the client’s Account and may
invest the client’s Account in a manner that differs
from the Model Portfolio. Baird does not monitor
the Account’s performance nor does it ascertain
whether the Overlay Manager or Implementation
Manager is implementing the Model Portfolio as
provided by the Recommended Manager. If the
Overlay Manager or Implementation Manager, in
the exercise of
to
implement the Model Portfolio differently, the
performance of a client’s Account could be
negatively impacted. Baird is not monitoring,
evaluating or reviewing the Overlay Manager or
Implementation Manager or the performance of a
client’s Account under those circumstances.
Baird’s Recommended Mutual Fund List
is
designed to include mutual funds and ETFs across
numerous asset classes. When selecting funds for
inclusion on the List, Baird generally seeks funds
that have investment managers with tenure of at
least three (3) years and have underlying
fund’s
adhere
investments
market capitalization policy and are consistent
with the manager’s stated investment process
and philosophy. Baird generally looks for funds
that are among the top-performing funds in a
style category in terms of risk-adjusted returns or
that are managed by individuals or firms that
have demonstrated success in other, related asset
classes; that have performance histories showing
sufficient ability to achieve returns in excess of
their respective style index; and that have
investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird’s
Asset Manager Research Department is primarily
for assisting with selecting and
responsible
evaluating funds included on the List. In selecting
funds,
Research
Department utilizes a quantitative and qualitative
evaluation process of the investment managers of
such funds. The process Baird uses for selecting
and removing funds for the Baird Recommended
Fund List is similar to the process Baird uses to
select and remove BRM Strategies described
under “Baird’s Recommended Managers List”
above. Baird’s
is
ultimately responsible for selecting funds included
on the List. The Baird Ultra Short Bond Fund,
Baird Short-Term Bond Fund, Baird Aggregate
Bond Fund, Baird Quality Intermediate Municipal
Bond Fund, Baird Core Intermediate Municipal
Bond Fund, and Baird Mid Cap Growth Fund,
mutual funds affiliated with Baird, have been
in Baird’s
for
selected by Baird
Recommended Mutual Fund List. This presents a
conflict of interest. However, the criteria used by
Baird in deciding to select Associated Funds for
Baird’s Recommended Mutual Fund List are the
same as those used for unassociated funds.
Baird’s Recommended Funds of Hedge Fund List
SMA
Strategies
for
Certain SMA Strategies offered by Baird Equity
Asset Management have been selected by Baird
for inclusion on Baird’s Recommended Managers
List. This presents a conflict of interest. However,
the criteria used by Baird in deciding to select
Associated
Baird’s
Recommended Managers List are the same as
those used for unassociated SMA Strategies.
Baird’s Recommended Funds of Hedge Fund List
may contain several types of funds of hedge
funds (“FOHFs”) that pursue various Alternative
Strategies or other Complex Strategies. Some
FOHFs primarily use credit-oriented investment
strategies, which Baird classifies as fixed income
diversifiers. Some FOHFs primarily use equity-
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
that Baird offers, and the level of expected
demand for the particular FOHF.
and
onsite
oriented investment strategies and are classified
as equity diversifiers. Other FOHFs use a
combination of credit- and equity-oriented
strategies, which Baird views as balanced
diversifiers. In certain circumstances, FOHFs may
be an appropriate substitute for part of a client’s
allocation to traditional high yield fixed income or
equity investments.
changes
After a FOHF is added to Baird’s Recommended
Funds of Hedge Fund List, it is monitored each
quarter,
reviews
subsequent
periodically take place. As part of its quarterly
monitoring, Baird evaluates a FOHF’s assets under
(subscriptions and
management and
flows
redemptions), organizational
(e.g.,
personnel changes or new offerings), recent
changes made to the FOHF portfolio (e.g., hedge
funds added or removed), and reasons for
performance differences between the FOHF and
its benchmark. Subsequent onsite reviews are
similar in nature and scope to the initial on-site
review.
for
the
fund; and
To be added to Baird’s Recommended FOHF List,
a FOHF must generally meet the
following
requirements: the investment advisor to the FOHF
is registered as an Investment Adviser under the
Advisers Act; the fund has stable to growing
assets under management as determined by
Baird, principals of the fund have an appropriate
level of hedge fund management experience and
a sufficient network of contacts in the industry as
determined by to Baird; in Baird’s opinion, the
fund has adequate diversification by number of
hedge funds and type of hedge fund strategy;
effective risk management programs have been
established
the service
providers to the fund (e.g., auditor, administrator,
and legal counsel) are deemed to be reputable in
the judgment of Baird. Baird also seeks FOHFs
that it believes possess one or more unique
attributes that may lead to favorable performance
relative to their peers going forward.
legal documents
offering memorandum,
Baird may place a FOHF on “watch” status if it has
experienced a material event that, in Baird’s
opinion, may negatively affect
the FOHF’s
performance going forward or possibly lead to the
departure of an important member(s) of the
FOHF. Examples include a large decline in assets
under management, high rate of redemptions,
notable change in the investment or compliance
teams, weakening performance, or regulatory
problems. Any firm that is placed on “watch”
status is evaluated more closely to determine if
the problem is likely to be temporary or long-
term, and whether it can be remedied. Baird will
remove a FOHF from “watch” status and return it
to active status if, in Baird’s opinion, the problem
has been or is in process of being adequately
addressed. However, Baird will terminate a FOHF
from the List if it believes the issue is likely to be
long-term and adversely affect the FOHF’s future
performance.
Baird’s Recommended Private Funds Lists
Baird maintains lists of recommended private
Funds (“Recommended Private Funds”), including
a Recommended Funds of Private Equity Funds
List, a Recommended Private Debt Fund List, and
a Recommended Private Real Assets Fund List.
In making
that determination,
Before adding a prospective FOHF to the List,
Baird’s Asset Manager Research Department
conducts an in-depth due diligence process. The
process begins with a review of the FOHF’s
responses to a due diligence questionnaire and of
(such as,
marketing and
subscription documentation, investor agreements,
and
organizational
documents, and the investment advisor’s Form
ADV Part 2A Brochures). This is followed by an
onsite review, where Baird meets with one or
more principals and analysts to assess how the
FOHF identifies, hires, monitors, and terminates
individual hedge funds. Baird also evaluates how
the FOHF constructs its hedge fund portfolio and
manages risk. At the conclusion of the onsite
review, an investment thesis is presented to and
discussed with a Baird Investment Committee.
The Committee votes on whether to add the FOHF
to Baird’s Recommended Funds of Hedge Fund
List.
the
Committee considers the information presented,
taking into account the merits of the individual
FOHF, how that FOHF compares to other FOHFs
Baird’s Recommended Funds of Private Equity
Funds List contains funds of private equity funds
that pursue certain Alternative Strategies or other
Complex Strategies. These strategies can include
buyout, growth equity, venture capital, special
situations or distressed
investments. The
investments are typically structured in the form of
co-
secondary
primary
funds,
funds
or
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
lead to favorable performance relative to their
peers going forward.
fund
client’s allocation
to
investments. Most will be to “middle market”
companies, many of which have above average to
high levels of leverage, or debt relative to equity.
In certain circumstances, funds of private equity
funds may be an appropriate substitute for part of
a
traditional equity
investments.
that pursue
or
Baird’s Recommended Private Debt Fund List
contains private debt funds (also known as
private
certain
funds)
credit
Alternative Strategies
other Complex
Strategies. The private debt funds on Baird’s
Private Debt Funds List generally make first lien,
second lien and unsecured loans, primarily to
middle market companies sponsored by private
equity firms. In certain circumstances, private
debt funds may be an appropriate substitute for
part of a client’s allocation to traditional high yield
fixed income or equity investments.
funds
that
or
the
to a
Before adding a prospective
Recommended Private Fund List, Baird’s Asset
Manager Research Department conducts an in-
depth due diligence process. The process begins
with a review of the fund’s responses to a due
diligence questionnaire (known as a DDQ or RFI)
and of marketing and legal documents (such as,
subscription documentation, investor agreements,
offering memorandum, organizational documents,
and the investment advisor’s Form ADV Part 2A
Brochures). This is followed by an onsite review,
where Baird meets with one or more principals
and analysts to assess how the fund makes
investment decisions. Baird also evaluates how
the fund constructs its portfolio and manages risk.
In addition, Baird may undertake a brief review of
the fund’s third-party service providers. At the
conclusion of the onsite review, an investment
thesis is presented to and discussed with a Baird
Investment Committee. The Committee votes on
whether to add the fund to a Baird Recommended
Private Fund List. In making that determination,
the Committee
information
considers
presented, taking into account the merits of the
individual fund, how that fund compares to other
similar funds that Baird offers, and the level of
expected demand for that particular fund.
utilities,
telecommunication,
The
investments may
with
companies
that
Baird’s Recommended Private Real Assets Fund
List contains private real estate and private
pursue
infrastructure
certain
Alternative Strategies
other Complex
Strategies. These strategies invest in different
real assets and may involve exposure to a range
of economic or market sectors, geographic
locations and asset
types. Examples of
investments may include, among others, real
and
estate,
transportation.
be
structured in the form of asset ownership or
leasing or include direct investment in or joint
ventures
control
infrastructure assets. In certain circumstances,
private real assets funds may be an appropriate
substitute for part of a client’s allocation to
traditional fixed income or equity investments.
After a fund is added to a Baird Recommended
Private Fund List, it is monitored each quarter,
and subsequent onsite reviews periodically take
place. As part of its quarterly monitoring, Baird
evaluates a fund’s assets under management and
fund
flows (subscriptions and redemptions),
organizational changes (e.g., personnel changes
or new offerings), recent changes made to the
portfolio, and reasons for performance differences
between the fund and its benchmark. Subsequent
onsite reviews are similar in nature and scope to
the initial on-site review.
To be added to a Baird Recommended Private
Fund List, a fund must generally meet the
following requirements: the investment advisor to
the fund is registered under the Advisers Act ; the
to growing assets under
fund has stable
management as determined by Baird; principals
of the fund have an appropriate level of applicable
experience and a sufficient network of contacts in
the industry as determined by Baird; effective risk
management programs have been established for
the fund; and the service providers to the fund
(e.g., auditor, administrator, and legal counsel)
are deemed to be reputable in the judgment of
Baird. Baird also seeks funds that it believes
possess one or more unique attributes that may
Baird may place a Recommended Private Fund on
“watch” status if it has experienced a material
event that, in Baird’s opinion, may negatively
affect the fund’s performance going forward or
possibly lead to the departure of an important
member(s) of the
investment team.
fund’s
Examples include a large decline in assets under
management, high rate of redemptions, notable
change in the investment or compliance teams,
weakening performance, or regulatory problems.
Any fund that is placed on “watch” status is
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Managed Futures
evaluated more closely to determine if the
problem is likely to be temporary or long-term,
and whether it can be remedied. Baird will
remove a fund from “watch” status and return it
to active status if, in Baird’s opinion, the problem
has been or is in process of being adequately
addressed. However, Baird will remove a fund
from a Recommended Private Fund List if it
believes the issue is likely to be long-term and
adversely affect the fund’s future performance.
Effective March 1, 2018, Baird ceased maintaining
an official list of managed futures funds that are
structured as limited partnerships. Therefore,
Baird does not, and will not in the future, provide
any evaluation, monitoring or review of those
funds or their sponsors. A client’s decision to
invest in, or to maintain an investment in, a
managed futures fund is based solely upon the
client’s own review and evaluation of the fund.
Certain Eligible Product Lists
Structured Products
Annuities
the
is calculated,
strength
ratings
When determining whether to make a structured
product available to Baird clients, Baird reviews
the offering documents for the structured product
and considers: the size of the issuer and issuer’s
credit rating, the maturity of the product, how
interest
the underlying asset
category (e.g., a basket of securities or currencies
or a market index), applicable caps, barriers, and
participation rate, and whether the structured
product has principal protection.
When determining whether to make an annuity
product available to Baird clients, Baird reviews
the offering documents for the product and
considers: the size of the insurer and the insurer’s
credit rating,
insurer’s distribution and
support model, and product specifications and
features of the product. Baird favors highly-rated
insurers and evaluates them by using credit rating
and
financial
agencies
independent third-party research.
Baird’s ETF Focus List
indices,
Baird tends to favor larger-sized issuers of
structured products over smaller-sized issuers
and also tends to favor structured products that
have shorter maturities, less complex payout
structures, underlying assets that are more liquid
or transparent, and offer full or partial principal
protection. If a product does not offer full
principal protection, Baird also considers how
much principal is exposed to loss, whether, in
Baird’s judgment, there is reasonable risk/reward
trade-off for that exposure, as well as the events
that could trigger loss of principal and Baird’s
belief as to the likelihood of the occurrence of
such events.
Investment Solutions Department
Baird’s ETF Focus List is designed to encompass
numerous asset classes and varied investment
objectives. Baird generally seeks to include ETPs,
primarily ETFs, with transparent, experienced
sponsors that have stable or growing assets under
management and have demonstrated consistent
strategy performance over time. Baird tends to
favor ETPs that have well-known, diversified
benchmark
fees and tracking
lower
errors, and higher trading liquidity relative to
other ETPs. Inclusion on or exclusion from the
Baird ETF Focus List is not meant to be a buy or
sell recommendation. Rather, the List
is a
collection of ETPs that may be appropriate to
meet particular client investment goals.
the
Programs.
Baird’s
PWM Stock Opportunities List
Compliance,
Legal,
and
Baird’s
is
primarily responsible for selecting and evaluating
structured products made available to clients
under
Alternative
Investment Committee, which includes members
of Baird’s Investment Solutions, Asset Manager
Research,
Risk
Management Departments, ultimately determines
whether to make a structured product available to
Baird clients.
Available Hedge Funds
yield,
The PWM Stock Opportunities List is comprised of
stocks that Baird’s PWM Equity Research team
believes offer timely investment opportunities
based on market, sector, and
fundamental
analysis. Stocks on the list must be covered by
Baird, Evercore ISI, or Morningstar and are
screened to curb near-term fundamental risk. The
List focuses on large cap and mid/small cap
companies,
and
investments with
speculative investment opportunities.
Baird makes hedge funds available to clients in
certain Programs sponsored by, affiliated with or
offered by Capital Integration Systems LLC or
CAIS Capital LLC (“CAIS”). An independent third-
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Activities and Affiliations—Certain Relationships
and Arrangements—Baird and Associated Parties”
below.
Other Funds
party research firm provides research and due
diligence materials to Baird on the hedge funds
available on the CAIS platform (“Available Hedge
Funds”). Clients interested in an Available Hedge
Fund or invested in an Available Hedge Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely
relies upon the independent third-party research
firm to provide an independent analysis of each
Available Hedge Fund, Baird does not conduct its
own research or due diligence on any Available
Hedge Fund, and Baird does not verify the
accuracy of the information contained in the
research and due diligence materials.
In certain instances when PAM believes it to be
consistent with a client’s investment goals, PAM
may recommend to the client certain Funds that
are not on a Baird recommended or available
Fund list or offered through CAIS. Baird does not
provide any research or due diligence on such
Funds, but they are reviewed by PAM
in
accordance with its investment process described
below.
Available Private Funds
Baird Trust Strategies
Baird makes available to clients five (5) portfolio
strategies developed and maintained by Baird
Trust (“Baird Trust Strategies”) described below.
The Baird Trust Strategies invest in a mix of
equity securities and ETFs.
third-party
research
firm
(1)
The Baird Trust Large Cap Equity strategy
invests in a fairly concentrated portfolio of large
cap equity securities. This strategy is intended for
clients seeking investment in large cap companies
as one part of their overall asset allocation. This
strategy is generally not intended to be a
complete investment program.
In addition to Recommended Private Funds, Baird
makes available to clients in certain Programs
other private funds sponsored by, affiliated with,
or offered by CAIS (“Available Private Funds”),
including Available Private Equity Funds, Available
Private Debt Funds, Available Private REITs and
Available Private Infrastructure Funds. When
determining whether to make a fund an Available
Private Fund, Baird utilizes the services of an
that
independent
provides research and due diligence materials to
Baird on the private funds available on the CAIS
platform. Clients interested in an Available Private
Fund or invested in an Available Private Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely
relies upon the independent third-party research
firm to provide an independent analysis of each
Available Private Fund, Baird does not conduct its
own research or due diligence on any Available
Private Fund, and Baird does not verify the
accuracy of the information contained in the
research and due diligence materials.
(2)
The Baird Trust Core + Satellite 100
strategy is a diversified portfolio with a 100%
target equity allocation. The strategy uses the
Baird Trust Large Cap Equity strategy as the core
the portfolio while providing
allocation of
exposure to satellite asset classes (such as mid
cap and small cap companies) through the use of
ETFs that principally invest in equity securities.
This model does not include fixed income.
Affiliated Private Equity Funds
(3)
The Baird Trust Core + Satellite 70/30
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation of the portfolio
while providing exposure to satellite asset classes
(such as mid cap and small cap companies) and
fixed income securities through the use of ETFs
that principally invest in equity securities and
fixed income securities. This strategy has a target
allocation of 70% of its assets to equity securities
and 30% of its assets to fixed income securities.
In addition to Recommended Funds of Private
Equity Funds and Available Private Equity Funds,
Baird makes available to clients private equity
funds that are affiliated with Baird (“Affiliated
Private Equity Funds”). Baird does not subject
Affiliated Private Equity Funds to the criteria
imposed upon Recommended Funds of Private
Equity Funds or Available Private Equity Funds
described above when making them available to
clients, and Baird does not perform any
evaluation, monitoring or review of Affiliated
Private Equity Funds. This presents a potential
conflict of interest. See “Other Financial Industry
(4)
The Baird Trust Core + Satellite 50/50
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation portion of the
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the
fixed
portfolio while providing exposure to satellite
asset classes (such as mid cap and small cap
companies) and fixed income securities through
the use of ETFs that principally invest in equity
securities and
income securities. This
strategy has a target allocation of 50% of its
assets to equity securities and 50% of its assets
to fixed income securities.
PAM will develop an Investment Policy Statement
through discussions with
client. The
Investment Policy Statement will set forth the
target asset allocation, set forth allowed and
disallowed assets, and provide a description of the
responsibilities of PAM, client’s other investment
managers, if any, and the client. The Investment
Policy Statement generally will be reviewed at
least annually, and PAM will recommend changes
if necessary to reflect any new circumstances
communicated to PAM by the client, such as a
change in a client’s liquidity needs or investment
time horizon. Generally, any changes will be
discussed with the client before implementation.
(5)
The Baird Trust Equity Income strategy
primarily invests in dividend paying companies
that Baird Trust believes have the ability to
consistently grow their dividend at attractive rates
over the long‑term.
Phase 2: Strategy Design
More specific information about the particular
investment strategies and methods of analysis
that Baird uses in connection with each Program
is further described below.
The PAM Investment Process
to
foreign equity securities,
fixed
PAM will compile, with data supplied by the client,
a source of funds document (“Source of Funds”),
listing investment assets to be transferred to
Baird and other significant investment assets
which may not be managed by PAM but which
PAM will consider in constructing the overall
investment portfolio. PAM will review the Source
of Funds with the client to reach agreement on
the total assets available for investment and the
ownership or registration of the same.
inverse
PAM may
using
also
other
investment
strategies,
such
Using the client’s target asset allocation, Source
of Funds and Investment Policy Statement, if any,
as guidelines, PAM will construct a recommended
target allocation for client’s portfolio to specific
investments
that will detail asset classes,
investment managers, investment vehicles (i.e.,
SMAs, mutual funds, ETFs, etc.) and target dollar
values for each. The recommended allocation may
include a series of investment phases to reach the
long term target allocation depending on client
preference, current investments, and market
conditions.
When providing advice to clients, PAM generally
recommends and provides
its clients a
diversified portfolio strategy incorporating U.S.
and
income
securities, Non-Traditional Assets, such as real
estate, commodities, currencies, and Alternative
Investment Products, which may include the use
of hedge funds, funds of hedge funds, private
equity funds, funds of private equity funds, REITs,
funds and structured
leveraged or
its
products.
base
recommendations
investment
strategies and investment products based upon a
client’s particular needs. PAM may recommend
certain
as
concentrated investment strategies and margin,
and certain types of investments, such as illiquid
securities. The exact composition of a client
portfolio will be constrained by the client’s legal
and tax considerations and greatly influenced by
the client’s liquidity needs and tolerance for
portfolio fluctuations.
fixed
The process by which PAM evaluates a client’s
investment needs and constructs and implements
a client portfolio are described below.
“passive” or
Phase 1: Evaluate
In constructing the portfolio, PAM considers
suitability of different asset classes (e.g., large
cap value domestic equity, mid cap value
domestic equity small cap value domestic equity,
international equity, fixed income, etc.), the
overall aggregate equity and
income
allocation for the entire portfolio, and use of
index-tracking
“active” and/or
the
for
investments. PAM may recommend
portfolio components from several different asset
classes and a mixture of active and passive
investments.
After gathering pertinent information regarding
the client, such as, tax considerations, liquidity
needs, and investment time horizon, PAM will
recommend a target allocation to one or more
asset classes described above. For some clients,
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a
For each recommended asset class, PAM will also
recommend specific investment managers. The
managers may include SMAs, mutual funds, ETFs,
and other investment vehicles. For most asset
classes, PAM will typically recommend more than
one manager in order to further reduce risk from
significant underperformance by
single
manager.
client’s final allocation. Final manager or fund
selection depends on the specific client needs,
which are defined through the investment policy
development and investment recommendation
stages. The managers or funds that are most
appropriate to meet the guidelines of the
client’s Investment Policy Statement, if any, are
then chosen.
The systematic process PAM uses for choosing
investment managers, commingled funds, mutual
funds and ETFs consists of the following steps:
The recommended allocation will also include the
fee for each manager, if any, as well as the PAM
Advisory Fee. A weighted-average fee based on
the recommended allocation will also be provided,
but the actual fee paid by a client will vary
depending on
the dollar amounts actually
invested, changes in the value of investments
over time, and other factors.
and
economic
Phase 3: Implement
• Quantitative Screening. On a quantitative basis,
takes a dynamic view of historical
PAM
time
statistics over various
performance
conditions. The
intervals
approach is two-pronged: (1) assess peer
universe comparisons; and (2) apply index-
based measures, both on an absolute and risk-
adjusted basis. The data is then analyzed using
a proprietary scoring model, which places
particular emphasis on consistent positive
relative performance over the long-term.
Once the recommended allocation is reviewed
with the client and a final allocation is approved
by the client, PAM will implement the agreed upon
plan. This usually includes setting up various
Baird accounts, transferring assets from outside
accounts to Baird, reconciling assets received
against client-provided information as to the
assets in the outside accounts, liquidation of some
assets, transfers of some assets to investment
managers, and purchase of mutual funds and
ETFs.
and
accounts,
professional
• Qualitative Screening. The candidate list is then
further reduced by reviewing broader issues
that help identify superior, stable organizations.
Some examples of the issues examined include:
size of assets under management, growth of
staff
assets
qualifications and turnover, a strong investment
buy and sell discipline, risk controls, and
business, regulatory and legal history.
In order to implement the overall client portfolio
strategy, PAM may utilize one or more of the
Services and a
combination of different
investment vehicles, such as SMAs, mutual funds
and ETFs.
More specific information about the particular
investment strategies and methods of analysis
that PAM and Baird use in connection with each
Service is further described below.
Service Information
PAM Investment Management Service
• Rank and Sort Semifinalists. The investment
selection process has now produced a short list
of candidates; generally, between three and ten
for each asset class. For new or emerging
managers, PAM will typically conduct an onsite
due diligence visit to determine and analyze
more about team structure and strength,
infrastructure, and hold discussions around
philosophy and strategy. PAM then determines
the appropriate investment structure to access
the investment manager(s)—whether it be an
SMA, commingled
institutional class
fund,
mutual fund or ETF—with a view to try and
select the structure that is the most cost
effective for clients.
Under the PAM Investment Management Service,
PAM may use various investment strategies. A
client’s particular investment strategy is typically
determined by PAM in consultation with the client
using the investment process described in the
section “The PAM Investment Process” above.
PAM Consultants, as a group, utilize a variety of
investment styles and strategies, including the
• Finalist Selection. PAM will analyze security
overlap and correlation with other potential
investment managers when determining the
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review of
lists,
see
flows, and an analysis of how
recommendation of a manager on Baird’s
Recommended Managers List and it may involve
managers not on such list. PAM typically conducts
additional qualitative and quantitative reviews of
managers on Baird’s Recommended Managers List
and will conduct qualitative and quantitative
reviews of managers not included on such List.
PAM’s evaluation process typically involves in-
person or telephonic interviews of the manager
and a
the manager’s historic
performance, size of assets under management,
asset
the
management firm adds value.
investment strategies described in the sections
“Methods of Analysis, Investment Strategies and
Risk of Loss—Investment Strategies” and “The
PAM Investment Process” above. They may also
use the model portfolios or recommended or
eligible product lists made available by Baird’s
PWM Research Groups, or they may use lists of
investment products that Baird has generally
deemed to be “available” for use in its advisory
programs. For more information about Baird
model portfolios, recommended lists and eligible
product
“Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis” above.
Service
The hiring of investment managers for a client
account includes an initial screening by PAM of a
potential manager for overall style, firm size, the
age of the investment advisor, its compliance with
GIPS composite standards, its average turnover,
and its performance record in said style for at
least the three (3) years preceding the review. A
quantitative score calculation is assessed to each
investment manager based upon the Sortino
Ratio, Alpha, Standard Deviation, Market Capture,
Batting Average and Retention, Sharpe ratio, one-
year trailing return, the most recent quarter
return, the up market capture ratio, and down
market capture ratio. A weight is then assigned to
each of the foregoing.
PAM manages client assets using investment
strategies and investment products based upon a
investment objectives and
client’s particular
financial goals. PAM may use a wide variety of
investment products to implement the client’s
investment strategy, which
investments are
further described under “Advisory Business—
Additional
Information—Permitted
Investments” above. PAM may also use certain
investment strategies, such as concentrated
investment strategies and margin, and certain
types of investments, such as illiquid securities
and Complex Investment Products,
including
REITs, private equity funds, funds of private
equity funds, leveraged or inverse funds and
structured products. These investment strategies
and products involve special risks and may not be
appropriate for all clients. Please see “Principal
Risks” below for more information.
PAM Recommended Managers Service
or
the heading
A review of the investment manager’s long term
and short term consistency with its stated
investment style is then performed. A select
group of managers who are found to meet
quantitative and qualitative analysis standards set
by PAM for this program are sent investment
manager questionnaires. Upon completion of the
form by the investment manager, PAM reviews
the history of the investment management firm,
investment professional
ownership structure,
biographies, investment professional turnover,
buy/sell disciplines, and operations and trading. A
model portfolio with holdings and weights is also
requested from the investment manager.
other
selecting
When
recommending
investment managers
to manage a client’s
Account in the PAM Recommended Managers
Service, PAM may utilize managers included on
Baird’s Recommended Managers List described
under
“Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis—Certain Recommended Lists—Baird’s
Recommended Managers List” above. PAM may
also select managers not included on Baird’s
Recommended Managers List though its own
manager evaluation process.
After the investment manager is selected, the
manager is reviewed by PAM daily whereby a
comparison of the manager’s performance is
tracked against a suitable benchmark and daily
trading activity of the manager is reviewed.
client’s
PAM will typically remove a manager when the
manager is removed from Baird’s Recommended
Managers List or when PAM believes that the
PAM will select or replace, or recommend the
selection or replacement of, a particular manager
based upon the client’s particular goals and
circumstances and
investment
the
strategy. This may involve the selection or
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manager is experiencing significant and prolonged
underperformance.
regarding any BSN Strategy or DC Strategy or
any representations regarding a BSN Manager’s or
DC Manager’s qualifications as an investment
adviser or abilities to manage client assets.
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, a client should note that PAM and Baird
do not monitor or ascertain whether a third party
Implementation Manager is fully and faithfully
implementing the Model Portfolio on a continuous
basis.
The Overlay Manager may provide review and
ongoing evaluations of certain BSN Managers that
it makes available through the BSN Program.
Clients should review Overlay Manager’s Form
ADV Part 2A Brochure for more information, which
is available upon request, or contact their PAM
Consultant for more information.
is
PAM and Baird do not monitor or ascertain
whether the Overlay Manager
fully and
faithfully implementing Model Portfolios under the
BSN Program on a continuous basis.
A client assumes ultimate responsibility
for
client’s selection of an Other Manager under the
PAM Recommended Managers Program (including
any third party Implementation Manager). PAM
and Baird assume no responsibility for the client’s
termination of an Other Manager (including any
third party Implementation Manager), the Other
Manager’s investment decisions, performance,
compliance with applicable laws or regulations, or
for any other matters involving or affecting the
Other Manager.
of
Loss—Principal
SMA Strategies offered under the BSN and DC
Programs are subject to certain risks. See
“Methods of Analysis, Investment Strategies and
Risks—Available
Risk
Investment Product Risks” below
for more
information.
Baird SMA Network and Dual Contract
Programs
the
A client should only participate in the BSN or DC
Programs if the client wishes to take more
responsibility for monitoring the client’s Account,
the PAM Recommended Managers Program does
not contain an SMA Strategy that meets the
client
client’s particular needs, and
understands the risks of doing so.
Clients participating in the BSN Program or the
DC Program should note that the level of initial
and ongoing review performed by PAM and Baird
on the managers and their SMA Strategies made
available under those Programs, including any
Associated SMA Strategies, is significantly less
than that performed by PAM and Baird with
respect to managers and their strategies eligible
for the PAM Recommended Managers Service.
retention of an
A client should note that the client’s appointment
investment
and continued
manager to manage the client’s Account in
connection with the BSN and DC Programs are
based ultimately upon the client’s independent
review of the investment manager and the
investment manager’s services. Once retained by
the client, an investment manager will only be
removed from managing the client’s Account upon
the investment manager’s withdrawal, removal
from the Program, or the client’s direction to do
so.
BSN and DC Managers are subject to an initial
review by Baird that considers the manager’s
assets under management,
regulatory and
compliance history, and certain other limited
factors deemed
qualitative and quantitative
relevant by Baird. The ongoing review is generally
performed on an annual basis and is generally
limited to significant changes in the managers’
assets under management in the SMA Strategy
and a review of the SMA strategy in comparison
to a relevant peer group or benchmark.
(including any
a
client who wishes
A client assumes ultimate responsibility
for
client’s selection of a manager under the BSN or
third party
DC Programs
Implementation Manager). PAM and Baird assume
no responsibility for the client’s termination of a
the BSN or DC Programs
manager under
(including any
Implementation
third party
Manager). PAM and Baird also assume no
The BSN and DC Programs are designed to
to
accommodate
independently select an investment manager not
available in the PAM Recommended Managers
Service to manage the assets in the client’s
Account. A client should note that PAM and Baird
do not make any recommendation to clients
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performance,
compliance
responsibility for any Other Manager’s investment
decisions,
with
applicable laws or regulations, or for any other
matters involving or affecting the Other Manager.
incentive to maximize the number of affiliated
investment options it makes available under the
PAM Investment Management Service due to the
fact that, by increasing investment options, Baird
will likely attract more client assets and thereby
increase Baird’s revenues. A client participating in
the PAM Investment Management Service should
monitor the client’s Account performance and
periodically discuss the performance of such
Account with the client’s PAM Consultant.
professionals,
an
Portfolio management services under the DC
Program may be provided by an investment
management department of Baird if the client
selects such an SMA Strategy. In order to provide
portfolio management services under the DC
Program, Baird requires that Baird associates
meet all applicable requirements set forth by
applicable law and regulations of self-regulatory
organizations, such as the Financial Industry
Regulatory Authority,
Inc., exchanges, and
governmental agencies.
or
for
and
Associated Managers.
Portfolio Management by PAM, Baird and
Associated Managers
Portfolio management services under the PAM
Investment Management, PAM Recommended
Managers and DC Programs may be provided by
Baird
Such
arrangements create a potential conflict of
interest because Baird and Associated Managers
may receive higher aggregate compensation if
clients retain Baird and Associated Managers
instead of retaining unassociated managers.
the heading
Portfolio management services under the PAM
Recommended Managers Service or DC Program
could be provided by Baird PWM home office
investment
investment
management department of Baird or an
Associated Manager should a client select an
Associated SMA Strategy. When Baird selects SMA
Strategies, or otherwise determines manager
availability
the Baird
eligibility,
Recommended Managers List or the DC Program,
Associated SMA Strategies and Associated
Managers are subject to the same selection and
review processes, if any, that Baird applies to
unassociated SMA Strategies and investment
managers participating in each respective Service.
The processes, if any, used by Baird for selecting
and reviewing SMA Strategies and Associated
SMA Strategies for those Services are further
described under
“Methods of
Analysis, Investment Strategies and Risk of
Loss—Service Information” above.
departments,
the heading
The following Services exclusively offer portfolio
management by Baird, its PAM Consultants, its
PWM home office investment professionals, its
investment management
or
investment managers that are affiliated with
Baird: PAM Investment Management Service. The
processes, if any, used by Baird for selecting and
reviewing those portfolio managers is described
under
“Methods of Analysis,
Investment Strategies and Risk of Loss—Service
Information” above.
When providing investment advisory services to
clients, PAM and Baird are fiduciaries and are
required to act solely in the best interest of
clients. Baird addresses the conflicts described
above through disclosure in this Brochure and by
adopting internal policies and procedures for PAM
and Baird and their associates that require them
to provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients). For more specific
information about these potential conflicts and
how Baird addresses them, please see the
sections “Other Financial Industry Activities and
Affiliations” and “Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
Principal Risks
Risk is inherent in any investment product and
PAM and Baird do not guarantee any level of
return on a client’s investments. There is no
A client should note that the processes and
standards used by Baird in determining whether
to make affiliated investment options available
under the PAM Investment Management Service
differ from those processes and standards used
by Baird in determining whether to make non-
affiliated investment options available under other
Services. Baird approves, and continues to make
available, affiliated investment options under the
PAM Investment Management Service that would
not be approved for, or would have been removed
from, such other Services. This practice presents
a conflict of interest because Baird has a financial
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client
accounts
about
managing
the
attractiveness, value and potential appreciation of
particular securities may prove to be incorrect.
For example, while the stock markets may
experience increases in value, the client’s Account
may experience a decline in value due to the
underperformance of the stocks selected for
investment in the client’s Account.
conditions and other
the associated
Investment Objective and Asset Allocation
Risks. A client’s investment objective and asset
allocation strategies involve the risk that certain
asset classes selected for the client’s Account may
not perform as well as other asset classes during
varying periods. In addition, clients who pursue
more aggressive investment objectives and asset
allocation strategies, while hoping to achieve high
returns, may face greater risk of loss than clients
with more conservative objectives and strategies.
In developing investment objectives and asset
allocation strategies, clients should carefully
consider their financial situation and needs,
investment goals, investment time horizon and
risk tolerance. A client should inform the client’s
PAM Consultant of these considerations so the
PAM Consultant can assist in determining the
client’s investment objectives and asset allocation
strategies.
assurance that a client’s investment objectives
will be achieved, and a client could lose all or a
portion of the amount invested. The management
of client accounts and recommendations made to
clients are based in part upon the use of forward-
looking projections, which in turn are based upon
certain assumptions about how markets will
perform in the future. There can be no guarantee
that markets will perform in the manner assumed
and the actual performance of markets and a
client’s Account could differ materially from those
assumptions. Also, a client’s Account value may
fluctuate, sometimes dramatically, depending
upon the nature of the client’s investments,
market
factors. By
participating in a Service, a client may be subject
to certain risks, including, but not limited to the
risks described below. The risks discussed below
vary by Service, investment style or strategy, and
the investments in the client’s Account, and each
risk may or may not apply to a client. Clients
should not pursue a strategy or invest in an
investment product unless they are prepared to
accept
risks. Clients are
encouraged to discuss with their PAM Consultant
the risks that apply to them. A client should also
the prospectus or other disclosure
review
document for any security or other investment
product in which the client invests, as it will
contain important information about the risks
associated with investing in such security or other
investment product.
Investment Risk Information
The investment risks of the Services generally
include the following:
Conflicts of Interest Risks. Issuers, advisors or
other sponsors of investment products or their
affiliates may engage in business practices that
conflict with the interests of investors. Among
other things, these business practices can have a
negative impact on the market price of the
investment product. Clients are encouraged to
review
the prospectus or other disclosure
document for the investment product and also
discuss with their PAM Consultant the conflicts of
interest risks that may apply to them.
Stock Market Risks. Equity security prices vary
and may fall, thus reducing the value of a client’s
investments. Certain stocks selected for a client’s
Account may decline in value more than the
overall stock market.
Market Risks. A client’s Account may change in
value due to overall market fluctuations. General
economic conditions, political developments,
international events and other factors may cause
the overall market to decline, which in turn may
reduce the value of the client’s Account regardless
of the relative strength of the securities held in
the Account. Securities prices often vary for
reasons unrelated to matters directly affecting the
issuers of the securities.
fluctuate
Equity Securities Risks. Equity securities may
experience sudden, unpredictable drops in value
or long periods of decline in value. This may occur
because of factors that affect the securities
markets in general, such as adverse changes in
economic conditions, the general outlook for
corporate earnings, interest rates or investor
Management and Securities Selection Risks.
A client’s Account may
in value
differently than, or in the opposite direction as,
the overall market or applicable benchmark
because of the selection of individual securities for
the Account. The judgments made by the persons
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sentiment. Equity securities may also lose value
because of factors affecting an entire industry or
sector, such as increases in production costs, or
factors directly related to a specific company,
such as decisions made by its management.
condition declines, so may the value of the
investment product. Issuers may experience
unanticipated financial problems and may be
unable to meet its payment obligations. Municipal
obligations in particular may be adversely affected
by political and economic conditions and
developments (for example, legislation reducing
state aid to local governments.) Bonds receiving
the lowest investment grade rating or a non-
investment grade rating may have speculative
characteristics and, compared to higher grade
debt obligations, may have a weakened capacity
to make principal and interest payments due to
changes in economic conditions or other adverse
circumstances. Ratings agencies such as Moody’s,
Fitch and S&P provide ratings on bonds based on
their analyses of information they deem relevant.
Ratings are essentially opinions or judgments of
the credit quality of an issuer and may prove to
be inaccurate. In addition, there may be a delay
between events or circumstances adversely
affecting the ability of an issuer to pay interest
and/or repay principal and an agency’s decision to
downgrade a security.
Common Stock Risks. Common stocks are
susceptible to general stock market fluctuations
and to volatile increases and decreases in value
as market confidence in and perceptions of their
issuers change. These investor perceptions are
based on various and unpredictable
factors
including: expectations regarding government,
economic, monetary and fiscal policies; inflation
and
interest rates; economic expansion or
contraction; and global or regional political,
economic and banking crises. Holders of common
stocks are generally subject to greater risk than
holders of preferred stocks and debt obligations of
the same issuer because common stockholders
generally have inferior rights to receive payments
from issuers in comparison with the rights of
preferred stockholders, bondholders and other
creditors.
less
liquid
larger companies. Therefore,
Fixed Income Security Risks. Fixed income
securities are subject to certain risks, including
interest rate risk, credit risk and liquidity risk. In
addition, they are subject to maturity risk.
Generally, the longer a bond’s maturity, the
greater the interest rate risk and the higher its
yield. Conversely, the shorter a bond’s maturity,
the lower the interest rate risk and the lower its
yield. Non-rated, split-rated, below investment
grade, and asset-backed securities, including
mortgage-backed securities and CMOs, have
additional, special risks.
them more susceptible
Capitalization Size Risks. A client may be
invested in small and mid cap stocks, which are
often more volatile and
than
investments in larger companies. The frequency
and volume of trading in securities of such
companies may be substantially less than is
typical of
the
securities of such companies may be subject to
greater and more abrupt price fluctuations. In
addition, small- and mid-size companies may lack
the management experience, financial resources
and product diversification of larger companies,
making
to market
pressures and business failure.
foreign
Interest Rate Risk. The value of some
investment products, particularly fixed income
securities, is affected significantly by changes in
interest rates. Generally, when interest rates rise,
the product’s market value declines and when
interest rates decline, its market value rises. In
addition, a rise in interest rates may have a
negative impact on the issuer, which, in turn,
could have a negative impact on the market value
of the investment product.
Credit Risk. The value of some investment
products, particularly fixed income securities, is
affected by changes in the product’s credit quality
rating or the issuer’s financial condition. If the
credit quality rating or the issuer’s financial
Foreign Issuer and Investment Risks.
Securities of
issuers, ADRs, Global
Depositary Receipts (“GDRs”) and European
Depositary Receipts (“EDRs”), and investments in
foreign markets generally, are subject to certain
inherent risks, such as political or economic
instability of the country of issue, the difficulty of
predicting international trade patterns and the
possibility of imposition of exchange controls.
Such securities may also be subject to greater
fluctuations in price than securities of domestic
corporations. Investors in foreign markets may
face delayed settlements, currency controls and
adverse economic developments as well as higher
overall transaction costs. In addition, fluctuations
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or
penalties,
reputational
investigate,
or
remediate
in
the
section
titled
in the U.S. dollar’s value versus other currencies
may enhance, erode, reverse gains or widen
losses from investments denominated in foreign
currencies. For instance, foreign governments
may limit or prevent investors from transferring
their capital out of a country. This may affect the
value of a client’s investment in the country that
adopts such currency controls. Exchange rate
fluctuations also may impair an issuer’s ability to
repay U.S. dollar denominated debt, thereby
increasing the credit risk of such debt. In
addition, there may be less publicly available
information about a foreign company than about a
domestic company. Foreign companies generally
are not subject to uniform accounting, auditing
and financial reporting standards comparable to
those applicable to domestic companies. With
respect to certain foreign countries, there is a
possibility of expropriation or
confiscatory
taxation, or diplomatic developments, which could
affect investment in those countries.
their
own
information
Investments
related
incidents
market
depth,
incidents,
Emerging Markets Risks.
in
emerging markets can involve risks in addition to
and greater than those generally associated with
investing in more developed foreign markets. The
extent of economic development, political
stability,
infrastructure,
capitalization, and regulatory oversight can be
less than in more developed markets. Emerging
market economies can be subject to greater
social, economic,
regulatory, and political
uncertainties. All of these factors can make
emerging market securities more volatile and
potentially less liquid than securities issued in
more developed markets.
(such as
through hacking, malware, social
engineering or theft of digital devices); or the
disruption of systems access to authorized users
(such as through denial of service attacks). Such
events can impede critical functions, compromise
sensitive business and protected customer
information, and may result in financial losses,
business interruptions, impediments to the ability
to process transactions, breaches of applicable
privacy, data protection, or other laws, regulatory
fines
harm,
reimbursement or other remediation costs, and
increased compliance or operational expenses.
Substantial costs may be incurred to prevent,
detect,
future
technology related incidents. Issuers’ increasing
use of AI systems introduces additional risks
“Artificial
discussed
Intelligence Risks” below. Issuers may also rely
on third party or cloud based platforms that
present
security,
cybersecurity, and other technology‑related risks.
Similar adverse consequences may arise from
technology
affecting
governmental authorities,
regulatory bodies,
financial market systems, exchanges, brokers-
dealers, banks, insurance companies, custodians,
or other market participants. Although issuers and
their service providers may adopt business
continuity plans, information security controls,
and risk management programs designed to
prevent or mitigate such
these
measures are subject to inherent limitations,
including the possibility that certain risks may not
be identified or fully addressed. As a result, client
Accounts and investments may be negatively
affected.
Intelligence Risks.
increasingly use AI systems
the
that
could
compromise
technology
Such
incidents may
Issuers of
Artificial
in
investments
various aspects of their business operations,
creating competitive market pressures to increase
the development and use of AI systems. Failure to
effectively develop or use AI systems may place
an issuer at a competitive disadvantage. At the
same time, AI systems present significant risks
that could materially affect an issuer’s business
and financial performance. AI Tools rely on
complex models, large datasets, and evolving
algorithms. AI Tools are highly-useful but
complex and fallible systems that can exhibit bias,
hallucinations, deceptive behaviors and other
flaws due to the construction of their underlying
models and the composition of their training data,
which can result in outputs that seem plausible
Information Security, Cybersecurity and
Technology-Related Risks. As issuers and their
service providers increasingly rely on digital
technologies, such as
Internet, cloud
computing, and AI‑enabled systems, they face
heightened information security, cybersecurity,
and other technology‑related risks,
including
the
incidents
confidentiality, integrity, or availability of their
systems, data, or
infrastructure.
Technology-related incidents may result from
deliberate adversarial actions (such as cyber
attacks) or unintentional events (such as systems
or human error) and could have a materially
adverse impact on the issuer’s performance and
operations.
involve
unauthorized access, disclosure, use, corruption,
degradation, or destruction of systems or data
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in
fact
inaccurate,
regulatory
scrutiny,
Government. While the U.S. Government provides
financial support to various U.S. Government-
sponsored agencies and instrumentalities, such as
those listed above, no assurance can be given
that it will always do so.
rely
on
third-party
AI
falling. Since
interest
federal
taxation,
in such
use
protected
Municipal Securities Risks. Repayment of
municipal securities depends on the ability of the
issuer or project backing such securities to
generate taxes or revenues. Municipal securities
may also decrease in value during times when tax
rates are
income on
municipal securities is normally not subject to
regular
the
income
attractiveness of municipal securities in relation to
other investment alternatives is affected by
changes in federal income tax rates applicable to,
or the continuing federal tax-exempt status of,
such interest income. Any proposed or actual
changes
rates or exempt status,
therefore, can significantly affect the liquidity,
for
marketability and supply and demand
municipal securities, which would in turn affect
Baird’s ability to acquire and dispose of municipal
securities at desirable yield and price levels.
Investment in tax-exempt debt obligations poses
additional risks. In many cases, the IRS has not
ruled on whether the interest received on a tax-
exempt obligation is tax-exempt, and accordingly,
purchases of these municipal securities are based
on the opinion of bond counsel to the issuers at
the time of issuance. Thus, there is a risk that
interest may be taxable on a municipal security
that is otherwise expected to produce tax-exempt
interest.
but are
incomplete, or
misleading. The use of erroneous outputs can
undermine customer trust and expose issuers to
substantial
litigation,
remediation costs, and reputational harm. AI tools
require timely access to high‑quality, compliant
data, and any disruption in data availability can
impair or disable AI Tool functionality. Issuers
often
systems,
infrastructure, and data, which can create vendor
dependency, limit visibility into and validation of
AI model performance, and increase the risk of
disruption in data availability. The regulatory
environment for AI is rapidly evolving and may
involve inconsistent or conflicting requirements
across
jurisdictions. Compliance may require
significant investment, changes to AI systems, or
the discontinuation of certain AI‑enabled features.
Non‑compliance may lead to fines, enforcement
actions, or operational constraints. AI systems are
vulnerable to cyberattacks or other adversarial
actions that can impair system performance and
integrity and compromise sensitive business and
protected customer information. The impairment
of AI systems or the unauthorized disclosure of
sensitive business or protected information can
result in material disruption and damage to
legal and
significant
business operations,
regulatory
remediation
liabilities, substantial
expenses, and reputational harm. AI systems may
information,
inadvertently
potentially giving rise to intellectual property
infringement claims and substantial damages.
Public concerns regarding fairness, transparency,
and responsible use of AI may reduce demand for
an issuer’s products or services. Failure to use AI
responsibly may harm an issuer’s reputation and
competitive position.
securities,
and/or
issued by
Government Obligation Risks. Client assets
may be invested in securities issued, sponsored or
guaranteed by the U.S. Government, its agencies
and instrumentalities. However, no assurance can
be given that the U.S. Government will provide
financial support to U.S. Government-sponsored
agencies or instrumentalities where it is not
obligated to do so by law. For instance, securities
issued by the Government National Mortgage
Association (“Ginnie Mae”) are supported by the
faith and credit of the United States.
full
Securities
the Federal National
Mortgage Association (“Fannie Mae”) and the
Federal Home Loan Mortgage Corporation
(“Freddie Mac”) have historically been supported
only by the discretionary authority of the U.S.
Money Market Fund Risks. A money market
fund is a type of mutual fund that generally
invests in short-term debt instruments. Many
investors use money market funds to store cash.
There are three primary types of money market
funds: (1) government money market funds
(funds that invest nearly all assets in cash,
government
repurchase
agreements collateralized by cash or government
securities); (2) retail money market funds (funds
that have policies and procedures reasonably
designed to limit beneficial ownership to natural
persons); and (3) institutional money market
funds (funds that permit beneficial ownership by
institutions and natural persons). The rules
governing money market funds vary based on the
type of money market fund. Government and
retail money market funds generally try to keep
their net asset value (NAV) at a stable $1.00 per
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addition, recent regulatory changes applicable to
financial intermediaries that make markets in
debt securities have restricted or made it less
desirable for those financial intermediaries to hold
large inventories of debt securities. Because
market makers provide stability to a market
through their intermediary services, a reduction in
dealer inventories may lead to decreased liquidity
and increased volatility in the fixed income
markets. In the event the client directs Baird to
liquidate an illiquid investment, the client should
understand that Baird may have difficulty finding
a buyer in the market for such investment and
such investment may be held in the Account for a
period of time while Baird attempts to satisfy the
client’s liquidation request.
for purchases or withdrawals.
redemptions
in
Concentration Risks. A client’s Account may
consist of a portfolio of securities that
is
concentrated in an issuer or group of issuers, an
industry or economic sector or group of related
industries or sectors, or concentrated in limited
asset classes. Client accounts with concentrated
positions are susceptible to greater volatility and
increased risk of loss than an Account that is
diversified across several issuers and industries or
sectors and asset classes. A client should not
engage in strategies using concentration unless
the client is prepared to experience significant
losses in the value of the client’s Account.
share using special pricing and valuation
conventions. Institutional money market funds
are required to calculate their NAV in a manner
such that the NAV will vary based upon the
market value of assets and liabilities of the fund
(also known as a “floating NAV”). An investment
in a money market fund is not insured or
guaranteed by the FDIC or any other government
agency. Although some money market funds seek
to preserve the value of an investment at $1.00
per share, there can be no assurance that will
occur, and it is possible to lose money should the
fund value per share fall. In some circumstances,
money market funds may be forced to cease
operations when the value of a fund drops. In
that event, the fund's holdings may be liquidated
and distributed to the fund's shareholders. This
liquidation process could take time to complete.
During that time, the amounts a client has
invested in the money market fund would not be
available
In
addition, retail and institutional money market
funds are required to impose redemption fees
(also known as liquidity fees) and suspend
redemptions (also known as redemption gates) in
certain
circumstances. Government money
market funds may also impose redemption fees
and suspend
those same
circumstances. More specific information about
how a money market fund calculates its NAV and
the circumstances under which it will impose a
redemption fee or suspend redemptions is set
forth in the prospectus for that money market
fund.
to
lower
to make a market
for
Frequent Trading and Portfolio Turnover
Risks. Some of the investment strategies offered
to clients in this Brochure may involve frequent or
active trading for client accounts, which could
result in high portfolio turnover. Strategies that
involve frequent or active trading increase the
management and securities selection
risks
because the persons managing the accounts are
making more trading decisions, which may prove
to be incorrect. A portfolio with a high turnover
rate will also incur more transaction costs than
one with a lower rate. Higher transaction costs
may negatively impact the return of the portfolio.
High portfolio turnover may also cause a client to
experience adverse tax consequences due to the
fact that the client may have increased instances
of realized gains and losses and such gains and
losses may commonly be characterized as short
term gains and losses under applicable tax law.
Illiquid Securities and Liquidity Risks.
Liquidity risk is the risk that certain investments
may be difficult or impossible to sell at the time
and price that a client would like to sell. Clients
the price, sell other
may have
investments or forego an investment opportunity,
any of which may have a negative effect on the
management or performance of client accounts.
The liquidity of a particular investment depends
on the strength of demand for the investment,
which is generally related to the willingness of
broker-dealers
the
investment as well as the interest of other
investors to buy the investment. During periods of
economic uncertainty, significant economic and
market downturns and periods in which financial
services firms are unable to commit capital to
make a market in, or otherwise buy, certain
investments, a client may experience challenges
in selling such investments at optimal prices. In
Asset-Backed Securities Risks. Asset-backed
securities are securities secured or backed by
mortgage loans, student loans, automobile loans,
installment sale contracts, credit card receivables
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credit
capitalization
risk,
foreign
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
rate
risk,
risk,
issuer and
investment style
investment risk, and emerging market risk.
Certain mutual funds pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of mutual fund selected. Also, investment
return and principal value will fluctuate, and
shares, when redeemed, may be worth more or
less than their original cost.
or other assets and are issued by entities such as
commercial banks, trusts, financial companies,
finance subsidiaries of
industrial companies,
savings and loan associations, mortgage banks
and investment banks. These securities represent
interests in pools of assets in which periodic
payments of interest or principal on the securities
are made, thus, in effect passing through periodic
payments made by the individual borrowers on
the assets that underlie the securities, net of any
fees paid to the issuer or guarantor of the
securities. Asset-backed securities are issued in
multiple classes (or tranches) and their relative
payment rights may be structured in many ways.
Asset-backed securities may be subject to greater
risk of default during periods of economic
downturn than other instruments. Asset-backed
securities also can be more sensitive to interest
rate risk than other types of fixed income
securities. Modest movements in interest rates
(both increases and decreases) may quickly and
significantly reduce the value of certain types of
these securities. Asset-backed securities are
subject to a number of other risks, including, but
not limited to, market and valuation risks,
liquidity risk, and prepayment risk.
Split-Rated,
and
equity,
securities
include market
selection
Non-Rated,
Below
Investment Grade Securities (High Yield or
“Junk” Bonds) Risks. Investing in securities or
other investment products that are not rated,
split-rated or are below investment grade (also
known as high yield or “junk” bonds) involve
significant, special risks. As a result, they may not
be suitable for some clients. The risks associated
with these investments include, but not limited to,
price volatility risk, credit risk, default risk, and
liquidity risk. Clients investing in securities or
other investment products that are not rated,
split-rated or are below investment grade should
have a high tolerance for risk, including the
willingness and ability to accept significant price
volatility, potential lack of liquidity and potential
loss of their investment.
credit
capitalization
risk,
foreign
including equity,
fixed
investment
style,
Exchange Traded Fund Risks. An ETF is
different from a mutual fund in that an ETF does
not sell its shares directly to public investors and
does not redeem shares from public investors.
Rather, shares of an ETF are commonly purchased
or sold in the secondary market on a securities
exchange, like common stocks. An ETF maintains
a net asset value but, based on demand and
other factors, the market price of shares of an
ETF may vary from its net asset value. ETFs
invest in and hold securities and other assets,
such as stocks, bonds, commodities and
currencies, and have stated investment objectives
and principal strategies. ETFs can have many
different investment objectives and strategies,
including
income, balanced,
fixed
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. Many ETFs seek to track the
performance of an index or other underlying
benchmark. Passively managed ETFs will not be
able to replicate exactly the performance of the
indices the ETFs track because the total return
generated by the securities will be reduced by
management fees, transaction costs and other
expenses incurred by the ETF. ETFs have other
risk,
risks, which may
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
rate
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk.
Certain ETFs pursue Complex Strategies, which
are subject to special risks. The degree of these
and other risks will vary depending on the type of
ETF selected.
securities
selection
Mutual Fund Risks. Mutual funds can have
investment objectives and
many different
strategies,
income,
balanced, international, and global strategies, and
strategies that focus on a particular market
capitalization,
economic
industry or sector, or geographic region. Mutual
funds have risks, which may include market risk,
risk,
management and
investment objective and asset allocation risk,
Closed-End Fund Risks. Unlike mutual funds
which continuously offer and redeem their shares
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equity,
that
fund
that
for purposes of making
securities
selection
deposited into the trust for a specified period of
time. The portfolio of a UIT is designed to follow
an investment objective over a specified time
period, although there is no guarantee that the
objective will be met. UITs can have many
different investment objectives and strategies,
including
income, balanced,
fixed
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. UITs are passively managed
and follow a “buy and hold” strategy, meaning
that UITs buy a fixed portfolio of securities and
hold on to that portfolio until their termination
date at which time the portfolio is liquidated with
the net proceeds paid to investors. UITs, thus,
generally have a relatively higher risk of loss than
other funds in the event of adverse changes in
market or economic conditions. UITs have other
risks, which may
include management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, and emerging market
risk. Certain UITs pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of UIT selected. Also, investment return and
principal value will fluctuate, and units, if and
when redeemed, may be worth more or less than
their original cost.
credit
capitalization
risk,
foreign
closed-end
on a daily basis at net asset value, closed-end
funds typically raise money by selling a fixed
number of shares of common stock in a single,
one-time offering, much the way a company
issues stock in an initial public offering. Closed-
end funds can have many different investment
objectives and strategies, including equity, fixed
income, balanced,
international, and global
focus on a
strategies, and strategies
particular market capitalization, investment style,
industry or sector, or geographic
economic
shares are not
region. Closed-end
investors cannot
redeemable, meaning
require closed-end funds to buy back their shares,
although closed-end fund shares are listed and
traded on an exchange. For many reasons,
closed-end fund shares often trade at a discount
to their net asset value and the market prices of
closed end fund shares often fall below their
public offering prices. Clients are therefore
cautioned about buying shares of a closed-end
fund in its initial public offering. Closed-end funds
often engage in leverage to raise additional
capital
investments
through borrowings and issuances of senior
securities (such as preferred stock). Such
leverage may present the opportunity to enhance
potential returns but also involve the risk of
exacerbating losses and depreciation in the value
of the underlying securities. Closed-end funds
have other risks, which may include market risk,
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
risk,
risk,
rate
investment style
issuer and
investment risk, and emerging market risk.
Certain
funds pursue Complex
Strategies, which are subject to special risks.
Some closed-end funds are organized as interval
funds, which differ from traditional closed-end
funds in that their shares do not trade on the
secondary market, but instead their shares are
subject to repurchase offers from the fund.
Closed-end funds structured as an interval fund
will, therefore be relatively less liquid. Interval
funds also often impose a redemption fee when
shares are sold back to the fund. The degree of
these and other risks will vary depending on the
type of close-end fund selected.
Unit Investment Trust Risks. A UIT is a pooled
in which a portfolio of
investment vehicle
the sponsor and
securities
is selected by
Risks Common to All Funds; Purchase and
Redemption Risks. Funds are generally subject
to the same risks as the securities or other assets
in which they invest. In addition, from time to
time Baird, a PAM Consultant, or an investment
manager may decide to add or remove a Fund to
or from an investment strategy or Service. In
addition, they may decide to increase or decrease
their clients’ account allocations to a Fund. In
general, they will place transactions for all
affected Accounts at one time, which may cause
the Fund to experience relatively large purchases
or
redemptions. Significant purchases and
redemptions may adversely affect the Fund in
question and consequently, a client’s investment.
A Fund receiving large purchase orders may have
difficulty investing the cash, which may have a
negative impact on the Fund’s performance. A
Fund experiencing large redemption orders may
have to sell portfolio securities, which may
negatively impact performance and which may
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negative
tax
consequences.
have
Large
redemptions could also reduce liquidity as the
Fund may suspend or delay redemptions. These
risks are more pronounced with respect to newer
Funds and those with smaller asset sizes.
by
the
Risks Associated with Certain Investment
Strategies
that were not predicted by
can be no assurance
that
Certain low-probability events or factors that are
assigned little weight may occur or prove to be
more likely or may have more relevance than
expected, for short or extended periods of time,
the portfolios
which may adversely affect
generated
investment manager’s
quantitative methodologies and processes. It is
also possible that prices of securities may move in
the
directions
investment manager’s quantitative methodologies
and processes or may fail to move as much as
predicted, for reasons that were not expected.
these
There
methodologies will enable a client to achieve the
client’s objective.
Growth and Value Investment Style Risks.
Investment styles or strategies that focus on
growth stocks may perform better or worse than
styles or strategies that focus on value stocks or
that are broader or more diversified. Similarly,
investment styles or strategies that focus on
value stocks may perform better or worse than
styles or strategies that focus on growth stocks or
that are broader or more diversified. A particular
style of investing may go out of favor at times
and for extended periods. Growth stocks are often
characterized by high price-to-earnings ratios and
may be more volatile than stocks with lower
price-to-earnings ratios. Value stocks are subject
to the risk that the broader market may not agree
with the manager’s assessment of, or recognize,
the investments’ intrinsic value.
Technical Strategy Risks. Some investment
managers and PAM Consultants may employ
technical analysis or investment methodologies to
make investment decisions or recommendations.
The primary risk of using technical analysis is that
past price and volume patterns and trends in the
trading markets cannot predict future prices,
volume patterns or trends. There is no guarantee
that technical investment methods used are
designed properly, are updated with new data as
it becomes available, or can accurately predict
future market or investment performance. In
order for technical investment methods to work,
there must be sufficient data about the markets
available so that trends can be identified and
predictions can be made. A technical method may
fail to identify trends or be able to accurately
predict future prices if a market does not have
sufficient data or trends or if the market behaves
erratically.
ESG Considerations Risk. Consideration of ESG
factors in the investment process may cause an
advisor or manager to forgo opportunities to
recommend or invest in certain companies or to
gain exposure to certain industries or regions.
Therefore, there is a risk that, under certain
market conditions, an Account pursuing strategies
that consider ESG factors may underperform
accounts that do not consider such factors. There
are not universally accepted ESG factors and
advisors and managers typically consider them in
their discretion.
the heading
Other Strategy Risks. The risks associated with
other types of investment strategies are described
“Methods of Analysis,
under
Investment Strategies and Risk of Loss—
Investment Strategies” above.
Non-Traditional Assets and Complex
Strategies Risks
such as
commodities,
an
investment
Quantitative Strategy Risks. Some investment
managers may employ quantitative investment
methodologies or processes to make investment
decisions. The success of
the quantitative
investment methodologies and processes used by
investment managers depends on the analyses
and assessments that were used in developing
such methodologies and processes, as well as on
the accuracy and reliability of models and data
provided by third parties. Incorrect analyses and
assessments or inaccurate or incomplete models
and data would adversely affect performance.
Additionally,
manager’s
methodologies and processes are predictive in
nature, based on historical outcomes and trends.
Non-Traditional Assets Risks. Non-Traditional
Assets,
currencies,
securities indices, interest rates, credit spreads,
private companies, and Digital Assets, are subject
to risks that are different from, and in some
instances, greater than, other assets like stocks
and bonds. Some Non-Traditional Assets are less
transparent and more sensitive to domestic and
foreign political and economic conditions than
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traditional
more
investments. Non-Traditional
Assets are also generally more difficult to value,
less liquid, and subject to greater volatility
compared to stocks and bonds.
Risks.
Investments
investments
decrease in the value of underlying securities in
the client’s Account, thereby increasing a client’s
risk of loss. The use of leverage may also increase
involving
an Account’s volatility. Strategies
margin can cause a client to lose more money
than deposited in the client’s margin account. A
client should not engage in strategies involving
leverage or margin unless the client is prepared
to experience significant losses in the value of the
client’s Account.
in
securities.
investment and
trading activities
or
consuming
Short Sales Risks. Short selling runs the risk of
loss if the price of the securities sold short does
not decline below the price at which they were
originally sold. This risk of loss is theoretically
unlimited, as there is no cap on the amount that
the price of a security may appreciate. In
lender may request, or market
addition, a
conditions may dictate, that securities sold short
be returned to the lender on short notice, which
may result having to buy the securities sold short
at an unfavorable price. A client should not
engage in short sales unless the client is prepared
to experience significant losses in the client’s
Account.
contracts
other
Commodities
in
commodities markets or a particular sector of the
in
commodities markets, and
securities or other instruments denominated in or
indexed or linked to commodities, are subject to
certain risks. Those investments generally will
subject a client Account to greater volatility than
The
traditional
investments
commodities markets are impacted by a variety of
factors, including changes in overall market
movements, domestic and foreign political and
economic conditions, interest rates, inflation rates
in
and
commodities. Prices of commodities may also be
affected by factors such as drought, floods,
weather, livestock disease, embargoes, tariffs and
other regulatory developments. The prices of
commodities can also fluctuate widely due to
supply and demand disruptions
in major
producing
regions. Certain
commodities may be produced in a limited
number of countries and may be controlled by a
small number of producers or groups of
producers. As a result, political, economic and
supply related events in such countries could have
a disproportionate impact on the prices of such
commodities. No active trading market may exist
for certain commodities investments, which may
impair the value of the investments.
instruments
in
that
Derivative Instrument Risks. The values of
options, convertible securities, futures, swaps,
forward
derivative
and
instruments is derived from an underlying asset,
such as a security, commodity, currency, or
index. Derivative instruments often have risks
similar to the underlying asset, however, in
certain cases, those risks are greater than the
risks presented by
the underlying asset.
Derivative instruments may experience dramatic
price changes and imperfect correlations between
the price of the derivative and the underlying
asset, which may increase volatility. Derivatives
generally create leverage, and as a result, a small
movement in the underlying asset's value can
result in large change in the value of the
derivative instrument. Derivatives are also subject
to liquidity risk, interest rate risk, market risk,
credit risk, management risk and counterparty
risk. The use of these
is not
appropriate for some clients because they involve
special risks. A client should not invest in these
instruments unless the client is prepared to
experience volatility and significant losses in the
client’s Account.
Currency Risks. Investments in currencies, and
investments in securities or other instruments
denominated in or indexed or linked to currencies,
are subject to certain risks. Those investments
are subject to all of the risks associated with
foreign investing generally. In addition, currency
markets generally are not as regulated as
securities markets. Also, changes in currency
exchange rates could adversely
impact the
investment. Devaluation of a currency by a
country will also have a significant negative
impact on
investment
the value of any
denominated
currency. Currency
investments may also be positively or negatively
affected by a country’s strategies intended to
make its currency stronger or weaker relative to
other currencies.
Leverage and Margin Risks. Leveraging
impact of any
strategies may amplify
the
Options Risks. In purchasing a put or call
option, the purchaser faces the risk of loss of the
premium paid for the option if the market price
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Complex Investment Product Risks
the underlying security or
funds have unique
moves in a direction opposite to what the
purchaser had expected. In selling or writing an
option, the seller faces significantly more risk. A
seller of a call option faces the risk of significant
loss
if the prevailing market price of the
underlying security or index increases above the
strike price, and a seller of a put option faces the
risk of significant loss if the prevailing market
index
price of
decreased below the strike price.
for those
fee
an
incentive
Hedging Risks. When a derivative instrument is
used as a hedge against an opposite position, any
loss on the derivative instrument should be
substantially offset by gains on the hedged
investment, and vice versa. Although hedging can
be an effective way to reduce the investment risk,
it may not always perfectly offset one position
with another. As a result, there is no assurance
that hedging transactions will be effective.
in
the marketplace and
Assets
involve
technological
limited
short
sales,
risks may
trading,
settlement,
and
securities
include: market
selection
validators, miners,
or
credit
capitalization
risk,
foreign
limited number of
Digital Assets Risks. Digital Assets are not
appropriate for some clients because they involve
substantial risk of loss including special risks not
present in traditional financial markets. Digital
Assets derive value primarily from the demand for
their
such assets
association with decentralized networks and other
technology. Digital Assets may lack an intrinsic
value and markets
for Digital Assets are
to extreme and sudden price
susceptible
movements and fragmented liquidity. Markets for
Digital Assets continue to evolve, but
lack
certainty regarding the status of regulation and
investor protections. The use and custody of
and
Digital
cybersecurity risks, including the potential for
system outages, protocol
flaws, operational
disruptions, hacking incidents, or failures of
third-party platforms and service providers that
support
storage
infrastructure. Many Digital Assets depend on
external
protocol
developers whose actions or inaction can impact
network stability or asset functionality and affect
value. Market structure risks—such as reliance on
a
trading venues or
counterparties—may impair the ability to transact
or liquidate positions during periods of market
stress. A client should not invest in these
instruments unless the client is prepared to
experience extreme volatility and significant
losses in the client’s Account.
Hedge Funds and Funds of Hedge Fund
Risks. Hedge funds typically engage in one or
more Complex Strategies, including the use of
Non-Traditional Assets, short sales, leverage and
other derivative instruments. Funds of hedge
funds typically invest substantially all of their
assets in other hedge funds. Hedge funds and
funds of hedge
tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Some
hedge funds and funds of hedge funds are subject
to limited regulation and offer limited disclosure
and transparency. Also, the costs of hedge funds
and funds of hedge funds are typically higher than
other types of funds. Investment advisers or
funds often receive a
managers
management
or
plus
performance-based fee. Because of the existence
of a performance-based fee, fund managers may
be motivated to make riskier investments that
have the potential for significant growth in value.
Hedge funds and funds of hedge funds are also
subject to a higher risk of incorrect valuations.
Many hedge funds hold investments for which
market quotations are not readily available, which
necessitates the use of “fair value” pricing. Fair
value pricing is an inherently subjective process
and may not accurately reflect the prices that can
actually be obtained upon sale of the assets for
which fair values are used. Investments in hedge
funds and funds of hedge funds also have reduced
liquidity compared to other investments and are
generally subject to a higher risk of volatility.
Investing in hedge funds and funds of hedge
funds involves other special risks, including, but
to, risks associated with Non-
not
Traditional Assets,
leverage,
derivative instruments, and Complex Strategies.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
risk,
risk,
rate
investment style
issuer and
investment risk, and emerging market risk. Hedge
funds and funds of hedge funds are complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in hedge funds or funds
of hedge funds should have a high tolerance for
risk, including the willingness and ability to accept
lack of
significant price volatility, potential
liquidity and potential loss of their investment.
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investments
Private equity funds and funds of private equity
funds are complex
that have
significant, special risks. As a result, they may not
be suitable for some clients. Clients investing in
private equity funds and funds of private equity
funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
in
certain
that may
sectors,
is
inversely correlated
to
those
events are
funds are subject to
to administrative service
evaluated
risks
during
compared
other
expect
risk
as
securities
selection
risk,
foreign
Private Equity Funds and Funds of Private
Equity Funds Risks. Private equity funds are
pools of actively managed capital that invest
primarily in private companies with the intent of
creating value in the companies in which they
invest by improving operations, reducing costs,
selling non-core assets and maximizing cash flow.
Private equity funds usually have an investment
focus on
objective or strategy
companies
industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes of investments. Funds of private equity
funds typically invest substantially all of their
assets in other private equity funds. Private
equity funds and funds of private equity funds
have unique tax characteristics. A client should
consult with a tax advisor before investing in
those funds. Private equity funds and funds of
private equity
limited
regulation and offer
limited disclosure and
transparency. Also, the costs of private equity
funds and funds of private equity funds are
typically higher than other types of
funds.
Investment advisers or managers for those funds
often receive a management fee plus an incentive
fee or carried interest. Private equity funds and
funds of private equity fund are also generally
subject
fees and
portfolio company transaction fees. Because of
the existence of a carried interest, fund managers
may be motivated to make riskier investments
that have the potential for significant growth in
value. Investments in private equity funds and
funds of private equity funds also have reduced
investments.
to
liquidity
Investors
receive
to
should not
distributions from a fund for a number of years.
Private equity investing is very risky. Many
investments made in portfolio companies are not
profitable. In addition, investments made by
private equity funds and funds of private equity
funds may be concentrated in one or more
economic
industries or sectors, geographic
regions, stages of development or operation, or
sizes of companies. Investing in private equity
funds and funds of private equity funds involves
other special risks, including, but not limited to,
dependence upon key personnel and conflicts of
interest risks. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
issuer and
investment style
investment risk, and emerging market risk.
Reinsurance Fund Risks. Reinsurance funds
invest primarily in insurance-linked securities or
other instruments. A fund’s return on those
the
investments
occurrence of applicable catastrophic or other
events, such as hurricanes, tornados, floods,
earthquakes or other natural disasters, or fires,
explosions, aviation or marine accidents or other
non-natural disasters. The occurrence and
severity of
inherently
unpredictable. A fund could lose all or a significant
portion of its investment upon the occurrence of
an applicable event and the occurrence of multiple
events could cause the fund to sustain substantial
losses. In addition, certain investments may
expose a fund to liability in excess of amounts
received in connection with the investment. The
performance of certain insurance-linked securities
is dependent upon underwriting decisions made
by insurance companies associated with those
securities. Thus, the fund is subject to the risk
that those insurance companies may not have
adequately
the
underwriting process. Reinsurance funds may also
be subject to concentration risk as the market for
certain insurance-linked securities is small and
competition to buy insurance-linked securities has
increased in recent years. Due to the nature of a
reinsurance fund’s underlying investments, an
investment in a reinsurance fund is subject to
fund’s underlying
the
valuation
investments may be difficult to accurately and
timely value. Investing in reinsurance funds
involves other special risks, including, but not
limited to, dependence upon key personnel, Non-
Traditional Assets risks, currency risks, leverage
risks, derivative instrument risks and hedging
risks. Other risks may include: market risk,
management and
risk,
investment objective and asset allocation risk,
equity securities risks, fixed income securities
risks, interest rate risk, credit risk, foreign issuer
and investment risks, emerging market risks,
illiquid securities risks, quantitative strategy risks,
and high yield or “junk” bond risks. Reinsurance
that have
funds are complex
investments
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should not
expect
to
significant, special risks. As a result, they may not
be suitable for some clients. Clients investing in
reinsurance funds should have a high tolerance
for risk, including the willingness and ability to
accept significant price volatility, potential lack of
liquidity and potential loss of their investment.
funds
involves special
risk,
foreign
fund
risks, currency
growth in value. Investments in private debt
funds and funds of private debt funds also have
reduced liquidity compared to other investments.
receive
Investors
distributions from a fund for a number of years.
Private debt investing is very risky. Investments
made by private debt funds and funds of private
debt funds may be concentrated in one or more
industries or sectors, geographic
economic
regions, stages of development or operation, or
sizes. Investing in private debt funds and funds of
private debt
risks,
including, but not limited to, dependence upon
key personnel, conflicts of interest risks, market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
issuer and
investment style
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
investment
risks and
leveraging risks. Private debt funds and funds of
private debt funds are complex investments that
have significant, special risks. As a result, they
may not be suitable for some clients. Clients
investing in private debt funds and funds of
private debt funds should have a high tolerance
for risk, including the willingness and ability to
accept lack of liquidity and potential loss of their
investment.
in certain sectors,
debt
funds
have
unique
warehouses,
receive a management
transaction
Private Debt Funds (or Private Credit Funds)
and Funds of Private Debt Funds Risks.
Private debt funds (also known as private credit
funds) are pools of actively managed capital that
invest primarily in loans or debt instruments
issued by companies in private transactions.
Sometimes, repayment of the loan is secured by
assets of the companies obtaining the loans.
However, the companies often have low or no
credit ratings. Thus, investments held by private
debt funds generally are subject the same risks as
below investment grade or “junk” bonds. Trading
markets for the investments held by those funds
are also limited and their investments may be
illiquid. Oftentimes, the interest rate paid by the
companies is determined by a reference interest
rate, such as the federal funds rate, which is
periodically reset. These types of investments are
sometimes referred to as floating rate corporate
debt, floating rate loans or floating rate bank
loans. Private debt
funds usually have an
investment objective or strategy that may focus
on companies
industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes, including focusing investments on
smaller capitalization, distressed or bankrupt
companies. Private debt funds commonly use
borrowings or leverage to make investments.
Funds of private debt funds typically invest
substantially all of their assets in other private
debt funds. Private debt funds and funds of
tax
private
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
debt funds and funds of private debt funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private debt funds and funds of private debt funds
are typically higher than other types of funds.
Investment advisers or managers for those funds
often
fee plus a
performance fee. Private debt funds and funds of
private debt fund are also generally subject to
operational expenses and
fees.
Because of the existence of a performance fee,
fund managers may be motivated to make riskier
investments that have the potential for significant
Real Estate Investment Trusts (“REITs”) and
Private REIT Risks. A REIT is a corporation,
trust or association that owns and typically
operates income-producing real estate or real
estate-related assets. The income-producing real
estate assets owned by a REIT may include office
buildings, shopping malls, multi-family housing,
student housing, hotels, resorts, hospitals and
health care facilities, self-storage facilities, data
centers,
telecommunications
facilities, and mortgages or loans. Many REITs are
registered with the SEC and their common stock
and preferred stock are publicly traded on a stock
exchange. These are known as publicly-traded
REITs. Others may be registered with the SEC but
are not publicly traded. These are known as
private REITs (also known as non-traded or non-
exchange traded REITs). There is no public
trading market for private REITs and the sole
method for disposing of the shares may be limited
to a periodic offer to redeem the shares by the
issuer, if the issuer offers a redemption program.
Private REITs are generally subject to limited
limited disclosure and
regulation and offer
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improved management
real estate
funds
typically
in which
they are
for those
risk, growth
risk, credit
risk,
foreign
should not
expect
to
investing
transparency. The shareholders of a REIT are
responsible for paying taxes on the dividends that
they receive and on any capital gains associated
with their investment in the REIT. Dividends paid
by REITs generally are treated as ordinary income
and are not entitled to the reduced tax rates on
other types of corporate dividends. Prices of REIT
securities and trading volumes may be more
volatile that other investments. Many REITs focus
on a particular sector of the real estate market,
such as apartments, student housing, hotels and
hospitality, health care, office buildings, shopping
malls, warehouses, self-storage facilities and the
like. Those REITs are subject to risks associated
with sectors
focused.
Additionally, many REITs may own properties that
are concentrated in a particular geographic region
or regions, which subject them to the risk of
deteriorating economic conditions in those areas.
Investing in REITs involves other special risks,
including, but not limited to, real estate portfolio
(including development, environmental,
risk
competition, occupancy and maintenance risk),
liquidity risk, leverage risk, distribution risk,
capital markets access
risk,
counterparty risk, conflicts of
interest risk,
risk, and
dependence upon key personnel
regulatory risk. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, interest
rate
issuer and
investment risk, and emerging market risk. REITs
involve significant, special risks and may not be
suitable for some clients. Clients investing in
REITs should have a high tolerance for risk,
including the willingness and ability to accept
significant price volatility and volatility of regular
distribution amounts, potential lack of liquidity
and potential loss of their investment.
fund
risks, currency
investments. Some may
in properties
industries,
involved
located
or
sponsor believes are undervalued or
undercapitalized or that require repositioning,
redevelopment,
or
additional capital to reach their full value. Private
real estate funds commonly use borrowings or
leverage to make investments. Trading markets
for investments held by those funds are limited
and their investments may be illiquid. Funds of
invest
private
substantially all of their assets in other private
real estate funds. Private real estate funds and
funds of private real estate funds have unique tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
real estate funds and funds of private real estate
funds are subject to limited regulation and offer
limited disclosure and transparency. Also, the
costs of private real estate funds and funds of
private real estate funds are typically higher than
other types of funds. Investment advisers or
managers
funds often receive a
management fee plus a performance fee. Private
real estate funds and funds of private real estate
fund are also generally subject to operational
expenses and transaction fees. Because of the
existence of a performance fee, fund managers
may be motivated to make riskier investments
that have the potential for significant growth in
value. Investments in private real estate funds
and funds of private real estate funds also have
reduced liquidity compared to other investments.
Investors
receive
distributions from a fund for a number of years.
Private real estate
is very risky.
Investments made by private real estate funds
and funds of private real estate funds may be
concentrated in properties involved in one or
more economic industries or sectors, geographic
regions, stages of development or operation, or
sizes. Investing in private real estate funds and
funds of private real estate funds involves special
risks, including, but not limited to, dependence
upon key personnel, conflicts of interest risks,
market risk, management and securities selection
risk, investment objective and asset allocation
risk, interest rate risk, credit risk, capitalization
risk, investment style risk, foreign issuer and
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
risks and
investment
leveraging risks. Private real estate funds and
funds of private real estate funds are complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in private real estate
Private Real Estate Funds and Private Real
Estate Fund of Funds. Private real estate funds
are pools of actively managed capital that directly
invest primarily in investments in real estate and
real estate-related
investments. Private real
estate funds may invest in any number of types of
real estate, such as office, apartment, retail,
lodging, industrial and other real estate and real
focus
estate-related
in certain
investment
sectors or
certain
in
geographic regions or that have certain sizes of
operations or investment requirements. Some
may focus investment on properties the manager
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
funds and funds of private real estate funds
should have a high tolerance for risk, including
the willingness and ability to accept lack of
liquidity and potential loss of their investment.
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in private infrastructure
funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
telecommunication,
Private
utilities,
infrastructure
throughout
for those
fees and
for
significant growth
reduced
liquidity compared
investments made
by
industries or
risks may
securities
include: market
selection
credit
capitalization
risk,
foreign
risk,
foreign
Exchange Traded Notes Risks. An ETN is a
type of debt security that trades on an exchange
and provides a return linked to the performance
of an underlying benchmark. The underlying
benchmark can be a particular security, bond,
commodity, currency, or other Non-Traditional
Asset type, a group or basket of companies,
securities, commodities, currencies, derivative
instruments, Non-Traditional Asset investments or
other assets, or an index or other benchmark
linked to stocks, market volatility, bonds, interest
rates, Treasury yields, yield curves and spreads,
derivative instruments, strategies, commodities,
currencies or other assets. ETNs trade on
the day at prices
exchanges
determined by the market. Unlike ETFs, issuers of
ETNs do not buy or hold assets to replicate or
approximate the performance of the underlying
benchmark. Also in contrast to ETFs, ETNs also do
not calculate their net asset value, are generally
not redeemable on a daily basis, and are not
registered under the Investment Company Act of
1940. Issuers may also have the right and option
to redeem ETNs. Redemptions are made at the
ETN’s “indicative value” or “closing indicative
value”. An ETN's closing indicative value is
computed by the issuer and is distinct from an
ETN's market price, which is the price at which an
ETN trades in the secondary market. Issuers of
ETNs may also issue and redeem notes as a
means to keep the ETN’s market price in line with
its indicative value, which have caused significant
fluctuations in ETN prices. Investing in ETNs
involves special risks, including, but not limited
to, risks associated with Non-Traditional Assets
and derivative instruments and the risk that the
actual market price for an ETN may vary
significantly from the indicative value computed
by the issuer. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
rate
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk. ETNs
are complex investments and involve significant,
Private Infrastructure Funds Risks. Private
infrastructure funds are pools of actively managed
capital that invest primarily in infrastructure
projects and assets and may involve exposure to
a
range of economic or market sectors,
geographic locations and asset types. Examples of
infrastructure investments may include, among
and
others,
transportation.
funds
usually have an investment objective or strategy
that may focus on certain sectors, industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes of investments. Private infrastructure
funds have unique tax characteristics. A client
should consult with a tax advisor before investing
in those funds. Private infrastructure funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private infrastructure funds are typically higher
than other types of funds. Investment advisers or
funds often receive a
managers
management fee plus an incentive fee. Private
infrastructure funds are also generally subject to
administrative service
investment
transaction fees. Because of the existence of
incentive fees, fund managers may be motivated
investments that have the
to make riskier
potential
in value.
Investments in private infrastructure funds also
to other
have
investments. Investors should not expect to
receive distributions from a fund for a number of
years. Private infrastructure investing is very
risky. Many investments are not profitable. In
addition,
private
infrastructure funds may be concentrated in one
or more economic
sectors,
geographic regions, stages of development or
operation, or sizes of companies. Investing in
private infrastructure funds involves other special
risks, including, but not limited to, dependence
upon key personnel and conflicts of interest risks.
Other
risk,
risk,
management and
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, and emerging market risk.
complex
Private
infrastructure
funds
are
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special risks. As a result, ETNs may not be
suitable for some clients.
inverse
pools
(typically
structured
in managed
funds and they
currencies,
Assets,
leverage,
benchmark they track. Leveraged inverse funds
seek to achieve a return that is a multiple of the
inverse performance of the underlying index. Most
funds “reset” daily,
leveraged and
meaning that they are designed to achieve their
stated objectives on a daily basis. Because of the
effects of compounding, volatility and the fund
expenses, the returns of a leveraged or inverse
fund over longer periods of time can differ
significantly from the performance (or inverse of
the performance) of their underlying index or
benchmark during the same period of time. To
achieve their objectives, leveraged and inverse
funds typically employ aggressive investment
techniques, such as the use of leverage, short
sales, swap contracts, futures, options and other
derivative instruments. Investing in leveraged
funds and inverse funds involves special risks,
including, but not limited to, risks associated with
Non-Traditional Assets, short sales, leverage, and
derivative instruments. Other risks may include:
market risk, management and securities selection
risk, investment objective and asset allocation
risk, stock market risk, equity securities risk,
common stock risk, fixed income securities risk,
interest rate risk, credit risk, foreign issuer and
investment risk, and emerging market risk.
Leveraged funds and inverse funds are complex
investments that have an increased risk of loss
compared to other
involve
significant, special risks. As a result, they may not
be suitable for some clients. A client should not
invest in these securities unless the client is
prepared to experience significant losses in the
value of the client’s Account.
Investing
Managed Futures Risks. Managed futures are
commodity
as
investment partnerships) managed by a futures
trading adviser that trade speculatively in various
derivative instruments and other investments.
There are significantly higher fees and expenses
associated with investments in managed futures
than other types of funds. Sponsors or managers
for these pools often receive a management fee
plus incentive or performance-based fee. Because
of the existence of a performance-based fee,
managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Managed futures may seek
exposure to different asset classes, such as equity
securities, fixed income securities, commodities
(such as metals, agricultural products, and energy
products), currencies, interest rates, and indices.
Managed futures often obtain this exposure
through derivative instruments, which may be
traded on U.S. or foreign exchanges or markets.
Managed futures often employ computerized,
systematic and often proprietary trading models
futures
and systems. Investing
involves special risks, including, but not limited
to, liquidity risks and risks associated with
and other Non-
commodities,
derivative
Traditional
instruments and Complex Strategies. Other risks
may include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
foreign issuer and investment risk, and emerging
market risk. Managed futures can be speculative
investments because of the types of investments
they make and they involve significant, special
risks. As a result, they may not be suitable for
some clients. Clients investing in these funds
should have a high tolerance for risk, including
the willingness and ability to accept significant
price volatility, potential lack of liquidity and
potential loss of their investment.
risks may
securities
include: market
selection
Structured Products Risks. Structured products
are a hybrid between two asset classes (typically
issued in the form of a CD or note) but instead of
having a pre-determined rate of interest, the
return is linked to the performance of an
underlying asset class, such as single security or
basket or index of securities; a commodity or
basket or index of commodities, including futures;
and a foreign currency or basket of foreign
currencies.
in structured products
involves special risks, including, but not limited
to, risks associated with derivative instruments.
Other
risk,
risk,
management and
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
issuer and
rate
risk,
investment
risk, credit
risk,
foreign
risk,
emerging market
Leveraged Fund and Inverse Fund Risks.
Leveraged funds and inverse funds may be
structured as ETNs, ETFs or open-end mutual
funds. Leveraged funds seek to deliver multiples
of the performance of the index or benchmark
they track. Inverse funds seek to deliver the
opposite of the performance of the index or
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commodities risk and currency risk. Structured
products are complex investments and involve
special risks. As a result, they may not be suitable
for some clients.
is
those
including, but not
Master Limited Partnership Risks. An MLP is a
form of publicly-traded partnership that is taxed
as a partnership. MLPs have unique
tax
characteristics. A client should consult with a tax
advisor before investing in MLPs. An MLP must
generally earn at least 90% of its income from
certain qualifying sources, which includes income
and gains from certain activities involving natural
resources such as oil, natural gas, natural gas
liquids, refined petroleum products, coal, carbon
dioxide and biofuels. An MLP
is generally
structured as a limited partnership or limited
liability company and managed and operated by a
general partner or manager. Owners of an MLP
are called “limited partners” or “unit holders”.
Unit holders own interests or units in the MLP
(“units”) that are traded on a stock exchange.
MLPs make distributions to unit holders of their
available cash flows. Many MLPs focus on a
particular sector or industry. Those MLPs are
subject to risks associated with sectors or
industries in which they are focused. The value of
an investment in an MLP and the amount of
distributions it makes may depend on the prices
of the underlying commodity, such as oil or
natural gas. Many MLPs are sensitive to changes
in the prevailing level of commodity prices. MLPs
have also shown sensitivity to interest rate
movements. Investing in MLPs involves other
special risks,
limited to,
macroeconomic risk, interest rate risk, liquidity
risk, operating risk, capital markets access risk,
growth risk, distribution risk, conflicts of interest
risk, and regulatory risk. MLPs are complex
investments that have significant, special risks. As
a result, MLPs may not be suitable for some
clients. Clients investing in MLPs should have a
high tolerance for risk, including the willingness
and ability to accept potential lack of liquidity and
potential loss of their investment.
risk, capital markets access
information
about
Additional
certain
Complex Investment Products and other
investments pursuing Complex Strategies,
including the risks associated with those
investments, is available on Baird’s website
at bairdwealth.com/retailinvestor and on
FINRA’s website
at www.finra.org/
Investors. A client is encouraged to read the
included on those
disclosure documents
websites carefully before investing.
Business Development Company Risks. A
BDC
closed-end
typically a domestic,
investment company that is operated for the
purpose of making equity and debt investments in
small and developing businesses, as well as
financially troubled businesses. As a result,
investments made by BDCs tend to be risky and
speculative. Investment advisers or managers for
BDCs often receive a management fee plus
incentive or performance-based fee. Because of
the existence of a performance-based
fee,
managers may be motivated to make riskier
investments that have the potential for significant
growth in value. BDCs commonly use borrowings
or leverage to make investments in portfolio
companies. Adverse interest rate movements can
impact a BDC’s ability to make
negatively
investments. Investments made by BDCs are
typically illiquid, and valuing such investments is
challenging. It is possible that valuations on
investments used are materially different from the
values that BDCs will ultimately receive upon
disposition of
investments. Changing
market and economic conditions affecting a BDC’s
investments may cause significant volatility in the
BDC’s net asset value and stock price. Due to the
nature of BDCs’ investments, securities issued by
BDCs are subject to greater liquidity risk than
other investments. A debt security or preferred
stock issued by a BDC, in many cases, is non-
rated or is rated below investment grade, which
can carry its own risks. Investing in BDCs involves
other special risks, including, but not limited to,
portfolio company credit and investment risk,
risk,
leverage
dependence upon key personnel
risk, and
regulatory risk. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, and
interest rate risk. BDCs can be speculative
investments because of the types of investments
they make and involve significant, special risks.
As a result, BDC investments may not be suitable
for some clients. Clients investing in BDCs should
have a high tolerance for risk, including the
willingness and ability to accept significant price
volatility, potential lack of liquidity and potential
loss of their investment.
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Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies
the headings
risk, interest rate risk, credit risk, asset-backed
securities risks, below investment grade (high
yield or “junk” bonds) securities risks, and the
“Non-
risks described under
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
Each Account is subject to the risks associated
with the investments in the Account. Generally,
an Account will be subject to the risks associated
with the portfolio listed below that corresponds to
the investment objective of the Account or the
asset allocation strategy pursued by the Account.
risk,
common
stock
to other primary
risks,
risks,
foreign
to other primary
risks,
risks,
foreign
All Growth Portfolio. An All Growth Portfolio will
generally be invested in a manner that seeks to
provide growth of capital. All Growth Portfolios
have historically experienced high fluctuations in
annual returns and overall market value, typically
as a result of changes to market and economic
conditions. The Portfolio’s investments are subject
to a high risk of price declines, especially during
periods when stock markets in general are
declining. An All Growth Portfolio’s primary risks
generally include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities
risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, emerging market risks, fixed
income security risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
Growth with Income Portfolio. A Growth with
Income Portfolio will generally be invested in a
manner that seeks to provide moderate growth of
capital and some current income. Growth with
Income Portfolios have historically experienced
moderate fluctuations in annual returns and
overall market value, typically as a result of
changes to market and economic conditions and
interest rates. The Portfolio’s investments are
subject to a risk of price declines, especially
during periods when stock markets in general are
declining or when interest rates are rising. A
Growth with Income Portfolio’s primary risks
generally include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
upon
Portfolio’s
foreign
issuer and
investment
Capital Growth Portfolio. A Capital Growth
Portfolio will generally be invested in a manner
that seeks to provide growth of capital. Capital
Growth Portfolios have historically experienced
moderately high fluctuations in annual returns
and overall market value, typically as a result of
changes to market and economic conditions. The
Portfolio’s investments are subject to a risk of
price declines, especially during periods when
stock markets in general are declining. A Capital
Growth Portfolio’s primary risks generally include:
market risk, management and securities selection
risk, investment objective and asset allocation
risk, stock market risk, equity securities risk,
common stock risk, and capitalization risks.
Depending
specific
the
investments, the Portfolio may also be subject to
other primary risks, including investment style
risks,
risks,
emerging market risks, fixed income securities
Income with Growth Portfolio. An Income with
Growth Portfolio will generally be invested in a
manner that seeks to provide current income and
some growth of capital. Income with Growth
Portfolios have historically experienced moderate
fluctuations in annual returns and overall market
value, typically as a result of changes to interest
rates and market and economic conditions. The
Portfolio’s investments are subject to a risk of
price declines, especially during periods when
interest rates are rising or when stock markets in
general are declining. An Income with Growth
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
fixed income securities risk, interest rate risk,
credit risk, money market fund risk, stock market
risk, equity securities risk, common stock risk,
and capitalization risks. Depending upon the
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risks,
foreign
investments, the Portfolio may also be subject to
other primary risks, including foreign issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
Portfolio’s specific investments, the Portfolio may
also be subject to other primary risks, including
investment style
issuer and
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
to
to
perception
take advantage of
of market
economic
The
the
Portfolios
have
the
investments made,
to other primary
risks,
risks,
foreign
Conservative Income Portfolio. A Conservative
Income Portfolio will generally be invested in a
manner that seeks to provide current income.
Relative
the portfolios described above,
Conservative Income Portfolios have historically
experienced smaller fluctuations in annual returns
and overall market value as a result of changes in
stock market conditions, but have experienced
fluctuations in relation to changes in interest rates
and
Portfolio’s
conditions.
investments are subject to risk of price declines,
especially during periods when interest rates are
rising. A Conservative Income Portfolio’s primary
risks generally include: market risk, management
and securities selection risk, investment objective
and asset allocation risk, fixed income securities
risk, interest rate risk, credit risk, money market
fund risk, equity securities risk, and common
stock risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
income. Relative
to
fixed
income
security
Opportunistic Portfolio. An Opportunistic
Portfolio will generally be invested in a manner
that seeks to provide long term growth through
capital appreciation and/or income by utilizing an
active management style that shifts the amount
of investment made in different asset classes and
the
market sectors
manager’s
pricing
anomalies, those market or industry sectors
deemed favorable for investment by the manager,
the current interest rate environment and/or
other macro-economic trends identified by the
manager to achieve growth while accounting for a
client’s specific short, intermediate and long term
investment and/or cash flow needs. Depending
investment strategy used, some
upon
Opportunistic
historically
experienced high fluctuations in annual returns
and overall market value, typically as a result of
changes to market and economic conditions.
Depending upon the investment strategy used
and
the Portfolio’s
investments may be subject to a high risk of price
declines, especially during periods when stock
markets in general are declining. An Opportunistic
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, and capitalization risks. Depending
upon the Portfolio’s specific investments, the
Portfolio may also be subject to other primary
risks, including investment style risks, foreign
issuer and investment risks, emerging market
risks,
risks, below
investment grade (high yield or “junk” bonds)
securities risks, and the risks described under the
headings “Non-Traditional Assets and Complex
Investment
Strategies Risks” and “Complex
Product Risks” above.
interest
rates are
fixed
Capital Preservation Portfolio. A Capital
Preservation Portfolio will generally be invested in
a manner that seeks to preserve capital while
the
generating current
portfolios described above, Capital Preservation
Portfolios have historically experienced smaller
fluctuations in annual returns and overall market
value as a result of changes in stock market
conditions, but have experienced fluctuations in
relation to changes in interest rates and economic
conditions. The Portfolio’s investments are subject
to risk of price declines, especially during periods
rising. A Capital
when
Preservation Portfolio’s primary risks generally
include: market risk, management and securities
selection risk, investment objective and asset
allocation risk,
income securities risk,
interest rate risk, credit risk, and money market
fund risk. Depending upon the Portfolio’s specific
Additional Considerations. A client should note
that an Account pursuing a particular investment
objective or asset allocation strategy will from
time to time be subject to actual risks that are
higher or lower than, or different from, the risks
described above under certain circumstances. See
“Investment Strategies—Important Information
about Implementation of Investment Objectives
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priorities,
changes
in
a combination of economic, political, and broader
macroeconomic developments. Conditions across
major economies have been influenced by shifting
geopolitical
policy
relationships, and evolving investor expectations.
and Investment Strategies” above for more
information. In addition to the specific risks
described above, a client’s Account may be
subject to additional risks, depending upon the
particular investments in the client’s Account. A
client should discuss the risks of particular
investments with the client’s PAM Consultant. A
client should also note that there is no guarantee
as to how an Account will perform in the future. It
is possible that an Account could experience more
dramatic return or market value fluctuations than
occurred in the past.
Available Investment Product Risks
that Baird
establishes
for
Within the United States, the current U.S.
intent on
administration has demonstrated
implementing policy changes through executive
orders and legislation, contributing to a less
certain policy environment. Potential adjustments
to federal programs, regulatory initiatives, and
legislative priorities create additional factors for
markets to assess, which may cause meaningful
inflation reduction
market uncertainty. While
remains a central
for policymakers,
focus
achieving the U.S. Federal Reserve Board’s long
term inflation target of 2% continues to prove
challenging. Although annual price increases have
generally moderated, the price of many goods
and services remains elevated compared to levels
from a few years ago. Leadership changes at the
Federal Reserve and political divisions and discord
add further uncertainty to the economic outlook.
less
if an Available
Product
experiences
organizational,
is a higher risk
that
Internationally, geopolitical risks have increased
as the U.S. and Israel are engaged in a military
conflict with Iran. The conflict has disrupted
global trade and caused an increase in the price
of oil. The continuation or escalation of military
strikes could lead to a lengthy period of military
conflict, and Iran’s military attacks and other
hostile actions against other countries present a
risk of widening the conflict. In addition, the war
between Ukraine and Russia is now passing its
fourth anniversary, instability in parts of the
Middle East persist, and relations between the
U.S. and other countries are strained.
Product
that
experiences
the
list of
Rapid advancements in artificial intelligence (AI)
and automation are increasingly influencing global
economic trends, corporate decision making, and
financial market dynamics. Expanding investment
in these technologies is contributing to shifts in
how industries operate, compete, and allocate
resources. The fast pace of technological change,
potential disruptions to existing business models,
and evolving regulatory responses
introduce
additional uncertainty and may contribute to
market volatility.
The use of Available Investment Products,
including SMA Strategies made available under
the BSN and DC Programs, are subject to
additional risks compared to the use of Baird
recommended
investment products. Available
Investment Products are investment products that
generally do not meet the qualifications and
its
standards
recommended product lists. As a result, there is a
higher likelihood that some Available Investment
Products will have poor performance and will
to an
significantly underperform compared
applicable benchmark
index or peer group.
Available Investment Products are also subject to
significantly
review by Baird
rigorous
compared to recommended investment products.
Investment Product
Thus,
experiences significant performance problems or
if the manager or sponsor of an Available
Investment
significant
management,
operational,
compliance, legal, regulatory or other problems,
there
the Available
Investment Product will be made available (and
will continue to be made available) to clients by
Baird. An investment by a client in an Available
Investment
the
occurrence of any such event could negatively
impact the client’s Account. Available Investment
Products should only be used by a client if the
client wishes to take more responsibility for
monitoring and managing the assets in the
client’s Account,
recommended
products does not contain an investment product
that meets the client’s particular needs, and the
client understands the risks of doing so.
Recent Events
Taken together, these developments may have a
significant negative impact upon global economic
conditions and contribute to a heightened risk
financial markets have continued to
Global
experience periods of elevated volatility, driven by
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environment. As a result, fluctuations in asset
prices may increase, and such volatility could
adversely affect the value of a client’s Account .
taken against
the
reasonably designed to ensure compliance with
applicable securities laws, regulations and rules.
Baird was censured and fined $200,000. The
firm
disciplinary action
supervisor did not relate to PAM or its business
operations.
certain of
the
its
Disciplinary Information
In April 2016, Baird, without admitting or denying
the findings, consented to the sanctions and
findings of the Financial Industry Regulatory
Authority, Inc. (“FINRA”) that it violated NASD
Conduct Rule 3010, FINRA Rule 3110, and FINRA
Rule 2010, by failing to establish and maintain a
supervisory system and procedures reasonably
designed to ensure that customers who purchased
mutual fund shares received the benefit of
applicable sales charge waivers. In May 2015,
Baird began a review to determine whether Baird
had provided available sales charge waivers to
eligible customers. Based on this review, in May
2015, Baird self-reported to FINRA that various
eligible customers had not received available
sales charge waivers. Baird was found to have
retirement plan and
disadvantaged certain
charitable organization customers
that were
eligible to purchase Class A shares in certain
mutual funds without a front-end sales charge.
The findings also stated that these customers
were instead sold Class A shares with a front-end
sales charge or Class B or C shares with higher
ongoing fees and the potential application of a
contingent deferred sales charge. Baird was
censured and required to pay restitution to
affected customers estimated to be approximately
$2.1 million including interest.
to adopt or
to
designed
provide
to Baird’s clients and
supervisor within
In September 2016, the SEC announced that
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
subadvisors
participating in Baird’s wrap fee programs offered
through
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
implement policies and
failed
procedures
specific
financial
information
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. Baird also was ordered to cease
and desist committing or causing any violations
and any future violations of Section 206(4) of the
Advisers Act and Rule 206(4)-7 thereunder and
pay a civil money penalty in the amount of
$250,000.
In July 2016, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that the firm and a
its Private Wealth
firm
Management business did not
reasonably
supervise a former Financial Advisor who misused
a customer’s funds. The findings stated that the
supervisor did not reasonably follow-up on red
flags associated with a trade correction request
submitted by the Financial Advisor that should
have alerted him to the Financial Advisor's misuse
of a customer’s funds. The supervisor also did not
follow certain of Baird’s written supervisory
procedures (“WSPs”) relating to trade corrections.
After the supervisor realized that the Financial
Advisor misused the customer’s funds, Baird
reimbursed the customer for the loss. The
findings also included that Baird did not establish
and maintain a supervisory system, including
WSPs, for correcting trade errors that was
In March 2019, Baird, without admitting or
denying the findings, consented to an order of the
SEC, which found that it violated Sections 206(2)
and 207 of
for making
the Advisers Act
inadequate disclosures to advisory clients about
mutual fund share classes. The order was part of
a voluntary self-reporting program initiated by the
SEC called the “Share Class Selection Disclosure
the program,
(or SCSD)
Initiative.” Under
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it charged
supervisory
system
firms bought
fees and/or
the conflict of
commission when
its published
minimum commission amount of $100 on 7,277
retail equity trades and failed to establish and
reasonably
maintain a
designed to prevent charging a customer a
commission that is unreasonable or unfair in
violation of FINRA Rules 3110, 2121, and 2010.
Baird also consented to a censure, a fine in the
amount of $150,000, and the payment of
restitution of $266,481 plus interest. The findings
related to FINRA’s routine examination of Baird in
2020. During that examination, Baird modified its
minimum commission schedule and supervisory
procedures. Baird also took steps to make
payments to the affected customers, which on
average amounted 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.
its
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 settlement terms imposed by the
SEC,
including returning money to affected
investment advisory clients. The central issue
identified by the SEC was that, in many cases,
for or
investment advisory
recommended to their investment advisory 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
advisory clients, and the investment advisory
firms did not adequately disclose their receipt of
12b-1
interest
associated with those 12b-1 paying share classes.
Baird and many other firms self-reported under
the program and entered
into substantially
identical orders. By self-reporting and consenting
to the order, Baird agreed to a censure and to
cease and desist from committing or causing any
violations and future violations of Sections 206(2)
and 207 of the Advisers Act. Baird also agreed to
establish a distribution fund and to deposit into
that fund the improperly disclosed 12b-1 fees
received by Baird plus prejudgment interest,
which will be paid to affected advisory clients.
More information about the order is contained in
Baird’s Form ADV, which is available on the SEC’s
Investment Advisory Public Disclosure website at
https://www.adviserinfo.sec.gov/IAPD/Default.as
px or in the SEC’s press release about the SCSD
Initiative at https://www.sec.gov/news/press-
release/2019-28.
other
reports about an
reports was engaged
to disclose
In June 2019, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that between late
April 2013 and early July 2013 it published
research
issuer without
disclosing that the research analyst who authored
the
in employment
discussions with the issuer that constituted an
actual, material conflict of interest and that the
failure
research analyst’s
the
employment discussions with the issuer in the
research reports made those reports misleading.
Baird was censured and fined $150,000.
the
In September 2023, Baird entered into an Offer of
Settlement with the SEC, 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
business-related
associates’
supervise
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
text and
properly retaining business-related
instant messages
off-channel
and
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.
While Baird had policies and procedures in place
prohibiting such off-channel communications, 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
findings were
adviser businesses, and
reported to the SEC. Baird took steps prior to and
after the SEC’s review, including implementing a
new communication tool designed
for Baird
associates’ personal devices, conducting training,
and periodically requiring requisite associates to
In August 2022, Baird, without admitting or
denying the findings, consented to the entry of
findings of FINRA, which found that it charged
unfair
certain
brokerage
customers
an
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communications. As part of
Certain Relationships and Arrangements
Baird and Associated Parties
including
for eligible
the
those
amount
the
training,
provide an attestation relating to their business-
related
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,
surveillance program,
technology solutions and similar matters related
to off-channel communications.
timing
of
state
investment
Financial
Advisors
located
Baird PWM has relationships or arrangements with
other Baird businesses units and the Associated
Parties described below,
referral
programs that pay special compensation to PAM
referrals. Additional
Consultants
referral programs,
information about
including
referral
of
compensation, is disclosed on Baird’s website at
bairdwealth.com/retailinvestor.
These
relationships or arrangements present a conflict of
interest because they provide a financial incentive
to Baird and PAM Consultants to use, select or
recommend the investment products and services
of Baird and Associated Parties over those of
unassociated parties and those that pay the
greatest level of compensation. Baird addresses
this potential conflict through disclosure in this
Brochure. Further, when acting as fiduciaries,
Baird and PAM Consultants are required to select
or recommend investment products only when
they determine it to be in the client’s best interest
to do so.
Baird Asset Management
In March 2026, Baird entered into an Offer of
Settlement with the Massachusetts Securities
Division to settle a regulatory matter relating to
the
adviser
representative registration approvals for two of
Baird’s
in
Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals
provided investment advisory services before
their Massachusetts registrations were completed
as a form was missing from their application
materials. 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.
Baird’s Asset Management business, Baird
Advisors, Baird Equity Asset Management, and
Chautauqua Capital Management (“CCM”), part of
provide
Baird Equity Asset Management,
investment management services to institutional
clients and Funds. PAM Consultants may refer
clients to Baird Asset Management.
Baird Funds
Additional information about Baird’s disciplinary
history is available on the SEC’s website at
www.adviserinfo.sec.gov.
including
Baird is the investment adviser and principal
underwriter for Baird Funds, Inc. (the “Baird
Funds”). Baird Advisors provides
investment
management, administrative, and other services
to certain Baird Funds investing primarily in fixed
income securities (the “Baird Bond Funds”). Baird
Equity Asset Management and CCM provide
investment management and other services to
certain Baird Funds investing primarily in equity
securities (the “Baird Equity Funds”), and
Greenhouse Funds LLLP, a party related to Baird,
is the investment subadvisor to one of those
Funds, the Baird Equity Opportunity Fund. PAM
Consultants may refer clients to the Baird Funds.
Baird Trust
Baird is affiliated, and may be deemed to be
under common control, with Baird Trust, a
Other Financial Industry Activities and
Affiliations
Baird’s Broker-Dealer Activities
Baird PWM offers brokerage accounts and related
services to its clients. Baird is also engaged in a
broad range of broker-dealer activities through
its Global
other business units,
Investment Banking, Fixed
Income Capital
Markets (including Baird Public Finance) and
Institutional Equities and Research Departments.
Certain PAM and Baird associates and certain
management persons of Baird are registered, or
have an application pending to register, as
registered representatives and associated persons
of Baird to the extent necessary or appropriate to
perform their job responsibilities.
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engaging
Trust
for
Services
Kentucky-chartered trust company, because both
entities are indirectly wholly owned by BFG. Baird
and PAM Consultants receive compensation from
Baird Trust for referring clients and providing
ongoing relationship management services to
clients
trust
Baird
administration services as described under the
heading “Advisory Business—Additional Service
Arrangements”
Information—Trust
above.
Baird Capital
underwriting opportunity receives a portion of the
compensation earned by Baird Public Finance on
that opportunity. Baird and PAM Consultants thus
have an incentive to recommend the securities
issued in those offerings. A PAM Consultant who
refers a corporation
to Baird’s Institutional
Equities business for a stock buy-back program
receives a portion of the commissions earned by
Baird’s Institutional Equities business. Baird and
its PAM Consultants may, therefore, have an
incentive to buy, and to recommend that clients
sell, the securities of issuers that are part of
Baird’s buyback services.
Sagard
Baird is engaged in a global private equity
business through Baird Capital (“Baird Capital”).
Baird and PAM Consultants may refer clients to
Baird Capital. PAM Consultants who assist in
obtaining a client’s investment in a private equity
fund offered through Baird Capital are eligible for
referral compensation.
Baird has a financial incentive to the extent it
would recommend that a client invest in a
portfolio company owned by a Baird Capital
private equity fund. A list of the portfolio
companies held by Baird Capital private equity
funds is located on Baird Capital’s website located
at https://www.bairdcapital.com/portfolio/baird-
capital-portfolio.aspx.
additional
compensation
Baird Global Investment Banking
Baird Institutional Equities and Research
Baird Public Finance
Sagard-affiliated
its Global
information
Baird’s direct parent corporation, BFC, has a
minority ownership interest (about 5%) in Sagard
Holdings Management, Inc. (“Sagard”) and the
right to appoint a member to Sagard’s board of
directors, which
is currently a management
person of Baird. Baird has agreed to use best
efforts, to the extent consistent with its fiduciary
duties, best
interest obligations, and other
regulatory responsibilities, to offer to clients
investment products managed by affiliates of
Sagard. Baird has an incentive to do so because
not reaching minimum thresholds would give
Sagard a right to redeem BFC’s ownership
interest
in Sagard and reaching significant
thresholds would give BFC the right to increase its
ownership interest. PAM Consultants do not
receive
for
any
investment
recommending
products. Additional
identifying
Sagard-affiliated
investment products will be
provided to clients prior to investment.
municipal
advisory,
55ip
55I, LLC (d/b/a 55ip, “55ip”) uses research and
other services from Riverfront, an affiliate of
Baird, in the development of its portfolios under
the BSN Program, and Riverfront
receives
compensation from 55ip with respect to those
portfolios. Due to its affiliation with Riverfront,
Baird has a financial incentive to favor 55ip
portfolios that use Riverfront services.
Through
Investment Banking,
Institutional Equities and Research, and Public
Finance Businesses, Baird provides investment
banking,
securities
underwriting, stock buyback and related services
to various corporate, municipal, and other issuers
of securities. Baird receives compensation from
such issuers in connection with the services it
provides, and the success of its services generally
depends upon Baird’s ability to sell the securities
of such issuers. Baird may, therefore, have an
incentive to favor the securities of issuers for
which Baird provides such services over the
securities of issuers for which Baird does not
provide such services.
Associated Investment Products and
Services
A PAM Consultant who refers a client to Baird
Investment Banking for a possible transaction in
which Baird Investment Banking earns a financial
advisory or underwriting fee receives a portion of
such fee. A PAM Consultant who refers a client to
Baird Public Finance for a municipal advisory or
Baird and PAM Consultants may select or
recommend Associated Investment Products and
Services, including the Associated Funds and
Associated SMA Strategies, listed in Appendix A to
this Brochure.
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Brochure. Further, when acting as fiduciaries,
Baird and its PAM Consultants are required to
select or recommend investment products only
when they determine it to be in the client’s best
interest to do so. The criteria used by them in
deciding to select or recommend Associated
Investment Products are generally the same as
those used for unassociated investment products.
However, a client should note that certain
Services and certain categories of investment
products only offer investment products and
services of Associated Parties. In those cases,
Baird and PAM Consultants do not impose the
same criteria or level of review.
including
Certain Associated Parties are associated with
Baird because BFC, Baird’s parent corporation,
owns some or all of the Associated Parties’ voting
securities. BFC’s parent corporation (and Baird’s
ultimate parent corporation), BFG, may be
deemed to indirectly own or control such voting
securities. Baird is deemed to be under common
control and “affiliated” with an Associated Party
when BFG indirectly owns or controls 25% or
more of such Associated Party’s voting securities
(or of an entity deemed
to control such
Associated Party). Baird considers itself “related”
to an Associated Party when BFG indirectly owns
or controls at least 10% but less than 25% of
such Associated Party’s voting securities (or of an
entity deemed to control such Associated Party).
Baird considers
itself “associated” with an
Associated Party when certain other relationships
or other arrangements exist between Baird and
such Associated Party that might present a
conflict of interest with clients.
An Associated Party receives fees or other
compensation for investment advisory or other
services that it provides to an Associated Fund.
The amount of fees and other compensation paid
by an Associated Fund to an Associated Party is
disclosed in the Associated Fund’s prospectus or
other offering document. An Associated Party also
receives fees from a client for services that it
provides related to the client’s Associated SMA
Strategy. Information about the amount of fees
paid to an Associated Party with respect to an
SMA Strategy is contained in the applicable Baird
Form ADV Part 2A Brochure, the applicable
Program Account Schedule, or in some instances,
the client’s contract with the Associated Party.
Relationships and Arrangements with
Investment Managers
Investment
those
managers,
participating in the Services, may select Baird, in
its capacity as a broker-dealer, to execute
portfolio trades for their clients, including for
Funds they advise and in which Baird clients
invest. Investment managers may also select
Baird to provide custody, research or other
services. Baird receives compensation for those
services. This may create an incentive for Baird to
favor the investment products and services of
such investment managers. However, Baird is a
fiduciary that is required to act in the best
interest of advisory clients when selecting or
recommending investment managers or their
investment products and services to such clients.
Baird addresses this potential conflict through
disclosure in this Brochure. Baird does not
consider the extent to which an investment
manager directs or is expected to direct trading,
custody or research services to Baird when
considering
investment
the eligibility of an
manager or its investment products or services
for the Services.
incentive
to
favor
the
Code of Ethics, Participation or
Interest in Client Transactions and
Personal Trading
Code of Ethics
Subject to the restrictions described below, Baird
and its affiliates and associates may engage in
securities transactions for their own accounts,
including the same or related securities that are
recommended to or owned by Baird clients. These
transactions may include trading in securities in a
manner that differs from, or is inconsistent with,
the advice given to Baird clients, and the
Baird and PAM Consultants have a financial
incentive to use, select or recommend Associated
Investment Products and Services because Baird
and BFG benefit financially if a client utilizes those
investment products and services rather than
unassociated investment products and services,
and PAM Consultants benefit financially from the
overall success of Baird and BFG. Similarly, Baird
and PAM Consultants also generally have a
financial
investment
products and services of Baird over Associated
Parties and to favor those of Associated Parties in
which BFG has a materially greater indirect
ownership interest over those of Associated
Parties in which BFG has a materially lesser
indirect ownership interest. Baird addresses this
this
potential conflict
through disclosure
in
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transactions may occur at or about the same time
that such securities are recommended to or are
purchased or sold for client accounts. This creates
a potential for a conflict between the interest of
clients and the interests of Baird and its affiliates
and associates.
account to a client rather than a brokerage
account if the client has, or is expected to have,
lower levels of trading activity in the client’s
account. Select clients may pay a fixed dollar fee,
which presents a conflict in that such fee does not
give the PAM Consultant an incentive to make
recommendations that could benefit the client’s
account, or a performance or incentive fee, which
presents a conflict because it gives the PAM
Consultant an incentive to recommend riskier
investments in order to achieve the level of
performance in the account that would result in
payment of the fee.
Commission-Based Fee Arrangements present a
conflict of interest because it gives Baird and the
client’s PAM Consultant an incentive to trade
actively for the client’s Account, or recommend or
select Other Managers that trade actively, and to
provide advice based upon the compensation
received rather than on a client’s needs. See
Fees—
and Compensation—Advisory
“Fees
Calculation and Payment of Advisory Fees—
Commission-Based Fee Arrangements” above for
more information.
or
by
Baird’s
Accounts and Investments Provide Different
Levels of Compensation
To address the potential for conflicts of interest,
Baird has adopted a Code of Ethics (the “Code”)
that applies to
its associates that provide
investment advisory services to clients, including
PAM Consultants, their supervisors, and certain
to non-public
associates who have access
information relating to advisory client accounts
(“Access Persons”). The Code prohibits Access
Persons from using knowledge about advisory
client account transactions to profit personally,
directly, or indirectly, by trading in his or her
personal accounts. The Code also generally
prohibits Access Persons
from executing a
security transaction for their personal accounts
during a blackout period one business day before
or after the date that a client transaction in that
same security is executed. The Code provides for
certain exceptions deemed appropriate by Baird
management
Compliance
Department. In addition, orders for the accounts
of Access Persons and other Baird associates that
are under discretionary management by Baird
may be aggregated with orders for other Baird
client accounts, so long as the order is executed
as part of a block transaction with client orders. A
copy of the Code is available to clients or
prospective clients upon request.
The types of accounts and investment products
offered
to clients provide Baird and PAM
Consultants different levels of compensation.
Baird and PAM Consultants have an incentive to
generate revenues
from client accounts by
selecting and recommending account types and
investment products that will provide them the
greatest level of compensation.
Recommendations of Associated Investment
Products and Services
the
Baird has also implemented certain policies and
procedures relating to Baird’s and its associates’
trading activities that are designed to prevent
them from improperly benefiting from the trading
activities of Baird’s advisory clients. In addition,
Baird’s Compliance Department monitors the
personal trading activities of all of Baird’s
associates providing advisory-related services to
clients.
Relationships
and
Participation or Interest in Client
Transactions
Investment Advisory Accounts
website
Baird and PAM Consultants have an incentive to
use, select or
investment
recommend
products and services of Associated Parties
because they will benefit financially. See “Other
Financial Industry Activities and Affiliations—
Certain
Arrangements—
Associated Investment Products and Services”
above and “Certain Parties Associated with Baird”
on
at
Baird’s
bairdwealth.com/retailinvestor.
Referral Compensation Paid to PAM Consultants
Asset-based Advisory Fee arrangements create an
incentive for Baird and PAM Consultants to set the
applicable fee rate at a high level and to
encourage clients to add more money into their
accounts. Baird and PAM Consultants also have an
incentive to recommend an investment advisory
PAM Consultants receive additional compensation
for referring clients to certain Associated Parties
described above. See “Other Financial Industry
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applicable fund. If any rebated fees remain in a
client’s Account at the time of billing, those
rebated amounts will be included in the Account
assets subject to the Advisory Fee.
Service
Activities and Affiliations—Certain Relationships
and Arrangements—Baird and Associated Parties”
above. PAM Consultants also receive additional
compensation for referring clients to unaffiliated
banks that make loans to clients under Baird’s
Securities-Based Lending Program. See “Advisory
Business—Additional
Information—
Securities-Based Lending Program” above. Such
compensation gives PAM Consultants an incentive
to recommend or refer clients to those Associated
Parties and to recommend that a client participate
in the Securities-Based Lending Program. For
more information about referral compensation
paid to PAM Consultants and related conflicts of
interest, please see “Baird Referral Programs” on
Baird’s website at bairdwealth.com/retailinvestor.
Ongoing Product Fees
If Baird receives 12b-1 fees with respect to
mutual fund shares that are designated as
unbillable assets in a client’s Account, Baird will
retain such 12b-1 fees. This presents a conflict of
interest because it provides Baird and its PAM
Consultants an
incentive to use, select or
recommend mutual fund shares that pay greater
12b-1 fees. Baird addresses this conflict by
adopting a Mutual Fund Share Class Policy
described above and by adopting internal policies
that limit the circumstances under which mutual
fund investments in client accounts can be
designated as unbillable assets and 12b-1 fees
can be retained.
receives ongoing
fees
Marketing Support and Revenue Sharing from
Mutual Fund and UIT Sponsors
invested
in
Baird
from certain
investment products that are purchased and held
in client Accounts. Those fees, such as distribution
(12b-1) and/or service fees (“12b-1 fees”) from
mutual funds, are based on the value of client
assets
those products. A PAM
Consultant’s compensation increases as those
fees increase. Thus, Baird and PAM Consultants
have an incentive to use, select or recommend
such products and to recommend such products
that pay the greatest ongoing fees.
Certain mutual funds charge 12b-1 fees, which
are paid to Baird. Baird receives 12b-1 fees on an
ongoing basis as compensation for the services
Baird provides to the applicable mutual fund. The
12b-1 fees paid by a mutual fund are disclosed in
the mutual fund’s prospectus.
Baird receives marketing support or revenue
sharing payments (“marketing support”) from the
sponsors and investment advisers of certain
mutual funds. These payments, which are based
on sales of, or client assets invested in, such
funds, are intended to compensate Baird for
providing marketing, distribution and other
services for the mutual funds. Marketing support
is not paid by sponsors or investment advisers of
mutual funds on mutual fund assets held in
investment advisory Retirement Accounts to the
extent prohibited by applicable
law. Baird
received marketing support payments over the
past two calendar years from the sponsors or
investment advisers of Alliance Bernstein Funds,
American Funds, Franklin Templeton Funds,
Goldman Sachs Funds, Hartford Funds, Invesco
Funds, John Hancock Funds, JPMorgan Funds,
Lord Abbett Funds, MFS Funds, PIMCO Funds and
Principal Funds. Baird also generally receives
marketing support related to the sale of units of
UITs. Sponsors of UITs typically make marketing
or concession payments to the firms that sell their
UITs,
including Baird. These payments are
typically calculated as a percentage of the total
volume of sales of the sponsor’s UITs made by
firm during a particular period. That
the
percentage typically increases as higher sales
volume levels are achieved. Descriptions of these
additional payments are provided in a UIT’s
prospectus. UIT sponsors that have paid volume
concessions to Baird over the past two calendar
Baird generally does not allow mutual funds with
12b-1 fees to be purchased for PAM Service
Accounts. If Baird receives 12b-1 fees from a fund
with respect to a client’s mutual fund investment
in the client’s Account and the client’s Account is
subject to an asset-based fee arrangement, Baird
either: (1) rebates such 12b-1 fees to the client’s
Account if the client is paying an asset-based
Advisory Fee on such investment; or (2) excludes
such fund shares from the calculation of the
client’s asset-based Advisory Fee (sometimes
referred to as “unbillable assets”) for such period
of time that Baird collects and retains the 12b-1
fee. 12b-1 fees rebated to a client’s Account are
estimated based on the average daily balance of
the mutual fund shares in the Account and the
annual rate of the 12b-1 fee paid by the
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Baird Conference Sponsorships
Trust
Portfolios
and
funds,
the opportunity
Please
see
seminars
supporting Baird
Please
see
years include Advisors Asset Management (AAM),
First
Guggenheim
Investments. Receipt of marketing support
payments from sponsors and investment advisers
of mutual funds and UITs provides Baird an
incentive to use, select and recommend such
mutual funds and UITs and to favor mutual funds
and UITs with sponsors or investment advisers
that make the greatest levels of such payments.
Baird does not share these payments with PAM
Consultants.
“Revenue
Sharing/Marketing Support and Other Third Party
Payments” at bairdwealth.com/retailinvestor for
more information.
Schwab Clearing Arrangement
Baird hosts a number of seminars and
conferences for PAM Consultants in any given
year, including Baird’s PWM Symposium, which
gives sponsors of investment products, such as
mutual
to make
presentations at, and contribute money toward
the cost of, such seminars and conferences. This
presents a conflict of interest in that it gives Baird
an incentive to promote or market the sponsors’
investment products in order to persuade them to
continue
and
“Revenue
conferences.
Sharing/Marketing Support and Other Third Party
Payments” at bairdwealth.com/retailinvestor for
more information.
PAM Consultants Receive Benefits from Product
Providers
Party
Payments”
for
PAM Consultants generally receive non-cash
compensation and other benefits from Baird and
from sponsors of investment products with which
Baird does business. Such non-cash compensation
and other benefits may include invitations to
attend conferences or educational seminars,
payment of related travel, lodging and meal
expenses, and receipt of gifts and entertainment.
For example, PAM Consultants are invited to
educational conferences hosted by sponsors of
mutual funds, annuities and other investment
products, with the costs associated with such
conference (including travel and lodging) paid by
the sponsors. In addition, PAM Consultants hold
client events with some or all of the costs of such
events paid by sponsors of investment products.
Product sponsors may also provide gifts and
entertainment in connection with those or other
events. These benefits present a conflict of
interest in that they give PAM Consultants an
incentive to use, select or recommend investment
products and their sponsors that provide the
greatest levels of such benefits. Please see
“Revenue Sharing/Marketing Support and Other
at
Third
bairdwealth.com/retailinvestor
more
information.
Cash Sweep Program
Program
Baird
Baird has a clearing arrangement with Charles
Schwab & Co., Inc. (“Schwab”) whereby Schwab
maintains an omnibus account with certain
mutual fund families for Baird on behalf of Baird
clients. Under the clearing arrangement, Schwab
provides clearing services for most “no load”
funds and “load” funds held by Baird clients.
Although Baird pays Schwab a fee for its clearing
and omnibus services, Schwab generally passes
through to Baird the shareholder servicing fees
that Schwab receives from the funds. Shareholder
servicing fees are not paid by Schwab on mutual
fund assets held in Retirement Accounts to the
extent prohibited by applicable law. The amount
of the shareholder servicing fees paid to Baird is
based on the value of the client assets invested in
those funds. However, the shareholder servicing
fee rate varies based on the type of fund (load or
no load), the value of client assets in those funds,
and the relationship that Schwab has with those
funds (whether or not Schwab receives payments
from those funds or their sponsors, and the rates
of such payments). As a result, Baird has an
incentive to use, select or recommend mutual
funds from which Baird would receive higher
payments from Schwab. However, Baird generally
does not compensate PAM Consultants based
upon the amounts Baird receives from Schwab
except with respect to amounts attributable to
sales loads and 12b-1 fees that Baird would
otherwise receive directly from a fund if it were
not for the existence of the clearing arrangement
with Schwab. If Baird receives 12b-1 fees from
Schwab with respect to a mutual fund investment
in a client’s Account, Baird rebates or retains such
fees as further described under the heading
“Ongoing Product Fees” above.
Baird has an incentive to have clients participate
and maintain significant balances in Baird’s Cash
Sweep
receives
because
substantial compensation on client cash balances
that are automatically swept into bank deposit
accounts and invested in money market mutual
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
funds under the program. Please see “Advisory
Business—Additional Service Information—Cash
Sweep Program” above
for more detailed
information.
Trust Services Arrangements
Consultant
receive
firm
and
to
for
it
them. Please see
Baird and PAM Consultants have an incentive to
recommend that a client retain Baird Trust for the
client’s trust services needs rather than an
unassociated
recommend
arrangements that involve Baird and the PAM
Consultant providing investment advisory services
to the client and Baird Trust only providing trust
is more
administration services because
profitable
“Advisory
Business—Additional Service Information—Trust
Services Arrangements” above for more detailed
information.
Margin Loans
to
recommend
revenue
is recurring, more predictable and
typically greater than the revenues Baird earns,
and the compensation PAM Consultants receive,
from brokerage accounts. In addition, because
Advisory Fees are paid by a client regardless of
the trade activity in the client’s advisory Account,
Baird will receive greater revenue, and the client’s
PAM
greater
will
compensation, from a low trade-activity advisory
Account than from a low trade-activity brokerage
account. Baird and PAM Consultants thus have an
incentive to recommend an investment advisory
Account to a client rather than a brokerage
account if the client has, or is expected to have,
lower levels of trading activity in the client’s
account. However, because Baird’s revenues and
the compensation paid to PAM Consultants from
brokerage accounts increase as the level of
trading increases, Baird and PAM Consultants
have an incentive to recommend a brokerage
account to a client rather than an investment
advisory Account if the client has, or is expected
to have, significant trading activity in the client’s
account. PAM Consultants also have a financial
incentive
certain wealth
management services, such as financial planning.
Please see “Fees and Compensation—Advisory
Fees—Advisory Fee Payments to Baird, PAM
Consultants and Investment Managers” above for
more detailed information.
Account Transfers and New Accounts
Baird has an incentive to recommend that a client
use margin because Baird receives interest on
client margin
loans, and Baird and PAM
Consultants also have an incentive to recommend
that a client use margin, because a margin loan
allows the client to make larger and more
securities purchases. It also increases the value of
a client’s Account and thus the Advisory Fee
associated with that Account because the margin
loan is not deducted for purposes of calculating
the fee. Please see “Advisory Business—Additional
Service Information—Margin Loans” above for
more detailed information.
Securities-Based Lending Program
for
Baird and a client’s PAM Consultant have an
incentive to recommend that the client transfer
the client’s accounts to Baird and establish new
accounts with Baird (including IRA rollovers)
because doing so will result in increased revenues
to Baird and compensation
the PAM
Consultant.
PAM
Consultants
receive
Recommendations to Open Different Types of
Accounts
Service
Baird and PAM Consultants have an incentive to
recommend that a client participate in Baird’s
Securities-Based Lending Program because Baird
referral
and
compensation and such loans allow a client to
keep more assets in the client’s Accounts, which
result in more advisory fees for us and paid to the
client’s PAM Consultant. Please see “Advisory
Information—
Business—Additional
Securities-Based Lending Program” above for
more detailed information.
Investment Advisory and Brokerage Account and
Service Recommendations
to
clients
rather
Baird and PAM Consultants generally have a
financial incentive to recommend investment
advisory Accounts
than
brokerage accounts because Advisory Fee
Baird and PAM Consultants have an incentive to
recommend that a client open different types of
accounts with Baird, such as individual accounts,
IRA rollovers, joint accounts, 529 plan accounts
and UGMA/UTMA accounts, because if a client has
different types of accounts with Baird, the client
brings more of the client’s investable assets to
Baird, on which fees can be generated, thereby
increasing Baird’s revenues and the client’s PAM
Consultant’s compensation. Also, if a client has
more account types with Baird, the client is
statistically more likely to maintain the client’s
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
relationship with Baird and the client’s PAM
Consultant for longer periods of time.
Baird Stock Ownership
invest
(or their spouses, partners or family members)
may have a position as an officer or director of a
company or issuer whose securities are offered
and sold to clients. In such cases, Baird and/or a
client’s PAM Consultant will have an incentive to
recommend that the client
in those
companies.
PAM Consultants Transferring to Baird
that
increase
the
Fees—Advisory
A PAM Consultant joining Baird from another firm
has an incentive to recommend that a client to
transfer the client’s accounts from such firm to
Baird because doing so will increase the PAM
Consultant’s compensation. Please see “Fees and
Compensation—Advisory
Fee
Payments
to Baird, PAM Consultants and
Investment Managers” above for more detailed
information.
Principal Trading
with
Baird,
even
if
Most PAM Consultants own common stock of BFG,
Baird’s ultimate parent, and when offered the
opportunity to buy BFG stock they usually do so.
The amount of BFG stock that a PAM Consultant
may purchase is based in part on the PAM
Consultant’s total production level. A client’s PAM
incentive to make
Consultant thus has an
recommendations
PAM
Consultant’s total production on the client’s
accounts with Baird. Moreover, revenues from
Baird’s PWM department,
in which PAM
Consultants operate, contribute substantially to
BFG’s overall revenues and profitability, and the
performance of BFG’s stock price is largely due to
the profitability of Baird’s PWM department. As a
result, a client’s PAM Consultant’s ownership of
BFG stock creates a financial incentive to make
recommendations to the client that increase the
amount of revenues generated from the client’s
accounts
those
recommendations will not increase the PAM
Consultant’s production, so as to increase the
revenues and profitability of Baird’s PWM
department and thus of BFG, which will serve to
grow the value of the BFG stock. For example,
ownership of BFG stock, the performance of which
is impacted by the success of Associated Parties,
provides a client’s PAM Consultant an incentive to
use, select or recommend Associated Investment
Products and Services to a client even though
such recommendation does not increase the
client’s PAM Consultant’s production.
Business—Additional
Other Client Relationships
Baird and PAM Consultants have an incentive to
execute a trade for a client on a principal basis.
The compensation that Baird and PAM Consultants
receive on principal trades, such as a markup or
markdown, is often higher than the compensation
they receive when executing trades as agent,
such as commissions. The compensation received
by Baird and PAM Consultants is in addition to the
asset-based Advisory Fee a client pays on the
client’s advisory Accounts. Thus, Baird and PAM
incentive to trade as
Consultants have an
principal rather than as agent. Principal trades
also allow Baird to sell securities from Baird’s
account that Baird deems undesirable and to buy
securities for Baird’s account that Baird deems
desirable. For more information, please see
“Advisory
Service
Information—Trading for Client Accounts—Trade
Execution Services Performed by Baird—Principal
Trades” above.
Baird Underwritten Offerings
Certain client accounts overseen by Baird and
PAM Consultants may have similar investment
objectives and strategies but may be subject to
different fee schedules or commission rates. Thus,
Baird and its PAM Consultants have an incentive
to favor client accounts that generate a higher
level of compensation.
Relationships with Issuers of Securities
in companies or
Baird and PAM Consultants have an incentive to
recommend that clients purchase securities in
offerings underwritten by Baird because the
underwriting compensation that Baird and PAM
Consultants will earn on those offerings tends to
be higher than the compensation they would
normally receive if clients were to buy them in the
secondary market, and because the profitability of
underwritten offerings to Baird depends upon
Baird’s ability to sell the securities allocated to
Baird in the offering.
From time to time, Baird may have proprietary
issuers whose
investments
securities are offered and sold to clients, a PAM
Consultant or another Baird associate may have
significant investments in companies or issuers
whose securities are offered and sold to clients, or
a PAM Consultant or another other Baird associate
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Allocations of IPOs and Other Public Offerings
Relationships
received by Baird and Baird Financial Advisors.
See “Other Financial Industry Activities and
Affiliations—Certain
and
Arrangements—Baird and Associated Parties”
above.
PAM Consultants have the incentive to favor some
clients over other clients when allocating shares
issued in public offerings, particularly those
clients with larger accounts or accounts that
generate high fees and compensation, as a
reward for their past business or to generate
future business.
Trade Error Correction
As a registered broker-dealer, Baird effects
transactions in securities on a national exchange
and may receive and retain compensation for
such services, subject to the limitations and
restrictions made applicable to such transactions
by Section 11(a) of the Exchange Act and Rule
11a2-2(T) thereunder.
It is Baird’s policy that a client’s account will be
fully compensated for any losses incurred as a
result of a trade error for which Baird is
responsible. If the trade error results in a gain,
the gain may be retained by Baird. For more
information, please see “Advisory Business—
Additional Service Information—Trading for Client
Accounts—Baird’s Trading Practices—Trade Error
Correction” above.
Baird’s Other Broker-Dealer and Related Activities
A client may choose to hold cash balances in the
client’s eligible accounts as broker-dealer “free
credits.” To the extent a client elects to hold cash
balances as free credits, a client understands that
Baird does not pay interest on such balances and
Baird may benefit from the possession or use in
the ordinary course of its business of any free
credit balances in the client’s accounts, subject to
restrictions imposed by Rule 15c3-3 under the
Exchange Act.
the size of
the order,
The investment advice provided to a client may
be based on the research opinions of Baird’s
research departments. Baird does, and seeks to
do, business with companies covered by those
research departments and as a result, Baird may
have a conflict of interest that could affect the
content of its research reports.
automated
sell
investments
recommended
non-institutional
participants
in
Information—Trading
for
Baird and its Associated Parties and associates
may buy or
that are
recommended to or owned by a client for their
own accounts, or they may act as broker or agent
for other clients buying or selling
those
investments. Those transactions may include
buying or selling investments in a manner that
differs from, or is inconsistent with, the advice
given to a client, and those transactions may
occur at or about the same time that such
investments are
to or are
purchased or sold for a client’s account. Baird
may also engage in agency cross transactions and
principal transactions with clients as further
described under “Advisory Business—Additional
Service
Client
Accounts—Trade Execution Services Performed by
Baird” above.
Baird selects securities trade execution venues
based on
trading
characteristics of the security, speed of execution,
likelihood of price improvement, availability of
efficient
transaction processing,
guaranteed automatic execution levels and other
qualitative factors. Baird receives payment or
liquidity rebates on certain options or equity
securities orders
to some venues
routed
(commonly known as “payment for order flow”).
The existence and amount of payments are
dependent upon the size and type of the routed
order. The
source and amount of any
compensation received by Baird in connection
with payment for order flow will be disclosed to
the
the
transaction upon request. This compensation
gives Baird an incentive to route client orders for
securities transactions to those venues that
provide Baird the greatest levels of compensation,
but Baird’s routing decision is always based upon
obtaining favorable executions for clients rather
than the availability of payment for order flow.
Information about Baird’s order routing practices
are
at:
available
http://www.rwbaird.com/help/account-
disclosures/routing-equity-orders.aspx.
Baird and PAM Consultants have an incentive to
favor the securities of issuers for which Baird’s
Global Investment Banking, Fixed Income Capital
Markets (including Baird Public Finance) and
Institutional Equities and Research Departments
the compensation
provide services due
to
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
from
time
• require them to provide investment advice that
is suitable for advisory clients (based upon the
information provided by such clients);
that
• are designed
securities
to ensure
allocations made to discretionary client accounts
are made in a manner such that all such clients
receive fair and equitable treatment over time;
Baird and its associates, by reason of Baird’s
investment banking or other
broker-dealer,
activities, may
time acquire
to
information deemed confidential, material and
non-public, about corporations or other entities
and their securities. Baird and its associates are
prohibited by applicable law or agreements from
disclosing such information to clients or acting
upon such information with respect to any client
Account. Baird’s other activities thus present a
potential conflict of
interest because such
activities may limit Baird’s ability to advise or
manage client Accounts.
• address Baird’s and its associates’ trading
activities and are designed to prevent them
from improperly benefiting from the trading
activities of Baird’s advisory clients; and
Other Conflicts of Interest
• address and limit cash and non-cash benefits
provided to PAM Consultants by third parties in
an attempt to avoid any question of propriety or
any conduct inconsistent with Baird’s high
standards of ethics.
Duration Compensation Will Be Received
Baird offers to clients other investment products
and services not described in this Brochure. These
investment products and
services provide
different levels of compensation to Baird and its
PAM Consultants. Baird and its PAM Consultants
have an incentive to favor those investment
products and services that generate a higher level
of compensation than those that generate a lower
level of compensation. For more information
about the other investment products and services
offered by Baird, clients should contact Baird or a
PAM Consultant.
extend beyond
a
client’s
If a client holds any of the investment products
described above, Baird, its Associated Parties and
associates will receive the fees and payments
described above for the duration of the client’s
In some
relationship with Baird.
advisory
circumstances, the receipt of such compensation
may
advisory
relationship with Baird if the client continues to
hold those assets at Baird.
financial
interest or practices
Financial
Industry
Activities
Other sections of this Brochure also describe
instances when Baird and its PAM Consultants
may recommend to clients, and may buy and sell
for client’s Account, securities in which Baird and
its Associated Parties and associates have a
material
that
interest. For more
present a conflict of
information, please see “Advisory Business—
Advisory Fees—Advisory Fee Payments to Baird,
PAM Consultants and Investment Managers” and
“Other
and
Affiliations” above, and “Client Referrals and
Other Compensation” below.
If Baird, or an Associated Party or associate of
Baird, receives any compensation or benefit
described in this Brochure from or related to a
client’s investment, they will generally retain the
compensation or benefit. Except as otherwise
described above, Baird generally does not rebate
these amounts to a client’s Account or credit the
amount against the Advisory Fees payable by a
client unless such compensation may not be
retained under applicable law or regulation.
Addressing Conflicts
Brokerage Practices
PAM’s and Baird’s Trading Practices
Broker-Dealer Selection
for Baird and
PAM and Baird will select the broker-dealers,
which may include Baird, that will execute trade
orders for Non-Discretionary Accounts and with
respect to Accounts that are managed directly by
PAM or Baird unless the client has provided
instructions to PAM to the contrary. As investment
adviser, PAM and Baird have an obligation to seek
“best execution” of client trade orders. “Best
The foregoing activities could create a conflict of
interest with clients. In addition to the measures
described above, Baird addresses conflicts posed
by those activities through disclosure in this
Brochure, the client’s agreements with Baird, the
Client Relationship Booklet and prospectuses,
offering documents or other disclosure documents
provided or made available to clients. Baird has
also adopted a Code of Ethics and other internal
its
policies and procedures
associates that:
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
into
consideration
account
best execution. In determining the amount to be
allocated to an account, if any, PAM and Baird
take
specific
investment restrictions, undesirable position size,
account portfolio weightings, client tax status,
client cash positions and client preferences.
financial
responsibility,
and
in a block
All advisory clients participating
transaction will receive the same execution price
for the security bought or sold. Average prices
may be used when allocating purchases and sales
to a client’s Account because such securities may
be purchased and sold at different prices in a
series of block transactions. As a result, the
average price received by a client may be higher
or lower than the price the client may have
received had the transaction been effected for the
client independently from the block transaction.
in
execution” means that they must place client
trade orders with those broker-dealers that they
believe are capable of providing
the best
qualitative execution of client trade orders under
the circumstances, taking into account the full
range and quality of the services offered by the
broker-dealer, including the value of the research
provided (if any), the broker-dealer’s execution
capabilities, the cost of the trade, the broker-
dealer’s
its
responsiveness to PAM and Baird. It is important
to note that PAM’s and Baird’s best execution
obligation does not require them to solicit
competitive bids for each transaction or to seek
the lowest available cost of trade orders, so long
as they reasonably believe that the broker-dealer
selected can be reasonably expected to provide
clients with the best qualitative execution under
the circumstances. From time to time, clients may
direct PAM to execute trades through Baird. See
“Directed Brokerage” below.
Trade Aggregation, Allocation and Rotation
Practices
treatment over
PAM and Baird may aggregate contemporaneous
buy and sell orders for the accounts over which
they have discretionary authority (a practice also
known as bunching trades or block transactions).
This practice may enable them to obtain more
favorable execution, including better pricing and
enhanced investment opportunities, than would
otherwise be available
if orders were not
aggregated. Using block transactions may also
assist them in potentially avoiding an adverse
effect on the price of a security that could result
from simultaneously placing a number of
separate, successive or competing, client orders.
The amount of securities available
the
marketplace, at a particular price at a particular
time, may not satisfy the needs of all clients
participating in a block transaction and may be
insufficient to provide full allocation across all
client accounts. To address this possibility, Baird
has adopted
trade allocation policies and
procedures that are designed to make securities
allocations to discretionary client accounts in a
manner such that all such clients receive fair and
equitable
time. If a block
transaction cannot be executed in full at the same
price or time, the securities actually purchased or
sold by the close of each business day will
generally be allocated pro rata among the clients
participating in the block transaction. However,
PAM may also make random allocations to client
accounts in certain circumstances, such as when
Baird deems a partial fill for the total block order
to be low. Adjustments may also be made to
avoid a nominal allocation to client accounts.
under
their
direct
favorable net price
When PAM is not able to aggregate trades, PAM
generally uses a trade rotation process that is
designed to be fair and equitable to its advisory
clients over time. However, a client should be
aware that PAM’s trade rotation practices may at
times result in a transaction being effected for the
client’s Account that occurs near or at the end of
the rotation and, in such event, client’s trade
orders will significantly bear the market price
impact, if any, of those trades executed earlier in
the rotation, and, as a result, the client may
receive a
for the
less
applicable trade.
PAM and Baird generally aggregate buy and sell
orders when executing trades for client account
assets
discretionary
management when they have the opportunity to
do so. When utilizing block transactions, PAM and
Baird generally aggregate a client’s trade orders
with trade orders for clients who are participating
in the same Service and pursuing the same model
portfolio or strategy. In some cases, PAM or Baird
may aggregate a client’s trade orders with trade
orders for other advisory clients who are not
participants in the Services described in this
Brochure. However, PAM and Baird determine
whether or not to utilize block transactions for a
client in their sole discretion and PAM’s and
Baird’s decision is subject to their duty to seek
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income securities
Notwithstanding the foregoing, if an aggregated
trade order involves fixed income securities, PAM
and Baird may allocate the securities based on
the needs of client accounts. In addition, PAM and
Baird will at times place aggregated trade orders
for fixed income securities prior to determining
how the aggregated trade order will be allocated
to client accounts. In those instances when an
aggregated trade order for fixed income securities
is placed prior to determining client allocations or
when such trade order is only partially filled, PAM
or Baird will seek to allocate trades in manner
intended to be fair and equitable to applicable
clients over time. Furthermore, when a trade
order for fixed income securities is only partially
filled, PAM and Baird may place orders for other
fixed
that have similar
characteristics, such as issuer name, structure,
credit rating, or market sector.
client will be solely responsible for monitoring,
evaluating and reviewing the arrangement with
the directed broker-dealer and paying any
commissions or markups or markdowns or other
costs imposed by the directed broker-dealer. A
client should also note that PAM generally will not
aggregate the client’s directed brokerage trade
orders with orders for other PAM clients. As a
result, a client’s transaction costs may be higher
because the client will not benefit from any
volume discounts or other reduced transaction
costs that PAM may obtain for its other clients. A
client should further note that PAM generally will
not include such client trade orders in its trade
rotation process and that PAM will generally place
the client’s trade orders with the directed broker-
dealer after PAM completes its trading for other
PAM client accounts. The client’s trade orders will
significantly bear the market price impact, if any,
of those trades executed earlier in PAM’s rotation.
As a result, the client may receive a less favorable
net price for the trade.
Because PAM and Baird are unable to buy or sell
any security for a client’s Non-Discretionary
Accounts without the client’s authorization, PAM
and Baird generally do not aggregate or bunch
trades for those Accounts with the same or similar
trades for other client accounts. Because similar
orders for the client and PAM’s or Baird’s other
clients may be placed and filled at different times,
the client may buy or sell securities at prices that
are different from the prices obtained by other
clients who received the same or similar advice
from PAM or Baird.
interest
Directed Brokerage Arrangements
If a client directs PAM to use a particular broker-
dealer, and if the particular broker-dealer referred
the client to PAM or if the particular broker-dealer
refers other clients to PAM or Baird in the future,
PAM and Baird may benefit from the client’s
directed brokerage arrangement. Because of
these potential benefits, PAM and Baird may have
an economic interest in having the client continue
the directed brokerage arrangement. The benefits
that PAM and Baird receive conflict with the
client’s
in having PAM or Baird
recommend that the client utilize another broker-
dealer to execute some or all transactions for the
client’s Account.
Before directing PAM to use a particular broker-
dealer, a client should carefully consider the
possible costs or disadvantages of directed
brokerage arrangements.
From time to time, PAM may request that PAM
clients direct PAM to execute trades through
Baird, as broker-dealer, including clients subject
to a commission-based fee arrangement. This
presents a conflict of interest, which is further
described under “Fees and Compensation—
Advisory Fees” above.
Cross Trading Involving Advisory Accounts
In some cases, a client may direct PAM to use a
particular broker-dealer for execution of the
client’s trade orders (a “directed brokerage
arrangement”), and PAM may agree to the
arrangement. This may occur when a client’s
Account is held at another broker-dealer firm and
a client directs PAM to execute trades through
such firm, or when a client’s Retirement Account
or other account is maintained on a platform
operated and managed by a third party and
trades must be executed through that platform. A
client should understand that PAM and Baird
consider such arrangements to be directed
brokerage arrangements. A client should also
understand that if the client has a directed
brokerage arrangement, PAM and Baird may be
unable to achieve best execution for the client’s
transactions. A client should note that any costs
related to the directed brokerage arrangement
are not included in the Advisory Fee and that the
PAM generally does not in engage in cross
transactions, including agency cross transactions,
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trading in opposition to a client. To avoid favoring
one client over another client, Baird attempts to
use objective market data in the correction of any
trading errors.
If a client’s Account is managed by an Other
Manager, the client should review the Other
the Other
Manager’s Brochure and contact
Manager for information about how the Other
Manager corrects trade errors.
the purchase of
Soft Dollar Benefits
except in limited instances such as when clients
buy or sell variable rate demand obligations which
are also known as “put bonds”. When PAM
believes that the transaction is consistent with
each client’s best
interest, PAM, acting as
investment manager, may cause (or in the case
of Non-Discretionary accounts, recommend) the
sale of securities from the account of an advisory
client while at or about the same time causing
(or, in the case of Non-Discretionary accounts,
recommending)
the same
securities for the account of another PAM advisory
client. Such transactions may have the benefit of
reducing transaction and market impact costs.
PAM and Baird receive no research or other
products from broker-dealers in connection with
PAM clients’ securities transactions.
Trading Practices of Investment Managers
If a client’s Account or a portion thereof is
managed by an investment manager, the client
should note that, like Baird, such investment
manager has a duty to seek best execution for
the client’s Account.
In such cases, because Baird is acting as
investment adviser for both buyer and seller,
Baird is subject to potentially conflicting interests
in causing (or recommending) the transactions.
Also, because Baird is acting as investment
adviser for both buyer and seller, transaction
prices may be determined more by reference to
market information or dealer indications for the
securities involved, and less through the type of
independent arms-length negotiation that might
otherwise occur. Baird has adopted internal
policies and procedures that require PAM and
Baird to obtain approval of Baird’s Compliance
Department before affecting a cross trade.
the
investment manager,
Trade Error Correction
Investment managers may participate in wrap fee
programs. In addition, investment managers may
manage institutional and other accounts not part
of a wrap
fee program. In the event an
investment manager purchases or sells a security
for all accounts using a particular SMA Strategy
the
offered by
investment manager may have to potentially
effect similar transactions through a number of
different broker-dealers. In some cases, to
address this situation, investment managers may
decide to aggregate all such client transactions
into a block trade that is executed through one
broker-dealer. This practice may enable the
investment manager to obtain more favorable
execution, including better pricing and enhanced
investment opportunities, than would otherwise
be available if orders were not aggregated. Using
block transactions may also assist the investment
manager in potentially avoiding an adverse effect
on the price of a security that could result from
simultaneously placing a number of separate,
successive or competing client orders.
It is Baird’s policy that if there is a trade error for
which PAM or Baird is responsible, PAM or Baird
will take actions, based on the
facts and
circumstances surrounding the error, to put the
client’s Account in the position that it would have
been in as if the error had not occurred, including
by adjusting or reversing the transaction, entering
an offsetting transaction, or other methods that
may be deemed appropriate by Baird. Errors
caused by PAM or Baird will be corrected at no
cost to client’s Account, with the client’s Account
not recognizing any loss from the error. PAM and
Baird may net gains and losses from a single error
event involving more than one transaction in a
security or transactions in multiple securities. The
client’s Account will be fully compensated for any
losses incurred as a result of an error event. If
the trade error results in a gain, the gain may be
retained by Baird but such gain is not given to or
shared with any PAM or Baird associate.
PAM and Baird offer many services and, from time
to time, may have other clients in other programs
Alternatively, an investment manager may utilize
a trade rotation process where one group of
clients may have a transaction effected before or
after another group of the investment manager’s
clients. A client should be aware that an
investment manager’s trade rotation practices
may at times result in a transaction being effected
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in
the
the Model Provider’s
monitor the performance of an Account pursuing
such a Model Portfolio strategy and compare that
performance with the performance reported for
the Model Portfolio by the Model Provider. A client
about Account
should
questions
discuss
performance or
trade
rotation policy with the client’s PAM Consultant.
information
for the client’s Account that occurs near or at the
end of the investment manager’s rotation and, in
such event, client’s trade orders will significantly
bear the market price impact, if any, of those
trades executed earlier
investment
manager’s rotation, and, as a result, the client
may receive a less favorable net price for the
trade. Additional
regarding an
investment manager’s trade rotation policies, if
any, is available in the investment manager’s
Form ADV Part 2A Brochure.
A client should note that each
investment
manager is solely responsible for ensuring that it
complies with its best execution obligations to the
client. A client should review the manager’s
trading for the client’s Account because PAM and
Baird do not monitor, review or evaluate whether
the manager is complying with its best execution
obligations to the client. A client should review
the manager’s Form ADV Part 2A Brochure,
inquire about the manager’s trading practices,
and consider that information carefully, before
selecting a manager.
on
A client should note that the client’s advisory
agreement permits PAM and Baird to trade as
principal on orders received from Other Managers.
See “Trade Execution Services Performed by
Baird—Principal Transactions” below for more
information.
Trade Execution Services Performed by
Baird
If Baird provides trade execution services for a
client’s Account, Baird will generally act as agent
when routing client trade orders for execution.
However, Baird may cross trades between client
accounts or may act as principal for its own
account in certain circumstances to the extent
permitted by applicable law as is more fully
described below.
in
A client should understand that certain securities,
such as securities traded over-the-counter and
fixed income securities, are primarily traded in
dealer markets. When Baird purchases or sells
these types of securities for client accounts, it
generally does so through broker-dealer firms
acting as a dealer or principal. Dealers executing
principal trades typically
include a markup,
markdown or spread in the net price at which
transactions are executed. A client bears such
costs in addition to the Advisory Fee.
Agency Cross Transactions
PAM generally does not in engage in agency cross
instances.
transactions,
except
in
limited
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after
they have
implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. The Overlay Manager has
provided to Baird a list of Model Providers that
have such trade rotation policies, which list is
at
website
Baird’s
available
bairdwealth.com/retailinvestor. A PAM
client
should understand that an Account pursuing a
Model Portfolio strategy offered by those Model
Providers will have trades executed for the client’s
Account at the end of the Model Provider’s trade
rotation on a regular and consistent basis. As a
result, trade orders for such an Account will
significantly bear the market price impact, if any,
of those trades executed earlier in the Model
Provider’s rotation and the performance of the
Account will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by the Model Provider. In
addition and for the same reasons described
above, the performance of a Model Portfolio, as
reported by the Model Provider, will differ,
perhaps in a materially negative manner, from
the actual performance realized by PAM client
Accounts pursuing the Model Portfolio strategy.
PAM and Baird do not make or control any
investment manager’s trade rotation policies, and
they do not monitor, evaluate or review any
the
investment manager’s compliance with
manager’s trade rotation policies or whether such
trade rotation policies result
inequitable
performance of client Accounts. A client selecting
a Model Portfolio offered by such a Model Provider
is urged to obtain a copy of the Model Provider’s
Form ADV Part 2A Brochure and review the
description of the Model Provider’s trade rotation
policy contained in that document. A copy of a
Model Provider’s Brochure can be obtained by
contacting a PAM Consultant. A client should also
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realize profits
in accordance with
interests of
However, in certain circumstances and to the
extent permitted by applicable law and regulation,
Baird and PAM Consultants may effect “agency
cross” transactions with respect to a client’s
Account. An “agency cross” transaction is a
transaction in which Baird or its affiliates act as
broker for the party or parties on both sides of
the transaction. As compensation for brokerage
services, Baird may receive compensation from
parties on both sides of an agency cross
transaction, the amount of which may vary. PAM
Consultants may receive compensation from Baird
related to agency cross transactions. Therefore,
Baird and PAM Consultants may have a conflicting
division of loyalties and responsibilities. However,
in all cases, Baird and PAM Consultants will seek
to obtain the best execution for each respective
advisory client and will effect agency cross
transactions only
the
requirements of Rule 206(3)-2 under the Advisers
Act. Furthermore, Baird will comply with
additional regulations applicable to Retirement
Accounts.
incentive
to
agency
transactions
“agency
Where applicable, a client’s advisory agreement
discusses
and
cross
authorizes Baird and PAM Consultants to effect
agency cross transactions for a client’s Account. A
client’s authorization to Baird and PAM
to effect
Consultants
cross”
is given pursuant to Rule
transactions
206(3)-2 under the Advisers Act and may be
revoked at any time by the client in client’s
sole discretion by notifying the client’s PAM
Consultant in writing.
Baird may
from principal
transactions with a client based on the difference
between the price Baird paid for the security and
the price at which Baird sold the security, which
may include a markup, markdown or spread from
the prevailing market price, an underwriting fee,
selling dealer concession, or other incentive to
execute the transaction. PAM Consultants may
from Baird related to
receive compensation
principal trades of securities underwritten by
Baird. Any compensation received by Baird or a
PAM Consultant in a principal transaction is in
addition to the Advisory Fee paid by the client.
Principal trades also allow Baird to sell securities
from its account that it deems undesirable and to
buy securities for its account that it deem
desirable. Thus, in trading as principal with a
client, Baird and PAM Consultants will have
potentially conflicting division of loyalties and
responsibilities regarding their own interests and
the
the client. This potential
compensation may give Baird and PAM
Consultants an
recommend a
transaction in which Baird and PAM Consultants
act as principal over other
transactions.
Nonetheless, Baird and PAM Consultants have a
fiduciary duty to act in the client’s best interest
and to seek best execution for advisory clients.
Baird addresses this conflict through disclosure in
this Brochure. Furthermore, Baird has adopted
internal procedures that require Baird and PAM
Consultants, when acting in a principal capacity,
to disclose all material information regarding
Baird’s interest in the transaction, and obtain the
client’s approval of the transaction prior to
settlement.
Principal Transactions
A client’s advisory agreement discloses, where
applicable, the possibility of Baird’s role in
transactions, and each
potential principal
transaction confirmation sent to PAM clients
discloses the capacity in which Baird served in the
transaction and whether Baird is a market maker
in each security the client bought or sold.
or
if
other
the Account
transactions.
Riskless
Subject to the requirements of applicable law,
Baird and PAM Consultants may execute
transactions for a client’s Account while acting as
principal for Baird’s own account. Baird and PAM
Consultants act as principal when they sell a
security from Baird’s inventory to a client or they
purchase a security from a client for Baird’s
inventory. Baird and PAM Consultants also act as
principal when they sell new issue securities to
clients in securities offerings underwritten by
Baird. Baird also acts as principal in riskless
principal
principal
transactions refer to transactions in which Baird,
after having received a client’s order, executes an
identical order in the marketplace to fill the
client’s order while acting as principal.
To the extent permitted by applicable law and
regulation, if a client’s Account participates in a
non-
Non-Discretionary Service
is
discretionary service, or
managed by an Other Manager, the client’s
advisory agreement provides Baird and PAM
Consultants with a blanket authorization to act as
principal for Baird’s own account in selling any
security to, or purchasing any security from, the
client’s Account. With this authorization, Baird
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Performance reporting may not be available for
Account assets that are not custodied at Baird.
For more information about performance reports
provided by PAM, see “Advisory Business—
Description of Advisory Services” above. PAM or
Baird may change or discontinue performance
reporting to a client at any time for any reason
upon notice.
and PAM Consultants may effect any and all
principal transactions with the client’s Account
without having
to provide specific written
disclosures or obtain written client consent prior
to completion of each proposed principal trade,
subject to the requirements of an exemptive
order issued by the SEC to Baird (Rel. No. IA-
4596) and other applicable law and regulation.
This authorization to enable Baird and PAM
Consultants to trade as principal with a
client’s Account may be revoked at any time
by the client in client’s sole discretion by
notifying the client’s PAM Consultant in
writing.
It is generally PAM’s practice to rebate to a client
any compensation that PAM receives relating to
agency cross trades or principal transactions
effected for the client’s Account.
Client performance reports usually contain a
portfolio valuation and typically show the asset
allocation of the client’s portfolio, changes in a
client’s portfolio, and account performance
compared to a benchmark market index or indices
(such as the S&P 500® Index or the Bloomberg
U.S.
Intermediate Government/Credit Bond
Index). The benchmark may be a blended
benchmark that combines the returns for two or
more indices.
A client should note that past performance does
not indicate or guarantee future results. None of
PAM, Baird, or investment managers managing
the client’s Account promise or guarantee any
level of investment returns or that the client’s
investment objective will be achieved.
Review of Accounts
Client Account Review
Client accounts are monitored on a periodic basis
by the client’s PAM Consultant and are subject to
review by the Baird Market Director or PWM
Supervision department supervisor (or his or her
respective designee) responsible for supervising
the client’s PAM Consultant. A client’s PAM
Consultant generally reviews the performance of
the client’s Account at least annually. However,
the client’s PAM Consultant may not review the
performance of a client’s SMAs managed by Other
Managers under the Baird SMA Network Program
or Dual Contract Program. Baird has designated
individuals who are responsible for monitoring a
client’s PAM Consultant with respect to the client
account’s trading activity and attempting to
ascertain whether client accounts within each
composite are being treated equitably.
Benchmarks shown in performance reports are for
informational purposes only. PAM’s selection and
use of benchmarks is not a promise or guarantee
that the performance of a client’s Account will
meet or exceed the stated benchmark. When the
client compares Account performance to the
performance of a market index, the client should
recognize that a market index merely reflects the
performance of a list of unmanaged securities
included in the index and the index performance
does not take into account management fees,
execution costs, and other expenses related to
investing for a client’s Account. The securities
included in a client’s Account generally do not
exactly mirror the securities included in the index.
performance
comparisons
Account Statements and Performance
Reports
If Baird provides transaction execution services to
a client, Baird will generally provide the client
with a monthly brokerage account statement
when activity occurs during
that month.
Otherwise, Baird will provide the client with a
quarterly statement if there has not been any
intervening monthly transaction activity.
The benchmarks used by Baird with respect to a
client’s SMA may differ from the benchmarks used
by the manager of the client’s SMA. As a result,
the
in Baird’s
performance reports may differ from reports
provided to clients directly by the investment
manager for the client’s SMA.
The performance of investment managers may,
under certain circumstances, be presented to
clients on a “gross” or “gross of fees” basis, which
A client’s PAM Consultant will provide the client
with a written report on the client’s Account’s
performance as often as the client and the PAM
Consultant may from time to time mutually agree.
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the assets in the client’s Account are held by a
custodian other than Baird, Baird may also use
valuation information provided by the client’s
third party custodian.
calculation of
is unreliable. Valuation data
in a timely manner, resulting
means the performance results being presented
does not reflect the deduction of Advisory Fees
and other costs that clients have incurred and will
incur when retaining the manager. Had applicable
Advisory Fees and other costs been included in
the performance calculation,
the manager’s
performance results would have been lower than
the performance results presented. Documents
presenting a manager’s performance results on a
gross of
fees basis should contain certain
disclosures about the performance results being
presented. Clients are urged to review carefully
those disclosures because they contain important
information about
the
the
performance results. If a client is presented
performance information for a manager’s strategy
on a gross of fees basis and the client has an
Account managed by that manager pursuant to
that strategy,
the client should obtain a
performance report for the Account and review
that performance information carefully because
the performance report for the Account will reflect
the deduction of applicable Advisory Fees and
other costs.
PAM and Baird do not conduct a review of
valuation information provided by third party
pricing services, issuers, sponsors, or custodians,
and they do not verify or guarantee the accuracy
of such information. PAM and Baird do not accept
responsibility for valuations provided by third
parties that are inaccurate unless they have a
reason to believe that the source of such
valuations
for
investments, particularly annuities and Complex
Investment Products, may not be provided to PAM
or Baird
in
valuations that are not current. The prices
obtained by PAM and Baird from the third party
pricing services, issuers, sponsors and custodians
may differ from prices that could be obtained
from other sources. Values used in account
statements and performance reports may vary
from prices received in actual transactions and
are not firm bids, offers or guarantees of any type
with respect to the value of assets in an Account,
and the values may be greater than the amount a
client would receive if the securities were actually
sold from the client’s Account.
If a client has assets held by a third party
custodian, the prices shown on a client’s Account
statements provided by the custodian could be
different from the prices shown on statements
and reports provided by PAM or Baird. See
“Custody” below for more information.
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after
they have
implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. As a result, the performance of a
Model Portfolio, as reported by the Model
Provider, will differ, perhaps in a materially
negative manner, from the actual performance
realized by Baird client Accounts pursuing the
Model Portfolio strategy. See “Additional Service
Information—Trading for Client Accounts—Trading
Practices of Investment Managers” above for
more information.
including, but not
limited
to,
role
in developing
the
these
fees
to
Client Referrals and Other
Compensation
PAM or Baird may provide compensation to
individuals who refer clients in some instances.
When applicable, the compensation paid is a
percentage of the client’s fee payments or the
value of the client’s Account. The amount of
compensation will vary, with the specific level
determined based upon consideration of various
factors
the
individual’s
client
relationship and the assets under management.
Baird may pay
registered
representatives of Baird and its Associated Parties
as well as to unassociated solicitors that have
entered into a written agreement with Baird.
When preparing a client’s Account statements and
performance reports, PAM and Baird generally
rely upon third party sources, such as third party
pricing services. In some instances, such as when
Baird is unable to obtain a price for an asset from
a pricing service, Baird may obtain a price from
its trading desk or it may elect to not price the
asset. Obtaining a price from its trading desk may
present a conflict of interest. In some cases, Baird
obtains prices from the issuers or sponsors of
investment products in the client’s Account when
prices are not otherwise readily available. This
frequently occurs with respect to the valuation of
annuities and Complex Investment Products. If
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to client Accounts on
and
Personal
Trading”
PAM and Baird and Baird’s Associated Parties and
associates may receive certain economic benefits
in connection with providing advisory services to
clients, which are described in the sections
entitled “Advisory Business—Additional Service
Information”, “Fees and Compensation”, “Other
Financial Industry Activities and Affiliations”,
“Code of Ethics, Participation or Interest in Client
and
Transactions
“Brokerage Practices” above.
from
Custody
Certain Services may require clients to custody
their Account assets at Baird. If Baird is the
custodian of a client’s assets, Baird will provide
certain custody services, including holding the
client’s Account assets, crediting contributions
and interest and dividends received on securities
held in a client’s Account, and making or
“debiting” distributions
the Account.
Information about account statements and
performance reports, if any, that PAM and Baird
provide to clients is contained under the heading
“Advisory Business–Consulting Services” and
“Review of Accounts” above.
held by a third party custodian due to the
increase in resources needed to administer those
Accounts. Further, such third party custody
limit the Services made
arrangements may
available to the client. In addition, a client should
understand that: (a) each third party custodian
has exclusive control over the investment options
made available
the
custodian’s platform; (b) PAM and Baird have no
authority or ability to add to, or remove from, a
custodian’s platform any investment option; (c)
any advice given by PAM or Baird with respect to
the Account is inherently limited by the options
available through a custodian’s platform; (d) PAM
or Baird may have provided different investment
advice with respect to the Account had they not
been limited to the investment options made
available through the custodian’s platform; and
(e) certain investments, such as mutual fund
shares, could be more or less expensive than if
the investment was obtained from Baird or
another firm. A client should further note that
PAM and Baird may not provide performance
review or reporting for Held-Away Assets. In
addition, a client who uses a third party custodian
is not eligible for cash sweep services offered by
Baird. Clients using a third party custodian are
encouraged to establish appropriate cash sweep
arrangements.
As custodian, Baird may hold a client’s Account
assets in nominee or “street” name, a practice
that refers
to securities and assets being
registered in Baird’s name or in a name that Baird
designates, rather than in a client’s name directly.
Baird will be the holder of record in those
instances.
Baird may utilize one or more subcustodians to
provide for the custody of a client’s assets in
certain circumstances. For instance, Baird utilizes
subcustodians to maintain custody of certain
client assets participating in the Cash Sweep
Program (described below) and securities that are
traded on foreign exchanges.
(e.g.,
A client who uses a third party custodian
authorizes PAM and Baird to give instructions to
the client’s custodian for all actions necessary or
incidental to the purchase, sale, exchange, and
delivery of securities held in the client’s Account.
Also, the client will receive account statements
directly from the client’s selected custodian. A
client should carefully review those account
statements and
them with any
compare
statements provided by PAM or Baird. A client
should note that the prices shown on a client’s
Account statements provided by the custodian
could be different from the prices shown on
statements and reports provided by PAM or Baird
due to a variety of factors, including the use of
different valuation sources and accounting
methods
settlement date
trade or
accounting) by the custodian and Baird.
PAM and Baird in their sole discretion may accept
into a client’s Account,
Held-Away Assets
including assets
that are held by another
custodian (a “third party custodian”). A client who
uses a third party custodian to hold Account
assets does so at the client’s risk. A client should
understand that PAM and Baird do not monitor,
evaluate or review any third party custodian. The
client should also understand that the client will
pay a custody fee to the third party custodian in
addition to the Advisory Fee. Baird may also
impose additional fees on Accounts with assets
Investment Discretion
Investment Selection and Trading
Authorizations
retains complete discretion over
A client
investment selection and trading decisions with
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respect to assets in a client’s Non-Discretionary
Service Accounts, and PAM and Baird will only
execute transactions for such Accounts pursuant
to the client’s instruction or authorization.
the client. Pursuant
If a client’s Account participates in a Discretionary
Service, the client’s advisory agreement provides
the client’s PAM Consultant, as
Baird and
applicable, discretionary authority to manage the
assets in the client’s Account in accordance with
the terms of the Service selected by the client.
investment manager, as applicable, complete and
unlimited trading authorization and appoints them
as the client’s agents and attorneys-in-fact to
manage the assets in the client’s Account on the
client’s behalf, subject to the terms of the Service
selected by
to such
authorization and powers of attorney, PAM, Baird,
the client’s PAM Consultant and the client’s
investment manager may, in their sole discretion
and at the client’s risk, purchase, sell, exchange,
convert and otherwise trade the securities and
other assets in the client’s Account, as well as
arrange for delivery and payment in connection
with the above, and act on the client’s behalf in
all matters necessary or incidental to the handling
of the client’s Account without prior notice to the
client. Such trading authorizations and powers of
attorney, whether granted to PAM, Baird, the
client’s PAM Consultant or the client’s investment
manager, shall remain in full force and effect until
terminated by the client, the client’s investment
manager, PAM or Baird.
a
client’s
If a client’s Account participates in the PAM
Recommended Managers Service, the client’s
advisory agreement provides Baird and the
client’s PAM Consultant discretionary authority to
appoint investment managers to manage the
client’s Account and to terminate or replace
investment managers for the client’s Account for
any reason without prior notice to the client. If
PAM or Baird terminates an investment manager
PAM
of
from management
Recommended Managers Service Account, the
client’s advisory agreement provides PAM and
Baird discretionary authority to manage the
assets in the client’s Account until a replacement
investment manager is selected or alternative
arrangements are made for the management of
the client’s assets.
include
If a client’s Account participates in an SMA
Service, the client’s advisory agreement provides
the investment manager selected to manage the
client’s Account, which may
an
Implementation Manager, discretionary authority
to manage the assets in the client’s Account in
accordance with the terms of the SMA Service
selected by the client.
Orders for the purchase and sale of securities in a
client’s Discretionary Service Accounts will
generally be executed by Baird, in its capacity as
broker-dealer, as further described under the
heading “Brokerage Practices” above, unless
Baird’s duty to seek to obtain best execution
otherwise requires or unless the client has
provided other instructions to Baird in writing.
PAM and Baird do not have discretionary authority
over the assets in a client’s SMAs that are
managed by an Other Manager and cannot
purchase or sell such assets without the consent
of the client or such Other Manager. The
investment manager for a client’s SMAs may
initiate securities transactions through Baird, in its
capacity as broker-dealer, as further described
under the heading “Brokerage Practices” above,
subject to the manager’s duty to seek to obtain
best execution, or unless a client has provided
other instructions in writing. Baird, as broker-
dealer, will rely upon any such instructions of any
investment managers selected to manage the
client’s Account.
for
buying,
holding,
If a client grants discretionary authority over the
client’s Account to PAM, Baird, the client’s PAM
Consultant or the client’s investment manager,
the client’s advisory agreement authorizes PAM,
Baird, the client’s PAM Consultant and the client’s
investment manager, as applicable, to manage
the client’s Account and to make investment
decisions for the client’s Account, with the
authority to determine the amount, type and
exchanging,
timing
converting and selling securities and other assets
for the client’s Account, subject to the terms of
the Service selected by the client. The client’s
advisory agreement also grants to PAM, Baird, the
client’s
client’s PAM Consultant and
the
If a client participates in an SMA Service, the
client authorizes PAM and Baird to share client’s
information with the Overlay Manager and any
Other Manager or
Implementation Manager
managing the client’s Account. The client also
authorizes and directs PAM and Baird to transmit
to the Overlay Manager and any such Other
Implementation Manager any
Manager or
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instructions that the client may provide to PAM or
Baird to the extent necessary to carry out the
client’s instructions.
other
from
the services
Associated Investment Products
The Services allow PAM and Baird to use the
discretionary authority granted to them by a
client to invest the client’s Account in Associated
Investment Products. Baird and Associated Parties
receive investment management or advisory fees
Associated
compensation
or
they
for
Investment Products
provide, the amount of which generally increases
when clients invest in such products. The amount
of fees or other compensation received by Baird
and Associated Parties is generally described in
the prospectus or other offering or disclosure
documents for the investment product. Additional
information is also available on Baird’s website at
bairdwealth.com/retailinvestor.
Client Investment Restrictions
The Discretionary and the SMA Services offer a
client the ability to impose reasonable investment
restrictions on the management of an Account,
including the designation of particular securities
or types of securities that should not be
purchased for the client’s Account, but a client
may not require that particular funds or securities
(or types) be purchased for the client’s Account.
Reasonable investment restrictions requested by
a client will apply only to those assets over which
PAM, Baird or a client’s investment manager has
discretion.
in Associated
investments
to
those
PAM may also offer clients a socially responsible
investing (“SRI”) service, which assists a client in
restricting
that are
consistent with the client’s social investment
guidelines or objectives. Clients electing the SRI
service generally bear the cost of the SRI service
as it is generally included in the Advisory Fee.
accounts without
restrictions
By signing an advisory agreement with Baird or
participating in a Service, a client consents to
PAM and Baird investing all or a portion of the
client’s Account
Investment
their
Products. PAM and Baird will use
discretionary authority to invest the client’s
Account in Associated Investment Products when
they determine it to be in the client’s best interest
to do so. Generally, the criteria used by them in
deciding to invest in Associated Investment
Products are the same as those used in deciding
to invest a client’s assets in investment products
unassociated with Baird. For more information
about the criteria used by PAM and Baird, clients
should review the section of the Brochure entitled
“Methods of Analysis, Investment Strategies and
Risk of Loss” above. A client’s consent may be
revoked at any time.
The Services allow Other Managers, including
Associated Managers, to use the discretionary
authority granted to them by a client to invest the
client’s Account in investment products managed
or sponsored by the Other Manager or any of its
associated firms, which may include Baird. The
Other Manager or its associated firms receive
investment management or advisory fees or other
compensation from such products for the services
they provide, the amount of which generally
increases when clients invest in such products.
In the event that a client’s Account is restricted
from investing in certain securities, PAM, Baird or
the client’s investment manager, as applicable,
will select such other replacement securities, if
any, as they deem appropriate. Accounts with
investment restrictions may perform differently
from
and
performance may be poorer. In addition, in the
event there is a change in the classification or
credit rating of a security held in the client’s
Account, a client’s investment restrictions may
force PAM, Baird or the client’s investment
manager to sell such security at an inopportune
impacting Account
time, possibly negatively
performance and causing the client’s Account to
realize taxable gains or losses, which could be
significant. A client should also be aware that, if
the client’s Account holds any investment vehicle
(such as a mutual fund or ETF), any investment
restrictions the client places on the client’s
Account may not flow through to the securities
owned by that investment vehicle.
Should a client wish to impose or modify existing
restrictions, or the client’s financial condition or
investment objectives have changed, the client
should contact the client’s PAM Consultant.
By signing an advisory agreement with Baird or
participating in a Service, a client consents to
each Other Manager, including each Associated
Manager, managing client’s Account investing all
or a portion of the client’s Account in investment
products managed or sponsored by the Other
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Manager or any of its associated firms, which may
include Baird. Each Other Manager is responsible
for providing to the client information about the
amount of fees received by the Other Manager
and its associated firms and the criteria used by
the Other Manager in deciding to invest in
products managed or sponsored by the Other
Manager or any of its associated firms. A client
should contact the Other Manager and review the
Other Manager’s Form ADV Part 2A Brochure for
more information. A client’s consent may be
revoked at any time.
Voting Client Securities
Non-Discretionary Accounts
With respect to any Accounts over which the
client retains discretionary investment authority,
a client retains the right to vote proxies with
respect to the securities held in such Accounts.
Accordingly, the client is responsible for voting
proxies and otherwise addressing all matters
submitted for consideration by security holders,
and PAM and Baird are under no obligation to
take any action or render any advice regarding
such matters. The client’s PAM Consultant may,
upon the client’s request, provide advice on proxy
voting or what other action the client could take.
Investment Policy Statements
PAM and Baird will not review, monitor, accept or
adhere to an investment policy statement or
similar document that was not prepared by PAM
or Baird, unless they otherwise specifically agree
to do so in writing. Adherence to any such
investment policy statement or similar document
is solely a client’s responsibility.
instances. For
Conversion, Exchange or Sale of Certain
Investments
By participating in a Service, a client authorizes
PAM and Baird to convert or exchange any shares
of mutual funds and other Funds held in the
client’s Account to a class of shares of the same
fund, such as advisory class shares, institutional
class shares, financial intermediary class shares,
or another class of shares primarily designed for
use in advisory programs (collectively, “Advisory
Class Shares”), to the extent made available by
the mutual fund or other Fund in accordance with
policies established by Baird from time to time,
including, without limitation the Mutual Fund
Share Class Policy that is described above.
Separately Managed Accounts
Under the PAM Recommended Managers Service,
Baird SMA Network Program and Dual Contract
Program, a client may retain the right to vote
proxies with respect to the securities held in the
client’s Account, or, in most instances, the client
may delegate such right to the investment
manager selected to manage the client’s Account
(which may include Baird, the Overlay Manager or
an Implementation Manager). A client may select
either option by making the appropriate election
in the client’s advisory agreement (and in the
case of a dual contract arrangement under the
Dual Contract Program, by providing proper
instructions to the manager directly). Some
managers do not offer proxy voting services in
connection with certain strategies, such as option
strategies. Clients pursuing those strategies will
automatically retain the right to vote proxies in
information about a
those
manager’s voting policies and procedures, clients
should review the manager’s Form ADV Part 2A
Brochure.
Discretionary Services
Under the PAM Investment Management Service,
a client may retain the right to vote proxies with
respect to the securities held in the client’s
Account, or a client may delegate such right to
Baird.
A client should understand that, the client may
not hold Advisory Class Shares in a non-Advisory
Account and that the client may not be able to
hold certain Advisory Class Shares in an account
held at another firm. Upon the termination of a
Service for an Account or the closure of an
Account for any reason, PAM and Baird may
convert or exchange the Advisory Class Shares
held in the Account to an appropriate non-
Advisory Class Shares issued by the same fund,
or, if an appropriate non-Advisory Class Shares is
not available, PAM and Baird may redeem or sell
such Advisory Class Shares.
If a client retains proxy voting authority, Baird will
forward proxy materials that Baird actually
receives to the client. The client will then be
solely responsible for analyzing the materials and
casting the vote.
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If a client delegates voting authority to Baird,
Baird will vote proxies solicited by, or with respect
to, securities held in the client’s Account for the
exclusive benefit of the client and in accordance
with policies and procedures adopted by Baird.
cast the vote in a manner he or she believes is in
the best interest of clients. The votes cast for a
client’s Account may differ from those votes cast
for other Baird clients based on differing views of
PAM Consultants and other Baird portfolio
managers.
Baird has adopted written policies and procedures
that are reasonably designed to ensure that it
votes client securities in the best interests of
clients. Those procedures address material
conflicts of interest that may arise between
Baird’s interests and those of its clients. Although
a description of Baird’s proxy voting policies and
procedures is provided below, Baird will furnish a
copy of its proxy voting policies and procedures to
clients upon their request. Additionally, clients
may obtain information on how Baird actually
voted proxies with respect to the securities held in
their accounts by contacting their PAM Consultant
or by calling (414) 765-3500.
Baird uses ISS’s electronic vote management
system to cast votes on behalf of clients. In
connection with Baird’s use of that system, ISS
pre-populates how client votes should be cast
based upon ISS’s voting recommendations. The
system allows Baird to change the pre-populated
vote (to the extent permitted by Baird’s proxy
voting policies) up until a certain time prior to the
applicable meeting (the “voting cut-off time”).
Baird’s proxy voting policies are designed to
address situations when additional information
becomes available after the votes are pre-
populated in the system and before the voting
cut-off time. However, there is no guarantee that
all information that could affect Baird’s proxy
voting decision will be received or considered by
Baird prior to a vote being cast.
interests. Baird utilizes
governance
services,
(or
voting
recommendations.
interests of
In situations in which a client has delegated to
Baird voting authority with respect to securities in
the client’s Account, Baird will vote proxies in a
manner that Baird believes is consistent with the
client’s best
an
independent provider of proxy voting and
corporate
currently
Institutional Shareholder Services (“ISS”), to
analyze proxy materials and votes and make
ISS
independent
provides proxy voting guidelines regarding its
position on various matters presented by
companies to their shareholders for consideration.
Baird will typically vote shares in accordance with
the recommendations made by ISS. However,
ISS’s guidelines are not exhaustive, do not
address all potential voting issues, and do not
necessarily correspond with the opinions of PAM
Consultants. In the event the client’s PAM
Consultant believes the ISS recommendation is
not in the best interest of the client, the PAM
Consultant will bring the issue to Baird’s Proxy
Voting Sub-Committee through a proxy challenge
then be
process. The Sub-Committee will
responsible for determining how the vote will be
cast. The decision made by the Proxy Voting Sub-
Committee on the proxy challenge applies to all
the PAM
advisory accounts managed by
Consultant (or team of PAM Consultants), unless
the client has directed Baird to utilize specific
voting guidelines (e.g., Taft-Hartley guidelines).
For those matters for which the independent
proxy voting service does not provide a specific
voting recommendation, each PAM Consultant will
The proxy voting policies and procedures also
address instances in which Baird’s interests may
appear to conflict with client interests, such as
when Baird or an affiliate of Baird is managing or
administering
to manage or
seeking
administer) a corporate retirement, pension or
employee benefit plan or providing (or seeking to
provide) advisory or other services to a company
whose management is soliciting proxies. In such
instances, there may be a concern that Baird
would be inclined to vote in favor of management
because of Baird’s relationship or pursuit of a
relationship with the company. In situations
where there is a potential conflict of interest,
Proxy Voting Sub-Committee will
Baird’s
determine the nature and materiality of the
conflict. If the conflict is determined to not be
material, the Sub-Committee will vote the proxy
in a manner the Sub-Committee believes is in the
the client and without
best
consideration of any benefit to Baird or its
affiliates. If the potential conflict is determined to
be material, Baird’s Proxy Voting Sub-Committee
will take one of the following steps to address the
potential conflict: (1) cast the vote in accordance
with the recommendations of ISS or other
independent third party; (2) refer the proxy to
the client or to a fiduciary of the client for voting
purposes; (3) suggest that the client engage
another party to determine how the proxy should
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with the rules of the New York Stock Exchange
and the SEC relating to such matters.
be voted; (4) if the matter is not addressed by
ISS, vote in accordance with management’s
recommendation; or (5) abstain from voting.
Legal Proceedings and Corporate Actions
Generally, none of PAM, Baird or any Other
Manager responsible for managing all or a portion
of the assets in a client’s Account will render
advice or take action on a client’s behalf with
respect to securities that are or were held in the
client’s Account, or the issuers thereof, which go
into default or become the subject of legal
proceedings, such as class action claims, defaults
or bankruptcies. Also, they may or may not vote
or advise clients on other corporate actions, like
tender offers, that are not solicited by a proxy
statement. At a client’s request, Baird will forward
information that Baird actually receives to the
client.
While Baird uses its best efforts to vote proxies,
there are instances when voting is not practical or
is not, in Baird’s or PAM Consultants’ view, in the
best interest of clients. For example, casting a
vote on a foreign security may involve additional
costs or may prevent, for a period of time, sales
of shares that have been voted. Also, when a
client has entered into a securities lending
program, Baird generally will not seek to recall
the securities on loan for the purpose of voting
the securities; however, Baird reserves the right
to recall the shares on loan on a best efforts basis
if the client’s PAM Consultant becomes aware of a
proxy proposal where the proxy vote is materially
important to the client’s Account.
In addition to the services described above, Baird
has engaged ISS for vote execution and record-
keeping services.
Financial Information
PAM does not require or solicit prepayment of
more than $1,200 in fees per client six months or
more in advance and, thus, has not included a
balance sheet of Baird’s most recent fiscal year.
Neither Baird nor PAM is aware of any financial
condition that is reasonably likely to impair their
ability to meet their contractual commitments to
clients, nor has either been the subject of a
bankruptcy petition at any time during the past
ten years.
Other Proxy Voting Information
Clients wishing to direct particular votes once
they have granted Baird discretionary voting
authority may do so by contacting their PAM
Consultant. However, if Baird has been granted
discretionary voting authority, neither PAM nor
Baird will provide a client with notice that Baird
has received a proxy solicitation, nor will they
consult with the client before casting a vote,
unless the client otherwise directs them to do so.
investment
other
compensation
related
to
Except to the extent a client has delegated proxy
voting authority to Baird, PAM and Baird have no
authority, direct or implicit, and accept no
responsibility for taking any action or rendering
any advice with respect to the voting of proxies
related to securities held in a client’s Accounts.
to
Special Considerations for Retirement
Accounts
Each Retirement Account Fiduciary of a client
should understand that PAM or Baird may invest
for the client, recommend that the client invest in,
or make available
to plan
for
participants, Associated Investment Products, that
Baird and its Associated Parties will receive fees
or
such
investments, and that they will retain such
compensation
the extent permitted by
applicable law, rule or regulation, including,
without limitation, Department of Labor (“DOL”)
Prohibited Transaction Exemption (“PTE”) 77-4,
DOL PTE 2020-02 or other advisory opinions
issued by the DOL.
To the extent Baird and its Associated Parties rely
upon PTE 77-4, each Retirement Account
Fiduciary should also understand that when PAM
or Baird invests the assets of a Retirement
Account in an Associated Investment Product that
pays investment advisory fees to Baird or any of
Providing Baird Voting Instructions
As mentioned above, Baird may be the holder of
record for certain securities in a client’s Account.
If the client retains voting authority over such
securities (or delegates such authority to party
other than Baird), and a proxy is solicited with
respect to any such securities, the client (or other
authorized party) will need to provide voting
instructions to Baird. To the extent the client (or
other authorized party) does not provide timely
voting instructions, Baird will vote such securities
to the extent permitted by law and in compliance
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
that
directed
the
fiduciary
Fiduciary
such Fiduciary
is
that
for complying with all
Parties
from
transactions, and
the duty
broker-dealer,
for
the Associated
and
terminating
monitoring
a
understand:
brokerage
the
arrangement must be for the exclusive benefit of
participants and beneficiaries of the Retirement
responsibilities
Account; and
discussed in ERISA Technical Bulletin 86-1. Each
should also
Retirement Account
solely
understand
responsible
fiduciary
in ERISA Technical
responsibilities discussed
Bulletin 86-1, including, without limitation, the
duty to make an initial determination that the
directed broker-dealer is capable of providing best
execution for the client’s brokerage transactions,
the duty to monitor the services provided by the
directed broker-dealer so as to assure that the
client has received best execution of the client’s
brokerage
to
determine that the commissions paid by the client
and any other fees or costs incurred by the client
are reasonable in relation to the value of the
brokerage and other services received by the
client. The client and each Retirement Account
Fiduciary of the client should also understand that
the client and the client’s Retirement Account
Fiduciaries are solely responsible for engaging a
directed
its
directed
performance
brokerage arrangement, and that PAM and Baird
are not responsible for determining whether a
directed broker-dealer is capable of providing best
execution.
the applicable
its Associated Parties, Baird and its Associated
Parties will receive such investment advisory fees
in accordance with the terms of DOL PTE 77-4,
and, as required thereby, PAM and Baird will
waive the asset-based Advisory Fees on that
portion of the assets invested in the Associated
Investment Product for such period of time so
invested or Baird will offset the investment
advisory fees received by Baird or any of its
the
Associated
Associated
Investment Product against
the asset-based
Advisory Fee that PAM and Baird charge to the
client. For the purpose of complying with the
terms of DOL PTE 77-4, the client and each
Retirement Account Fiduciary of
the client
acknowledge in the client’s advisory agreement
that: (i) the investment in Associated Investment
Products for the client’s Account is appropriate
because of, among other things, the investment
goals, redeemability, liquidity, and diversification
of those products; (ii) subject to the terms of the
applicable Service, all assets of the client’s
Account may be invested in one or more of the
Associated Investment Products; (iii) the client
and such Retirement Account Fiduciary received
prospectuses or other offering or disclosure
Investment
documents
Products that may be used in connection with the
Account, each of which include a summary of all
fees that may be paid by the Associated
Investment Products to Baird or its Associated
Parties; and (iv) the client received information
concerning
the nature and extent of any
differential between the rate of such Associated
Investment Product fees and the Advisory Fees
payable by the client. The differential between the
fees to be charged by PAM and Baird for the
investment advisory services they provide to the
client and, if applicable, the investment advisory
and other similar fees paid by the Associated
Investment Product to Baird or its Associated
Parties with respect to the services Baird or any of
its Associated Parties provides to the Associated
Investment Product is the difference between the
Advisory Fee disclosed in the client’s advisory
agreement and
investment
management, investment advisory and other
similar fees detailed in the applicable prospectus
or other offering or disclosure documents for the
Associated Investment Product.
If the client’s Account is a Retirement Account,
the client and each Retirement Account Fiduciary
of the client should note that the advisory
agreement authorizes Baird, in its capacity as
broker-dealer, to effect or execute securities
transactions for the client’s Account and to
receive commissions for such services, subject to
DOL PTE 86-128. In order to assist the client and
each Retirement Account Fiduciary of the client
with the determination as to whether such
authorization should be made, PAM will provide
the client with a copy of DOL PTE 86-128 and the
form to be used to terminate such authorization,
as well as the description of Baird’s brokerage
placement practices, which is set forth below.
PAM also will provide such other reasonably
available information that the client may request
for such purpose.
If the client’s Account is a Retirement Account
and if PAM is directed to implement a directed
brokerage arrangement for the Account, each
Retirement Account Fiduciary of the client should
When placing orders for securities transactions for
clients as a broker-dealer pursuant to DOL PTE
86-128, Baird has an obligation to use reasonable
diligence to ascertain the best market for the
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Services, please see “Other Financial Industry
Activities and Affiliations” above.
likelihood of price
in certain
funds. Baird may place orders
subject security and to buy or sell in such market
so that the resultant price to the client is as
favorable as possible under prevailing market
conditions. Baird routes or places client orders to
various market makers, exchanges and other
execution venues based on their quality of
execution and execution capabilities in order to
obtain the best possible price and speed of
for clients. Baird selects market
execution
makers, exchanges and other execution venues
based on the size of the order, the trading
characteristics of the particular security, speed of
improvement,
execution,
availability of efficient automated transaction
processing, guaranteed automatic execution level
and other qualitative
factors. Order routing
decisions are not based on the availability of
payment for order flow or other remuneration,
although Baird receives payments for order flow
or other remuneration
instances.
Additional information about Baird’s routing of
equity orders is available on Baird’s website at
bairdwealth.com/retailinvestor. Baird does not
place orders with market makers or other third
parties for the purpose of compensating such
firms for their efforts in marketing Baird-affiliated
for
mutual
securities transactions with third party broker-
dealers and other firms that provide research
products and services to Baird.
than
the
client
If a client’s Account is a Retirement Account and if
the client is selecting Associated Investment
Products and Services, each Retirement Account
Fiduciary of the client understands and agrees
that in making such selection: (a) Baird and its
Associated Parties may receive higher aggregate
compensation
selected
if
investment managers, funds or other products
not associated with Baird and thus Baird may
have an incentive to offer Associated Investment
Products and Services; (b) Baird makes available
to the client investment managers, funds and
products not associated with Baird and the client
may obtain additional information about such
unassociated investment managers, funds or
products at any time by contacting the client’s
PAM Consultant; and (c) the client is free to
choose another investment option or participate
in another Baird advisory program that does not
use investment managers, funds or products
associated with Baird at any time by contacting
the client’s PAM Consultant. For more information
Investment Products and
about Associated
110
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Appendix A
Associated Investment Products and Services
Entity Type
Name
Relationship
Baird Advisors1
Baird Department
Baird Equity Asset Management1
Baird Department
Chautauqua Capital Management1
Baird Department
55I, LLC (d/b/a 55ip, “55ip”)
Associated
Investment Advisor
GAMMA Investing, LLC
Affiliated
Greenhouse Fund GP LLC
Related
Greenhouse Funds LLLP
Related
LoCorr Fund Management, LLC
Related
Reinhart Partners, LLC
Affiliated
Riverfront Investment Group, LLC
Affiliated
Dual Registrant2
Strategas Securities, LLC
Affiliated
Trust Company
Baird Trust Company1
Affiliated
Baird Funds, Inc.1
Affiliated
Bridge Builder Trust (Baird series)
Affiliated
Mutual Fund
Financial Investors Trust (Riverfront series)
Affiliated
LoCorr Investment Trust
Related
Managed Portfolio Series Trust (Reinhart series)
Affiliated
Pace® Select Advisors Trust (Baird Series)
Affiliated
Advisors’ Inner Circle Fund III (Strategas series)
Affiliated
ETF
ALPS ETF Trust (Riverfront Series)
Affiliated
First Trust Exchange-Traded Fund III (Riverfront series)
Affiliated
Automated Quantitative Analysis (AQA®) Portfolio Series
Affiliated
UIT
Dividend Income Trust (DIT) Series
Affiliated
Strategas Trust, Series 1-1
Affiliated
CIT
Reliance Trust Institutional Retirement Trust (Baird/Chautauqua series)
Affiliated
Greenhouse Master Fund LP
Related
Hedge Fund
Greenhouse Onshore Fund LP
Related
Greenhouse Overseas Fund Ltd.
Related
Chautauqua Global Growth Equity QP Fund, LP
Affiliated
Private Fund
Chautauqua International Growth Equity QP Fund, LP
Affiliated
Chautauqua Series Fund, LLC
Affiliated
Appendix A - 1
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Venture Partners Management Company III, LLC
Baird Venture Partners III Limited Partnership
Affiliated
BVP III Affiliates Fund Limited Partnership
BVP III Special Affiliates Limited Partnership
Baird Venture Partners Management Company IV, LLC
Baird Venture Partners IV Limited Partnership
Affiliated
BVP IV Affiliates Fund Limited Partnership
BVP IV Special Affiliates Limited Partnership
Baird Venture Partners Management Company V, LLC
Baird Venture Partners V Limited Partnership
Affiliated
BVP V Affiliates Fund Limited Partnership
BVP V Special Affiliates Fund Limited Partnership
Baird Capital Partners Management Company V, LLC
Baird Capital1,3
Baird Capital Partners V Limited Partnership
Affiliated
Investment Advisor
BCP V Affiliates Fund Limited Partnership
Private Equity Fund
BCP V Special Affiliates Limited Partnership
Baird Capital Management Company, LLC
Baird Venture Partners GP VI, LLC
Baird Venture Partners VI LP
Affiliated
BVP VI Affiliates Fund LP
BVP VI Special Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management I LP
Baird Capital Global Fund I LP
Affiliated
Baird Capital Global Fund I-DE LP
BCGF I Special Affiliates LP
BCGF I Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management II LLC
Baird Capital Global Fund II Limited Partnership
Affiliated
BCGF II Affiliates Fund Limited Partnership
BCGF II Special Affiliates Limited Partnership
Appendix A - 2
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Capital Management Company, LLC
Baird Capital Global GP III LLC
Baird Capital Global Fund III LP
Affiliated
Baird Capital1,3
BCGF III Affiliates Fund LP
Investment Advisor
BCGF III Special Affiliates LP
Private Equity Fund
Baird Capital Partners Europe Limited4
Baird Capital Partners Europe II LP
Affiliated
Baird Capital Partners Europe II Special Affiliates LP
The Growth Fund
Baird Principal Group Management Company I, LLC
Baird Principal Group5
Baird Principal Group Partners Fund I Limited Partnership
Investment Advisor
Baird Principal Group Management Company II, LLC
Affiliated
Private Equity Fund
Baird Principal Group Partners Fund II Limited Partnership
Baird Principal Group Management Company, LLC
Baird Principal Group Partners Fund III, LP
Holding Company
Sagard Holdings Management, Inc.6
Associated
1. Participates in a Baird PWM Referral Program that pays compensation to PAM Consultants for eligible referrals.
2. Registered with the SEC as a broker-dealer and investment advisor.
3. Baird Capital, Baird’s private equity business.
4. Baird Capital Partners Europe Limited, an English limited company, is regulated and authorized by the Financial
Conduct Authority.
5. Baird Principal Group, a group within Baird that has private equity funds only available to Baird employees.
6. Baird has a contractual relationship with and a small minority investment in Sagard Holdings Management, Inc., a
holding company for various financial services businesses whose investment products are made available to clients under
the Services. See “Other Financial Industry Activities and Affiliations—Certain Relationships and Arrangements—Baird and
Associated Parties” above for more information.
Appendix A - 3
Baird PAM F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Additional Brochure: BAIRD PRIVATE ASSET MANAGEMENT - WRAP (2026-03-27)
View Document Text
Baird Private Asset Management
Wrap Fee Program Brochure
March 27, 2026
Baird Private Asset Management
777 East Wisconsin Avenue
Milwaukee, Wisconsin 53202
Toll Free: 888-596-1592
www.rwbaird.com
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue
Milwaukee, WI 53202
1-800-792-2473
rwbaird.com
Member FINRA & SIPC
SEC File No. 801-7571
This wrap fee program brochure (“Brochure”) provides information about the qualifications and
business practices of Robert W. Baird & Co. Incorporated (“Baird”) and Baird Private Asset
Management (“PAM”), part of Baird’s Private Wealth Management department. Clients should
carefully consider this information before becoming a client of PAM. If you have any questions about
the contents of this Brochure, please contact PAM at the toll-free phone number listed above. The
information contained in this Brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority. Additional information
about Baird is available on the SEC’s website at www.adviserinfo.sec.gov.
Material Changes
Baird Private Asset Management (“PAM”), part of the Private Wealth Management department of Robert W.
Baird & Co. Incorporated (“Baird”), updated its Form ADV Part 2A wrap fee program brochure (the
“Brochure”) on March 27, 2026. The following summary discusses the material changes that PAM has made
to the Brochure since March 21, 2025, the date of the last annual update to the Brochure.
• In January 2026, Baird’s direct parent corporation, Baird Financial Corporation (“BFC”), made a
significant minority investment in Reinhart Partners, LLC (“Reinhart”), an investment advisor that offers
investment products and services through the Programs. As a result of the investment transaction, Baird
and Reinhart are affiliated, providing Baird a financial incentive to use, select or recommend Reinhart
investment products and services.
“Additional
Information—Other Financial
• In September 2025, Baird entered into a strategic partnership with Sagard Holdings Management, Inc.
(“Sagard”). Baird’s direct parent corporation, BFC, acquired a minority ownership interest in Sagard and
the right to appoint a member to Sagard’s board of directors. Baird agreed to use best efforts,
consistent with its fiduciary duties and other regulatory responsibilities, to offer investment products
managed or sponsored by affiliates of Sagard deemed suitable by Baird for its PWM clients, providing
Baird a financial incentive to recommend such investment products. See the Section of the Brochure
entitled
Industry Activities and Affiliations—Certain
Relationships and Arrangements—Baird and Associated Parties” for more information.
• Baird updated its description of the DC Program. The DC Program is designed to accommodate a client
who wishes to independently select an investment manager not available in the PAM Recommended
Managers Service or BSN Program to manage the assets in the client’s Account. The Program is also
designed for a client that wants to independently select a manager and negotiate the manager’s
Portfolio Fee rate directly with the manager. Certain managers offer lower Portfolio Fee rates to clients
through the DC Program compared to the BAM, PAM Recommended Managers, or BSN Programs. A
client considering an SMA Strategy should discuss with client’s PAM Consultant SMA Strategy availability
and the different Portfolio Fee rates, costs, and the types and levels of service provided in connection
with the different Programs. If a client has decided to participate in the DC Program, upon the client’s
request, the client’s PAM Consultant may assist the client with the client’s negotiation with the manager
of the Portfolio Fee rate for the applicable SMA Strategy. The Portfolio Fee negotiated by the client could
be higher or lower than the Portfolio Fee that applies to the same SMA Strategy that is available through
other Programs. The client is ultimately responsible for understanding the differences between the SMA
Programs, deciding to participate in the DC Program, selecting the SMA Strategy, and negotiating and
agreeing to the Portfolio Fee rate.
• Baird updated information about tax management and direct indexing strategies, including the
associated limitations and risks. See the Sections of the Brochure entitled “Services, Fees and
Compensation—Additional Service Information—Tax Management Services” and “Portfolio Manager
Selection and Evaluation—Methods of Analysis, Investment Strategies and Risk of Loss—Investment
Strategies” for more information.
• Baird provided additional information about possible tax consequences of a client’s investment activities.
See the Section of the Brochure entitled “Services, Fees and Compensation—Additional Service
Information—Legal and Tax Considerations” for more information.
• Baird updated the rates of Portfolio Fees charged by managers under the Services. See the Section of
the Brochure entitled “Services, Fees and Compensation—Advisory Fees” for more information.
• Baird updated information about Baird’s regulatory assets under management. See the Section of the
Brochure entitled “Portfolio Manager Selection and Evaluation—Selection and Evaluation—Advisory
Business” for more information.
ii
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• Baird updated its disclosures about the research, information and tools used by Baird PWM home office
investment professionals and PAM Consultants when formulating investment advice, which may include
the use of artificial intelligence (“AI”) tools, and the related risks. See the Section of the Brochure
entitled “Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and
Risk of Loss—Methods of Analysis” for more information.
• Baird included a description of the PWM Stock Opportunities List. See the Section of the Brochure
entitled “Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and
Risk of Loss—Methods of Analysis—Certain Eligible Product Lists” for more information.
• Baird updated investment risk information related to information security, cybersecurity, and other
technology‑related events, issuers’ use of AI, investments in digital assets, such as cryptocurrencies,
and those associated with recent events, such as those associated with the U.S. administration’s policy
initiatives, inflation, conflicts in Iran and the Middle East, the war between Ukraine and Russia, and the
strain in relationships between the U.S. and other countries. See the Section of the Brochure entitled
“Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and Risk of
Loss—Principal Risks” for more specific information.
• In March 2026, Baird entered into an Offer of Settlement with the Massachusetts Securities Division to
settle a regulatory matter relating to the timing of state investment adviser representative registration
approvals for two of Baird’s Financial Advisors located in Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals provided investment advisory services before their
Massachusetts registrations were completed as a form was missing from their application materials. 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.
• Baird updated information about firms affiliated with, related to, or otherwise associated with Baird. See
the Section of the Brochure entitled “Additional Information—Other Financial Industry Activities and
Affiliations” and Appendix A to the Brochure for more information.
A client should note that the foregoing summary only discusses material changes made to the Brochure
since March 21, 2025. The updated Brochure contains changes that are not listed above.
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Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Table of Contents
Services, Fees and Compensation ................................................................... 1
The Client-Baird Fiduciary Relationship ............................................................ 1
Summary of PAM’s Services ........................................................................... 1
Consulting Services ...................................................................................... 4
Discretionary Services ................................................................................... 6
PAM FOCUS Portfolios Program ................................................................. 6
PAM Investment Management Service ....................................................... 6
Non-Discretionary Services ............................................................................ 7
Baird Advisory Choice Program ................................................................. 7
SMA Services ............................................................................................... 9
PAM Recommended Managers Service ....................................................... 9
Baird SMA Network Program .................................................................. 11
Dual Contract Program .......................................................................... 13
Other SMA Strategy Information ............................................................. 14
Additional Service Information ..................................................................... 15
Investment Discretion ........................................................................... 15
Trading for Client Accounts .................................................................... 17
Complex Strategies and Complex Investment Products .............................. 24
Permitted Investments .......................................................................... 27
Unsupervised Assets ............................................................................. 28
Special Considerations for the Services .................................................... 29
Household Management ......................................................................... 30
Tax Management Services ..................................................................... 31
Investment Objectives ........................................................................... 33
Mutual Fund Share Class Policy ............................................................... 34
Custody Services .................................................................................. 35
Cash Sweep Program ............................................................................ 36
Trust Services Arrangements .................................................................. 38
Margin Loans ........................................................................................ 38
Securities-Based Lending Program .......................................................... 39
Other Non-Advisory Services .................................................................. 40
Client Responsibilities ............................................................................ 40
Retirement Accounts ............................................................................. 40
Legal and Tax Considerations ................................................................. 40
Advisory Fees ............................................................................................ 41
Fee Options and Fee Schedules............................................................... 41
Service Account Minimums ..................................................................... 43
Calculation and Payment of Advisory Fees ................................................ 44
Obtaining Services Separately: Brokerage or Advisory? Factors
to Consider ...................................................................................... 46
Advisory Fee Payments to Baird, PAM Consultants and
Investment Managers ........................................................................ 47
Other Fees and Expenses ............................................................................ 49
Cost and Expense Information for Certain Investment Products .................. 49
Additional Account Fees and Charges ...................................................... 49
Other Fees and Charges ........................................................................ 49
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Baird PAM Wrap Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Compensation Received by PAM and Baird ..................................................... 50
Account Requirements and Types of Clients .................................................. 51
Opening an Account .................................................................................... 51
Certain Account Requirements ..................................................................... 51
Minimum Account Size ........................................................................... 51
Account Contributions and Withdrawals ................................................... 51
Liens and Use of Account Assets as Collateral ........................................... 53
Electronic Delivery of Documents ............................................................ 53
Termination of Accounts .............................................................................. 53
Types of Clients.......................................................................................... 54
Portfolio Manager Selection and Evaluation .................................................. 54
Selection and Evaluation ............................................................................. 54
PAM Recommended Managers ................................................................ 54
Baird SMA Network and Dual Contract Programs ....................................... 55
PAM FOCUS Portfolios Program and PAM Investment
Management Service ......................................................................... 56
Oversight of the Services ....................................................................... 56
Performance Calculation .............................................................................. 57
Portfolio Management by PAM, Baird and Associated Managers ........................ 58
Advisory Business ....................................................................................... 58
Performance-Based Fees and Side-By-Side Management ................................. 59
Methods of Analysis, Investment Strategies and Risk of Loss ........................... 59
Investment Strategies ........................................................................... 59
Methods of Analysis .............................................................................. 67
Program Portfolio Strategies ................................................................... 78
Principal Risks ...................................................................................... 80
Voting Client Securities ............................................................................... 99
Baird Advisory Choice Program and Other Non-Discretionary
Accounts .......................................................................................... 99
Separately Managed Accounts ................................................................ 99
Discretionary Services ........................................................................... 99
Other Proxy Voting Information ............................................................. 101
Providing Baird Voting Instructions......................................................... 101
Legal Proceedings and Corporate Actions ................................................ 101
Client Information Provided to Portfolio Managers ..................................... 101
Client Contact with Portfolio Managers ....................................................... 101
Additional Information ................................................................................ 101
Disciplinary Information ............................................................................. 101
Other Financial Industry Activities and Affiliations .......................................... 104
Baird’s Broker-Dealer Activities .............................................................. 104
Certain Relationships and Arrangements ................................................. 104
Relationships and Arrangements with Investment Managers ...................... 106
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading ................................................................................... 106
Code of Ethics ..................................................................................... 106
Participation or Interest in Client Transactions ......................................... 107
Review of Accounts .................................................................................... 113
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Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Client Account Review .......................................................................... 113
Account Statements and Performance Reports ......................................... 114
Client Referrals and Other Compensation ..................................................... 115
Financial Information ................................................................................. 115
Special Considerations for Retirement Accounts ............................................ 115
Associated Investment Products and Services ............................. Appendix A-1
vi
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
contain
information about
and
retirement
accounts, which
adviser under the Investment Advisers Act of
1940, as amended (the “Advisers Act”). PAM and
Baird are deemed to have a fiduciary relationship
with a client when providing the investment
advisory services that are described in this
Brochure. That means that PAM and Baird are
required to act in the best interest of the client
when providing investment advisory services.
From time to time PAM and Baird may engage in
certain business practices or may
receive
compensation or other benefits that create a
potential for conflict between the interests of
clients and the interests of PAM and Baird. PAM
and Baird generally address potential conflicts of
interest by disclosing them to clients through
documents provided to clients, including, without
limitation, this Brochure, Brochure supplements
individuals
that
providing investment advice to clients and the
services they provide, and the agreements clients
enter into with PAM and Baird. In addition, Baird
has adopted internal policies and procedures for
PAM and Baird that require them to: provide
investment advice that is suitable for advisory
clients (based upon the information provided by
such clients); make full disclosure of all potential,
material conflicts of interest; act with utmost care
and good faith in dealings with advisory clients;
and seek to obtain “best execution” of advisory
client transactions. The specific business practices
that create potential conflicts of interest with
clients and additional measures used by PAM and
Baird to address them are discussed in other
sections of this Brochure.
(“IRC”)
(collectively,
A client should note that registration as an
investment adviser does not imply a certain level
of skill or training.
including
advisory
account
advised by
Services, Fees and Compensation
This Brochure describes some of the investment
advisory services that Robert W. Baird & Co.
Incorporated (“Baird”) offers to its clients through
Private Asset Management (“PAM”), a team of
Baird Financial Advisors (“PAM Consultants”)
within Baird’s Private Wealth Management
(“PWM”) department. Baird and PAM offer other
investment advisory services not described in this
Brochure. Separate brochures describe those
other investment advisory services and discuss
the terms and conditions, fees and costs and
potential conflicts of interest associated with
those services. This Brochure also references
other documents that contain additional important
information about Baird. Those documents
describe the types of investment products and
services that Baird makes available to clients,
including the terms, conditions, fees, costs, risks,
and conflicts of interest applicable to those
investment products
services. Those
documents are available on Baird’s website at
bairdwealth.com/retailinvestor. Included on that
website is Baird’s Client Relationship Booklet,
contains Baird’s Form CRS Client
which
and Baird’s Client
Relationship Summary
Relationship Details document. The Client
Relationship Booklet also contains an important
disclosure document for retirement investors that
have
include
employee pension benefit plan accounts that are
subject to the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”) and
individual retirement accounts (“IRAs”) that are
subject to the Internal Revenue Code of 1986, as
“Retirement
amended
Accounts”). A client of Baird should have already
received a copy of the Client Relationship Booklet.
A client or prospective client who wishes to obtain
a brochure for another investment advisory
service provided by Baird, or a paper copy of any
of the other documents referenced
in this
Brochure,
the Client Relationship
Booklet, should contact a PAM Consultant or call
Baird toll-free at 1-800-792-2473.
reporting and
The information contained in this Brochure is
current as of the date above and is subject to
change at Baird’s discretion. Please retain this
Brochure for your records.
Summary of PAM’s Services
This Brochure describes certain
investment
advisory programs and services that PAM and
Baird offer to clients (“Services”) and applies to
each
PAM
(“Account”). The investment advisory services
offered under the Services generally include
investment advice and consulting services,
performance
related account
services, which are provided by Baird PWM’s
home office investment professionals or PAM,
and, depending upon the Service that a client
selects,
include portfolio
the Service may
management. The Services consist of:
The Client-Baird Fiduciary Relationship
is registered with the Securities and
Baird
Exchange Commission (“SEC”) as an investment
1
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
consulting
services
(“Consulting
• certain
Services”);
the client has
between the client and PAM and Baird; the client
does not have an agreement directly with the
client’s investment manager. Under the Dual
Contract Program, a client has a “dual contract”
arrangement, meaning
two
contracts; one contract with PAM and Baird and
another contract with the client’s investment
manager.
• discretionary services, whereby a client gives
PAM or Baird (including Baird PWM’s home
office investment professionals or the client’s
PAM Consultant) full discretionary authority to
manage the client’s Account (“Discretionary
Services”);
provide
investment
advice
Certain Programs may allow a client to invest in
groups of mutual funds and ETFs (referred to as
“sleeves”) and other model portfolios of securities
managed by Baird PWM (such sleeves and model
portfolios collectively, “PWM-Managed Portfolios”).
client’s
Account
• non-discretionary services, whereby PAM or
Baird
and
recommendations but the client retains full
authority with respect to the management of
the
(“Non-Discretionary
Services”); and
The SMA Programs allow a client to select among
a variety of SMA Strategies offered by third party
investment managers (“Other Managers”), which
may include Other Managers affiliated with,
related to, or otherwise associated with Baird
(“Associated Managers”), or Baird to manage the
client’s Account.
• separately managed account (“SMA”) programs
and services, whereby an investment manager
manages the client’s Account according to a
strategy (each, an “SMA Strategy”) with full
discretionary authority, and PAM and Baird
provide additional consulting services to the
client (collectively, “SMA Services”).
Depending on their particular needs or objectives,
clients may use one or more of these Services.
include:
The Consulting Services include: assisting a client
with the development of an investment policy
statement; asset allocation reporting; investment
manager search, investment manager interviews,
performance reviews, performance monitoring,
asset allocation and funding requirement analysis;
asset liability modeling; and annuity modeling. In
certain instances, PAM may also provide clients
with asset allocation and funding requirement
liability modeling. The
analysis and asset
Discretionary Services
include: PAM FOCUS
Portfolios; and PAM Investment Management. The
Non-Discretionary
Baird
Services
Advisory Choice. The SMA Services include: PAM
Recommended Managers; Baird SMA Network
(“BSN”); and Dual Contract (“DC”).
Manager,
and
Baird has engaged an overlay management firm,
Envestnet Asset Management, Inc. (the “Overlay
Manager”) to provide certain subadvisory services
to clients that participate in certain SMA Services.
The SMA Services make available two types of
SMA Strategies: (1) manager-traded strategies,
whereby the manager itself manages a client’s
Account and conducts the trading to implement
the SMA Strategy selected by the client (a
“Manager-Traded Strategy”); and (2) model-
traded strategies, whereby the manager does not
manage a client’s Account (a “Model Provider”)
but instead provides a model portfolio (“Model
Portfolio”) to an overlay management firm, which
may include the Overlay Manager, Baird or other
third party
firm (each, an “Implementation
Manager”), that in turn manages a client’s
Account and conducts the trading to implement
the SMA Strategy selected by the client (a
“Model-Traded Strategy”). If a client selects a
Model-Traded Strategy, the Model Provider will
provide the Model Portfolio and updates to the
Implementation
the
Implementation Manager will manage the client’s
Account with full discretionary authority according
to the strategy selected by the client. Otherwise,
if the client selects a Manager-Traded Strategy,
the investment manager will directly manage the
client’s Account with full discretionary authority as
more fully described below.
The SMA Services are generally offered under a
“single contract” arrangement. Under a single
contract arrangement, a client enters into an
advisory agreement with PAM and Baird, and
Baird, in turn, enters into a subadvisory or similar
agreement with the investment manager on the
client’s behalf. This type of arrangement is
frequently referred to as a single contract
arrangement because there is only one contract
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Baird PAM Wrap Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks” below for more
information.
allocation
strategies
have
Fee.
See
“Additional
Baird is also registered with the SEC as a broker-
dealer under Securities Exchange Act of 1934, as
amended (the “Exchange Act”). PAM and Baird
provide the Services described in this Brochure
under a “wrap fee” arrangement. This means that
in addition to the investment advisory services
that PAM and Baird provide in connection with
each Service, Baird, in its capacity as broker-
dealer, also provides clients with trade execution,
custody and other standard brokerage services for
a single fee (“Advisory Fee”). A client should note
that the client may incur costs in addition to the
Service
Advisory
Information—Trading for Client Accounts” and
“Other Fees and Expenses” below for more
information.
to execute
transactions without
referred
intend
Each Service is designed to address different
investment needs of clients. All of the Services
discussed in this Brochure may not be appropriate
for every client. For example, the Services may
not be appropriate for clients who have low or no
trading activity, who desire to pay transaction-
based fees, who maintain their accounts invested
in high levels of cash or other concentrated
positions, who do not want ongoing professional
investment advice or account monitoring, who
tend
the
recommendation or advice of an advisor, which
to as “unsolicited”
are commonly
to utilize an
transactions, or who
investment strategy, product or solution that is
not available in a Service.
Certain Services make available asset allocation
investment strategies. Asset allocation strategies
involve investing in one or more categories of
assets, such as equity securities, fixed income
securities, Non-Traditional Assets, Alternative
Investment Products and cash, and one or more
subcategories of assets, called asset classes.
Asset
varying
investment objectives and investment strategies.
Some asset allocation strategies use strategic
investment strategies, which involve investing
accounts in accordance with a predetermined
target allocation to different asset classes. Some
asset allocation strategies use tactical investing,
which typically involves tactically and actively
adjusting account allocations to different asset
classes based upon the manager’s perception of
how those asset classes will perform in the short-
term. Some asset allocation strategies involve the
use of both strategic and tactical investment
strategies, sometimes referred to as dynamic
strategies. Asset allocation strategies may be
implemented using a variety of investment types,
such as individual securities, mutual funds and
exchange traded products (“ETPs”), including
exchange traded funds (“ETFs”) and exchange
traded notes (“ETNs”). The amount allocated to
an asset class or investment type varies by
strategy, and some strategies may have little or
no allocation to one or more asset classes or
types of
investments described above. See
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of
Loss—Investment Strategies—Asset
Allocation Strategies” below for more information.
and bonds
(collectively,
funds, ETFs, unit
investment products
Some Services offer clients the ability to pursue
alternative investment strategies (“Alternative
Strategies”) or other non-traditional or complex
investment strategies that involve special risks
not apparent in more traditional investments like
“Complex
stocks
Strategies”). Similarly, some Programs offer
clients the ability to invest in non-traditional or
real assets (“Non-Traditional Assets”). Some
Programs also offer the ability to invest in
that pursue Alternative
investment products
Strategies (“Alternative Investment Products”) or
other Complex Strategies (collectively, “Complex
these
Investment Products”). The use of
involves
strategies and
special risks, and a client should not engage in a
strategy or purchase an investment product
unless the client understands the related risks.
See “Additional Service Information—Complex
Strategies and Complex Investment Products”
and “Portfolio Manager Selection and Evaluation—
The Services make available many different
investment products and services offered by third
parties that are not associated with Baird, such as
mutual
investment trusts
(“UITs”), collective investment trusts (“CITs”),
private equity funds, hedge funds, private funds
and other investment pools (collectively “Funds”).
However, certain
investment products and
services managed, advised or sponsored by Baird
or other parties affiliated with, related to, or
otherwise associated with Baird,
including
Associated Managers (“Associated Parties”), have
been selected for inclusion in certain Services or
are made available to clients through Service
Accounts (“Associated Investment Products and
3
Baird PAM Wrap Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
“Account Requirements and Types of Clients”
below for more information.
“Additional
Services”). Associated Investment Products and
Services generally consist Funds managed,
advised or sponsored by Baird or Associated
Parties (“Associated Funds”) and other investment
products managed, advised or sponsored by Baird
or Associated Parties (collectively, “Associated
Investment Products”), and SMA Strategies
managed or advised by Baird or Associated
Managers (“Associated SMA Strategies”). Baird
and PAM Consultants may use, select or
recommend Associated Investment Products and
Services. This may present a conflict of interest. A
client is free at any time to select investment
products and services that are not associated with
Baird. For specific information about Associated
Parties and Associated Investment Products and
Services, see
Information—Other
Financial Industry Activities and Affiliations”
below.
As mentioned above, Baird, in its capacity as
broker-dealer, also provides PAM clients with
trade execution, custody and other standard
brokerage services. For this reason, a client will
also enter into a client relationship agreement or
other account agreement with PAM and Baird
(“account agreement”) if the client has not
already done so. The client’s account agreement
authorizes PAM and Baird to execute trades for,
and perform related brokerage and custody
services to, the client’s Account. Baird generally
does not permit a client to include assets in the
client’s Account that are held by a third party
custodian or that are otherwise held outside of a
Baird account (“Held-Away Assets”), although
PAM will provide Consulting Services on Held-
Away Assets when requested by a client and
agreed to by PAM.
Service
has
different
include
a
client’s
age,
and
ongoing
research,
Each
structures,
administration, types and levels of service, and
fees and expenses. In particular, a client should
note that the
investment advisory services
provided by PAM and Baird, including the depth of
initial
evaluation,
monitoring and review of the investments in a
client’s Account, varies by Service and the
investments selected for the Account.
the
A client’s PAM Consultant will offer or recommend
appropriate Services, investment strategies, and
investment products and services based upon a
client’s
investment profile and an Account’s
investment objective, which establishes an
Account’s investment return objective and risk
investment profile will
tolerance. A client’s
generally
other
investments, financial situation and needs, tax
status, investment goals, investment experience,
investment time horizon, liquidity needs, risk
tolerance and other relevant information provided
by a client and updated from time to time.
Although a PAM Consultant may offer or
recommend appropriate options, a client will
investment objective,
ultimately select
Services, investment strategies, and investment
products and services for an Account.
The foregoing discussion of the Services is only a
summary. More specific information about the
Services and the particular investment advisory
services that PAM and Baird provide in connection
with each Service are further described below and
in the client’s advisory agreement. Clients are
encouraged to review this Brochure and their
advisory agreement carefully.
Consulting Services
PAM offers the following Consulting Services.
in preparing an
the client’s
A client that wishes to participate in a Service will
enter into a client relationship agreement or other
investment advisory agreement with PAM and
Baird
client’s
(“advisory agreement”). The
advisory agreement will contain the specific terms
applicable to the services selected by the client,
fees payable by the client, and other terms
applicable to the client’s advisory relationship with
PAM and Baird. A client should note that the
client’s advisory relationship with PAM and Baird
does not begin until they enter into the applicable
advisory agreement with the client, which occurs
when Baird PWM’s Home Office has accepted the
client’s advisory agreement and determined that
all of the client’s paperwork is in order. See
Investment Policy Statement. PAM will assist a
Investment Policy
client
Statement reflecting
investment
objectives, policies, constraints, and risk profile.
The Investment Policy Statement is designed to
provide guidance to the client’s
investment
manager(s). The Investment Policy Statement is
a product of information and data provided by the
client; therefore, the client is responsible for
review and final approval of the Investment Policy
4
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the
provide
a
accurately
reflects
the
Statement. The client is solely responsible for
Investment Policy
determining whether
Statement
client’s
investment objectives, policies, constraints, and
risk profile.
Performance Monitoring Reports. PAM will
periodically
client written
to
Performance Monitoring Reports which include
calculations of the performance of the client’s
Account(s) over various
time periods and
compare various aspects of such performance to
one or more benchmark indices.
PAM offers the following consulting services to
clients only in special arrangements:
Asset
Allocation
and
for
determining whether
into account by PAM
Asset Allocation Report. PAM provides to a client
or its fiduciaries an Asset Allocation Report which
identifies one or more investment portfolios for
the client (in terms of risk and return) based on
certain
information requested by PAM and
provided by the client. The client is solely
the
responsible
information taken
in
formulating an Asset Allocation Report is accurate
and complete.
Annual
Funding
the
Requirements. Annually, PAM evaluates
adequacy of the client’s current and target asset
allocation to meet projected liabilities. The client
provides actuarial data that PAM relies upon as
accurate and complete. PAM’s analysis assesses
the long term funding risks associated with the
client’s current asset allocation, and if necessary,
PAM recommends a rebalancing plan which
supports the transition to, and maintenance of,
the client’s target asset allocation.
for any
Investment Manager Search Report. PAM provides
to a client an Investment Manager Search Report
that lists investment managers with investment
philosophies and investment strategies believed
to be consistent with the client’s investment
objectives, policies, constraints, and risk profile,
as specified by the client to PAM. PAM does not
assume responsibility for the client’s choice of any
investment manager or
investment
this
manager’s performance when providing
service to the client, nor is PAM responsible for an
unaffiliated
investment manager’s compliance
with applicable law or for matters beyond PAM’s
reasonable control. Investment Manager Search
Interviews. PAM coordinates client interviews with
a select number of investment managers listed on
the Investment Manager Search Report. The
interviews enable the client to gain additional
information regarding such investment managers’
respective investment philosophies, policies and
business operations.
Asset Liability Modeling. As a client’s actuarial
inputs, economic situations, and/or
liabilities
change, the client’s current asset allocation
should be altered. PAM provides a liability model
to help the client determine the appropriate time
to alter the asset mix, as well as the proper
assets to draw down in the proper sequence.
Actuarial assumptions used to forecast the size of
the future liability stream are provided by the
client or the client’s agent, and PAM relies upon
such information as accurate and complete. As
the client’s liabilities come due, the client works
with PAM to determine the order and amount of
each segment of the portfolio(s) to withdraw from
in order to minimize transition costs. This service
is typically performed annually.
compares
various
aspects
of
appropriate
given
annual
changes
Past Performance Reviews. PAM provides to a
client a Past Performance Review which, based on
information supplied by the client, includes the
historical performance of the client’s portfolios
and
such
performance to one or more benchmark indices.
Account data will be derived from information
provided by the client or its agent(s) for the
agreed upon time period. PAM is not responsible
for verifying information supplied by the client or
its agent(s).
Annual Annuity Modeling. Annually,
PAM
recommends changes to the client’s asset/liability
projection model. PAM assists the client model
projected liabilities under various assumptions to
contribution
project
requirements
liability
in
projections, actuarial assumptions, the current
level of assets held and the current expected
asset growth assumptions. PAM maintains and
refines the calculation models.
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Baird PAM Wrap Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Discretionary Services
PAM FOCUS Portfolios Program
in
certain
strategic
asset
allocation
Service
PAM and Baird may replace investments in a
client’s Account, rebalance a client’s Account
assets to be consistent with the client’s chosen
PAM FOCUS Portfolio strategy, change the client’s
asset allocation, or engage in tax management
circumstances. See
strategies
“Additional
Information—Special
Considerations for PAM FOCUS and SMA Clients”
Information—Tax
Service
“Additional
Management” below for more information.
Important
Information about Affiliated
Funds. Some of the mutual funds offered by the
Baird Funds, which is affiliated with Baird, have
been selected by Baird for inclusion in certain PAM
FOCUS Portfolios. This presents a conflict of
interest. For more information, see “Additional
Information—Other Financial Industry Activities
and Affiliations” below.
PAM Investment Management Service
Under the PAM FOCUS Portfolios Program, PAM
and Baird manage a client’s Account with full
discretionary authority according to a proprietary
model
strategy
developed by PAM and Baird (each such model a
“PAM FOCUS Portfolio”) that is selected by the
client. The PAM FOCUS Portfolios Program offers
model asset allocation portfolios
that have
different investment objectives and use different
strategic investment strategies. Each PAM FOCUS
Portfolio provides for specific levels of investment
across different asset classes, such as equity
securities, fixed income securities, Non-Traditional
Assets, Alternative Investment Products and cash.
Each Portfolio generally uses mutual funds and
ETPs, primarily ETFs, in order to implement the
model asset allocation strategy. The amount
allocated to an asset class or type of investment
varies by Portfolio, and some Portfolios may have
little or no allocation to one or more asset classes
or types of investments described above.
Under the PAM Investment Management Service,
a client grants full discretionary authority and
management of the client’s Account to Baird and
the client’s PAM Consultant.
reviews
the client’s
PAM and Baird construct each PAM FOCUS
Portfolio and adjust the asset allocation of each
PAM FOCUS Portfolio from time to time. PAM and
Baird also determine the mutual funds and ETFs
that are available in the PAM FOCUS Portfolios
Program, including the percentage each mutual
fund or ETF comprises in each asset class within a
PAM FOCUS Portfolio. PAM and Baird may make
changes to a PAM FOCUS Portfolio from time to
time as they deem appropriate and without
providing prior notice to, or obtaining the consent
of, a client.
specific
information about
In the PAM Investment Management Service, a
client’s PAM Consultant seeks to meet the client’s
particular investment needs by developing a
customized
investment strategy based upon
guidelines that are jointly established by the client
and
the
the client’s PAM Consultant. At
commencement of services, the client’s PAM
Consultant
investment
objectives and risk tolerance. Based upon that
review and other information provided by the
client, the PAM Consultant makes a subsequent
recommendation to the client as to which
investment style the PAM Consultant believes is
best suited for the client. A client makes the final
decision as to which investment style is chosen
for the client’s Account. More specific information
as to how the client’s PAM Consultant will manage
the client’s Account is provided to the client in
connection with the opening of the Account.
For more
the
investment options made available through the
Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those investment options,
if any, see “Portfolio Manager Selection and
Investment
Evaluation—Methods of Analysis,
Strategies and Risk of Loss—Program Portfolio
Strategies—PAM FOCUS Portfolios Program”
below.
to, equity securities,
fixed
A PAM Consultant may make investments in
various types of securities, including, but not
income
limited
securities, mutual funds, ETFs, Non-Traditional
Assets and
Investment
certain Alternative
Products. All or a portion of the assets in a client’s
Account may be held in cash or cash equivalents,
including securities issued by money market
Some of the services provided under this Program
may be provided to a client by a PAM Consultant
assigned to the client’s Account. Typically, a client
selects the PAM FOCUS Portfolio appropriate for
the client’s Account with the assistance of the
client’s PAM Consultant.
6
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Some of the services provided under this Program
may be provided to a client by a PAM Consultant
assigned to the client’s Account.
“Additional
Service
Investments” below.
PAM
about
Strategies—PAM
mutual funds, or may be deposited in interest-
bearing bank accounts. Additional information
about the types of investments a PAM Consultant
may use for client accounts is contained under the
Information—
heading
For more
Permitted
information
Investment
the
Management Service, see “Portfolio Manager
Selection and Evaluation—Methods of Analysis,
Investment Strategies and Risk of Loss—Program
Portfolio
Investment
Management Service” below.
Some PAM Consultants may recommend that a
client implement a model portfolio in the client’s
Advisory Choice Account. A client implementing a
model portfolio in the client’s Advisory Choice
Account may have the option to have Baird and
the client’s PAM Consultant rebalance the client’s
Advisory Choice Account to the target asset
allocations specified by the model portfolio at
predetermined intervals. Currently, Baird offers
the following rebalance options to applicable
Advisory Choice Accounts: annual, semi-annual
and quarterly.
Baird may remove any PAM Consultant or
strategy from the Service at any time and
transfer day-to-day management responsibility of
a client’s Account to another PAM Consultant or
Baird Financial Advisor at any time without
providing prior notice to, or obtaining the consent
of, a client.
investments
portfolio,
the model
PAM and Baird do not have discretionary authority
over the assets in a client’s Baird Advisory Choice
Account, and PAM and Baird cannot purchase or
sell any securities or other investments in the
client’s Baird Advisory Choice Account, including
purchases and sales to rebalance the Account,
without the client’s authorization. Ultimately, the
client makes the final decision as to selection of
investments for the client’s Baird Advisory Choice
Account. Furthermore, if a client selects a model
portfolio for the client’s Baird Advisory Choice
Account, a client should understand that the client
is ultimately responsible for: the selection of the
portfolio’s
model
implementation, and the selection of a rebalance
option, if any.
products.
See
“Additional
Important Information about PAM Investment
Management Service Accounts. A client should
note that PAM Consultants may engage
in
strategies that involve concentrated and less
diversified portfolios of securities, leverage or
margin. In addition, PAM Consultants may invest
client accounts in illiquid securities and Complex
Investment Products. These types of strategies
and
involve special, sometimes
significant, risks and are not appropriate for all
clients. A client should understand those risks
before engaging in those strategies or investing in
those
Service
Information—Complex Strategies and Complex
Investment Products” and “Portfolio Manager
Selection and Evaluation—Methods of Analysis,
Investment Strategies and Risk of Loss—Principal
Risks” below for more information.
regarding:
financial
for
Associated Investment Products are available to
clients under the PAM Investment Management
Service. This presents a conflict of interest. For
more information, see “Additional Information—
Other Financial Industry Activities and Affiliations”
below.
Non-Discretionary Services
Baird Advisory Choice Program
The Baird Advisory Choice Program is a Non-
Discretionary Service whereby PAM and Baird
provide advice to a client in connection with the
client’s own management of the client’s Account.
A client should understand that PAM and Baird
only provide a client with certain consulting
services and,
for eligible Accounts, Account
rebalancing services under the Baird Advisory
Choice Program. The consulting services that may
be available in the Program from the client’s PAM
Consultant include research, analysis, advice and
recommendations
and
investment goals and needs; asset allocation
strategies, investment strategies and investment
implementing
restrictions; methods
investment strategies; trends and expectations
regarding securities and other
investments,
securities markets, and economic sectors and
industries; and the purchase, holding and sale of
securities and other investments. The specific
consulting services to be provided to a client will
be determined by mutual agreement between the
client and the client’s PAM Consultant. PAM and
Baird do not undertake to provide any other
consulting or investment advisory services under
7
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
this Program unless PAM and Baird agree to do so
in writing.
PAM Consultant may
in various
bank
is contained under
Service
Portfolio
Baird or the client’s PAM Consultant will provide
investment recommendations
for the client’s
Account and may recommend the amount, type
and timing with respect to buying, holding,
exchanging, converting and selling securities and
other assets for the client’s Account. Baird or the
recommend
client’s
investments
types of securities,
including, but not limited to, equity securities,
fixed income securities, Non-Traditional Assets,
certain Alternative Investment Products and
mutual funds and ETPs that in turn invest in those
investments. All or a portion of the assets in a
client’s Account may be held in cash or cash
equivalents, including securities issued by money
market mutual funds, or may be deposited in
interest-bearing
accounts. Additional
information about the types of investments Baird
or a PAM Consultant may recommend for client
accounts
the heading
“Additional
Information—Permitted
Investments” below. For more information about
the Baird Advisory Choice Program, see “Portfolio
Manager Selection and Evaluation—Methods of
Analysis, Investment Strategies and Risk of
Loss—Program
Strategies—Baird
Advisory Choice Program” below.
about
the
investment
A client should ask the client’s PAM Consultant
questions
styles,
philosophies, strategies, analyses and techniques
the client’s PAM Consultant will use in order to
meet the client’s objectives.
anticipated use of other Baird products and
services, and the costs and benefits of the
Account. The costs of a Baird Advisory Choice
Account may be more or less than in an account
where the client is charged on a per-transaction
basis. A Baird Advisory Choice Account may not
be appropriate for a client who anticipates little or
no trading activity, a client who prefers to direct
investment strategies and
the client’s own
security selection independent of the advice of
PAM or Baird or a client who does not receive or
request investment advisory or other non-trading
services from PAM or Baird. A Baird Advisory
Choice Account is also not for day trading or other
extreme trading activity,
including excessive
options trading or trading in mutual funds based
on market timing. If a client’s Baird Advisory
Choice Account engages in “excessive trading
activity” (herein defined as activity that would be
considered “excessive” by industry professionals
in a non-discretionary, fee-based program, as
determined by Baird in its sole discretion), PAM or
Baird may, to the extent permitted by applicable
law, immediately, upon sending notice to the
client, restrict the activity occurring in the client’s
Account, terminate the Account, convert the
Account to a commission-based account, or
charge a higher fee at such rate as PAM or Baird,
in their sole discretion, may elect. A client is
responsible for monitoring the client’s Account
and determining the desirability of maintaining
the Account as opposed
to maintaining a
traditional, commission-based brokerage account.
In addition to Baird Advisory Choice Accounts and
traditional,
brokerage
commission-based
accounts, PAM offers various other advisory
programs in which it has investment discretion. A
client should periodically reevaluate whether the
ongoing use of this Non-Discretionary Advisory
Program is desired and request a PAM Consultant
to explain the benefits and disadvantages of
maintaining a Baird Advisory Choice Account and
the availability of alternative arrangements.
is
appropriate.
In making
Additional information regarding the differences
between brokerage and advisory relationships can
be found in the “Understanding Brokerage and
Investment Advisory Relationships” document
that
is available on Baird’s website at
bairdwealth.com/retailinvestor.
relevant
factors,
including
it
into a
A client may terminate a Baird Advisory Choice
Account and convert
traditional,
commission-based brokerage account at any time
by contacting PAM. PAM and Baird also have the
Important Information about Baird Advisory
Choice Accounts. A Baird Advisory Choice
Account provides a fee-based alternative to a
traditional, commission-based brokerage account.
Unlike a traditional brokerage account where a
client is paying for traditional brokerage services,
an Advisory Choice client is also paying for
investment advice and other investment advisory
services above and beyond those available in a
traditional brokerage account. Each client should
determine whether a Baird Advisory Choice
this
Account
determination, a client should carefully consider
all
the client’s
investment objectives, risk tolerance, past and
anticipated trading practices, current assets,
current investments, the value and type of
Permitted Investments to be held in the Account,
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Baird PAM Wrap Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
right, at any time upon notice to a client, to
terminate a client’s Baird Advisory Choice Account
and convert it into commission-based brokerage
account.
For more specific information about the managers
and SMA Strategies made available through the
PAM Recommended Managers Service and the
level of initial and ongoing research, evaluation,
monitoring and review performed by Baird on
those managers and SMA Strategies, see
“Portfolio Manager Selection and Evaluation—
Selection and Evaluation—PAM Recommended
Managers Service” below.
trading.
PAM Recommended Managers have varying
investment objectives, styles and strategies, and
they may invest a client’s Account in various
types of securities, which will be chosen by the
PAM Recommended Manager and which may
include mutual funds, ETFs or other investment
products associated with the manager or Baird.
Service
are urged
review
the
information
about
A client should note that the client’s Baird
Advisory Choice Account may be engaged in
strategies that involve concentrated and less
diversified portfolios of securities, leverage or
margin, options, and
In
frequent
addition,
the client’s Baird Advisory Choice
Account may be invested in illiquid securities and
Complex Investment Products. These types of
strategies and
involve special,
investments
significant,
sometimes
risks and are not
appropriate
for all clients. A client should
understand those risks before engaging in those
strategies or investing in those products. See
“Additional
Information—Complex
Strategies and Complex Investment Products”
and “Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks” below for more
information.
the
Clients
PAM
to
Recommended Manager’s Form ADV Part 2A
contain additional
Brochure, which
should
PAM
the
important
Recommended Manager, including information
about
PAM Recommended Manager’s
strategies, the types of investments the PAM
Recommended Manager may use for a client’s
Account, and the risks associated with investing in
a PAM RM Strategy. Such brochures are available
upon request.
Associated Investment Products are available to
clients under the Advisory Choice Program. This
presents a conflict of
interest. For more
information, see “Additional Information—Other
Financial Industry Activities and Affiliations”
below.
SMA Services
PAM Recommended Managers Service
initially selects
Some of the services provided under the PAM
Recommended Managers Service will be provided
to a client by a PAM Consultant assigned to the
client’s Account. A client, typically working with a
PAM Consultant,
the PAM
Recommended Manager and PAM RM Strategy for
the client’s Account. Thereafter, whenever Baird
or the client’s PAM Consultant deems it necessary,
Baird or the client’s PAM Consultant will replace a
PAM Recommended Manager or PAM RM Strategy
with another PAM Recommended Manager or PAM
RM Strategy for the client’s Account.
The PAM Recommended Managers Service is a
program whereby a client provides Baird and the
client’s PAM Consultant with discretionary
authority to appoint investment managers to
manage the client’s Account with full discretionary
authority and to terminate or replace investment
managers for the client’s Account. The PAM
Recommended Managers Service is designed for a
client who wishes to have the client’s Account
investment managers that are
managed by
monitored by PAM and Baird on an ongoing basis.
the
Under the PAM Recommended Managers Service,
PAM and Baird determine
investment
managers (“PAM Recommended Managers”) and
their strategies (“PAM RM Strategies”) eligible to
participate in the Service through an initial and
ongoing evaluation process.
full discretionary authority
If a client participates in the PAM Recommended
Managers Service, the client authorizes and
directs PAM and Baird
to appoint PAM
Recommended Managers to serve as sub-adviser
to the client’s Account and to otherwise manage
the client’s Account in accordance with the terms
of the PAM Recommended Managers Service. The
client also authorizes and directs the PAM
Recommended Managers to manage the client’s
Account with
in
accordance with the PAM RM Strategy selected.
9
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
RM
Strategies
offered
below
Providers will differ, perhaps in a materially
negative manner, from the performance of other
client accounts managed by
those Model
Providers. See “Additional Service Information—
Trading for Client Accounts—Trading Practices of
Investment Managers”
for more
information.
the client should understand
the discretionary
full discretionary authority
recommendation or
full discretionary authority
If a client’s Account is managed by an Other
Manager under the PAM Recommended Managers
that,
Service,
notwithstanding
authority
granted to Baird and the client’s PAM Consultant
under the Service: Baird and the client’s PAM
Consultant do not manage the Account and do not
otherwise have any influence over the Other
Manager’s
investment decisions or securities
selections, and therefore, Baird and the client’s
PAM Consultant are not responsible for the
decisions made by the Other Manager; and Baird
and the client’s PAM Consultant do not provide
investment advice
any
regarding the purchase or sale of investment
products made for the client’s Account.
Certain PAM RM Strategies are only made
available through Implementation Managers. The
PAM
through
Implementation Managers consist of Manager-
Traded Strategies and Model-Traded Strategies. If
a PAM RM Strategy offered
through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs PAM
and Baird to appoint the Implementation Manager
to serve as sub-adviser to the client’s Account. If
a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to manage the client’s
Account with
in
accordance with the selected PAM RM Strategy. If
a Manager-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to appoint the applicable
PAM Recommended Manager as sub-adviser, and
the client also authorizes and directs such PAM
Recommended Manager to manage the client’s
Account with
in
accordance with the selected PAM RM Strategy.
from
the
the
implement
the direction of
the
client’s Account,
the prior manager and
From time to time, PAM or Baird may remove
PAM
investment managers
Recommended Managers Service, and PAM or
Baird may select a replacement manager to
manage the client’s Account. In such event, PAM
the client’s
or Baird, at
replacement manager, or the client’s replacement
manager may sell all or a portion of the securities
or other investments in the Account that were
managed by
the
replacement manager will reinvest the cash
proceeds of those sales. Sales of securities or
other investments could result in adverse tax
consequences for the client.
faithfully
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Implementation Manager will
Account,
typically
the Model Portfolio as
proposed by the Model Provider. However, since
the Implementation Manager has discretionary
authority over
the
Implementation Manager may implement the
Model Portfolio differently than proposed by the
Model Provider if the Implementation Manager
determines such action to be necessary and in the
client’s best interest. A client should note that
PAM and Baird do not monitor or ascertain
whether a third party Implementation Manager is
fully and
implementing the Model
Portfolio on a continuous basis. The client should
periodically discuss the Account’s performance
with the client’s PAM Consultant.
in
If PAM or Baird terminates an
investment
manager from the PAM Recommended Managers
Service, a client authorizes PAM and Baird to
invest, with full discretionary authority, the assets
in the client’s Account previously managed by the
terminated
other
investment manager
securities, including, but not limited to, mutual
funds and ETPs. PAM’s and Baird’s discretionary
authority to make such other investments will
continue until a replacement investment manager
is selected or alternative arrangements are made
for the management of the client’s assets.
Certain managers of Model-Traded Strategies
offered
through the Overlay Manager have
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a PAM client Account pursuing a
Model Portfolio strategy offered by those Model
10
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
if any, see
and
Evaluation—Selection
performed by Baird on those managers and SMA
“Portfolio Manager
Strategies,
Selection
and
Evaluation—Baird SMA Network and Dual Contract
Programs” below.
the
A client who prefers to continue using an
investment manager that has been removed from
the PAM Recommended Managers Service, or who
directs or otherwise requests that a particular
investment manager not recommended by PAM
be selected to manage the client’s Account, will
need to move to another Service, such as the
BSN Program. See “Baird SMA Network Program”
below for more information. Clients who elect to
do so will no longer receive the same level of
rigorous ongoing monitoring, evaluation, or
review of that investment manager from PAM or
Baird.
A client should only participate in the BSN
Program if the client wishes to take more
responsibility for monitoring the client’s Account,
the PAM Recommended Managers Program does
not contain an SMA Strategy that meets the
client’s particular needs, and
client
understands the risks of doing so.
have
varying
departments
of Baird,
BSN Managers
investment
objectives, styles and strategies, and they may
invest a client’s Account in various types of
securities, which will be chosen by the BSN
Manager and which may include mutual funds,
ETFs or other investment products associated with
the manager or Baird. Certain managers offer
strategies that exclusively invest in Funds (“Fund
Strategist Portfolios”).
Important
Information about Affiliated
Managers. The PAM Recommended Managers
Service makes available to clients investment
services that are offered by Baird Advisors and
investment
Baird Equity Asset Management,
management
and
Riverfront, an affiliate of Baird. This presents a
conflict of interest. For more information, see
“Additional Information—Other Financial Industry
Activities and Affiliations” below.
Baird SMA Network Program
a
is designed
client who wishes
Clients are urged to review the BSN Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the BSN
Manager, including information about the BSN
Manager’s strategies, the types of investments
the BSN Manager may use for a client’s Account,
and the risks associated with investing in a BSN
Strategy. Such brochures are available upon
request.
The BSN Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
to
client. The BSN Program
accommodate
to
independently select an investment manager not
available in the PAM Recommended Managers
Program to manage the assets in the client’s
Account.
Some of the services provided under the BSN
Program may be provided to a client by a PAM
Consultant assigned to the client’s Account, and
the client’s PAM Consultant may provide his or her
own advice and recommendations about BSN
Managers.
(“BSN
Strategies”)
eligible
If a client participates in the BSN Program, the
client authorizes and directs PAM and Baird to
appoint the BSN Manager selected by the client to
serve as sub-adviser to the client’s Account. The
client also authorizes and directs the BSN
Manager to manage client’s Account with full
discretionary authority in accordance with the
BSN Strategy selected by the client.
Under the BSN Program, Baird determines the
investment managers (“BSN Managers”) and their
to
strategies
participate in the Program through a significantly
less rigorous evaluation process compared to the
PAM Recommended Managers Service. However,
a client should note that PAM and Baird do not
make any recommendation to clients regarding
any BSN Strategy or any
representations
regarding a BSN Manager’s qualifications as an
investment adviser or abilities to manage client
assets.
Certain BSN Strategies are only made available
through the Overlay Manager. The BSN Strategies
offered through the Overlay Manager consist of
Manager-Traded Strategies and Model-Traded
For more specific information about the managers
and SMA Strategies made available through the
BSN Program and the level of initial and ongoing
research, evaluation, monitoring and review
11
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
influence over
reviewing
the
Strategies. If a client selects a BSN Strategy
offered through the Overlay Manager for the
client’s Account, the client authorizes and directs
PAM and Baird to appoint the Overlay Manager to
serve as sub-adviser to the client’s Account. If a
client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to manage the client’s Account
with full discretionary authority in accordance
with the BSN Strategy selected by the client. If a
client selects a Manager-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to appoint the applicable BSN
Manager as sub-adviser, and the client also
authorizes and directs such BSN Manager to
manage the client’s Account with full discretionary
authority in accordance with the BSN Strategy
selected by the client.
If a client’s Account is managed by an Other
Manager under the BSN Program, the client
should understand that: PAM and Baird do not
manage the Account and do not otherwise have
any
the Other Manager’s
investment decisions or securities selections, and
therefore, PAM and Baird are not responsible for
the decisions made by the Other Manager; PAM
and Baird do not provide any recommendation or
investment advice regarding the purchase or sale
of investment products made for the client’s
Account; and PAM and Baird only provide the
client with certain consulting services, which may
include the client’s PAM Consultant’s assistance
with determining the client’s financial needs,
investment goals and investment restrictions and
periodically
manager’s
performance. PAM and Baird do not undertake to
provide any other consulting or
investment
advisory services under the BSN Program unless
PAM and Baird agree to do so in writing.
the Account and
its
regarding
A client that participates in the BSN Program is
strongly encouraged to contact the client’s PAM
Consultant or BSN Manager on a periodic basis to
discuss:
investment
performance; the BSN Manager’s investment
philosophy and style (to determine if the BSN
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information
the BSN Manager,
described on the manager’s Form ADV, which is
available on the SEC's website at www.adviser
info.sec.gov.
If a client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the Overlay Manager will typically
implement the Model Portfolio as proposed by the
Model Provider. However, since the Overlay
Manager has discretionary authority over the
client’s Account, the Overlay Manager may
implement the Model Portfolio differently than
proposed by the Model Provider if the Overlay
Manager determines such action to be necessary
and in the client’s best interest. A client should
note that PAM and Baird do not monitor or
ascertain whether the Overlay Manager is fully
and faithfully implementing the Model Portfolio on
a continuous basis. The client should periodically
discuss the Account’s performance with the
client’s PAM Consultant.
Information—Trading
for
Certain managers of Model-Traded Strategies
offered
through the Overlay Manager have
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a PAM client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by those Model Providers. See
“Additional Service
for
Client Accounts—Trading Practices of Investment
Managers” below for more information.
The BSN Strategies and BSN Managers made
available under the BSN Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the BSN Program,
PAM and Baird cannot appoint a replacement
manager or otherwise manage a client’s Account
assets. Given the terms of the BSN Program,
upon the withdrawal or removal of an investment
manager from the BSN Program, a client’s BSN
Program Account will be automatically removed
from the BSN Program and the Account will
become an unmanaged brokerage account, unless
the client provides contrary instructions to PAM.
See “Portfolio Manager Selection and Evaluation—
Selection and Evaluation—Baird SMA Network and
further
Dual Contract Programs” below
information.
12
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Important Information about
the BSN
Program. Portfolios managed by 55I, LLC (d/b/a
55ip, “55ip”) are made available under the BSN
Program. 55ip uses research and other services
from Riverfront, an affiliate of Baird, in the
development of certain of those portfolios, and
Riverfront receives compensation from 55ip with
respect to those portfolios. This presents a conflict
of interest. For more information, see “Additional
Information—Other Financial Industry Activities
and Affiliations” below.
Under the DC Program, Baird determines the
investment managers (“DC Managers”) and their
strategies (“DC Strategies”) eligible to participate
in the Program through a significantly less
rigorous evaluation process compared to the PAM
Recommended Managers Service. However, a
client should note that PAM and Baird do not
make any recommendation to clients regarding
any DC Strategy or any representations regarding
a DC Manager’s qualifications as an investment
adviser or abilities to manage client assets.
if any, see
and
Evaluation—Selection
appointment
For more specific information about the managers
and SMA Strategies made available through the
DC Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those managers and SMA
“Portfolio Manager
Strategies,
Selection
and
Evaluation—Baird SMA Network and Dual Contract
Programs” below.
in managing
the client’s Account
A client should only participate in the DC Program
if the client wishes to take more responsibility for
monitoring
the PAM
the client’s Account,
Recommended Managers Program does not
contain an SMA Strategy that meets the client’s
particular needs, and the client understands the
risks of doing so.
the
foregoing when deciding
DC Managers have varying investment objectives,
styles and strategies, and they may invest a
client’s Account in various types of securities,
which will be chosen by the DC Manager and
which may include mutual funds, ETFs or other
investment products associated with the manager
or Baird.
The BSN Program is designed to accommodate a
client who wishes to independently select an
investment manager that is not available in the
PAM Recommended Managers Service to manage
the client’s Account. The client assumes ultimate
responsibility for monitoring the client’s BSN
the BSN Manager’s
Program Account and
performance. A
and
client’s
continued retention of a BSN Manager to manage
the client’s Account are based ultimately upon the
client’s independent review of the BSN Manager
and the BSN Manager’s services. The client
ultimately determines that the BSN Strategy to be
used
is
consistent with the client’s stated investment
objectives and financial needs and risk tolerance.
Once retained by the client, a BSN Manager will
only be removed from managing the client’s BSN
Program Account upon the manager’s withdrawal,
removal from the BSN Program, or the client’s
direction to do so. A client should carefully
consider
to
participate in the BSN Program and also consider
whether another Service, such as the PAM
Recommended Managers Service, may be more
appropriate for the client.
Dual Contract Program
a
is designed
client who wishes
Clients are urged to review the DC Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the DC
Manager, including information about the DC
Manager’s strategies, the types of investments
the DC Manager may use for a client’s Account,
and the risks associated with investing in a DC
Strategy. Such brochures are available upon
request.
The DC Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
to
client. The DC Program
accommodate
to
independently select an investment manager not
available in the PAM Recommended Managers
Service or BSN Program to manage the assets in
the client’s Account. The Program is also designed
for a client that wants to independently select a
manager and negotiate the manager’s Portfolio
Fee rate directly with the manager.
Some of the services provided under the DC
Program may be provided to a client by a PAM
Consultant assigned to the client’s Account, and
the client’s PAM Consultant may provide his or her
own advice and recommendations about DC
Managers.
13
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Under the DC Program, DC Managers are offered
to clients through a dual contract arrangement,
and a client will need to enter into a separate
agreement with the DC Manager in addition to the
advisory agreement the client enters into with
PAM and Baird. A client participating in the DC
Program is solely responsible for negotiating the
client’s agreement with the client’s DC Manager,
and neither PAM nor Baird will participate or
advise a client regarding the terms of such an
agreement, the advisability of entering into such
an agreement, or the retention of the client’s DC
Manager unless PAM and Baird agree to do so in
writing.
discretion. Under the terms of the DC Program,
PAM and Baird cannot appoint a replacement
manager or otherwise manage a client’s Account
assets. Given the terms of the DC Program, upon
the withdrawal or removal of an investment
manager from the DC Program, a client’s DC
Program Account will be automatically removed
from the DC Program and the Account will
become an unmanaged brokerage account, unless
the client provides contrary instructions to PAM.
See “Portfolio Manager Selection and Evaluation—
Selection and Evaluation—Baird SMA Network and
for more
Dual Contract Programs” below
information.
Information about
the DC
Important
Program. Other
investment management
departments of Baird and Associated Managers
are available to clients under the DC Program.
This presents a conflict of interest. For more
information, see “Additional Information—Other
Financial Industry Activities and Affiliations”
below.
appointment
reviewing
the
If a client’s Account is managed by an Other
Manager under the DC Program, the client should
understand that: PAM and Baird do not manage
the Account and do not otherwise have any
influence over the Other Manager’s investment
decisions or securities selections, and therefore,
PAM and Baird are not responsible for the
decisions made by the Other Manager; PAM and
Baird do not provide any recommendation or
investment advice regarding the purchase or sale
of investment products made for the client’s
Account; and PAM and Baird only provide the
client with certain consulting services, which may
include the client’s PAM Consultant’s assistance
with determining the client’s financial needs,
investment goals and investment restrictions and
periodically
manager’s
performance. PAM and Baird do not undertake to
provide any other consulting or
investment
advisory services under the DC Program unless
PAM and Baird agree to do so in writing.
in managing
the client’s Account
the Account and
its
the DC Manager’s
the
foregoing when deciding
The DC Program is designed to accommodate a
client who wishes to independently select an
investment manager. The client assumes ultimate
for monitoring the client’s DC
responsibility
the DC Manager’s
Program Account and
performance. A
and
client’s
continued retention of a DC Manager to manage
the client’s Account are based ultimately upon the
client’s independent review of the DC Manager
and the DC Manager’s services. The client
ultimately determines that the DC Strategy to be
is
used
consistent with the client’s stated investment
objectives and financial needs and risk tolerance.
Once retained by the client, a DC Manager will
only be removed from managing the client’s DC
Program Account upon the manager’s withdrawal,
removal from the DC Program, or the client’s
direction to do so. A client should carefully
consider
to
participate in the DC Program and also consider
whether another Service, such as the PAM
Recommended Managers Service, may be more
appropriate for the client.
Other SMA Strategy Information
A client that participates in the DC Program is
strongly encouraged to contact the client’s PAM
Consultant or DC Manager on a periodic basis to
investment
discuss:
performance;
investment
philosophy and style (to determine if the DC
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information regarding the DC Manager, described
on the manager’s Form ADV, which is available on
the SEC's website at www.adviserinfo.sec.gov.
Certain SMA Strategies are available through
multiple Services. The overall cost of an SMA
Strategy and the types and levels of service
provided to a client in connection with an SMA
The DC Strategies and DC Managers made
available under the DC Program are subject to
change or removal at any time in Baird’s sole
14
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
compared
to
client’s advisory agreement provides PAM and
Baird discretionary authority to manage the
assets in the client’s Account until a replacement
investment manager is selected or alternative
arrangements are made for the management of
the client’s assets.
include
Strategy will vary depending upon the particular
Service selected by the client. Certain managers
offer lower Portfolio Fee rates to clients through
the PAM
the DC Program
Recommended Managers or BSN Programs. A
client considering an SMA Strategy should discuss
with client’s PAM Consultant SMA Strategy
availability and the different Portfolio Fee rates,
costs, and the types and levels of service
provided in connection with the different Services.
A client is solely responsible for selecting the SMA
Strategy and the Service in which the client’s
Account will participate.
If a client’s Account participates in an SMA
Service, the client’s advisory agreement provides
the investment manager selected to manage the
client’s Account, which may
an
Implementation Manager, discretionary authority
to manage the assets in the client’s Account in
accordance with the terms of the SMA Service
selected by the client.
invested
in concentrated and
information about
A client should note that certain SMA Strategies
may be
less
diversified portfolios of securities and may involve
the use of leverage, margin, and options. A client
should discuss with the client’s PAM Consultant
the specific strategies and investments used by a
manager. Additional
the
strategies and investments used by a manager
are available in a manager’s Form ADV Part 2A
Brochure.
for
buying,
holding,
Additional Service Information
Investment Discretion
Investment Selection and Trading
Authorizations
the
retains complete discretion over
A client
investment selection and trading decisions with
respect to assets in a client’s Non-Discretionary
Service Accounts, and PAM and Baird will only
execute transactions for such Accounts pursuant
to the client’s instruction or authorization.
the client. Pursuant
If a client’s Account participates in a Discretionary
Service, the client’s advisory agreement provides
the client’s PAM Consultant, as
Baird and
applicable, discretionary authority to manage the
assets in the client’s Account in accordance with
the terms of the Service selected by the client.
If a client grants discretionary authority over the
client’s Account to PAM, Baird, the client’s PAM
Consultant or the client’s investment manager,
the client’s advisory agreement authorizes PAM,
Baird, the client’s PAM Consultant and the client’s
investment manager, as applicable, to manage
the client’s Account and to make investment
decisions for the client’s Account, with the
authority to determine the amount, type and
timing
exchanging,
converting and selling securities and other assets
for the client’s Account, subject to the terms of
the Service selected by the client. The client’s
advisory agreement also grants to PAM, Baird, the
client’s
client’s PAM Consultant and
investment manager, as applicable, complete and
unlimited trading authorization and appoints them
as the client’s agents and attorneys-in-fact to
manage the assets in the client’s Account on the
client’s behalf, subject to the terms of the Service
selected by
to such
authorization and powers of attorney, PAM, Baird,
the client’s PAM Consultant and the client’s
investment manager may, in their sole discretion
and at the client’s risk, purchase, sell, exchange,
convert and otherwise trade the securities and
other assets in the client’s Account, as well as
arrange for delivery and payment in connection
with the above, and act on the client’s behalf in
all matters necessary or incidental to the handling
of the client’s Account without prior notice to the
client. Such trading authorizations and powers of
attorney, whether granted to PAM, Baird, the
client’s PAM Consultant or the client’s investment
manager, shall remain in full force and effect until
terminated by the client, the client’s investment
manager, PAM or Baird.
a
client’s
If a client’s Account participates in the PAM
Recommended Managers Service, the client’s
advisory agreement provides Baird and the
client’s PAM Consultant discretionary authority to
appoint investment managers to manage the
client’s Account and to terminate or replace
investment managers for the client’s Account for
any reason without prior notice to the client. If
PAM or Baird terminates an investment manager
PAM
of
from management
Recommended Managers Service Account, the
15
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
guidelines or objectives. Clients electing the SRI
service generally bear the cost of the SRI service
as it is generally included in the Advisory Fee.
accounts without
restrictions
Orders for the purchase and sale of securities in a
client’s Discretionary Service Accounts will
generally be executed by Baird, in its capacity as
broker-dealer, as further described under the
heading “Trading for Client Accounts” below,
unless Baird’s duty to seek to obtain best
execution otherwise requires or unless the client
has provided other instructions to Baird in writing.
PAM and Baird do not have discretionary authority
over the assets in a client’s SMAs that are
managed by an Other Manager and cannot
purchase or sell such assets without the consent
of the client or such Other Manager. The
investment manager for a client’s SMAs may
initiate securities transactions through Baird, in its
capacity as broker-dealer, as further described
under the heading “Trading for Client Accounts”
below, subject to the manager’s duty to seek to
obtain best execution, or unless a client has
provided other instructions in writing. Baird, as
broker-dealer, will rely upon any such instructions
of any investment managers selected to manage
the client’s Account.
In the event that a client’s Account is restricted
from investing in certain securities, PAM, Baird or
the client’s investment manager, as applicable,
will select such other replacement securities, if
any, as they deem appropriate. Accounts with
investment restrictions may perform differently
from
and
performance may be poorer. In addition, in the
event there is a change in the classification or
credit rating of a security held in the client’s
Account, a client’s investment restrictions may
force PAM, Baird or the client’s investment
manager to sell such security at an inopportune
impacting Account
time, possibly negatively
performance and causing the client’s Account to
realize taxable gains or losses, which could be
significant. A client should also be aware that, if
the client’s Account holds any investment vehicle
(such as a mutual fund or ETF), any investment
restrictions the client places on the client’s
Account may not flow through to the securities
owned by that investment vehicle.
Should a client wish to impose or modify existing
restrictions, or the client’s financial condition or
investment objectives have changed, the client
should contact the client’s PAM Consultant.
Associated Investment Products
If a client participates in an SMA Service, the
client authorizes PAM and Baird to share client’s
information with the Overlay Manager and any
Other Manager or
Implementation Manager
managing the client’s Account. The client also
authorizes and directs PAM and Baird to transmit
to the Overlay Manager and any such Other
Manager or
Implementation Manager any
instructions that the client may provide to PAM or
Baird to the extent necessary to carry out the
client’s instructions.
Client Investment Restrictions
other
from
the services
The Services allow PAM and Baird to use the
discretionary authority granted to them by a
client to invest the client’s Account in Associated
Investment Products. Baird and Associated Parties
receive investment management or advisory fees
Associated
compensation
or
they
for
Investment Products
provide, the amount of which generally increases
when clients invest in such products. The amount
of fees or other compensation received by Baird
and Associated Parties is generally described in
the prospectus or other offering or disclosure
documents for the investment product. Additional
information is also available on Baird’s website at
bairdwealth.com/retailinvestor.
The Discretionary and the SMA Services offer a
client the ability to impose reasonable investment
restrictions on the management of an Account,
including the designation of particular securities
or types of securities that should not be
purchased for the client’s Account, but a client
may not require that particular funds or securities
(or types) be purchased for the client’s Account.
Reasonable investment restrictions requested by
a client will apply only to those assets over which
PAM, Baird or a client’s investment manager has
discretion.
investments
to
those
in Associated
PAM may also offer clients a socially responsible
investing (“SRI”) service, which assists a client in
restricting
that are
consistent with the client’s social investment
By signing an advisory agreement with Baird or
participating in a Service, a client consents to
PAM and Baird investing all or a portion of the
Investment
client’s Account
their
Products. PAM and Baird will use
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Conversion, Exchange or Sale of Certain
Investments
discretionary authority to invest the client’s
Account in Associated Investment Products when
they determine it to be in the client’s best interest
to do so. Generally, the criteria used by them in
deciding to invest in Associated Investment
Products are the same as those used in deciding
to invest a client’s assets in investment products
unassociated with Baird. For more information
about the criteria used by PAM and Baird, clients
should review the section of the Brochure entitled
“Portfolio Manager Selection and Evaluation”
below. A client’s consent may be revoked at any
time.
By participating in a Service, a client authorizes
PAM and Baird to convert or exchange any shares
of Funds, such as mutual funds, ETFs, closed-end
funds, UITs, Complex Investment Products, and
other similar investment pools, held in the client’s
Account to a class of shares of the same fund,
such as advisory class shares, institutional class
shares, financial intermediary class shares, or
another class of shares primarily designed for use
in advisory programs (collectively, “Advisory Class
Shares”), to the extent made available by the
mutual fund or other Fund in accordance with
policies established by Baird from time to time,
including, without limitation the Mutual Fund
Share Class Policy that is described below.
The Services allow Other Managers, including
Associated Managers, to use the discretionary
authority granted to them by a client to invest the
client’s Account in investment products managed
or sponsored by the Other Manager or any of its
associated firms, which may include Baird. The
Other Manager or its associated firms receive
investment management or advisory fees or other
compensation from such products for the services
they provide, the amount of which generally
increases when clients invest in such products.
A client should understand that, the client may
not hold Advisory Class Shares in a non-Advisory
Account and that the client may not be able to
hold certain Advisory Class Shares in an account
held at another firm. Upon the termination of a
Service for an Account or the closure of an
Account for any reason, PAM and Baird may
convert or exchange the Advisory Class Shares
held in the Account to an appropriate non-
Advisory Class Shares issued by the same fund,
or, if an appropriate non-Advisory Class Shares is
not available, PAM and Baird may redeem or sell
such Advisory Class Shares.
Trading for Client Accounts
PAM’s and Baird’s Trading Practices
Placement of Client Trade Orders
By signing an advisory agreement with Baird or
participating in a Service, a client consents to
each Other Manager, including each Associated
Manager, managing client’s Account investing all
or a portion of the client’s Account in investment
products managed or sponsored by the Other
Manager or any of its associated firms, which may
include Baird. Each Other Manager is responsible
for providing to the client information about the
amount of fees received by the Other Manager
and its associated firms and the criteria used by
the Other Manager in deciding to invest in
products managed or sponsored by the Other
Manager or any of its associated firms. A client
should contact the Other Manager and review the
Other Manager’s Form ADV Part 2A Brochure for
more information. A client’s consent may be
revoked at any time.
Investment Policy Statements
PAM and Baird will not review, monitor, accept or
adhere to an investment policy statement or
similar document that was not prepared by PAM
or Baird, unless they otherwise specifically agree
to do so in writing. Adherence to any such
investment policy statement or similar document
is solely a client’s responsibility.
PAM and Baird will select the broker-dealers that
will execute trade orders for Non-Discretionary
Accounts and with respect to Accounts that are
managed directly by PAM or Baird unless the
client has provided instructions to PAM to the
contrary. As investment adviser, PAM and Baird
have an obligation to seek “best execution” of
client trade orders. “Best execution” means that
they must place client trade orders with those
broker-dealers that they believe are capable of
providing the best qualitative execution of client
trade orders under the circumstances, taking into
account the full range and quality of the services
offered by the broker-dealer, including the value
of the research provided (if any), the broker-
dealer’s execution capabilities, the cost of the
trade, the broker-dealer’s financial responsibility,
and its responsiveness to PAM and Baird. It is
important to note that PAM’s and Baird’s best
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
execution obligation does not require them to
solicit competitive bids for each transaction or to
seek the lowest available cost of trade orders, so
long as they reasonably believe that the broker-
dealer selected can be reasonably expected to
provide clients with the best qualitative execution
under the circumstances.
into
consideration
account
transactions. For
management when they have the opportunity to
do so. When utilizing block transactions, PAM and
Baird generally aggregate a client’s trade orders
with trade orders for clients who are participating
in the same Service and pursuing the same model
portfolio or strategy. In some cases, PAM or Baird
may aggregate a client’s trade orders with trade
orders for other advisory clients who are not
participants in the Services described in this
Brochure. However, PAM and Baird determine
whether or not to utilize block transactions for a
client in their sole discretion and PAM’s and
Baird’s decision is subject to their duty to seek
best execution. In determining the amount to be
allocated to an account, if any, PAM and Baird
take
specific
investment restrictions, undesirable position size,
account portfolio weightings, client tax status,
client cash positions and client preferences.
Because a client does not pay commissions to
Baird when Baird, acting as broker-dealer,
executes a client’s trade orders, and because a
client may incur commission costs in addition to
the Advisory Fee if trade orders were to be
executed by another broker-dealer firm, clients
generally receive a cost advantage whenever
Baird executes client
this
reason, and given Baird’s execution capabilities as
that Baird will
broker-dealer, PAM expects
generally execute trade orders, as broker-dealer,
for Non-Discretionary Accounts and the client’s
Accounts that are directly managed by PAM or
Baird.
that may require PAM or Baird,
All advisory clients participating
in a block
transaction will receive the same execution price
for the security bought or sold. Average prices
may be used when allocating purchases and sales
to a client’s Account because such securities may
be purchased and sold at different prices in a
series of block transactions. As a result, the
average price received by a client may be higher
or lower than the price the client may have
received had the transaction been effected for the
client independently from the block transaction.
in
However, in some instances, circumstances may
arise
in
compliance with their best execution obligations
to a client, to place a client’s trade order with a
firm other than Baird. If they place trade orders
for the client’s Account for execution by a firm
other than Baird, and the other firm imposes a
commission or equivalent fee on the trade
(including a commission imbedded in the price of
the investment), the client will incur trading costs
in addition to the Advisory Fee.
Trade Aggregation, Allocation and Rotation
Practices
treatment over
PAM and Baird may aggregate contemporaneous
buy and sell orders for the accounts over which
they have discretionary authority (a practice also
known as bunching trades or block transactions).
This practice may enable them to obtain more
favorable execution, including better pricing and
enhanced investment opportunities, than would
otherwise be available
if orders were not
aggregated. Using block transactions may also
assist them in potentially avoiding an adverse
effect on the price of a security that could result
from simultaneously placing a number of
separate, successive or competing, client orders.
The amount of securities available
the
marketplace, at a particular price at a particular
time, may not satisfy the needs of all clients
participating in a block transaction and may be
insufficient to provide full allocation across all
client accounts. To address this possibility, Baird
has adopted
trade allocation policies and
procedures that are designed to make securities
allocations to discretionary client accounts in a
manner such that all such clients receive fair and
equitable
time. If a block
transaction cannot be executed in full at the same
price or time, the securities actually purchased or
sold by the close of each business day will
generally be allocated pro rata among the clients
participating in the block transaction. However,
PAM may also make random allocations to client
accounts in certain circumstances, such as when
Baird deems a partial fill for the total block order
to be low. Adjustments may also be made to
avoid a nominal allocation to client accounts.
PAM and Baird generally aggregate buy and sell
orders when executing trades for client account
discretionary
assets
under
their
direct
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
favorable net price
When PAM is not able to aggregate trades, PAM
generally uses a trade rotation process that is
designed to be fair and equitable to its advisory
clients over time. However, a client should be
aware that PAM’s trade rotation practices may at
times result in a transaction being effected for the
client’s Account that occurs near or at the end of
the rotation and, in such event, client’s trade
orders will significantly bear the market price
impact, if any, of those trades executed earlier in
the rotation, and, as a result, the client may
receive a
for the
less
applicable trade.
income securities
Notwithstanding the foregoing, if an aggregated
trade order involves fixed income securities, PAM
and Baird may allocate the securities based on
the needs of client accounts. In addition, PAM and
Baird will at times place aggregated trade orders
for fixed income securities prior to determining
how the aggregated trade order will be allocated
to client accounts. In those instances when an
aggregated trade order for fixed income securities
is placed prior to determining client allocations or
when such trade order is only partially filled, PAM
or Baird will seek to allocate trades in manner
intended to be fair and equitable to applicable
clients over time. Furthermore, when a trade
order for fixed income securities is only partially
filled, PAM and Baird may place orders for other
that have similar
fixed
characteristics, such as issuer name, structure,
credit rating, or market sector.
a client directs PAM to execute trades through
such firm, or when a client’s Retirement Account
or other account is maintained on a platform
operated and managed by a third party and
trades must be executed through that platform. A
client should understand that PAM and Baird
consider such arrangements to be directed
brokerage arrangements. A client should also
understand that if the client has a directed
brokerage arrangement, PAM and Baird may be
unable to achieve best execution for the client’s
transactions. A client should note that any costs
related to the directed brokerage arrangement
are not included in the Advisory Fee and that the
client will be solely responsible for monitoring,
evaluating and reviewing the arrangement with
the directed broker-dealer and paying any
commissions or markups or markdowns or other
costs imposed by the directed broker-dealer. A
client should also note that PAM generally will not
aggregate the client’s directed brokerage trade
orders with orders for other PAM clients. As a
result, a client’s transaction costs may be higher
because the client will not benefit from any
volume discounts or other reduced transaction
costs that PAM may obtain for its other clients. A
client should further note that PAM generally will
not include such client trade orders in its trade
rotation process and that PAM will generally place
the client’s trade orders with the directed broker-
dealer after PAM completes its trading for other
PAM client accounts. The client’s trade orders will
significantly bear the market price impact, if any,
of those trades executed earlier in PAM’s rotation.
As a result, the client may receive a less favorable
net price for the trade.
Because PAM and Baird are unable to buy or sell
any security for a client’s Non-Discretionary
Accounts without the client’s authorization, PAM
and Baird generally do not aggregate or bunch
trades for those Accounts with the same or similar
trades for other client accounts. Because similar
orders for the client and PAM’s or Baird’s other
clients may be placed and filled at different times,
the client may buy or sell securities at prices that
are different from the prices obtained by other
clients who received the same or similar advice
from PAM or Baird.
interest
Directed Brokerage Arrangements
If a client directs PAM to use a particular broker-
dealer, and if the particular broker-dealer referred
the client to PAM or if the particular broker-dealer
refers other clients to PAM or Baird in the future,
PAM and Baird may benefit from the client’s
directed brokerage arrangement. Because of
these potential benefits, PAM and Baird may have
an economic interest in having the client continue
the directed brokerage arrangement. The benefits
that PAM and Baird receive conflict with the
client’s
in having PAM or Baird
recommend that the client utilize another broker-
dealer to execute some or all transactions for the
client’s Account.
Before directing PAM to use a particular broker-
dealer, a client should carefully consider the
In some cases, a client may direct PAM to use a
particular broker-dealer for execution of the
client’s trade orders (a “directed brokerage
arrangement”), and PAM may agree to the
arrangement. This may occur when a client’s
Account is held at another broker-dealer firm and
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
possible costs or disadvantages of directed
brokerage arrangements.
the trade error results in a gain, the gain may be
retained by Baird but such gain is not given to or
shared with any PAM or Baird associate.
Cross Trading Involving Advisory Accounts
PAM and Baird offer many services and, from time
to time, may have other clients in other programs
trading in opposition to a client. To avoid favoring
one client over another client, Baird attempts to
use objective market data in the correction of any
trading errors.
If a client’s Account is managed by an Other
Manager, the client should review the Other
Manager’s Brochure and contact
the Other
Manager for information about how the Other
Manager corrects trade errors.
the purchase of
Trading Practices of Investment Managers
PAM generally does not in engage in cross
transactions, including agency cross transactions,
except in limited instances such as when clients
buy or sell variable rate demand obligations which
are also known as “put bonds”. When PAM
believes that the transaction is consistent with
each client’s best
interest, PAM, acting as
investment manager, may cause (or in the case
of Non-Discretionary accounts, recommend) the
sale of securities from the account of an advisory
client while at or about the same time causing
(or, in the case of Non-Discretionary accounts,
the same
recommending)
securities for the account of another PAM advisory
client. Such transactions may have the benefit of
reducing transaction and market impact costs.
If a client’s Account or a portion thereof is
managed by an investment manager, the client
should note that, like Baird, such investment
manager has a duty to seek best execution for
the client’s Account.
the
investment manager,
In such cases, because Baird is acting as
investment adviser for both buyer and seller,
Baird is subject to potentially conflicting interests
in causing (or recommending) the transactions.
Also, because Baird is acting as investment
adviser for both buyer and seller, transaction
prices may be determined more by reference to
market information or dealer indications for the
securities involved, and less through the type of
independent arms-length negotiation that might
otherwise occur. Baird has adopted internal
policies and procedures that require PAM and
Baird to obtain approval of Baird’s Compliance
Department before affecting a cross trade.
Trade Error Correction
Investment managers may participate in other
wrap fee programs sponsored by firms other than
Baird. In addition, investment managers may
manage institutional and other accounts not part
of a wrap
fee program. In the event an
investment manager purchases or sells a security
for all accounts using a particular SMA Strategy
offered by
the
investment manager may have to potentially
effect similar transactions through a number of
different broker-dealers. In some cases, to
address this situation, investment managers may
decide to aggregate all such client transactions
into a block trade that is executed through one
broker-dealer. This practice may enable the
investment manager to obtain more favorable
execution, including better pricing and enhanced
investment opportunities, than would otherwise
be available if orders were not aggregated. Using
block transactions may also assist the investment
manager in potentially avoiding an adverse effect
on the price of a security that could result from
simultaneously placing a number of separate,
successive or competing client orders. However,
as it pertains to PAM clients, this practice may
result in “trading away” from Baird, which is more
fully described below.
Alternatively, an investment manager may utilize
a trade rotation process where one group of
It is Baird’s policy that if there is a trade error for
which PAM or Baird is responsible, PAM or Baird
facts and
will take actions, based on the
circumstances surrounding the error, to put the
client’s Account in the position that it would have
been in as if the error had not occurred, including
by adjusting or reversing the transaction, entering
an offsetting transaction, or other methods that
may be deemed appropriate by Baird. Errors
caused by PAM or Baird will be corrected at no
cost to client’s Account, with the client’s Account
not recognizing any loss from the error. PAM and
Baird may net gains and losses from a single error
event involving more than one transaction in a
security or transactions in multiple securities. The
client’s Account will be fully compensated for any
losses incurred as a result of an error event. If
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in
the
the Model Provider’s
Form ADV Part 2A Brochure and review the
description of the Model Provider’s trade rotation
policy contained in that document. A copy of a
Model Provider’s Brochure can be obtained by
contacting a PAM Consultant. A client should also
monitor the performance of an Account pursuing
such a Model Portfolio strategy and compare that
performance with the performance reported for
the Model Portfolio by the Model Provider. A client
about Account
should
questions
discuss
performance or
trade
rotation policy with the client’s PAM Consultant.
information
clients may have a transaction effected before or
after another group of the investment manager’s
clients. A client should be aware that an
investment manager’s trade rotation practices
may at times result in a transaction being effected
for the client’s Account that occurs near or at the
end of the investment manager’s rotation and, in
such event, client’s trade orders will significantly
bear the market price impact, if any, of those
trades executed earlier
investment
manager’s rotation, and, as a result, the client
may receive a less favorable net price for the
regarding an
trade. Additional
investment manager’s trade rotation policies, if
any, is available in the investment manager’s
Form ADV Part 2A Brochure.
as
broker-dealer,
on
Because a client does not pay commissions to
Baird when Baird, acting as broker-dealer,
executes a client’s trade orders, and because a
client generally would incur trading costs in
addition to the Advisory Fee if trade orders were
to be executed by another broker-dealer firm,
clients generally
receive a cost advantage
whenever Baird executes PAM client transactions.
For this reason, and given Baird’s execution
capabilities
investment
managers may determine that placing trade
orders for the client’s Account with Baird is the
most favorable option for the client. However,
investment managers may place a client’s trade
orders with a broker-dealer firm other than Baird
if the manager determines that it must do so to
comply with its best execution obligations. This
practice is frequently referred to as “trading
away” and these types of trades are frequently
called “step out trades”. A client’s trade order so
executed is then cleared and settled through
Baird in what is frequently referred to as a “step
in”.
the other
In some instances, step out trades are executed
by
firm without any additional
commission or markup or markdown, but in other
instances, the executing firm may impose a
commission or a markup or markdown on the
trade. If a client’s investment manager places
trade orders for the client’s Account with a firm
other than Baird, and the other firm imposes a
commission or equivalent fee on the trade
(including a commission imbedded in the price of
the investment), the client will incur trading costs
in addition to the Advisory Fee.
in
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after
they have
implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. The Overlay Manager has
provided to Baird a list of Model Providers that
have such trade rotation policies, which list is
at
website
Baird’s
available
bairdwealth.com/retailinvestor. A PAM
client
should understand that an Account pursuing a
Model Portfolio strategy offered by those Model
Providers will have trades executed for the client’s
Account at the end of the Model Provider’s trade
rotation on a regular and consistent basis. As a
result, trade orders for such an Account will
significantly bear the market price impact, if any,
of those trades executed earlier in the Model
Provider’s rotation and the performance of the
Account will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by the Model Provider. In
addition and for the same reasons described
above, the performance of a Model Portfolio, as
reported by the Model Provider, will differ,
perhaps in a materially negative manner, from
the actual performance realized by PAM client
Accounts pursuing the Model Portfolio strategy.
PAM and Baird do not make or control any
investment manager’s trade rotation policies, and
they do not monitor, evaluate or review any
the
investment manager’s compliance with
manager’s trade rotation policies or whether such
trade rotation policies result
inequitable
performance of client Accounts. A client selecting
a Model Portfolio offered by such a Model Provider
is urged to obtain a copy of the Model Provider’s
Some managers have historically placed nearly all
client trades with broker-dealer firms other than
Baird for execution. Some managers have placed
nearly all or all client trades resulting from
changes to their model portfolios or strategies
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird—Principal Transactions” below for more
information.
Trade Execution Services Performed by Baird
with firms other than Baird. Similarly, some
managers have frequently placed client trade
orders for fixed income, foreign and small cap
securities with firms other than Baird. In some
cases, the other executing broker-dealer firm
imposes a commission or markup or markdown
(which is embedded in the price of the security)
for executing the trade. As a result, these types of
managers and their strategies could be more
costly to a client than managers that primarily
place client trade orders with Baird for execution.
If Baird provides trade execution services for a
client’s Account, Baird will generally act as agent
when routing client trade orders for execution.
However, Baird may cross trades between client
accounts or may act as principal for its own
account in certain circumstances to the extent
permitted by applicable law as is more fully
described below.
is based solely upon
independently verified
A client should understand that certain securities,
such as securities traded over-the-counter and
fixed income securities, are primarily traded in
dealer markets. When Baird purchases or sells
these types of securities for client accounts, it
generally does so through broker-dealer firms
acting as a dealer or principal. Dealers executing
principal trades typically
include a markup,
markdown or spread in the net price at which
transactions are executed. A client bears such
costs in addition to the Advisory Fee.
A list of managers that have informed Baird that
they have traded away from Baird during 2024 -
2025 and general information about the additional
cost of those trades (if any) is available on Baird’s
website at bairdwealth.com/retailinvestor. The
information about each manager provided on
Baird’s website
the
information provided to Baird by such manager.
Baird has not
the
information, and as a result, none of Baird or any
of its Associated Parties or associates makes any
representation as to the accuracy of any such
information.
Agency Cross Transactions
except
in
limited
A client should contact the client’s PAM Consultant
or investment manager if the client would like to
obtain specific information about trade aways and
the amount of commissions or other costs, if any,
the client incurred in connection with step out
trades.
in accordance with
A client should note that each
investment
manager is solely responsible for ensuring that it
complies with its best execution obligations to the
client. A client should review the manager’s
trading for the client’s Account because PAM and
Baird do not monitor, review or evaluate whether
the manager is complying with its best execution
obligations to the client. A client should review
the manager’s Form ADV Part 2A Brochure,
inquire about the manager’s trading practices,
and consider that information carefully, before
selecting a manager. In particular, the client
should carefully consider any additional trading
costs the client may incur before selecting a
manager to manage the client’s Account.
PAM generally does not in engage in agency cross
transactions,
instances.
However, in certain circumstances and to the
extent permitted by applicable law and regulation,
Baird and PAM Consultants may effect “agency
cross” transactions with respect to a client’s
Account. An “agency cross” transaction is a
transaction in which Baird or its affiliates act as
broker for the party or parties on both sides of
the transaction. As compensation for brokerage
services, Baird may receive compensation from
parties on both sides of an agency cross
transaction, the amount of which may vary. PAM
Consultants may receive compensation from Baird
related to agency cross transactions. Therefore,
Baird and PAM Consultants may have a conflicting
division of loyalties and responsibilities. However,
in all cases, Baird and PAM Consultants will seek
to obtain the best execution for each respective
advisory client and will effect agency cross
transactions only
the
requirements of Rule 206(3)-2 under the Advisers
Act. Furthermore, Baird will comply with
additional regulations applicable to Retirement
Accounts.
A client should note that the client’s advisory
agreement permits PAM and Baird to trade as
principal on orders received from Other Managers.
See “Trade Execution Services Performed by
Where applicable, a client’s advisory agreement
and
cross
discusses
agency
transactions
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
“agency
authorizes Baird and PAM Consultants to effect
agency cross transactions for a client’s Account. A
client’s authorization to Baird and PAM
cross”
Consultants
to effect
transactions
is given pursuant to Rule
206(3)-2 under the Advisers Act and may be
revoked at any time by the client in client’s
sole discretion by notifying the client’s PAM
Consultant in writing.
Principal Transactions
transaction in which Baird and PAM Consultants
act as principal over other
transactions.
Nonetheless, Baird and PAM Consultants have a
fiduciary duty to act in the client’s best interest
and to seek best execution for advisory clients.
Baird addresses this conflict through disclosure in
this Brochure. Furthermore, Baird has adopted
internal procedures that require Baird and PAM
Consultants, when acting in a principal capacity,
to disclose all material information regarding
Baird’s interest in the transaction, and obtain the
client’s approval of the transaction prior to
settlement.
A client’s advisory agreement discloses, where
applicable, the possibility of Baird’s role in
potential principal
transactions, and each
transaction confirmation sent to PAM clients
discloses the capacity in which Baird served in the
transaction and whether Baird is a market maker
in each security the client bought or sold.
transactions.
Riskless
or
if
other
the Account
Subject to the requirements of applicable law,
Baird and PAM Consultants may execute
transactions for a client’s Account while acting as
principal for Baird’s own account. Baird and PAM
Consultants act as principal when they sell a
security from Baird’s inventory to a client or they
purchase a security from a client for Baird’s
inventory. Baird and PAM Consultants also act as
principal when they sell new issue securities to
clients in securities offerings underwritten by
Baird. Baird also acts as principal in riskless
principal
principal
transactions refer to transactions in which Baird,
after having received a client’s order, executes an
identical order in the marketplace to fill the
client’s order while acting as principal. Baird and
PAM Consultants commonly engage in principal
trades with clients in the Baird Advisory Choice
Program.
realize profits
To the extent permitted by applicable law and
regulation, if a client’s Account participates in a
non-
Non-Discretionary Service
discretionary service, or
is
managed by an Other Manager, the client’s
advisory agreement provides Baird and PAM
Consultants with a blanket authorization to act as
principal for Baird’s own account in selling any
security to, or purchasing any security from, the
client’s Account. With this authorization, Baird
and PAM Consultants may effect any and all
principal transactions with the client’s Account
without having
to provide specific written
disclosures or obtain written client consent prior
to completion of each proposed principal trade,
subject to the requirements of an exemptive
order issued by the SEC to Baird (Rel. No. IA-
4596) and other applicable law and regulation.
This authorization to enable Baird and PAM
Consultants to trade as principal with a
client’s Account may be revoked at any time
by the client in client’s sole discretion by
notifying the client’s PAM Consultant in
writing.
It is generally PAM’s practice to rebate to a client
any compensation that PAM receives relating to
agency cross trades or principal transactions
effected for the client’s Account.
interests of
Baird may
from principal
transactions with a client based on the difference
between the price Baird paid for the security and
the price at which Baird sold the security, which
may include a markup, markdown or spread from
the prevailing market price, an underwriting fee,
selling dealer concession, or other incentive to
execute the transaction. PAM Consultants may
from Baird related to
receive compensation
principal trades of securities underwritten by
Baird. Any compensation received by Baird or a
PAM Consultant in a principal transaction is in
addition to the Advisory Fee paid by the client.
Principal trades also allow Baird to sell securities
from its account that it deems undesirable and to
buy securities for its account that it deem
desirable. Thus, in trading as principal with a
client, Baird and PAM Consultants will have
potentially conflicting division of loyalties and
responsibilities regarding their own interests and
the
the client. This potential
compensation may give Baird and PAM
recommend a
Consultants an
incentive
to
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Complex Strategies and Complex Investment
Products
to value, less liquid, and subject to greater
volatility compared to stocks and bonds.
Margin and Leverage
or
Margin
including by
investing
and
venture
capital
and
in
such
as
options,
Margin involves borrowing money from a firm,
such as Baird, to buy securities or other property.
It is generally PAM’s practice to not use margin as
part of an investment strategy, although a client’s
investment manager may do so. If a client wishes
to pay for securities by borrowing part of the
purchase price from Baird, a client must open a
margin account with Baird, and Baird may provide
the client with a margin loan. Securities held in a
client’s margin account are used as Baird’s
collateral for the margin loan. The value of the
the margin account must be
collateral
maintained at a certain level relative to the
margin loan for the duration of the loan. If the
securities in the margin account decline in value,
so does the value of the collateral supporting the
margin loan, and as a result, Baird may take
action, such as issue a margin call and sell
securities in the account.
Leverage
is contained under
of
instruments. While
returns,
Some Services offer clients the ability to pursue
other Complex
Alternative Strategies
Strategies that involve special risks not apparent
in more traditional investments like stocks and
bonds. Complex Strategies may be pursued in
in
multiple ways,
alternative mutual funds, ETFs, hedge funds,
managed futures, private equity funds and SMAs
third party managers. Some
managed by
Complex Strategies
in Non-Traditional
invest
Assets, such as real estate, commodities (which
may
include metals, mining, energy and
agricultural products), currencies, movements in
securities indices, credit spreads and interest
buyout
rates,
investments in private companies. Some Complex
Strategies engage in the use of margin or
leverage or selling securities short (“short sales”).
Some Complex Strategies invest in derivative
convertible
instruments
securities, futures, swaps, or forward contracts.
Complex Investment Products generally engage in
one or more Complex Strategies. Additional
information about Alternative Strategies and
the
Complex Strategies
“Portfolio Manager Selection and
heading
Investment
Evaluation—Methods of Analysis,
Strategies
Loss—Investment
and Risk
Strategies—Alternative Strategies and Complex
Strategies” below. Additional information about
Complex Strategies and Complex Investment
Products, generally, is provided below.
Non-Traditional Assets
Leverage generally attempts to obtain investment
exposure in excess of available assets through the
use of borrowings, short sales and other
leverage can
derivative
potentially enhance
can also
it
exacerbate losses if changes in the markets, or
the values of the investments subject to the
leverage, are adverse to the strategy being
pursued. The use of leverage may also increase
an Account’s volatility.
currencies,
securities
Short Sales
to benefit
tokens
investment
from an
Short selling attempts
anticipated decline in the market value of a
security. To affect a short sale, a client sells a
security the client does not own. When a client
sells a security short, Baird borrows the security
from a lender and makes delivery to the buyer on
the client’s behalf. Because short sales involve an
extension of credit from Baird to the client, a
client must use a margin account. A client must
also eventually purchase the same shares sold
short and return them back to the lender. It is
possible that the prices of securities that a client
sells short may increase in value, in which case
the client may lose money on the short position.
Short selling thus runs the risk of loss if the price
Non-Traditional Assets, such as investments in
commodities,
indices,
interest rates, credit spreads, private companies,
and digital assets, such as cryptocurrencies, non-
fungible
stablecoins, and
(“NFTs”),
tokenized
products (collectively,
“Digital Assets”) may be used for diversification
purposes. They may also be used to try to reduce
market and inflation risk. The performance of
Non-Traditional Assets may not correspond to the
performance of the stock markets generally, and
investments
in Non-Traditional Assets will
generally impact an account’s returns differently
than more traditional investments like stocks or
bonds. Non-Traditional Assets are subject to risks
that are different from, and in some instances,
greater than, other assets like stocks and bonds.
Non-Traditional Assets are generally more difficult
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
to buy, the underlying security or index at the
exercise price prior to expiration of the option.
of the securities sold short does not decline below
the price at which they were originally sold. This
risk of loss is theoretically unlimited, as there is
no cap on the amount that the price of a security
may appreciate.
Clients should note that investment managers
investment
managing a client’s Account or
products in the client’s Account may also engage
in short sales. Thus, a client’s Account will be
subject to short sales risks if the investment
manager managing the client’s Account or an
the client’s Account
in
investment product
engages in short sales.
Options and Other Derivative Instruments
Derivative Instruments
instruments,
securities,
futures,
In buying a call option, the purchaser expects
that the market value of the underlying security
or index will appreciate, which would enable the
purchaser of a call to buy the underlying security
or index at a strike price lower than the prevailing
market price. The purchaser of the call option
makes a profit if the prevailing market price is
greater than the sum of the strike price plus the
premium paid for the option. The seller of a call
option earns income in the form of the premium
received from the purchaser for the option and
expects that the market value of the underlying
security or index will depreciate such that the
option will expire without being exercised. The
seller of a call option makes a profit if the
prevailing market price of the underlying security
or index is less than the sum of the strike price
plus the premium received.
than,
the
traditional
investments.
Investing
involves
such as options,
Derivatives
convertible
swaps, and
forward contracts are financial contracts that
derive value based upon the value of an
underlying asset, such as a security, commodity,
currency, or index. Derivative instruments may be
used as a substitute for taking a position in the
underlying asset. Derivative instruments may also
be used to try to hedge or reduce exposure to
other risks. They may also be used to make
speculative investments on the movement of the
value of an underlying asset. The use of
derivative instruments involves risks different
risks
from, or possibly greater
associated with investing directly in securities and
in
other
derivatives also generally
leverage.
Derivatives are also generally less liquid, and
subject to greater volatility compared to stocks
and bonds.
Options
In buying a put option, the purchaser expects that
the market value of the underlying security or
index will depreciate, which would enable the
purchaser of a put to sell the underlying security
or index at a strike price higher than the
prevailing market price. The purchaser of the put
option makes a profit if the prevailing market
price is less than the sum of the strike price and
the premium paid for the option. The seller of a
put option earns income in the form of the
premium received from the purchaser for the
option and expects that the market value of the
underlying security or index will appreciate such
the option will expire without being
that
exercised. The seller of a put option makes a
profit if the prevailing market price of the
underlying security or index is greater than the
difference between the strike price and the
premium.
Options transactions may involve the buying or
writing of puts or calls on securities. In some
cases, Baird may require clients to open a margin
account to engage in options trading.
security or
In purchasing a put or call option, the purchaser
faces the risk of loss of the premium paid for the
option if the market price moves in a direction
opposite to what the purchaser had expected. In
selling or writing an option, the seller faces
significantly more risk. A seller of a call option
faces the risk of significant loss if the prevailing
market price of the underlying security or index
increases above the strike price, and a seller of a
put option faces the risk of significant loss if the
prevailing market price of the underlying security
or index decreased below the strike price.
With a call option, the purchaser has the right to
buy, and the seller (writer) the obligation to sell,
the underlying
index at a
predetermined price (i.e., the exercise or strike
price) prior to expiration of the option. The
premium paid to the seller (writer) for the option
is in consideration for the underlying obligations
imposed on the seller should the option be
exercised. With a put option, the purchaser has
the right to sell, and the seller has the obligation
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and
any
Clients should note that investment managers
managing a client’s Account or
investment
products in the client’s Account may also engage
in options transactions. Thus, a client’s Account
will be subject to options risks if the investment
manager managing the client’s Account or an
investment product
the client’s Account
in
engages in options transactions.
Complex Investment Products
Products
include
below for more information. Before using those
types of strategies or products, a client is strongly
urged to discuss them with the client’s PAM
investment manager
Consultant
managing the client’s Account. A client should
also carefully review the client’s agreements with
Baird and related disclosure documents, which the
client should have received when opening the
Account. Additional information about Complex
Strategies and Complex Investment Products is
provided under the heading “Portfolio Manager
Selection and Evaluation—Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment Strategies—Alternative Strategies and
Complex Strategies” below and on Baird’s website
at bairdwealth.com/retailinvestor.
futures, but also
for notifying
and
any
ETNs,
business
Complex Investment Products typically invest
primarily in Non-Traditional Assets or engage in
one or more Complex Strategies. Complex
Investment
Alternative
Investment Products, such as hedge funds, funds
of hedge funds, private equity funds, funds of
private equity funds, private debt funds, and
managed
include other
investments
pursuing Complex Strategies,
including but not limited to, exchange or swap
funds, leveraged funds, inverse funds, and other
special situation funds, structured certificates of
(“structured
deposit and
structured notes
products”),
development
companies (“BDCs”), real estate investment trusts
limited partnerships
(“REITs”), and master
(“MLPs”).
A client assumes responsibility for engaging in
Complex Strategies and investing in Complex
Investment Products. If a client determines that
the client no longer wants to engage in those
strategies or invest in those products, the client is
the client’s PAM
responsible
Consultant
investment manager
managing the client’s Account. PAM and Baird are
not responsible for any losses resulting from any
Other Manager’s failure or delay in implementing
any such instructions.
thereby making
“Advisory
Complex
Strategies
or
website
In addition, a client should be aware that more
traditional investments, such as mutual funds,
ETFs, UITs and variable annuities may also pursue
Complex Strategies,
them
Complex Investment Products. A client should
carefully review the prospectus or other offering
document for each investment and understand
the strategy being pursued before deciding to
invest. More detailed information about mutual
funds, ETFs, UITs and variable annuities is
available
at
Baird’s
on
bairdwealth.com/retailinvestor.
Interest
The use of Complex Strategies or Complex
Investment Products has a unique impact upon
the calculation of a client’s asset-based Advisory
Fee. See
Fees—Calculation and
Payment of Advisory Fees” below for more
information. A client should also understand that
Baird and the client’s PAM Consultant have a
financial incentive to use, select or recommend
certain
Complex
Investment Products, including margin and short
Information—Code of
sales. See “Additional
Ethics, Participation or
in Client
Transactions and Personal Trading” below.
Additional Important Information
losses
in
As a creditor, Baird may have interests that are
adverse to a client. Neither PAM nor Baird will act
as investment adviser to a client with respect to
the liquidation of securities held in an Account to
meet a call on a margin loan. Any such sale of
assets will be executed in Baird’s capacity as
broker-dealer and creditor and may, as permitted
by law, result in executions on a principal basis.
The use of Complex Strategies or Complex
Investment Products is not appropriate for some
clients because they involve special risks. A client
should not engage in those strategies or invest in
those products unless the client is prepared to
experience significant
the client’s
Account. This is especially true for short selling,
which can result in unlimited losses as there is no
limit to the amount borrowed securities can rise in
value. See “Portfolio Manager Selection and
Investment
Evaluation—Methods of Analysis,
Strategies and Risk of Loss—Principal Risks”
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Permitted Investments
stocks,
Investments”).
• fixed income securities, including but not limited
to, debt securities issued by domestic and
corporations and other entities;
foreign
securities
asset-backed
preferred
(including mortgage-backed securities and
collateralized mortgage obligations (“CMOs”));
convertible debt securities; obligations issued
by U.S., state, or foreign governments or their
agencies, instrumentalities, or authorities, such
as securities issued by the U.S. Treasury,
federal
federal government agencies or
government-sponsored enterprises
(“Agency
securities”), or foreign governments; municipal
securities; money market mutual
funds;
certificates of deposit (“CDs”) (primary or
secondary); commercial paper;
Under the Discretionary and Non-Discretionary
Services, Baird determines the asset categories
and investment products that clients may access
for investment (“Permitted Investments”) and
those that are not permitted in Program Accounts
(“Unpermitted
Permitted
Investments vary by Service. Although Baird
determines the Permitted Investments under
those Services, the level of initial and ongoing
evaluation, monitoring and review that PAM and
Baird perform on Permitted Investments varies.
For more information, see the descriptions of each
Service under “Services, Fees and Compensation”
above and under “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Program Portfolio
Strategies” below.
• rights or warrants on equity securities, and
written covered call and written cash secured
put equity options;
PAM or Baird may add Permitted Investments or
restrict client access to a Permitted Investment at
any time in their sole discretion.
load-waived, or
for purchase; shares
of
an
Account.
See
Some Permitted Investments contain restrictions
that limit their use, and clients will not be
permitted to purchase or hold such investments
outside
“Account
Requirements and Types of Clients” below for
more information.
In certain limited instances, Baird may allow a
client to hold an investment in an Account that is
an Unpermitted Investment.
• open-end mutual funds shares that Baird has
selected for use in the Program, which generally
includes only those funds with which Baird has a
selling agreement and only those funds that are
institutional are
no-load,
that were
allowed
originally purchased
in a Baird brokerage
account and not sold when transitioned to an
advisory account will held in the account as
non-billable assets when the original purchase
was subject to a
front-end sales charge
(typically 36 months) or until the Contingent
Deferred Sales Charge (CDSC) expires (typically
13 months) if subject to a back-end sales
charge after which time they will be converted
to the appropriate advisory share class and
become billable assets;
information,
see
for use
in
PAM FOCUS Portfolios Program. The PAM
FOCUS Portfolios Program generally only permits
investments in certain mutual funds and ETPs that
PAM and Baird have selected for use in that
Program. For more
the
descriptions of the PAM FOCUS Portfolios Program
under “Services, Fees and Compensation” above.
for
Baird Advisory Choice Program. Permitted
the Baird Advisory Choice
Investments
Program generally include, but are not limited to,
the following types of investments:
• closed-end funds, ETFs, and UITs that have cost
structures designed
fee-based
investment advisory programs; UITs originally
purchased in a brokerage account and not sold
when transitioned to an advisory account will be
held as non-billable assets until the UIT
termination date at which time they will be
liquidated and the proceeds are billable;
• BDCs, publicly-traded REITs, certain non
publicly-traded (or private) REITs, and MLPs
(which may be organized as limited liability
companies (“LLCs”));
• equity securities, including, but not limited to,
common stocks, American Depositary Receipts
(“ADRs”), and ordinary shares,
including
whether exchange-traded, or over-the-counter
traded;
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• ETNs, opportunity zone funds, and other special
situation mutual funds, and exchange or swap
funds;
• certain hedge funds, funds of hedge funds,
private equity funds, funds of private equity
funds, reinsurance funds, structured products,
private debt funds and managed futures that
Baird has selected for use in the Program;
SMA Services. Investment products under the
SMA Services are selected solely by
the
investment manager providing services to the
client. The investment products used by an
investment manager may include products that
Baird does not permit to be used in connection
with the other Programs and Services described
above. A client should review the investment
manager’s Form ADV Part 2A Brochure for more
information.
Unsupervised Assets
for use
fee-based
• variable annuities that have cost structures
designed
investment
in
advisory programs; and
• cash and cash equivalents.
or
supervised
by
them
for the Baird
The Unpermitted Investments
Advisory Choice Program generally include, but
are not limited to:
• Class B or Class C shares offered by mutual
funds or any other class of mutual fund shares
that impose a contingent deferred or level sales
charge (back-end or level load);
• inverse funds;
• UITs that impose an initial or deferred sales
charge (load);
If
a
client
holds
in
fee-based
• all annuities and insurance products, except for
variable annuities that have cost structures
designed
investment
for use
advisory programs;
or
options
on
• commodities,
futures
commodities, and commodity pools; and
investment
funds
• private
and Complex
Investment Products that Baird has not selected
for use in the Services.
Investments
and
Investment Management Service.
PAM
Unpermitted
Permitted
Investments for the PAM Investment Management
Service are generally the same as the Baird
Advisory Choice Program, except the following
types of investments are generally not permitted
Investment Management Service
for PAM
Accounts:
• put options; and
Under certain circumstances, Baird, in its sole
discretion, may accept a client request to hold an
asset in an Account that is not included in the
investment advisory services provided by Baird or
a PAM Consultant or otherwise monitored,
overseen
(an
“Unsupervised Asset”). For example, if Baird
permits a client
to hold an Unpermitted
Investment in an Account, the asset is typically
also considered an Unsupervised Asset. Baird, in
its sole discretion, may also designate an asset
that is otherwise a Permitted Investment as an
Unsupervised Asset under certain circumstances,
such as when a client acquires the asset in an
unsolicited transaction, transfers the asset from
an account held at another
firm or Baird
brokerage account, or continues to hold the asset
against Baird’s or the client’s PAM Consultant’s
an
recommendation.
Unsupervised Asset in an Account, the client
should understand that the Unsupervised Asset
may not be included in performance reports
provided to the client and that Baird and PAM
Consultants do not manage, provide investment
advice, or otherwise act as an investment adviser
with respect to the Unsupervised Asset, even if
the Unsupervised Asset is included in account
statements or performance reports provided to
the client. Because Baird and PAM Consultants do
not manage or provide investment advisory
services regarding Unsupervised Assets, no asset-
based Advisory Fee is charged on Unsupervised
Assets. While Unsupervised Assets are not subject
to the asset-based Advisory Fee, Baird may
impose additional fees upon Accounts holding
Unsupervised Assets. See “Other Fees and
Expenses” below for more information. A client
should also understand
that holding an
Unsupervised Asset in an Account may increase
the risk of trade errors, overinvestment, and
negative Account performance. A client should
• variable annuities.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
consult the client’s PAM Consultant for further
information.
rebalance options made available in another
Service.
Special Considerations for the Services
PAM FOCUS Clients
Selection of Investment Options
Accounts
are
also
Generally, PAM FOCUS Portfolios Program Account
allocations are monitored weekly and rebalanced
automatically if an asset class drifts by more than
5% from the target. PAM FOCUS Portfolios
rebalanced
Program
automatically whenever the cash amount is
negative or drifts by more than 1% above its
target.
for
PAM and Baird solely determine the investment
options made available to a client under the PAM
FOCUS Portfolios Program. PAM FOCUS Portfolios
Program Accounts will generally be invested in
mutual funds and ETPs. PAM and Baird have
discretion over Client’s PAM FOCUS Portfolios
Program Account and PAM or Baird may invest
such Account in any investment product they
deem appropriate
the client’s Accounts
participating in that Program.
inconsistent with
Replacement of Investment Options
PAM and Baird, at times, may adjust their typical
rebalancing of a client Account based on certain
tax considerations. For example, Baird will
generally not rebalance an Account, particularly
during the fourth calendar quarter, to the extent
doing so would be
its
implementation of tax management services for
the Account as described above. For more
specific, current information about the frequency
and conditions under which a particular Account
will be rebalanced, a client should contact the
client’s PAM Consultant.
If a
From time to time, PAM or Baird may remove
mutual funds or ETPs from the PAM FOCUS
Portfolios Program, and PAM or Baird may replace
them with other mutual funds or ETPs as they
deem appropriate.
client’s Account
participates in that Program, PAM and Baird may
replace any such investments in the client’s
Account whenever PAM or Baird removes the
investment option from that Program. PAM or
Baird may make such replacement in the client’s
Account without providing prior notice to, or
obtaining the consent of, the client.
Timing of Investment
impacted
by market
PAM and Baird reserve the right to delay or stop
the rebalancing of a client's Account if PAM or
Baird believes it is in the client’s best interest to
do so. For example, PAM and Baird oftentimes
delay rebalancing when doing so would cause the
client’s Account to recognize taxable gains in the
fourth quarter or have other negative tax
consequences on
the client’s Account. The
rebalancing of a client Account may be delayed or
negatively
events,
operational limitations or other conditions beyond
PAM’s or Baird’s control.
to minimize potential negative
In certain instances, Baird may delay investing
client assets when Baird determines it is in the
client’s best interest to do so. For example, in
order
tax
consequences on a client, Baird may delay
investing assets in a new PAM FOCUS Program
Account when the Account is opened shortly
before a scheduled mutual fund distribution date.
Asset Allocation Changes and Rebalancing
or
the
client’s
With respect to the PAM FOCUS Program, PAM or
Baird may also change a client’s asset allocation
for any reason, which may include, but shall not
be limited to, updates made by PAM to the target
asset allocations of its model portfolio strategies
or changes in market conditions, PAM or Baird’s
opinion on the future performance of particular
asset
financial
classes
circumstances.
Any rebalance of a client’s Account or other
change in asset allocation may result in taxable
gains or losses.
If a client’s Account participates in the PAM
FOCUS Portfolios Program, the client authorizes
PAM and Baird to rebalance the client’s Account
assets to be consistent with the client’s chosen
target asset allocation strategy in accordance with
the rebalance option selected by the client. When
PAM or Baird rebalances a client’s Account, all or
only a portion of, the Account may be traded. The
rebalance options made available under a Service
may change at any time in PAM’s and Baird’s
the
discretion and may be different
from
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Third Party Information
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of
Loss—Investment Strategies—Asset
Allocation Strategies” below.
(a
is
and
When providing services to a client, PAM and
Baird rely on information provided by third parties
and other external sources believed to be reliable,
including, but not limited to, information provided
by investment managers. PAM and Baird assume
that all such information is accurate, complete
and current. PAM and Baird do not conduct an in-
depth review of, or verify, such information, and
they do not guarantee the accuracy of the
information used. See
“Portfolio Manager
Selection
Evaluation—Performance
Calculation” and “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Methods of Analysis”
below for more information.
Household Management
Unless otherwise specified in writing, clients that
are part of the same household will include their
eligible Advisory Accounts in the same household
for management purposes
“Household
Management Plan”). It
the client’s sole
responsibility to notify PAM that the client should
be excluded from a household so that PAM is
aware that the client’s Advisory Accounts are to
be managed independently. It is also the client’s
sole responsibility to notify PAM whenever the
client ceases to be part of a household if an
account is part of a Household Management Plan.
Failure to do so could have a materially negative
impact on applicable accounts.
the
household
level
is
part
An account will be removed from a Household
Management Plan: (1) upon request or consent of
the client, (2) if the Account ceases to be an
eligible Advisory Account, (3) in the event the
Account
another Household
of
Management Plan, if the client notifies PAM that
the client ceases to be a member of the applicable
household, or (4) upon written notice from Baird
that it is no longer able to manage the Account
according to the Household Management Plan.
included
Unless otherwise specified in writing, PAM and
Baird manage client Advisory Accounts together
at
(“Household
Management”). Household Management provides
that the client’s Advisory Accounts are managed
together toward a single, overall investment
objective selected by the client with the flexibility
of using multiple, eligible Advisory Accounts
(“Household Management Accounts”) that may
have different investment strategies or objectives.
Household Management Accounts, taken together,
will be managed or advised by Baird and client’s
PAM Consultant in such a way so as to seek to
achieve a single, overall goal or investment
objective (“Household Management Objective”)
chosen by the client. Each individual Account
included in Household Management will also be
managed or advised by Baird and client’s PAM
Consultant in accordance with the terms of the
applicable Advisory Program or Service and any
investment strategy or objective applicable to the
individual account
Account. However, each
included in Household Management may be
managed or advised in any manner believed by
Baird or the client’s PAM Consultant to be
for the Household
necessary or appropriate
Management Accounts, taken together, to seek to
achieve the Household Management Objective.
Given the nature of Household Management, a
client should understand that each Account
enrolled in a Household Management Plan may
not be invested in a manner such that the
individual Account alone would be able to achieve
the Household Management Objective. It is likely
that one or more Accounts
in a
Household Management Plan, taken alone, will be
managed or advised differently and will be subject
to greater or enhanced risks than would be the
case if the Account alone had the same objective
as the Household Management Objective. Such
enhanced risks include, without limitation, market
risks, investment objective and asset allocation
risks, capitalization risks, investment style risks,
illiquid securities and liquidity risks, concentration
risks, frequent trading and portfolio turnover
risks, Non-Traditional Assets and Complex
Strategies risks, and Complex Investment Product
risks.
A client should note that: if an Account is
removed from a Household Management Plan for
The Household Management Objectives that Baird
makes available to clients as part of Household
Management include: (1) All Growth; (2) Capital
Growth; (3) Growth with Income; (4) Income
with Growth; (5) Conservative Income; and (6)
Capital Preservation. A description of those
the heading
objectives
is contained under
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Plan will
for
tax
purposes
in
Information—Legal
and
and Risk
of
applicable tax rules, such as the IRS wash sales
rules and straddle rules, which will disallow, limit
or defer a client’s ability to recognize losses in an
specified
Account
circumstances. Tax management strategies and
services also involve special risks. See “Additional
Service
Tax
Considerations” and “Portfolio Manager Selection
and Evaluation—Methods of Analysis, Investment
Strategies
Loss—Investment
Strategies—Tax Management Strategies” below
for more information.
any reason, including if the client ceases to be a
member of the same household, the Service and
strategy for the Account removed from the
remain
Household Management
unchanged unless a change is requested by the
client; further, the Account removed from the
Household Management Plan will not be allocated
assets from other Accounts included in the
Household Management Plan unless the client and
all other applicable clients, if any, consent and
direct Baird to do so and then only to the extent
permitted by applicable law; and PAM and Baird
will have no liability for implementing a Household
Management Plan unless a client requests, in
writing, that an Advisory Account be excluded
from the Household Management Plan.
Tax Management Services
A client should understand the terms of the tax
management services that will be implemented,
including the associated limitations, risks and
additional costs, if any, before enrolling an
Account in a Service or selecting a manager for
that Account. A client is strongly urged to consult
with the client’s tax advisor about potential tax
implications before enrolling an Account in a
Service or selecting a manager for that Account. A
client is also encouraged to discuss the client’s tax
management needs with
the client’s PAM
Consultant.
Many Services and managers make available tax
management strategies and services that are
intended to reduce the negative impact of U.S.
federal income taxes on an Account and enhance
Account performance by selectively
trading
investments in the Account to recognize or avoid
investment gains and losses.
Baird and PAM Tax Management Strategies
Certain Services and managers
include tax
management services as a default feature of the
Services or the manager’s services. A client that
wishes to opt an Account out of participation in a
tax management service should contact the
client’s PAM Consultant.
As a default feature of the PAM FOCUS Portfolios
Program, the Baird PWM Home Office and PAM
implement certain tax management investment
strategies described below (“Baird TM Strategies”)
for each non-Retirement Account enrolled in that
Program unless the client opts out by contacting
the client’s PAM Consultant.
PAM Consultants
also
offer
Tax management services are provided solely
information
the direction and
based upon
provided by a
client. The offering and
performance of tax management services to a
client’s Account does not constitute tax advice. A
client is ultimately responsible for all tax-related
consequences resulting from the client’s decision
to enroll in a Service or select a manager that
utilizes tax management services.
implementation of
Certain
tax
management investment strategies (“PAM TM
Strategies”), described below, to non-Retirement
Accounts enrolled in PAM Consultant-directed
Services, including the Advisory Choice Program
and PAM Investment Management Service. A
client is encouraged to ask the client’s PAM
Consultant if PAM TM Strategies will be used if the
Account is enrolled in a Service. PAM Consultants
who offer PAM TM Strategies will generally
implement such strategies for Accounts they
manage on a discretionary basis unless a client
opts out by contacting
the client’s PAM
Consultant. The Baird PWM Home Office will assist
with
the PAM TM
the
Strategies.
Tax management strategies are not intended to,
and likely will not, eliminate a client’s U.S. federal
income tax obligations relating to investments in
an Account. Like all investment strategies, there
is no guarantee that the implementation of a tax
management strategy will be successful. A client’s
use of a tax management strategy may not
actually
lower a client’s tax obligations or
otherwise achieve a client’s tax goals. The
effectiveness of tax managed strategies and
impacted by
services may be negatively
Each Baird TM Strategy and PAM TM Strategy is a
to
secondary
investment strategy designed
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Capital Gains Avoidance Strategy
achieve a secondary objective of an Account to
reduce the negative impact of U.S. federal income
taxes and each such strategy is implemented
together with the other primary investment
strategies for the Account that are designed to
achieve the client’s primary investment objectives
or goals.
The Baird TM Strategies and PAM TM Strategies
features are not available to Retirement Accounts.
Tax Harvesting Strategy
identified as part of
A capital gains avoidance strategy seeks to avoid
capital gains attributable to an investment in the
Account for U.S. federal income tax purposes by
selling the investment before the capital gain is
distributed by the issuer. When implementing a
capital gains avoidance strategy, the Baird PWM
Home Office or the PAM Consultant, as applicable,
periodically, but at least annually, monitors the
issuers of investments held in the Account for
capital gains distributions announcements and
capital gains avoidance opportunities. When an
opportunity is identified, the Baird PWM Home
Office or the PAM Consultant, as applicable, sells
(or recommends the sale of) such securities in the
client’s Account
the
monitoring process in order for the Account to
avoid a capital gain distribution made by the
issuer. The Baird PWM Home Office or the PAM
Consultant will then reinvest (or recommend the
reinvestment of) the proceeds of such sale in cash
until the capital gain distribution has been paid by
the issuer, and then the securities will be
purchased again. If the securities are sold at a
loss, then Baird PWM or the PAM Consultant may
employ (or recommend the employment of) the
tax harvesting strategy described above.
Generally, the capital gains avoidance strategy is
limited to open end mutual fund positions in a
client Account, and a mutual fund position will be
included in the implementation of the strategy
only if the potential net U.S. federal income tax
benefit to the Account related to such position is
estimated by Baird to be $1,000 or more. For
purposes of calculating the $1,000 threshold, the
Account’s current unrealized gain or loss in each
mutual fund position is analyzed in light of the
applicable amount of capital gains distribution
announced by the mutual fund company.
Additional Important Information about Baird’s
and PAM’s Tax Management Strategies.
implementation of a
A tax harvesting strategy seeks to improve the
value of an Account, on a post U.S. federal
income tax basis, by offsetting capital losses in
the Account with capital gains. This strategy is
oftentimes referred to a “tax harvesting” or “tax
loss harvesting”. When
implementing a tax
harvesting strategy, the Baird PWM Home Office
or the PAM Consultant, as applicable, periodically,
but at least annually, conducts an assessment of
the Account to identify capital losses for tax
harvesting opportunities. When an opportunity is
identified, the Baird PWM Home Office or the PAM
Consultant, as applicable, sells (or recommends
the sale of) certain securities in the client’s
Account in order for the Account to recognize the
unrealized capital losses identified as part of the
assessment process. The Baird PWM Home Office
or the PAM Consultant will then reinvest (or
recommend the reinvestment of) the proceeds of
such sale in one or more replacement securities
that
the PAM Consultant believes are not
“substantially identical” for purposes of the IRS
wash sales rules. Replacement securities may
include, without limitation, ETFs, cash, cash
equivalents or other securities. Unless the client
instructs otherwise, investment in replacement
securities will be made on a temporary basis and
generally only for the duration of any applicable
IRS wash sale rule period, currently 30 days after
the sale, and within a reasonable time thereafter,
the proceeds will be reinvested in a manner
consistent with the way the Account was invested
prior to the employment of the tax harvesting
strategy.
the
implementation of
the
Generally,
tax
harvesting strategy is limited to open end mutual
fund and ETF positions with unrealized capital
losses over $1,000 for U.S. federal income tax
purposes, unless Baird and the client otherwise
agree.
tax management
The
strategy is based upon Baird’s or the PAM
Consultant’s, as applicable, estimates of capital
gains and losses associated with investments in
client’s Account and information provided to them
by third parties, such as issuers of securities.
Capital losses will remain in an Account following
the implementation of a tax harvesting strategy,
and the Account will realize capital gains following
the implementation of a capital gains avoidance
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the extent such estimates or
Investment Objectives
strategy,
to
information are incorrect.
for an Account based upon
responsible
for
selecting
for
Generally, every Account will have one of the
investment objectives described below. Although
a PAM Consultant may recommend an investment
objective
the
information provided by a client, the client is
ultimately
the
the Account. The
investment objective
investment objective will determine, in part, and
limit the Services, investment products and
services that will be made available to the
Account.
The implementation of the tax harvesting strategy
and capital gains avoidance strategy (or the
recommendation to implement a strategy) is done
in the sole discretion of the Baird PWM Home
Office or PAM Consultant, as applicable, and
securities may be excluded from implementation
of such strategies for a number of reasons,
including without limitation, the length of time the
security has been in the Account, the lack of a
replacement security acceptable to Baird or the
PAM Consultant, withdrawal and deposit activity
in
the Account, market conditions deemed
unfavorable by Baird or the PAM Consultant, or if
doing so would, in Baird’s or the PAM Consultant’s
judgment, negatively impact management of the
Account.
All Growth. An All Growth investment objective
typically seeks to provide growth of capital.
Typically, an Account pursuing an All Growth
investment objective will experience high
fluctuations in annual returns and overall market
value. Under normal market conditions, such an
Account generally invests nearly all of its assets in
equity securities. Such an Account may also hold
other types of investments.
The tax harvesting and capital gains avoidance
strategies are provided by Baird and PAM
Consultants on an Account-by-Account basis.
When employing such strategies for a client
Account, Baird does not monitor or consider the
trading activity in any other client account,
including any Account held at Baird or another
firm.
A client should also note that when normal
for the client’s
is resumed
trading activity
Account, such activity could generate taxable
gains or losses.
Capital Growth. A Capital Growth investment
objective typically seeks to provide growth of
capital. Typically, an Account pursuing a Capital
Growth
investment objective will experience
moderately high fluctuations in annual returns
and overall market value. Generally, under
normal market conditions, such an Account will
primarily invest in a mix of equity securities and
fixed income securities, with a significantly higher
allocation to equity securities. Such an Account
may also hold other types of investments.
Third Party Manager Tax Management
Services
review
the
Some investment managers participating in the
SMA Services offer tax management services and
others do not. A client should consult the client’s
investment
PAM Consultant or
manager’s Form ADV Part 2A Brochure for specific
information.
Client-Directed Tax Management Strategies
Growth with Income. A Growth with Income
investment objective typically seeks to provide
moderate growth of capital and some current
income. Typically, an Account pursuing a Growth
with Income investment objective will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of equity securities and fixed
income securities, with a bias towards equity
securities. Such an Account may also hold other
types of investments.
A client may direct PAM and Baird, and PAM and
Baird may agree, to implement an investment
strategy designed by the client or client’s tax
advisors for the client’s specific tax purposes (a
“client-designed strategy”). PAM and Baird do not
undertake any responsibility for the development,
evaluation or efficacy of any client-designed
strategy.
Income with Growth. An Income with Growth
investment objective typically seeks to provide
current income and some growth of capital.
Typically, an Account pursuing an Income with
Growth
investment objective will experience
moderate fluctuations in annual returns and
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
long-term growth by
investments based upon
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of fixed income securities and
equity securities, with a bias towards fixed income
securities. Such an Account may also hold other
types of investments.
in
to
implement a
typically
objective
and
overweighting
index or
Tactical. A tactical investment objective seeks to
provide
tactically and
actively adjusting account allocations to different
the
categories of
manager’s perception of how those investment
the short-term.
categories will perform
tactical
Strategies used
investment
involve
account
underweighting
allocations to certain asset classes, geographic
locations or market sectors relative to an
applicable long-term strategic asset allocation,
the market generally.
benchmark
Accounts with a tactical investment objective may
have investments focused or concentrated in
certain asset classes, geographic locations or
market sectors and they often experience higher
levels of trading and portfolio turnover relative to
accounts with other investment objectives.
Conservative Income. A Conservative Income
investment objective typically seeks to provide
current income. Typically, an Account pursuing a
Conservative Income investment objective will
experience relatively small fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, such an Account
will primarily invest in a mix of fixed income
securities, cash and equity securities, with a
significantly higher allocation to fixed income
securities. Such an Account may also hold other
types of investments.
A
Tax-Managed
indicates
that
the
account
investment
Tax-Managed.
is
objective
transitioning from one investment strategy to
another using one or more tax management
strategies or tax management considerations. The
primary investment strategy or consideration for
investment
Accounts with a Tax-Managed
objective will involve tax management, and such
accounts may not be successful in pursuing any
other investment strategies, objectives or goals.
Capital Preservation. A Capital Preservation
investment objective typically seeks to preserve
capital while generating current income. Typically,
an Account pursuing a Capital Preservation
investment objective will experience relatively
small fluctuations in annual returns and overall
market value. Under normal market conditions,
such an Account generally invests nearly all of its
assets in a mix of fixed income securities and
cash. Such an Account may also hold other types
of investments.
Goal. A Goal investment objective indicates that
the Account is a Goal Management Account that is
part of a Goal Management Plan and the Account
will be managed or advised in accordance with
the applicable Goal Management Objective.
for
a
client’s
specific
Investment Objectives
For information about the risks associated with
the investment objectives described above, see
the section of the Brochure entitled “Portfolio
Manager Selection and Evaluation—Methods of
Analysis, Investment Strategies and Risk of
Loss—Principal Risks—Risks Associated with
Certain
and Asset
Allocation Strategies” below.
Mutual Fund Share Class Policy
investment
objective
Opportunistic. An Opportunistic
investment
objective typically seeks to provide long term
growth
through capital appreciation and/or
income by utilizing an active management style
that shifts the percentage of assets held in
various investment categories to take advantage
of the manager’s perception of market pricing
anomalies, market sectors deemed favorable for
investment by the manager, the current interest
rate environment or other macro-economic trends
identified by the manager to achieve growth while
accounting
short,
intermediate and long term investment and/or
cash flow needs. Depending upon the investment
strategy used, an Account pursuing an
Opportunistic
could
experience high fluctuations in annual returns and
overall market value. The types of investments in
which such an Account may invest will also vary
widely, depending upon the particular investment
strategy used.
Most mutual funds offer different share classes.
While each share class of a given mutual fund has
the same underlying investments, those share
classes have different fees, costs and investment
minimums, and they provide different levels of
compensation to Baird. In an effort to provide
clients with appropriate low cost mutual fund
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
fund. Clients may be able to obtain a less
expensive share class in other Programs or at
another firm.
payments,
revenue
sharing
the applicable mutual
Interest
Baird receives certain compensation from mutual
fund families in the form of distribution (12b-1)
fees, shareholder servicing fees, transfer agency
fees, networking fees, accounting fees, marketing
support
and
administration fees. The amount of compensation
paid to Baird generally varies based upon the
share class of
fund
purchased by clients. Because the compensation
that Baird receives from certain mutual funds is
based upon share class purchased by clients,
Baird has a financial incentive to make available
to clients those share classes that provide Baird
greater compensation, which, in many instances,
would cause clients investing in those share
classes to incur higher ongoing costs relative to
other share classes made available by the fund
families. This presents a conflict of interest. Baird
addresses this conflict through the Share Class
Policy described above and through disclosure in
this Brochure. For more information about the
compensation that Baird receives from mutual
funds, see “Additional Information—Code of
Ethics, Participation or
in Client
Transactions and Personal Trading—Participation
or Interest in Client Transactions—Investment
Product Selling and Servicing—Mutual Funds”
below.
of
Shares of mutual funds held in client Accounts
that do not meet the requirements of the Share
Class Policy will generally be converted to the
applicable Approved Share Class subject to
certain restrictions. The Share Class Policy is
subject to change at Baird’s discretion without
notice to clients. Additional information about the
Share Class Policy is available on Baird’s website
at bairdwealth.com/retailinvestor.
The Share Class Policy does not apply to the
portion of a UAS Account managed by third party
managers. Third party managers are responsible
for establishing their own criteria for selecting
investments, including mutual funds, if any.
Custody Services
Certain Services may require clients to custody
their Account assets at Baird. If Baird is the
custodian of a client’s assets, Baird will provide
certain custody services, including holding the
investment options for their fee-based investment
advisory accounts, Baird has established a mutual
fund share class policy (“Share Class Policy”) for
certain PAM-directed Services, including Advisory
Choice and PAM Investment Management (the
“Share Class Policy Services”). Typically, only one
share class of a given mutual fund family will be
made available for purchase by clients in the
Share Class Policy Services pursuant to the Share
Class Policy (the “Approved Share Class”). When
selecting the Approved Share Class for a mutual
fund family, Baird endeavors to select the share
class with the lowest expense ratio, based upon
the average expense ratio of the class across all
mutual funds in the mutual fund family, that are
widely available for trading on the mutual fund
trading platform of Charles Schwab & Co., Inc.
(“Schwab”). In selecting the share class for a
mutual fund family to be made available for
purchase by clients in the Share Class Policy
Services, Baird considers a number of factors,
including the number of funds within the fund
family that offer the share class, client positions
in and demand
funds, and the
for those
availability of the share classes and funds for
purchase on the Schwab mutual fund trading
platform. Generally, share classes designed for
retirement plans and those that pay a distribution
(12b-1) fee to Baird will not be permitted in those
Services, or, if such share classes are permitted
and the client’s Account is subject to an asset-
based fee arrangement, Baird will either: (1)
rebate the distribution (12b-1) fees to a client if
the client is paying an asset-based Advisory Fee
on such investment; or (2) exclude such fund
shares from the calculation of the client’s asset-
based Advisory Fee (sometimes referred to as
“unbillable assets”) for such period of time that
Baird collects and retains the distribution (12b-1)
fee as further described under the heading
“Additional
Ethics,
Information—Code
Participation or Interest in Client Transactions and
Personal Trading—Participation or Interest
in
Client Transactions—Investment Product Selling
or Servicing—Mutual Funds” below. Clients should
note that the Approved Share Class for a mutual
fund family is based upon the average expense
ratio for the class across all mutual funds in the
fund family and not on a fund-by-fund basis.
Further, the expenses of every mutual fund can
and will vary over time. Therefore, while Baird
has endeavored to select the lowest cost share
classes as described above, in some instances,
the Approved Share Class is not the least
expensive share class for a particular mutual
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
from
client’s Account assets, crediting contributions
and interest and dividends received on securities
held in a client’s Account, and making or
the Account.
“debiting” distributions
Information about account statements and
performance reports, if any, that PAM and Baird
provide to clients is contained under the heading
“Services, Fees and Compensation–Consulting
Services” above and “Additional Information—
Review of Accounts” below.
been limited to the investment options made
available through the custodian’s platform; and
(e) certain investments, such as mutual fund
shares, could be more or less expensive than if
the investment was obtained from Baird or
another firm. A client should further note that
PAM and Baird may not provide performance
review or reporting for Held-Away Assets. In
addition, a client who uses a third party custodian
is not eligible for cash sweep services offered by
Baird. Clients using a third party custodian are
encouraged to establish appropriate cash sweep
arrangements.
As custodian, Baird may hold a client’s Account
assets in nominee or “street” name, a practice
that refers
to securities and assets being
registered in Baird’s name or in a name that Baird
designates, rather than in a client’s name directly.
Baird will be the holder of record in those
instances.
Baird may utilize one or more subcustodians to
provide for the custody of a client’s assets in
certain circumstances. For instance, Baird utilizes
subcustodians to maintain custody of certain
client assets participating in the Cash Sweep
Program (described below) and securities that are
traded on foreign exchanges.
(e.g.,
A client who uses a third party custodian
authorizes PAM and Baird to give instructions to
the client’s custodian for all actions necessary or
incidental to the purchase, sale, exchange, and
delivery of securities held in the client’s Account.
Also, the client will receive account statements
directly from the client’s selected custodian. A
client should carefully review those account
statements and
them with any
compare
statements provided by PAM or Baird. A client
should note that the prices shown on a client’s
Account statements provided by the custodian
could be different from the prices shown on
statements and reports provided by PAM or Baird
due to a variety of factors, including the use of
different valuation sources and accounting
settlement date
trade or
methods
accounting) by the custodian and Baird.
Cash Sweep Program
to client Accounts on
to provide FDIC
Baird maintains a Cash Sweep Program that is
intended for clients who want to earn interest and
receive FDIC insurance protection on their cash
over short periods of
time while awaiting
investment. If a client participates in Baird’s Cash
Sweep Program, uninvested cash in the client’s
accounts will be automatically deposited or swept,
on a daily basis, into one or more FDIC-insured
deposit accounts at participating banks (the “Bank
Sweep Feature”) or, under certain conditions, will
be automatically invested in shares of a money
market mutual fund that Baird makes available in
the program (the “Money Market Fund Feature”),
subject to the terms and conditions of the
program. By using multiple participating banks as
opposed to a single bank, the Bank Sweep
Feature seeks
insurance
protection for a client’s cash balances of up to an
aggregate deposit limit determined under the
program (currently, $2,500,000 for most account
PAM and Baird in their sole discretion may accept
into a client’s Account,
Held-Away Assets
including assets
that are held by another
custodian (a “third party custodian”). A client who
uses a third party custodian to hold Account
assets does so at the client’s risk. A client should
understand that PAM and Baird do not monitor,
evaluate or review any third party custodian. The
client should also understand that the client will
pay a custody fee to the third party custodian in
addition to the Advisory Fee. Baird may also
impose additional fees on Accounts with assets
held by a third party custodian due to the
increase in resources needed to administer those
Accounts. Further, such third party custody
arrangements may
limit the Services made
available to the client. In addition, a client should
understand that: (a) each third party custodian
has exclusive control over the investment options
made available
the
custodian’s platform; (b) PAM and Baird have no
authority or ability to add to, or remove from, a
custodian’s platform any investment option; (c)
any advice given by PAM or Baird with respect to
the Account is inherently limited by the options
available through a custodian’s platform; (d) PAM
or Baird may have provided different investment
advice with respect to the Account had they not
36
Baird PAM Wrap Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
responsible for any insured or uninsured portion
of a client’s deposits at a bank. Cash invested in a
money market mutual fund under the Money
Market Fund Feature is not FDIC insured, but is
protected by Securities
Investor Protection
Corporation (“SIPC”) coverage up to applicable
limits.
receives
compensation
for
is
available
types and $5,000,000 for joint accounts). A client
receives interest on cash balances in deposit
accounts under the Bank Sweep Feature at tiered
rates that are based on the aggregate value of
the accounts within the client’s household. The
applicable client household tier values are: less
than $1 million; at least $1 million but less than
$2 million; at least $2 million but less than $5
million; and $5 million are more. Current rate
at
information
rwbaird.com/cashsweeps. Each deposit account at
a bank constitutes a direct obligation of the bank
and is not directly or indirectly Baird’s obligation.
account
values
of
less. For
Any aggregate cash balances held by a client in
excess of the applicable aggregate deposit limit
are automatically invested in shares of a money
market mutual fund that Baird makes available in
the Money Market Fund feature of the program.
Cash held in employee benefit plan accounts,
employee health and welfare plan accounts, donor
advised fund accounts, and SEP and SIMPLE IRAs
will be automatically invested or swept into a
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the program. In addition, clients with aggregate
cash balances of $5 million or more across all of
their accounts with Baird within the same
household may opt out of the Bank Sweep
Feature and instead have all of their cash
balances automatically swept into an institutional
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the program. More information about the Money
Market Fund Feature of Baird’s Cash Sweep
Program is available at rwbaird.com/cashsweeps.
related
to
those assets, and
Baird
the
administrative, accounting and other services that
Baird provides under the program, which is paid
out of the aggregate interest that is paid by the
participating banks on the aggregate client
balances in the deposit accounts participating in
the Bank Sweep Feature. Baird’s annual rate of
compensation may be up to 3.60% of the
for clients with
aggregate client balances
than
less
household
$1,000,000, 2.45% for clients with household
account values of $1,000,000 but less than
$2,000,000, 2.00% for clients with household
account values of $2,000,000 but less than
$5,000,000, and 1.75% for clients with household
account values of $5,000,000 or more. In a lower
interest rate environment Baird’s annual rate of
compensation will be
fee-based
investment advisory IRA accounts participating in
the Bank Sweep Feature, Baird’s compensation is
a monthly per account fee (which is the same
regardless of client balances in bank deposit
accounts). The per account fee for these advisory
IRA accounts is generally paid out of the interest
that the banks pay on aggregate client balances
in the deposit accounts, and the per account fee
varies based on the applicable Fed Funds Target
Rate but in no event will it exceed $19.00 per
month. Baird also receives an annual rate of
compensation of up to 0.50% of the aggregate
client balances automatically invested into money
market mutual funds under the Money Market
Fund Feature. A client should note that the client
will be charged the asset-based Advisory Fee on
the value of all of the assets in the client’s
Accounts, including cash that is swept into a bank
deposit account or invested into a money market
mutual fund under the Cash Sweep Program. As a
result, Baird receives two layers of fees on a
client’s assets swept or invested in the Cash
Sweep Program:
the Advisory Fee, which
compensates Baird for the investment advice,
trading and custody services provided to the
client
the
compensation paid by the banks or money market
funds related to those assets, which compensates
Baird for the services Baird provides to the banks
The Bank Sweep Feature seeks to provide FDIC
insurance protection for a client’s cash balances
up to an aggregate deposit limit determined
under the program. Any deposits, including CDs,
that a client maintains, directly or indirectly
through an intermediary (such as us or another
broker), with a bank participating in the Cash
Sweep Program in the same capacity with the
bank will be aggregated with the client’s cash
balances deposited with the bank under the Cash
Sweep Program for purposes of calculating the
$250,000 FDIC insurance limit. Total deposits
exceeding $250,000 at a bank may not be fully
insured by the FDIC. A client is responsible for
monitoring the total amount of other deposits that
the client has with a bank outside the Cash Sweep
Program in order to determine the extent of
deposit insurance coverage available. Baird is not
37
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and funds and for Baird’s efforts in maintaining
the Cash Sweep Program. The compensation that
Baird receives from the Cash Sweep Program
gives Baird a financial incentive to recommend
that a client participate in the Cash Sweep
Program and maintain high levels of uninvested
cash balances in the client’s accounts.
any
trust
financial
incentive
to
As an alternative to the Cash Sweep Program,
Baird makes available other money market
mutual funds and other cash alternatives in which
a client may invest, often at a higher yield,
although these investments do not have an
automatic sweep feature. In addition, instead of
maintaining cash balances in an advisory Account,
a client has the option to maintain such cash
balances in a brokerage account that is not
subject to an asset-based Advisory Fee.
it
services under the Trust Alliance Program made
by Baird and its PAM Consultants is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
oversee
services
such
arrangement. Baird has a financial incentive to
recommend that clients use Baird Trust, an
affiliate, over other non-affiliated trust companies.
As a result of this affiliation, Baird Trust also has
a financial incentive to retain Baird to provide
investment advisory or other services on behalf of
the client. In addition, Baird and PAM Consultants
have a
recommend
arrangements that involve Baird and the PAM
Consultant providing investment advisory services
to the client and the trust company only providing
trust administration services compared to an
arrangement whereby a trust company would
investment advisory and trust
provide both
administration services because
is more
profitable to Baird and the PAM Consultant.
in connection with
A client should understand that the Cash Sweep
Program is an ancillary account service and it is
not nor is it part of any advisory program or
investment advisory service. PAM and Baird do
not act as investment adviser or a fiduciary to a
client
the Cash Sweep
Program. However, a client should note that the
amount of the client’s advisory Account dedicated
to cash and cash equivalents is part of the overall
investment allocation advice provided to the client
and thus the amount of such cash and cash
equivalents included in the calculation of the
Advisory Fee for the client’s advisory Account.
ongoing
Baird
Trust
generally
on
website
More detailed information about the Cash Sweep
Program and the compensation Baird receives is
at
Baird’s
available
www.rwbaird.com/cashsweeps. A
client also
receives information about the compensation
Baird receives from the Cash Sweep Program
through a client’s account statements.
Trust Services Arrangements
In addition, outside of the Trust Alliance Program,
PAM Consultants may refer a client to Baird Trust
to provide investment management and trust
administration services to the client. If a client
enters into such a relationship with Baird Trust,
Baird and the client’s PAM Consultant typically
relationship management
provide
services.
provides
compensation to Baird and the client’s PAM
Consultant for the referral and providing ongoing
services, which may be up to 50% of the ongoing
fees that a client pays to Baird Trust, and which is
credited to the client’s PAM Consultant
for
purposes of determining the PAM Consultant’s
compensation. The compensation paid to Baird
and a client’s PAM Consultant does not increase
the fees that the client pays to Baird Trust. Due to
Baird’s affiliation with Baird Trust and the
compensation paid to Baird and PAM Consultants,
Baird and PAM Consultants have a financial
incentive to favor Baird Trust over other trust
companies.
trust administration
trust administration, custody,
Margin Loans
its
Margin involves borrowing money from Baird
using eligible securities as collateral, including for
the purpose of buying securities. If a client uses
margin, the client will pay Baird interest on the
amount the client borrows. The rate of interest
Baird maintains an alliance with
certain
institutions, both non-affiliated and affiliated,
including Baird Trust Company (“Baird Trust”),
services,
that provide
including
tax
reporting and recordkeeping. PAM Consultants at
times refer clients seeking trust services to
institutions that are members of the alliance.
Subject to
fiduciary duties, the trustee
oftentimes retains Baird to provide investment
advisory services to the client trust. A client
should understand that any such referral for trust
38
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
have a conflict to the extent they would
recommend that a client use the Baird margin
loan program instead of the Securities-Based
Lending Program because a client pays interest
and other fees to Baird instead of a third-party
lender.
visit
contact
website
a
Additional important information about margin,
including the risks and margin interest rates that
apply, is set forth in the “Margin” section of
Baird’s website at bairdwealth.com/retailinvestor.
Securities-Based Lending Program
loan, Baird has an
incentive
that any margin balance
(i.e.,
the
loan or
that a client pays on a margin loan will be at a
base rate determined by Baird plus or minus a
specified percentage that varies based on the
outstanding debit balance of the margin loan and
the client’s household account value. Interest
rates are lower for larger debit balances and
those with higher household account balances. As
a result, rates will vary. To determine the actual
interest rate that may apply to a client’s margin
at
Baird’s
loan,
rwbaird.com/loanrates
PAM
or
Consultant. Because a client will pay interest to
Baird on the outstanding balance of the client’s
margin
to
recommend to the client investment products and
services that involve the use of margin. Baird and
PAM Consultants also have an incentive to
recommend investment products and services
that involve the use of margin, because a margin
loan allows a client to make larger securities
purchases and retain assets
in the client’s
that pay an ongoing asset-based
Accounts
Advisory Fee instead of liquidating them to fund a
cash need, which increases the asset-based fees
Baird earns on a client’s Accounts. A client should
note
the
outstanding amounts of the margin loan the client
owes to Baird) in the client’s advisory Accounts
will not be applied to reduce the client’s billable
account value in calculating the client’s asset-
based Advisory Fee, which gives Baird and PAM
Consultants further incentive to recommend client
use of margin instead of liquidating assets to fund
a cash need. Because the interest Baird receives
and fees Baird earns on a client’s Accounts
increase as the amount of the client’s margin loan
increases, Baird and PAM Consultants also have
an
incentive to recommend that the client
continue to maintain a margin loan balance with
Baird at high levels. Baird has the right to lend
the securities a client pledges as collateral for the
client’s margin loan, and Baird receives additional
compensation for lending those securities, which
provides Baird a further incentive to recommend
margin to a client.
Baird offers clients an opportunity to borrow
money from a third party lender under Baird’s
Securities-Based Lending Program. These loans, if
made, can be used for any personal or business
purpose other than to purchase, carry or trade
securities, or to repay margin debt. These loans
are secured by the investments and other assets
in the client’s accounts with Baird. A client will
pay interest on the outstanding balance of the
client’s loan. The rates of interest charged by the
bank depends on many factors, such as the
prevailing interest rate environment, the amount
line of credit, a client’s
of
creditworthiness, and the aggregate assets in a
client’s Baird accounts in the client’s household
(“relationship size”). The interest rates are based
on a benchmark
rate, plus an applicable
percentage that varies based on the approved
loan amount and the relationship size. Rates are
generally higher for smaller loans and relationship
sizes and lower for larger loans and relationship
sizes. The interest rate that will apply to a client’s
loan will be set forth in the loan agreement the
client enters into with the bank. Baird receives an
ongoing administrative fee from the bank, at an
annual rate of up to 2.50% of the outstanding
balance under a client’s loan, which is paid by the
bank out of the interest the client pays to the
bank. A client’s PAM Consultant typically receives
an ongoing referral fee at an annual rate of up to
0.25% of the outstanding balance of the client’s
loan, which is paid out of Baird’s administrative
fee. A client should note that Baird and PAM
Consultants will continue to receive compensation
on assets held in the client’s accounts that serve
as collateral for the client’s loans, including
Advisory Fees. Because Baird
receives an
administrative fee and PAM Consultants receive a
referral fee if a client obtains a loan from a third
party
lender under Baird’s Securities-Based
Lending Program, Baird and PAM Consultants
A client should note that Baird’s margin loan
program is generally intended to be used to fund
additional purchases of securities. or short-term
liquidity needs. If a client wishes to obtain a loan
for some other purpose, a client should instead
consider whether the client is eligible for Baird’s
Securities-Based Lending Program, which involves
clients obtaining loans from third-party lenders for
general use purposes. Baird and PAM Consultants
39
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
financial
incentive
for promptly informing the client’s PAM Consultant
of any significant life changes (e.g., change in
marital status, significant health issue, or change
in employment) or if there is any change to the
client’s investment objectives, risk tolerance,
financial circumstances, investment needs, or
other circumstances that may affect the manner
in which the client’s assets are invested. None of
the client’s PAM Consultant or any
Baird,
investment manager managing a client’s Account
is responsible
for any adverse consequence
arising out of the client’s failure to promptly
inform the client’s PAM Consultant of any such
changes. Since investment goals and financial
circumstances change over time, a client should
review the client’s participation in a Service with
the client’s PAM Consultant at least annually.
of
website
have an incentive to recommend that a client
obtain loans under that program. Baird and PAM
Consultants will continue to receive compensation
on assets held in a client’s accounts that are
collateral for such loans, including Advisory Fees
on such assets if those assets are in the client’s
advisory Account. As a result, Baird and PAM
Consultants have a
to
recommend that a client obtain a loan under the
program to provide for the client’s needs instead
of liquidating assets in the client’s accounts with
Baird because a decline in the amounts the client
has in the client’s accounts will result in lower
revenues to Baird and compensation paid to the
client’s PAM Consultant. Additional important
information about securities-based lending is set
forth in the “Securities-Based Lending Program”
at
Baird’s
section
bairdwealth.com/retailinvestor.
Retirement Accounts
A client should understand that any referral made
the
by Baird and PAM Consultants under
Securities-Based Lending Program is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
oversee any such lending arrangement.
Other Non-Advisory Services
Additional laws, regulations and other conditions
apply to Retirement Accounts. Each owner,
sponsor, adopting employer,
trustee, plan
responsible plan fiduciary, named fiduciary, or
other fiduciary acting on behalf of a Retirement
Account (“Retirement Account Fiduciary”) should
understand that PAM and Baird do not provide
legal advice regarding Retirement Accounts. A
Retirement Account Fiduciary is urged to consult
with his or her own legal advisor about the laws
and regulations that may apply to Retirement
Accounts. ERISA and the IRC prohibit PAM and
Baird from offering certain types of investment
products and services to Retirement Accounts.
Legal and Tax Considerations
A client’s investment activities may have legal
and tax consequences to the client.
purchases,
sales,
Certain Baird associates from time to time may
provide clients with tax return preparation, bill
pay or related services. In some instances, the
fee for those services may be bundled with the
Advisory Fee. A client should understand that the
provision of such services is separate from, and
not related to, the Services offered under this
Brochure and will be governed by an agreement
separate from the client’s advisory agreement
with Baird. A client should understand that Baird
and its associates do not act as investment
advisor or fiduciary to the client when providing
tax return preparation, bill pay or related non-
advisory services to the client.
Client Responsibilities
The investment strategies used for a client’s
Account and transactions in a client’s Account,
including
liquidations,
redemptions, and rebalancing transactions, may
cause the client to realize gains or losses for
tax purposes. Funds often make
income
distributions of income and capital gains to
investors, which may cause the client to realize
income for tax purposes.
Certain investment products, such as Alternative
Investments and Complex Investments, are
classified as partnerships. Clients invested in such
investment products will be treated as partners
for U.S. federal income tax purposes, which has
A client is responsible for providing information to
Baird and the client’s PAM Consultant reasonably
requested by them in order to provide the
services selected by the client. Baird, the client’s
PAM Consultant and investment managers, if any,
will rely on this information when providing
services to the client. A client is also responsible
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Baird PAM Wrap Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
tax implications different from other types of
investments, including Schedule K-1 reporting.
In most instances, a client pays an ongoing
Advisory Fee based upon the value of assets in
the client’s Account (an “asset-based
fee”),
although other options, such as a flat fee, are
available.
Asset-Based Fee Arrangement
fee
taxable
PAM generally offers one asset-based
arrangement: a breakpoint fee schedule.
Clients with tax-exempt Accounts, such as certain
Retirement Accounts or charitable or religious
organization Accounts, should be aware that some
investments, such as some Non-Traditional
Assets, Alternative Investments and Complex
Investments, may produce
income,
referred to as unrelated business taxable income
(“UBTI”). In such circumstances, such clients will
be required to pay tax on the UBTI produced by
the tax-exempt Accounts.
Under a breakpoint fee schedule, the asset-based
fee is determined by reference to the market
value of the client’s Account assets, with the fee
rate being lower for accounts with higher levels of
assets. The breakpoint fee, once determined, is
then applied to all of the assets in the client’s
Account.
The asset-based fee may be a fixed percentage
across all asset categories or
investment
strategies or may be a percentage that varies by
investment strategy. For
asset category or
example, an Account pursuing an equity strategy
may pay a higher fee rate than an Account
pursuing a fixed income strategy.
A client’s ability to recognize losses in an Account
for tax purposes may be disallowed, limited or
deferred by applicable tax rules. For example, IRS
wash sales rules will disallow a client’s tax
deductions for a loss in an Account related to the
sale of an investment if the client purchases
(whether through Baird or another firm) a
“substantially identical” investment within the
wash sale period (currently 30 days before or 30
days after the date of the sale). Similarly, IRS
straddle rules limit and defer a client’s ability to
claim tax deductions related to the loss on a sale
of an investment in an Account if the client holds
an offsetting position in any account held at Baird
or another firm.
The typical asset-based fee varies depending
upon the Service and the fee option selected by
the client. Fee options and rates may also differ
among different Accounts held by the same client,
for an
depending on the services selected
Account.
the Services,
the
tax
implications of
All new client Accounts paying an asset-based fee
are generally subject to a unified advice fee
arrangement (“Unified Advice Fee Arrangement”),
which is described below.
Unified Advice Fee Arrangement
PAM and Baird do not offer legal or tax advice to
clients. The information, recommendations, and
services provided by PAM and Baird to clients
through
including, without
limitation, tax management strategies, do not
constitute tax advice. A client is responsible for
understanding
the
investment activities in the client’s accounts
(whether held at Baird or another firm) and
complying with applicable tax rules. A client is
strongly urged to consult with the client’s tax
advisor about potential tax implications before
making investment or trading decisions. PAM and
Baird do not undertake any responsibility to
monitor or verify a client’s compliance with
applicable tax rules, and they are not responsible
for any tax‑related effects or obligations resulting
from the investments or transactions in a client’s
Account.
Advisory Fees
Fee Options and Fee Schedules
Under a Unified Advice Fee Arrangement, the
asset-based Advisory Fee is comprised of an
advice fee (“Advice Fee”) and, for some Services,
an additional portfolio fee (“Portfolio Fee”). The
Advice Fee covers certain investment advisory,
brokerage and custody services provided by PAM
and Baird. The Portfolio Fee covers portfolio
management and other services provided by
Baird and the manager to the client’s Account,
which may include departments or affiliates of
Baird. If a client has a Unified Advice Fee
Arrangement, the client’s Advisory Fee rate will be
equal to the sum of the applicable Advice Fee rate
and the applicable Portfolio Fee rate, if any.
A client’s advisory agreement will set forth the
actual compensation the client will pay to Baird.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Breakpoint Advice Fee Schedule
Additional Advisory Services
Clients with a Unified Advice Fee Arrangement
generally choose a breakpoint fee schedule for the
Advice Fee portion of the Advisory Fee.
Value of Assets
Annual Fee Rate
Breakpoint Advice Fee Schedules
$0 to $249,999
3.00%
$250,000 to $499,999
2.50%
rates
for
$500,000 to $999,999
2.25%
PAM Recommended Managers Service. The
following fee schedule sets forth the maximum
the PAM
breakpoint Advice Fee
Recommended Managers Service.
$1,000,000 to $1,999,999
2.00%
Breakpoint Advice Fee Schedule
$2,000,000 to $4,999,999
1.75%
PAM Recommended Managers Service
$5,000,000 and above
1.50%
Value of Assets
Annual Fee Rate
Up to $5,000,000
1.05%
$5,000,001 – $10,000,000
0.85%
Consulting Services. The following fee schedule
sets forth the maximum breakpoint Advice Fee
rates for the Consulting Services provided by
PAM.
$10,000,001 – $20,000,000
0.80%
$20,000,001 – $30,000,000
0.70%
Breakpoint Advice Fee Schedule
$30,000,001 – $50,000,000
0.55%
Consulting Services
$50,000,001 – $100,000,000
0.45%
Value of Assets
Annual Fee Rate
Over $100,000,000
Negotiable
Up to $10 million
0.50%
$10 million - $25 million
0.45%
$25,000,001 - 50 million
0.35%
for
Above $50 million
Negotiable
PAM
Investment Management Service. The
following fee schedule sets forth the maximum
breakpoint Advice Fee
the PAM
rates
Investment Management Service.
Portfolio Fee Schedule
Breakpoint Advice Fee Schedule
PAM Investment Management Service
following
fee schedule sets
forth
Equity and
Balanced
Strategies
Fixed
Income
Strategies
The Portfolio Fee
rate varies by Service,
investment vehicle, and the type of investment
strategy or style being pursued by the Account.
The
the
maximum Portfolio Fee rates or range of rates for
the Services.
Annual Fee
Rate
Annual Fee
Rate
Value of Assets
Portfolio Fee Schedule
$100,000 to $499,999
3.00%
1.25%
$500,000 to $999,999
2.50%
1.25%
Service
Annual Fee Rate
or Range of Rates
0.00%
Baird Advisory Choice
Over $1,000,000
2.00%
1.00%
0.00%
PAM FOCUS Portfolios
PAM Investment Management
0.00%
PAM Recommended Managers
0.20% - 0.75%
Equity SMA Strategies
0.20% - 0.52%
Balanced SMA Strategies
Additional Advisory Services. The following fee
schedule sets forth the maximum breakpoint
Advice Fee rates for other advisory services
provided by PAM,
including Client Selected
Managers, Baird Advisory Choice, and PAM FOCUS
Portfolios.
0.25% - 0.40%
Fixed Income SMA Strategies
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Portfolio Fee Schedule
Payments” available on Baird’s website at
bairdwealth.com/retailinvestor.
Service
Annual Fee Rate
or Range of Rates
0.25% - 0.70%
Global and International SMA
Strategies
0.35% - 0.60%
Alternative SMA Strategies
0.10%
Tax Managed Strategies
0.09%
Index SMA Strategies
Baird SMA Network (BSN)
0.22% - 0.77%
Equity SMA Strategies
0.22% - 0.52%
Balanced SMA Strategies
0.10% - 0.27%
Fixed Income SMA Strategies
0.27% - 0.52%
Global and International SMA
Strategies
0.37% - 0.77%
Alternative SMA Strategies
Certain managers offer lower Portfolio Fee rates
for SMA Strategies to clients through the DC
Program compared to the PAM Recommended
Managers or BSN Programs. If a client has
decided to participate in the DC Program, upon
the client’s request, the client’s PAM Consultant
may assist the client with the client’s negotiation
with the manager of the Portfolio Fee rate for the
applicable SMA Strategy. The Portfolio Fee
negotiated by the client could be higher or lower
than the Portfolio Fee that applies to the same
SMA Strategy that is available through other
Services. The client is ultimately responsible for
understanding the differences between the SMA
Programs, deciding to participate in the DC
Program, selecting
the SMA Strategy, and
negotiating and agreeing to the Portfolio Fee rate.
—1
Dual Contract (DC)
Flat Fee Arrangement
1 Fees charged by managers under the DC Program are
negotiated by each client pursuant to a separate
agreement that does not include Baird. Baird, therefore,
does not have the necessary information to provide a
definitive range of fees paid to managers under the DC
Program.
Under a flat fee arrangement, the applicable fee
may be determined according to a fixed asset-
based fee rate or may be a fixed dollar amount.
Specific services may each have their own,
separately-stated, flat fee, or several services
may be grouped together under a single flat fee.
Some services may entail a flat fee per usage.
Flat fees are negotiable and vary by client. The
details of flat fee arrangements, including fee
amounts, the billing schedule, and the services
covered, will be included in the client’s advisory
agreement.
The Portfolio Fee rates are current as of the date
of this Brochure. A client’s actual Portfolio Fees
could be higher or lower than the amounts shown
above if Baird adds new investment managers to
the Services with higher or lower fees or if Baird
and a manager renegotiate the amount of the
subadvisory fee.
Service Account Minimums
The minimum asset value to open an Account in a
Service is set forth in the table below.
Account Minimum
Service
Asset Level
The Advice Fee and Portfolio Fee rates do not
reflect the internal fees and expenses of any
Funds or other investment products used in
connection with a strategy, the costs of which are
borne by a client in addition to the Advisory Fee.
See “Other Fees and Expenses” below.
Consulting Services
Negotiable
Baird Advisory Choice
$10,000
Baird SMA Network
$100,000(1)
Dual Contract
$100,000(1)
PAM FOCUS Portfolios
$10,000
PAM Investment Management
$100,000
titled
“Administrative
PAM Recommended Managers
$100,000(1)
In some instances, Baird provides operational and
administrative services to third party managers in
connection with their management of client
Accounts. As compensation for those services,
Baird receives a portion of the Portfolio Fee at an
annual rate of up to 0.02% of the value of the
Account. Additional information is contained in the
document
Servicing,
Revenue Sharing, and Other Third Party
(1) BSN Fund Strategist Portfolios have a minimum
account requirement of $10,000. Other SMA
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the IRC may result. The terms of any such
household fee arrangement will be set forth in the
client’s advisory agreement.
Strategies typically have an account minimum of
$100,000. However, each investment manager sets
its own minimum account size requirements, which
can range from $25,000 to more than $1,000,000.
As a result, some investment managers may not be
available to clients with smaller accounts.
A client’s Account may also be subject to a
minimum quarterly Advisory Fee that will be set
forth in the client’s advisory agreement regardless
of the value of the assets in the client’s Account.
The minimum annual Advice Fee
for PAM
Investment Management Accounts is generally
$3,000 for equity or balanced Accounts and
$1,250 for fixed income Accounts. In addition, if a
third party custodian has custody of the client’s
Account assets, Baird may
impose Account
requirements different than those set forth above,
including but not limited to higher minimums, and
it may impose additional fees due to the increase
in resources needed to administer the Account.
While PAM and Baird may perform an analysis as
to whether any client Accounts may be eligible for
a household fee arrangement, a client should note
that it is client’s sole responsibility to inform the
client’s PAM Consultant that client’s household or
family has two or more Advisory accounts that
are eligible for a household fee arrangement. PAM
and Baird do not undertake any obligation to
ensure client Accounts are eligible for a household
fee arrangement. By agreeing to a household fee
arrangement, each client subject
to such
household fee arrangement consents to PAM and
Baird providing to each other client subject to
such household fee arrangement, in PAM’s or
Baird’s sole discretion, information about the
aggregate level, or range, of household assets
used for fee calculation purposes. As a result,
each such client should understand that the other
clients included in the household fee arrangement
may be able to ascertain the amount of the
client’s assets at Baird.
A client is encouraged to periodically review with
the client’s PAM Consultant the client’s Advisory
Fee and the services provided to determine if the
services and fees continue to meet the client’s
needs.
Calculation and Payment of Advisory Fees
Baird will calculate a client’s Advisory Fee by
applying the applicable fee rate to the value of all
of the assets in the client’s Accounts, including
cash and its equivalent and including all Held-
Away Assets, unless otherwise agreed to in
writing. Liabilities held in a client's Accounts,
including the value of margin debit balances, open
short sale positions and open options positions
with a negative market value will be excluded
from the calculation of a client's Advisory Fee. The
value of cash balances held in a client’s Account
will be excluded from the calculation of a client's
Advisory Fees in an amount equal to the value of
any open short sale positions and options
positions with a negative market value held in the
margin account.
For purposes of calculating a client’s asset-based
Advisory Fee, the value of a client’s assets is
generally determined by Baird. Baird generally
relies upon third party sources, such as third
party pricing services when valuing Account
assets. In some instances, such as when Baird is
unable to obtain a price for an asset from a
pricing service, Baird may obtain a price from its
trading desk or it may elect to not price the asset.
Obtaining a price from its trading desk may
present a conflict of interest. In some cases, Baird
obtains prices from the issuers or sponsors of
investment products in the client’s Account when
prices are not otherwise readily available. This
frequently occurs with respect to the valuation of
annuities and Complex Investment Products. If
the assets in the client’s Account are held by a
custodian other than Baird, Baird may also use
valuation information provided by the client’s
third party custodian in determining the value of
the assets in the client’s Account.
If requested by a client and approved by Baird, a
client’s Advisory Fee may be determined by also
including the aggregate value of assets in certain
other Advisory accounts held by a client and
certain members of the client’s household or
family (a “household fee arrangement”). A client
should note that Retirement Accounts may not be
included in a household fee arrangement to the
extent a prohibited transaction under ERISA or
Neither PAM nor Baird conducts a review of
valuation information provided by third party
pricing services, issuers, sponsors, or custodians,
and they do not verify or guarantee the accuracy
of such information. PAM and Baird do not accept
responsibility for valuations provided by third
parties that are inaccurate unless they have a
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
is unreliable. Valuation data
shown on statements and reports provided by
Baird. See “Services, Fees and Compensation—
Additional Service Information—Custody Services”
above for more information.
third party pricing services,
reason to believe that the source of such
valuations
for
investments, particularly annuities and Complex
Investment Products, may not be provided to
Baird in a timely manner, resulting in valuations
that are not current. The prices obtained by Baird
from
issuers,
sponsors and custodians may differ from prices
that could be obtained from other sources.
the
Values used for fee-calculation purposes may vary
from prices received in actual transactions and
are not firm bids, offers or guarantees of any type
with respect to the value of assets in an Account,
and the Advisory Fee for some securities may be
calculated based on values that are greater than
the amount a client would receive if the securities
were actually sold from the client’s Account.
A client’s Advisory Fees are payable in accordance
with the terms of the client’s advisory agreement.
Typically, Advisory Fees are payable on a calendar
quarterly basis, in advance. The initial billing
period begins when
client’s advisory
agreement is accepted by Baird and the Account
is opened by Baird (the “Opening Date”). The
initial Advisory Fee payment will be adjusted for
the number of days remaining in the then current
quarter. The initial Advisory Fee will be based on
the value of assets in the client’s Account on the
Opening Date. The period which such payment
covers shall run from the Opening Date through
the last business day of the then current calendar
quarterly billing period. Thereafter, the quarterly
Advisory Fees shall be calculated based upon the
Account’s asset value on the last business day of
the prior calendar quarter and shall become
payable on the first business day of the then
current calendar quarter.
As mentioned above, Baird will include cash and
cash equivalent balances in a client’s Account
when calculating a client’s asset-based Advisory
Fee. Baird has adopted internal policies that
monitor the percentage of an Account swept into
cash under the Cash Sweep Program. These
internal policies are designed to inform PAM
Consultants and their clients who hold large cash
sweep balances in their Accounts for sustained
periods that those Accounts are holding large
cash sweep balances and that there may be other
investment or account options for their cash and
that Baird receives direct compensation
in
addition to the Advisory Fee from client balances
in the Cash Sweep Program.
the
client’s Account may
A client’s Advisory Fees and other charges will be
automatically deducted from the client’s Account,
unless the client requests, and PAM and Baird
agree, to an alternate arrangement, such as
having Baird issue the client an invoice for the
Advisory Fees (“direct billing”). A client should
understand that the client’s Advisory Fees and
other charges relating to the client’s Account may
be satisfied from free credit balances and other
assets in the client’s Account. If free credit
balances in a client’s Account are insufficient to
pay the Advisory Fees or other charges when due,
investment manager
PAM, Baird and any
sell
managing
investments from the client’s Account to the
extent they deem necessary and appropriate, in
their sole discretion, to pay the client’s Advisory
Fees and other charges.
If a client maintains a debit balance in the client’s
margin account with Baird, such balance has no
bearing on the asset-based Advisory Fees charged
on client’s Account. In other words, the margin
balance (i.e., the outstanding amounts of the
margin loan a client owes to Baird) in client’s
Account will not be applied to reduce the client’s
billable Account value in calculating the Advisory
Fee.
If a client’s Account is subject to direct billing, the
client is required to pay each bill within 30 days of
the date of the invoice. PAM and Baird may
automatically deduct a client’s Advisory Fees and
other charges from the client’s Account as
described above in the event that Baird does not
receive payment from the client within 30 days of
the date of the invoice. PAM or Baird may rescind
a direct billing arrangement with a client at any
The Account value used for the Advisory Fee
calculation may differ from that shown on a
client’s Account statement or performance report
due to a variety of factors, including the client’s
use of margin, options, short sales, and other
considerations. If a client has assets held by a
third party custodian, the prices shown on a
client’s Account statements provided by the
custodian could be different from the prices
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
time. Direct billing may not be available for
Retirement Accounts.
To the extent permitted by applicable law, PAM or
Baird may increase a client’s existing fees and
other charges or add additional fees or charges by
providing the client with 30 days’ prior written
notice.
The fee schedules set forth above are the current
fee schedules for the Services. Each Service has
had other fee schedules in effect, which may
reflect fees that are lower or higher, as the case
may be, than those shown above. As new fee
schedules are put into effect, they are made
applicable only to new clients, and fee schedules
applicable to existing clients may not be affected.
Therefore, some clients may pay different fees
than those shown above.
Obtaining Services Separately: Brokerage or
Advisory? Factors to Consider
investment advice,
If PAM, Baird or the client terminates the client’s
advisory agreement or the client’s participation in
a Service, a pro-rated refund from the date of
termination through the end of the applicable
billing period will generally be made to the client
in the client’s affected Accounts. PAM and Baird
will not implement a decrease in the client’s fee
rate during a billing period or otherwise reimburse
or adjust Advisory Fees during any such period for
asset value appreciation or depreciation in a
client’s Account during such period. For example,
if a client’s Account is subject to a tiered or
breakpoint fee schedule and the asset levels of
the Account move into a new tier or cross a
breakpoint during such period, no rebate or fee
adjustment will be made. However, PAM and
Baird, in their sole discretion, may make fee
adjustments in response to asset fluctuations in a
client’s Account occurring during a billing period
that result from contributions to, or withdrawals
from, the client’s Account.
Under certain circumstances, PAM offers the
Services to clients on an unbundled basis. In
other words, PAM may permit clients to pay for
trade
services, such as
execution, and custody separately. In addition,
Baird offers brokerage accounts and other
services to clients, and certain services provided
to a client in connection with a particular Service
may be available to a client outside of the Service
separately. Thus, a client’s participation in a
Service could cost the client more or less than if
the client purchased each service separately. A
number of factors bear upon the relative cost of
each Service. In comparing the Services to
brokerage accounts or other services, a client
should consider a number of factors, including,
but not limited to:
• whether a client prefers to have ongoing
monitoring, investment advice or professional
management of the client’s investments, which
are provided to Service Accounts, or whether
the client does not want or need such services;
• whether the types of investment strategies,
products and solutions the client seeks are
available;
Each Service may have a minimum asset value in
order to open an Account, and a minimum
Advisory Fee may be assessed against a client’s
Account as further described under “Advisory
Fee—Fee Schedules” above. The minimum
Advisory Fee will be described in the client’s
advisory agreement. PAM may waive
the
minimum asset value or minimum Advisory Fee at
its discretion. The minimum Advisory Fee is
subject to change upon notice to the client.
• whether there are limitations on the types of
securities and other investments available for
purchase and whether those limitations are
significant to the client;
• whether the nature and level of transaction
services, account performance reporting, or
other ancillary services the client wants are
available;
• whether the client prefers to pay an ongoing
Advisory Fee for continuous advice or pay
The Advisory Fee and minimum account value are
negotiable in certain instances and may vary
based upon a number of factors, including but not
limited to the size and nature of the assets in the
client’s Account, the client’s particular investment
strategy or objective, and any particular services
requested by the client. In some instances, clients
may pay a higher fee than indicated in the fee
schedules above. The fees paid by a client may
differ from the fees paid by other clients based on
a number of factors, including but not limited to
the factors identified above.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
commissions and other fees on a transaction-
by-transaction basis;
• the relative costs and expenses of a Service
Account and a brokerage account, which will
vary depending upon:
fee or commission rate
the client
o the
negotiates;
o the size of the client’s account;
o the level of trading activity and size of trade
orders;
Client Accounts are generally subject to a Unified
Advice Fee Arrangement in which the Advisory
Fee consists of an Advice Fee and a separate
Portfolio Fee. Baird pays the manager out of the
Portfolio Fee paid by the client. The Portfolio Fee
rates are set forth under “Fee Options and Fee
Schedules—Unified Advice Fee Arrangement—
Portfolio Fee” above. However, Baird, in many
instances, retains a portion of the Portfolio Fee
when a client’s Account is managed by an Other
Manager. The maximum portion of the Portfolio
Fee retained by Baird in those instances is equal
to an annual rate of 0.10% of the value of a
client’s Account. Such amounts are retained by
Baird for the services it provides.
o applicable account fees and charges;
o the client’s use of third party managers who
charge their own fees for managing accounts
in addition to PAM’s Advice Fee; and
As the portion of the Advisory Fee or Portfolio Fee
paid to an Other Manager increases, the portion
of the Advisory Fee or Portfolio Fee that is
retained by Baird decreases. Thus, Baird (but not
PAM) has an incentive to recommend or favor
investment managers that are paid less, because
Baird will receive a higher portion of the Advisory
Fee or Portfolio Fee.
o the amount of the client’s account invested in
investment products that have additional
internal ongoing operating fees and expenses
(e.g., Funds).
Additional important information about brokerage
accounts and facts to consider when making
account type decisions is contained in the Client
Relationship Details document, which should have
been delivered to the client and is available on
Baird’s website at bairdwealth.com/retailinvestor.
In addition, Baird has an incentive to favor
Associated SMA Strategies over other SMA
Strategies because the entire Advisory Fee is
retained by Baird and Associated Managers and
because Baird benefits from its receipt of Advisory
Fees and the overall success of Associated
Managers. For more information, see “Additional
Information—Other Financial Industry Activities
and Affiliations” below.
incentive
A client should review other account types and
programs with the client’s PAM Consultant to
determine whether they are more appropriate or
should be used in addition to a Service.
Advisory Fee Payments to Baird, PAM
Consultants and Investment Managers
Given the nature of the Advisory Fee, Baird also
has an
to select or recommend
investment managers that trade less frequently
with or that trade away from Baird because Baird
will incur lower trading costs with respect to such
managers and such relationships will be more
profitable to Baird.
PAM and Baird and Associated Managers benefit
from the Advisory Fees and charges that clients
pay for the services described in this Brochure.
Fee or
subadvisory
to
Baird retains the entire Advisory Fee paid by
clients, except as further described below. With
respect to SMA Strategies available under the
SMA Programs managed by Other Managers,
Baird pays Other Managers (including Associated
Managers and Implementation Managers, if any)
a Portfolio
fee as
compensation for the manager’s services as
further described below.
A PAM Consultant is primarily compensated on a
monthly basis based upon a percentage of the
PAM Consultant’s total production each month,
which primarily consists of the total advisory fees
and transaction-based fees paid to Baird by the
PAM Consultant’s clients and any other fees Baird
earns on advisory and brokerage accounts held by
those clients, including trail fees paid by third
parties. The percentage of the PAM Consultant’s
total production actually paid
the PAM
Consultant will increase as the total amount of the
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
benefits provides PAM Consultants an incentive to
favor investment products and their sponsors that
provide the greatest levels of compensation and
benefits.
recognition
trips
for
achievement
of
PAM Consultant’s production increases, meaning
that, as the total amount of the PAM Consultant’s
production increases, the rate and amount of
compensation that Baird pays to the PAM
Consultant also
increase. PAM Consultants
generally also receive deferred compensation or
bonuses based on various criteria, including net
new assets they gather, performing certain wealth
management activities, such as financial planning,
and their total production levels. PAM Consultants
who achieve certain production thresholds are
eligible for professional development conferences,
business development coaching, reimbursements,
awards and
to attractive
destinations. PAM Consultants are also eligible for
bonuses
professional
designations depending on a PAM Consultant’s
total production level. Thus, PAM Consultants
have a general incentive to generate financial and
other plans and charge higher fees for advisory
accounts and recommend larger investments in
advisory accounts.
Interest
Given the structure of their compensation, they
also have an incentive to recommend that a client
transfer the client’s accounts to Baird, establish
new accounts with Baird (including IRA rollovers)
and add more money into the client’s accounts. In
addition, most PAM Consultants are shareholders
of Baird Financial Group, Inc. (“BFG”), Baird’s
ultimate parent company, and thus benefit
financially from the overall success of Baird and
its Associated Parties. The number of shares of
BFG stock that a PAM Consultant may purchase is
based in part on the PAM Consultant’s total
level. PAM Consultants generally
production
receive compensation for referrals to certain
affiliated managers and products and for referrals
to a limited number of other firms. More specific
is provided under the headings
information
“Additional Information—Other Financial Industry
Activities and Affiliations” and
“Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
in Client
Trading—Participation or
Transactions” below. They also generally receive
non-cash compensation and other benefits from
Baird and from sponsors of investment products
with which Baird does business. Such non-cash
compensation and other benefits may include
invitations to attend conferences or educational
seminars, payment of related travel, lodging and
meal expenses, reimbursement for branch and
receipt of gifts and
client events, and
entertainment. Receipt of such compensation and
PAM Consultants generally receive recruitment
bonuses and/or special compensation from Baird
when they join Baird from another firm. The
amount of such special compensation is typically
based on the PAM Consultant’s production at the
prior firm for the 1-year period prior to joining
Baird or on the level of the PAM Consultant’s
client assets at the prior firm. All or a substantial
portion of the special compensation is paid in the
form of an upfront bonus when the PAM
Consultant joins Baird, and the remaining portion,
if any, is paid in the form of back end bonuses
generally in equal installments on an annual basis
thereafter
for a certain number of years
(generally from one to three years). Installment
payments are generally contingent upon the PAM
Consultant achieving annual production or client
asset levels that exceed a significant percentage
of the PAM Consultant’s annual production for the
1-year period prior to joining Baird or the client
assets that the PAM Consultant had prior to
is
joining Baird. The special compensation
intended to compensate PAM Consultants for the
significant effort involved in transitioning their
business from the prior firm. This compensation
provides PAM Consultants who have left another
firm additional incentive to recommend that
clients of the prior firm become Baird clients and
to recommend investment products and services
that increase their production, and thus presents
a conflict of interest. The special compensation is
generally structured in the form of a forgivable
loan from Baird to the PAM Consultant. Under the
terms of the forgivable loan, Baird makes the
upfront or installment payment to the PAM
Consultant in the form of a loan, and Baird
forgives a portion of the loan made to the PAM
Consultant each month for so long as the PAM
Consultant remains Baird’s employee. Should the
PAM Consultant cease to be Baird’s employee
prior to the maturity date of the loan, the PAM
Consultant is required to repay Baird the amount
of the loan outstanding and not forgiven by Baird.
In other words, upon leaving Baird, the PAM
Consultant would be required to repay to Baird a
portion of the special compensation that the PAM
Consultant had received and that had not been
forgiven. The amount of such repayment declines
over time in proportion to the time the PAM
Consultant remains Baird’s employee. Structuring
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in
the
to PAM Consultants
under
the
heading
important
Interest
this special compensation
form of
forgivable loans provides the PAM Consultant
added incentive to remain Baird’s employee and
to recommend that persons become and remain a
Baird client. Additional information about referral
and non-cash compensation and other financial
is
incentives provided
provided
“Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading—Participation or
in Client
Transactions” below.
transactions for the investment product’s portfolio
(“ongoing operating expenses”). These ongoing
operating expenses are separate from, and in
addition to, the Advisory Fees. As a result of
making investments in these types of products, a
client should be aware that the client is paying
multiple layers of fees and expenses on the
amount of the client’s assets so invested—the
ongoing operating expenses and the Advisory
Fee. Additional
information about
ongoing fees and expenses that apply to those
types of investments is provided in Baird’s Client
Relationship Details document and Baird’s website
at bairdwealth.com/retailinvestor. A client can
find the actual ongoing fees and expenses of an
investment product that the client will pay or bear
in the product’s prospectus or offering document.
than
Additional Account Fees and Charges
website
Due to the manner in which Baird compensates
PAM Consultants, a PAM Consultant generally will
have a financial incentive to trade less for Baird
Advisory Choice Accounts
traditional
brokerage accounts and to reduce trading or
increase a client’s Advisory Fees if trading for a
client’s Advisory Choice Account exceeds certain
levels established by Baird. From time to time,
Baird PAM Consultants outside of PAM may refer
their clients to PAM Consultants. In those
instances, the PAM Consultant generally shares a
portion of his or her compensation with the
referring Baird Financial Advisor.
If the client’s Account is custodied at Baird, the
client is also responsible for all applicable account
fees and service charges Baird may impose in
connection with the client’s agreements with
Baird. A schedule of fees and service charges is
available
at
Baird’s
on
bairdwealth.com/retailinvestor.
Other Fees and Charges
In addition to the Advisory Fee described above, a
client of PAM will incur other fees and expenses. A
client is responsible for bearing or paying, in
addition to the Advisory Fee, the costs of all:
Baird addresses the conflicts described above
through disclosure in this Brochure and by
adopting internal policies and procedures for PAM
and Baird and their associates that require them
to provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients).
Other Fees and Expenses
Cost and Expense Information for Certain
Investment Products
• markups, markdowns, and spreads charged by
Baird in a principal transaction with a client or
charged by other broker-dealers that buy
securities from, or sell securities to, the client’s
Account (such costs are inherently reflected in
the price the client pays or receives for such
securities);
• front-end or deferred sales charges, redemption
fees, or other commissions or charges
associated with securities transferred into or
from an Account;
• redemption fees, surrender charges or similar
fees that an investment product or its sponsor
may impose;
• underwriting discounts, dealer concessions or
similar fees related to the public offering of
investment products;
A client should be aware that certain investment
products in which the client invests, such as
mutual funds and other Funds, annuities and
their own ongoing
other products, have
management and other operating
fees and
expenses that are deducted from the assets of the
product (or income or gains generated by the
product on its investments) and thus reduce the
value or return of the client’s investment in the
product. These fees and expenses may include
investment management fees, distribution (12b-
1) fees, shareholder servicing fees, transfer
agency fees, networking fees, accounting fees,
marketing support payments, administration fees,
fees, expense reimbursements, and
custody
expenses associated with executing securities
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• extra or special fees or expenses that may
result from the execution of odd lot trade orders
(i.e., “odd-lot differential”);
through another
A client may also be assessed other trading costs
in addition to the Advisory Fee if client trades are
executed
firm. Please see
“Services, Fee and Compensation—Additional
Service Information—Trading for Client Accounts”
above for more information.
• electronic fund fees, wire transfer fees, fees for
transferring an investment between firms, and
similar fees or expenses related to account
transfers (including any such fees imposed by
Baird);
• currency conversions and transactions;
conversions,
• securities
including, without
limitation, the conversion of ADRs to or from
foreign ordinary shares;
• interest, fees and other costs related to margin
accounts, short sales and options trades;
related
to
the
• fees
establishment,
administration or termination of Retirement
Accounts, retirement or profit sharing plans,
trusts or any other legal entity, including,
without limitation, the calculation and payment
of unrelated business income tax (“UBIT”);
If a client holds an Unsupervised Asset in the
client’s Account, the client may be charged a
commission, markup or markdown in connection
with its purchase or sale. The cash proceeds from
the sale of an Unsupervised Asset that remain in
a client’s Account are considered Permitted
Investments subject to the asset-based Advisory
Fee. If an asset becomes an Unsupervised Asset
during a quarterly billing period, that asset will be
excluded for purposes of determining the asset-
based Advisory Fee beginning at the start of the
next quarterly billing period, and no portion of the
asset-based Advisory Fee paid by a client in
advance for the quarter will be refunded or
rebated to the client. Additionally, Unsupervised
Assets in an Account are subject to any applicable
set-up, maintenance and administrative
fees
established by Baird. Baird may waive such fees
in its discretion.
• fees imposed by the SEC or securities markets,
including transaction fees imposed by electronic
trading platforms, which fees may be imbedded
in the price the client receives for the security;
and
imposed upon or
resulting
• taxes
Clients who have Accounts managed by PAM may
also have other accounts with Baird that are not
managed by PAM. Those accounts may be subject
to fees, commissions or other expenses that are
entirely separate from the payment of fees and
expenses for the services provided by PAM.
from
transactions effected for a client’s Account, such
as income, transfer or transaction taxes, foreign
stamp duties, or any other costs or fees
mandated by law or regulation.
Clients who use a custodian other than, or in
addition to, Baird will pay the other custodian’s
fees and expenses in addition to the Advisory Fee.
In addition, if a third party custodian has custody
of the client’s Account assets, the Account is
subject to any applicable set-up, maintenance and
administrative fees established by Baird. Baird
may waive such fees in its discretion.
In addition to the Advisory Fee, a client will also
be responsible for paying the fees charged by
each investment manager selected by the client
under the Dual Contract Program. If a client
directs PAM or Baird to pay the client’s DC
Manager’s fee out of the client’s Account, and
PAM or Baird agree to do so, PAM and Baird will
not be responsible for verifying the calculation or
accuracy of such fee.
Compensation Received by PAM and Baird
The individual who recommends a Service to a
client,
including a PAM Consultant, receives
compensation from Baird that is based upon the
amount of the Advisory Fee paid by the client.
The amount of the compensation may be more
than what the individual would receive if the client
participated in other Baird investment advisory
services or paid separately for investment advice,
brokerage, and other services. Accordingly, the
individual may have a financial incentive to
recommend a Service over other programs or
services offered by Baird. However, when
providing investment advisory services to clients,
PAM and Baird are fiduciaries and are required to
act solely in the best interest of clients. Baird
addresses this conflict through disclosure in this
Brochure and by adopting internal policies and
procedures for PAM and Baird and their associates
that require them to provide investment advice
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
specific
about
to
Compensation—Additional
and
“Services,
Fees
Fees—Advisory
that is suitable for advisory clients (based upon
the information provided by such clients). For
more
Baird’s
information
compensation and other benefit arrangements
and how Baird addresses the potential conflicts of
interest, please see the sections “Services, Fees
Service
and
and
Information”
Fee
Compensation—Advisory
Payments
to Baird, PAM Consultants and
Investment Managers” above, and “Additional
Information—Other Financial Industry Activities
and Affiliations” and “Additional Information—
Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading” below.
when the client’s paperwork is accepted by Baird
PWM’s Home Office and following such acceptance
Baird has delivered
the client written
confirmation of the Account’s enrollment in the
applicable Service. A client should understand
that the advisory agreement will not become
effective, and Baird will not provide any advisory
services to the client, until such time that Baird
has accepted the advisory agreement. Baird may
delay acceptance of the advisory agreement and
the provision of advisory services to the client for
various reasons, including deficiencies in the
client’s paperwork. Once it has become effective,
the agreement shall continue until it is terminated
in accordance with the terms described in the
advisory agreement.
Account Requirements and Types of
Clients
Opening an Account
A client that wishes to engage PAM will enter into
an advisory agreement with PAM and Baird. The
client’s advisory agreement will contain the
specific terms applicable to the services selected
by the client, Advisory Fees payable by the client,
and other terms applicable to the client’s advisory
relationship with PAM and Baird.
retain
those documents
for
The terms of a client’s agreements and this
Brochure apply to all Accounts that a client
establishes with PAM, including any Accounts that
a client may open with Baird in the future. Some
of the information in those documents may not
apply to a client now, but may apply in the future
if a client changes services or establishes other
Accounts with PAM. PAM will generally not provide
a client another copy of the agreements or this
Brochure when a client changes services or
establishes new Accounts unless
the client
requests a copy from PAM. Therefore, a client
should
future
reference as they contain important information if
a client changes services or establishes other
Accounts with PAM.
Certain Account Requirements
Minimum Account Size
In addition to the investment advisory services
that PAM and Baird provide in connection with
each Service, Baird, in its capacity as broker-
dealer, also provides clients with trade execution,
custody and other standard brokerage services.
For this reason, a client will also enter into a client
account agreement with Baird if the client has not
already done so. The client account agreement is
a brokerage agreement that authorizes Baird to
execute trades for, and perform related brokerage
and custody services to, the client’s Account.
Baird generally requires that assets in a client’s
Account be held in a Baird account, for which
Baird acts as custodian. However, in certain
limited circumstances when requested by a client,
Baird may permit a client to include Held-Away
Assets in the client’s Account.
Each Service has a minimum account size and
may have a minimum Advisory Fee, which are
described in the section entitled “Services, Fees
and Compensation—Advisory Fees” above. PAM or
Baird may remove an Account from a Service and
immediately terminate the advisory agreement
with respect to an Account upon written notice to
the client if the client fails to maintain the
required minimum asset levels in an Account or if
the client fails to otherwise abide by the terms of
a Service as determined by PAM or Baird in their
sole discretion.
Account Contributions and Withdrawals
A client may fund an Account with cash and with
securities that PAM, Baird and the client’s
to be
investment manager,
if any, deem
their sole discretion. Funds
acceptable
in
After a client has signed and delivered an
advisory agreement to Baird, the agreement is
subject to review and acceptance by the client’s
PAM Consultant, his or her Market Director or
PWM Supervision department supervisor (or his or
her respective designee), and Baird PWM’s Home
Office. The agreement and Baird’s advisory
relationship with a client will become effective
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment manager until
deposited or transferred to a client’s SMAs from
another Baird account and funds deposited or
transferred to a client’s SMAs from outside of
Baird will not be available for investment by the
client’s
the next
business day and therefore the investment of
such funds, at the discretion of the manager, will
occur no earlier than the next business day.
sale
could
in adverse
certain
appointed. In such event, Baird, at the direction
of the client’s replacement manager, or the
client’s replacement manager may sell all or a
portion of the securities or other investments in
the Account that were managed by the prior
manager and the replacement manager will
reinvest the cash proceeds of those sales. Any
such
tax
result
consequences for the client. A client should note
that securities transferred into an Account may be
subject to the Advisory Fee immediately upon its
transfer into the Account, even if the client paid a
commission or front-end sales charge on the
security prior to its transfer into the Account. In
addition, if the securities are subject to deferred
sales charges or redemption fees, the client will
be responsible for paying those charges and fees.
To the extent permitted by applicable law, certain
funding transactions may be handled by Baird on
a principal basis, and such transactions are not
considered investment advisory services of PAM,
Baird or the client’s investment manager.
If an asset transferred to an Account is an
Unpermitted Investment under the terms of the
applicable Service, PAM, Baird or the client’s
investment manager may sell the asset or
transfer it into a separate brokerage account.
Alternatively, they may designate such asset as
an Unsupervised Asset as further described under
“Services, Fees and Compensation—Additional
Service
Assets”
Information—Unsupervised
above.
Some PAM Consultants will invest, or recommend
investing, cash contributions made to an Account
over a period of time. This method of investment
is sometimes referred to dollar cost averaging
(“DCA”). The goal of this method of investment is
to reduce the risk of making large purchases of
securities at an inopportune time or price. The
Overlay Manager
investment
and
managers also offer an optional DCA service for
Accounts they manage. Additional information will
be provided to a client if the client enrolls in a
DCA service. A client should note that, if dollar
cost averaging is used to invest cash in the
client’s Account, the returns for the Account
could, depending upon market and other
conditions, be lower than the returns that could
have been obtained had all the cash in the
Account been fully invested upon contribution to
the Account. In addition, a client should note that,
when dollar cost averaging is used, the amount of
cash in the client’s Account will be included in the
value of the Account for fee calculation purposes.
Whenever assets are contributed to an Account, a
client should discuss with the client’s PAM
Consultant the timing of when the assets will be
invested. If DCA will be used to invest the assets,
a client should ask for more specific information
about how the assets will be invested and the
associated timing for investing.
that
A client is responsible for notifying PAM and any
the client’s
investment manager managing
Account of any contributions made into the
Account and instructing PAM and any investment
manager to liquidate positions in the event the
from the
client wishes to withdraw assets
Account. PAM and Baird have no responsibility to
invest cash deposits (other than complying with a
client’s cash sweep instructions) or liquidate
positions with respect to an Account managed by
an Other Manager, and they are not responsible
for any losses that may result from a client’s
failure to notify PAM and any investment manager
managing the client’s Account regarding deposits
or withdrawals.
A client may also incur additional expenses and
liabilities, including tax related liabilities, when
transferring assets out of an Account or Baird’s
custody. See “Termination of Accounts” below.
When a client funds an Account with securities,
including when a client changes Services for an
Account or changes investment managers for an
Account within the same Service, the client should
understand that PAM’s, Baird’s or the client’s
investment manager’s review of securities used to
fund the Account may delay
investing. In
addition, PAM, Baird or the client’s investment
manager,
the
if any, may determine
securities contributed to the Account may not be
appropriate for the client’s strategy, and PAM,
Baird or the investment manager, if any, may
sell, or recommend the sale of, such securities.
Further, an investment manager may be removed
from the management of a client’s Account and a
investment manager may be
replacement
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Liens and Use of Account Assets as Collateral
A client should understand that neither PAM nor
Baird will provide advice on or oversee a
securities-based lending or collateral arrangement
and they will not act as investment adviser or a
fiduciary to the client with respect to the
liquidation of securities held in the client’s
Account to meet a collateral call. Any such
liquidation will be executed in Baird’s capacity as
broker-dealer and may, as permitted by law,
result in executions on a principal basis.
“Services,
Fees
In some instances, Baird and PAM Consultants
may refer a client to a third party lender under
Baird’s Securities-Based Lending Program that
certain
pays Baird and PAM Consultants
compensation.
and
See
Compensation—Additional Service Information—
Securities-Based Lending Program” above for
more information.
As security for the full and complete payment
when due of any debts and other obligations that
a client owes to PAM and Baird, and to the extent
permitted by applicable law or regulation, all
assets in a client’s Account held at Baird will be
subject to a first priority security interest, lien and
right of setoff in favor of Baird. Baird may sell
assets in an Account to satisfy the lien. As a
secured party, Baird may have interests that are
adverse to a client. Neither PAM nor Baird will act
as investment adviser to a client with respect to
such sale of assets held in an Account. Any such
sale of assets will be executed in Baird’s capacity
as broker-dealer and creditor and may, as
permitted by law, result in executions on a
principal basis. Such sales could have adverse tax
consequences, disrupt a client’s
investment
strategy, and have an adverse impact on the
Account’s performance. A client should review the
client’s agreements for more information.
Investment Products” above
Securities purchased on margin are used as
Baird’s collateral for the margin loan. Clients that
have a margin account should review the section
“Services, Fees and Compensation—Additional
Service Information—Complex Strategies and
Complex
for
additional information.
Electronic Delivery of Documents
All of the assets in a client’s Account must be free
and clear from any security interest, lien, charge
or other encumbrance (other than a security
interest, lien, charge or other encumbrance in
favor of Baird) and must remain so for the
duration of the client’s relationship with Baird,
unless Baird otherwise specifically agrees in
writing.
By signing an advisory agreement, a client
consents to the electronic delivery of documents
that PAM or Baird may deliver to the client. The
term of the consent to electronic delivery is
indefinite but a client may revoke the consent at
any time by notifying PAM.
If a client wishes to obtain loans secured by
assets in the client’s Account (commonly referred
to as “securities-based lending”) and PAM and
Baird agree to the arrangement, the client should
understand that the lender may exercise certain
rights and powers over the assets in the Account,
including the disposition and sale of any and all
assets pledged as collateral for the loan to meet a
collateral call, which may occur without prior
notice to the client. A collateral call could have
adverse tax consequences, disrupt a client’s
investment strategy, and have an adverse impact
on the Account’s performance. A client should be
aware of these and other potential adverse effects
of securities-based lending and collateralizing
Accounts before deciding to do so.
A client is required to disclose the terms of the
client’s agreements with Baird to any lender
seeking to use Account assets as collateral. A
client must promptly notify PAM and Baird of any
default or similar event under the client’s
collateral arrangements.
Termination of Accounts
The client’s advisory agreement will survive any
event that causes the client’s PAM Consultant to
be unable to provide services to the client (either
on a temporary or permanent basis), including if
the client’s PAM Consultant ceases
to be
employed by Baird. In any such event, Baird will
endeavor to continue to provide services to the
client and will as promptly as practicable assign
another PAM Consultant or Baird Financial Advisor
to the client’s Accounts (either on a temporary or
permanent basis) and the client will be notified of
any such change or, if Baird determines that it is
unable to continue to provide advisory services to
the client, Baird may remove the applicable
Account from a Service or Program and convert
the Account to a brokerage account upon notice
to the client.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
PAM or Baird may remove an Account from a
Service and immediately close an Account upon
written notice to a client if the client fails to abide
by the terms of the Service. PAM or Baird may
also remove an Account from a Service at any
time upon written notice to a client if the client
fails to maintain the required minimum asset
levels in such Account.
to how Account
their use, and such
investments may be
unavailable for purchase or holding outside of an
Account. For example, certain mutual funds, ETFs
or other Funds held in an Account may only be
available to a client through a PAM Service or may
not be held at another firm. If such restrictions
apply and the client terminates a Service or closes
an Account, the Client will be required to sell or
redeem such Funds or exchange them for other
Funds that may be more costly to the client or
have poorer performance. A client should consider
restrictions applicable to investments carefully
before participating in a Service. A client should
contact the client’s PAM Consultant for specific
information as
closure,
termination of an agreement, or asset transfers
might impact the assets in the client’s Accounts.
exclusive
responsibility
to
in
writing,
Upon the termination of an Account’s enrollment
in a Service, PAM, Baird and, if relevant, any
other
investment manager managing such
Account, shall have no obligation to act as
investment adviser to such Account. If such
Account is custodied at Baird, the Account shall
be converted to and designated as a brokerage
account. PAM, Baird, and, if relevant, any other
investment manager managing such Account,
shall be under no obligation to recommend any
action with regard to, or to liquidate the securities
or other investments in, such Account. After an
Account is removed from a Service, it is the
issue
client’s
instructions,
the
regarding
management of any assets in such Account.
Types of Clients
PAM offers the Services to all types of current or
prospective clients, including, but not limited to:
individuals; banks or thrift institutions; pension
and profit sharing plans;
trusts; estates;
charitable organizations; and corporations or
other business entities.
Portfolio Manager Selection and
Evaluation
The persons providing portfolio management
services to clients vary by Service. Information
about how Baird may select and evaluate portfolio
managers is further described below.
Selection and Evaluation
PAM Recommended Managers
or
If a client directs Baird to liquidate assets in
connection with a closure of an Account, the client
should understand that Baird acts as broker-
dealer, and not
investment adviser, when
processing such a liquidation request and that the
client will generally be charged commissions,
sales charges, sales “loads”, or other applicable
transaction-based fees in accordance with the
applicable Baird fee schedule or other third-party
transaction-based fee schedule for the particular
investment then in effect. Additional information
about the compensation that a client pays to
Baird for effecting brokerage transactions is
contained in Baird’s Client Relationship Details
document, available on Baird’s website at
bairdwealth.com/retailinvestor.
the heading
selecting
other
When
recommending
investment managers
to manage a client’s
Account in the PAM Recommended Managers
Service, PAM may utilize managers included on
Baird’s Recommended Managers List described
under
“Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis—Certain Recommended Lists—Baird’s
Recommended Managers List” below. PAM may
also select managers not included on Baird’s
Recommended Managers List though its own
manager evaluation process.
A client may incur significant expenses and
liabilities, including tax-related liabilities for which
the client will be solely liable, if the client closes
an Account, terminates an advisory agreement, or
transfers assets out of Baird’s custody. PAM and
Baird will not be liable to a client in any way with
respect to the termination, closure, transfer or
liquidation of the client’s Accounts.
client’s
Some of the investments offered in connection
with the Services contain restrictions that limit
PAM will select or replace, or recommend the
selection or replacement of, a particular manager
based upon the client’s particular goals and
circumstances and
investment
the
strategy. This may involve the selection or
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
manager is experiencing significant and prolonged
underperformance.
review of
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, a client should note that PAM and Baird
do not monitor or ascertain whether a third party
Implementation Manager is fully and faithfully
implementing the Model Portfolio on a continuous
basis.
flows, and an analysis of how
recommendation of a manager on Baird’s
Recommended Managers List and it may involve
managers not on such list. PAM typically conducts
additional qualitative and quantitative reviews of
managers on Baird’s Recommended Managers List
and will conduct qualitative and quantitative
reviews of managers not included on such List.
PAM’s evaluation process typically involves in-
person or telephonic interviews of the manager
and a
the manager’s historic
performance, size of assets under management,
asset
the
management firm adds value.
A client assumes ultimate responsibility
for
client’s selection of an Other Manager under the
PAM Recommended Managers Program (including
any third party Implementation Manager). PAM
and Baird assume no responsibility for the client’s
termination of an Other Manager (including any
third party Implementation Manager), the Other
Manager’s investment decisions, performance,
compliance with applicable laws or regulations, or
for any other matters involving or affecting the
Other Manager.
Baird SMA Network and Dual Contract
Programs
The hiring of investment managers for a client
account includes an initial screening by PAM of a
potential manager for overall style, firm size, the
age of the investment advisor, its compliance with
GIPS composite standards, its average turnover,
and its performance record in said style for at
least the three (3) years preceding the review. A
quantitative score calculation is assessed to each
investment manager based upon the Sortino
Ratio, Alpha, Standard Deviation, Market Capture,
Batting Average and Retention, Sharpe ratio, one-
year trailing return, the most recent quarter
return, the up market capture ratio, and down
market capture ratio. A weight is then assigned to
each of the foregoing.
Clients participating in the BSN Program or the
DC Program should note that the level of initial
and ongoing review performed by PAM and Baird
on the managers and their SMA Strategies made
available under those Programs, including any
Associated SMA Strategies, is significantly less
than that performed by PAM and Baird with
respect to managers and their strategies eligible
for the PAM Recommended Managers Service.
A review of the investment manager’s long term
and short term consistency with its stated
investment style is then performed. A select
group of managers who are found to meet
quantitative and qualitative analysis standards set
by PAM for this program are sent investment
manager questionnaires. Upon completion of the
form by the investment manager, PAM reviews
the history of the investment management firm,
investment professional
ownership structure,
biographies, investment professional turnover,
buy/sell disciplines, and operations and trading. A
model portfolio with holdings and weights is also
requested from the investment manager.
BSN and DC Managers are subject to an initial
review by Baird that considers the manager’s
assets under management,
regulatory and
compliance history, and certain other limited
factors deemed
qualitative and quantitative
relevant by Baird. The ongoing review is generally
performed on an annual basis and is generally
limited to significant changes in the managers’
assets under management in the SMA Strategy
and a review of the SMA strategy in comparison
to a relevant peer group or benchmark.
a
client who wishes
After the investment manager is selected, the
manager is reviewed by PAM daily whereby a
comparison of the manager’s performance is
tracked against a suitable benchmark and daily
trading activity of the manager is reviewed.
PAM will typically remove a manager when the
manager is removed from Baird’s Recommended
Managers List or when PAM believes that the
The BSN and DC Programs are designed to
to
accommodate
independently select an investment manager not
available in the PAM Recommended Managers
Service to manage the assets in the client’s
Account. A client should note that PAM and Baird
do not make any recommendation to clients
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
performance,
compliance
regarding any BSN Strategy or DC Strategy or
any representations regarding a BSN Manager’s or
DC Manager’s qualifications as an investment
adviser or abilities to manage client assets.
Manager). PAM and Baird also assume no
responsibility for any Other Manager’s investment
decisions,
with
applicable laws or regulations, or for any other
matters involving or affecting the Other Manager.
The Overlay Manager may provide review and
ongoing evaluations of certain BSN Managers that
it makes available through the BSN Program.
Clients should review Overlay Manager’s Form
ADV Part 2A Brochure for more information, which
is available upon request, or contact their PAM
Consultant for more information.
is
Portfolio management services under the DC
Program may be provided by an investment
management department of Baird if the client
selects such an SMA Strategy. In order to provide
portfolio management services under the DC
Program, Baird requires that Baird associates
meet all applicable requirements set forth by
applicable law and regulations of self-regulatory
organizations, such as the Financial Industry
Regulatory Authority,
Inc., exchanges, and
governmental agencies.
PAM and Baird do not monitor or ascertain
whether the Overlay Manager
fully and
faithfully implementing Model Portfolios under the
BSN Program on a continuous basis.
PAM FOCUS Portfolios Program and PAM
Investment Management Service
of
Loss—Principal
home
office
SMA Strategies offered under the BSN and DC
Programs are subject to certain risks. See
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risks—Available
Risk
Investment Product Risks” below
for more
information.
Portfolio management services under the PAM
FOCUS Portfolios Program and PAM Investment
Management Services are provided by Baird,
Baird
investment
PWM’s
professionals, and PAM.
the
A client should only participate in the BSN or DC
Programs if the client wishes to take more
responsibility for monitoring the client’s Account,
the PAM Recommended Managers Program does
not contain an SMA Strategy that meets the
client’s particular needs, and
client
understands the risks of doing so.
In order
to provide portfolio management
services, Baird requires that PAM Consultants and
other Baird associates meet all applicable
requirements set forth by applicable law and
regulations of self-regulatory organizations, such
as the Financial Industry Regulatory Authority,
Inc., exchanges, and governmental agencies.
Oversight of the Services
retention of an
Asset Management,
PWM
oversees
The Investment Advisory Oversight Committee
(“IAOC”) of Baird, which includes members of
Baird’s
Sales
Management,
Investment Solutions, Asset
Manager Research, Compliance, Legal, and Risk
Management
the
Departments,
standards and implementation of the Services.
A client should note that the client’s appointment
and continued
investment
manager to manage the client’s Account in
connection with the BSN or DC Programs are
based ultimately upon the client’s independent
review of the investment manager and the
investment manager’s services. Once retained by
the client, an investment manager will only be
removed from managing the client’s Account upon
the investment manager’s withdrawal, removal
from the Program, or the client’s direction to do
so.
(including any
Program
PAM
A client assumes ultimate responsibility
for
client’s selection of a manager under the BSN or
DC Programs
third party
Implementation Manager). PAM and Baird assume
no responsibility for the client’s termination of a
the BSN or DC Programs
manager under
Implementation
third party
(including any
The IAOC delegates its day-to-day oversight
responsibilities to certain subcommittees of the
IAOC, the applicable Market Director and Baird’s
PWM Supervision, Investment Solutions and
Compliance Departments to monitor the Services
and the performance of Baird associates providing
portfolio management services under the PAM
FOCUS
Investment
and
Management Service. The applicable Market
Director, along with Baird’s PWM Supervision and
Compliance Departments and other designees,
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the
• Monthly returns are calculated using
Modified Dietz calculation.
Baird’s
Investment
along with
• Returns for periods greater than a month are
calculated by geometrically linking the monthly
returns. Returns for periods greater than one
year are annualized.
provide periodic review of the performance of PAM
Consultants providing portfolio management
services.
Solutions
the Compliance
Department,
Department and other designees, provide periodic
the performance of other Baird
review of
portfolio management
associates
providing
services under
those Services. Performance
is provided to the IAOC or a
information
subcommittee or delegate thereof.
• Reporting is net of fees at the total portfolio,
but gross of fees for individual investment
categories (e.g., equity or fixed income).
its
or
calculates
No independent third party reviews the composite
performance information calculated by Baird to
verify
compliance with
accuracy
presentation standards.
Performance Calculation
As part of Baird’s selection and evaluation of
portfolio managers, Baird
the
investment performance of:
• PAM and Baird associates acting as portfolio
managers under
the PAM FOCUS, PAM
Investment Management Services and PWM-
Managed Portfolios; and
• Other Managers participating in the PAM
Recommended Managers, BSN and DC
Programs that directly manage client accounts
under a Manager-Traded Strategy.
independent
third party
reviews
To the extent Baird selects or reviews other
portfolio managers participating in the Programs,
Baird does not calculate investment performance
information for such managers. Baird obtains
investment performance information for those
managers directly from the managers (including
the Overlay Manager) or from other external
sources that Baird believes to be reliable. A client
should understand
that: Baird does not
recalculate the performance provided by such
managers or external sources; neither Baird nor
any
the
performance
information provided by such
managers to verify its accuracy or compliance
with presentation standards unless otherwise
stated in writing; those managers may not
calculate performance on a uniform or consistent
basis; and Baird does not guarantee the accuracy
of information provided by such managers or any
external source.
Fixed
When Baird calculates a manager’s investment
performance, Baird generally uses composites of
the manager’s client accounts to calculate the
manager’s performance. A composite
is an
aggregation of client accounts managed by the
manager that are representative of a particular
investment strategy, style, or objective. Examples
of composites include large cap growth, all cap
value, balanced (which includes equity and fixed
income securities), and fixed income. Composites
may be further broken down to separate taxable
and non-taxable portfolios.
income
composites may be categorized by portfolio
duration.
Investment
recommendations. Baird
When calculating composite performance, Baird
seeks to utilize calculation methods that adhere to
Performance Standards
Global
calculates
(GIPS®)
composite performance generally using
the
following principles:
• A total return calculation is used in reporting.
• Current market value including accrued income
is used.
A client should note that Baird does not generally
present its investment performance calculations
to clients. The information that PAM or Baird
provides to clients about portfolio managers from
time to time may not be calculated by PAM or
Baird but may be calculated by the managers
themselves or derived from external sources. PAM
and Baird do not audit or verify that investment
performance information presented to clients that
is calculated by managers or external sources is
accurate. In addition, a client should note that
such investment performance information may
not be calculated on a uniform or consistent basis
or reviewed by any independent third party. A
client should ask the client’s PAM Consultant for
more information.
• Trade date accounting is used in deriving
valuations.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
professionals,
an
or
for
Portfolio Management by PAM, Baird and
Associated Managers
Portfolio management services under the PAM
FOCUS, PAM Investment Management, PAM
Recommended Managers and DC Programs may
be provided by Baird and Associated Managers.
Such arrangements create a potential conflict of
interest because Baird and Associated Managers
may receive higher aggregate compensation if
clients retain Baird and Associated Managers
instead of retaining unassociated managers.
departments,
Programs
and
Evaluation—Selection
Portfolio management services under the PAM
Recommended Managers Service or DC Program
could be provided by Baird PWM home office
investment
investment
management department of Baird or an
Associated Manager should a client select an
Associated SMA Strategy. When Baird selects SMA
Strategies, or otherwise determines manager
the Baird
eligibility,
availability
Recommended Managers List or the DC Program,
Associated SMA Strategies and Associated
Managers are subject to the same selection and
review processes, if any, that Baird applies to
unassociated SMA Strategies and investment
managers participating in each respective Service.
The processes, if any, used by Baird for selecting
and reviewing SMA Strategies and Associated
SMA Strategies for those Services are further
described under the heading “Portfolio Manager
Selection
and
Evaluation” above.
is described under
The following Services exclusively offer portfolio
management by Baird, its PAM Consultants, its
PWM home office investment professionals, its
investment management
or
investment managers that are affiliated with
Investment
Baird: PAM FOCUS and PAM
Management
(“Affiliates-Only
Programs”). The processes, if any, used by Baird
for selecting and reviewing
those portfolio
the headings
managers
“Portfolio Manager Selection and Evaluation—
Selection and Evaluation” above and “Portfolio
Manager Selection and Evaluation—Methods of
Analysis, Investment Strategies and Risk of
Loss—Program Portfolio Strategies” below.
When providing investment advisory services to
clients, PAM and Baird are fiduciaries and are
required to act solely in the best interest of
clients. Baird addresses the conflicts described
above through disclosure in this Brochure and by
adopting internal policies and procedures for PAM
and Baird and their associates that require them
to provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients). For more specific
information about these potential conflicts and
how Baird addresses them, please see the
sections “Additional Information—Other Financial
Industry Activities and Affiliations” and “Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
Advisory Business
Baird is privately-held, employee-owned global
investment and wealth management firm formed
in the State of Wisconsin in 1919.
thereby
and periodically discuss
A client should note that the processes and
standards used by Baird in determining whether
to make affiliated investment options available
under Affiliates-Only Programs differ from those
processes and standards used by Baird
in
determining whether
to make non-affiliated
investment options available under other
Services. Baird approves, and continues to make
available, affiliated investment options under
Affiliates-Only Programs
that would not be
approved for, or would have been removed from,
such other Services. For the Affiliates-Only
Programs, this practice presents a conflict of
interest because Baird has a financial incentive to
maximize the number of affiliated investment
options it makes available under Affiliates-Only
Programs due to the fact that, by increasing
investment options, Baird will likely attract more
client assets and
increase Baird’s
revenues. A client participating in an Affiliates-
Only Program should monitor the client’s Account
performance
the
performance of such Account with the client’s PAM
Consultant.
Baird is owned indirectly by its associates through
several holding companies. Baird
is owned
directly by Baird Financial Corporation (“BFC”).
BFC is, in turn, owned by Baird Financial Group,
Inc. (“BFG”), which
is the ultimate parent
company of Baird. Associates of Baird own
substantially all of the outstanding stock of BFG.
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
analysis
and
Act.
Performance-based
research,
analysis
planning;
investment
and
account
transactions
and
Performance-based fee arrangements involve the
payment of fees based upon the capital gains or
capital appreciation of a client’s account. Any such
fee arrangements are made in compliance with
applicable provisions of Rule 205-3 under the
Advisers
fee
arrangements present a potential conflict of
interest for Baird (but not PAM) with respect to
other client accounts that are not subject to
performance-based fee arrangements because
such arrangements give Baird an incentive to
favor client accounts subject to performance-
based fees over client accounts that are not
subject to performance-based fees.
interest
of
fee
Baird offers various investment advisory services
to clients, including services not described in this
Brochure. The investment advisory services Baird
include: portfolio management and
offers
recommendations
analysis;
investment
regarding asset allocation and
strategies;
and
recommendations regarding investment managers
and individual securities; investment consulting;
financial
policy
development;
performance
monitoring. Baird also offers clients execution of
administrative
brokerage
services, including maintaining custody of account
assets. Clients may also negotiate other services
with Baird. Baird offers its services separately or
in combination with other services. PAM and Baird
tailor advisory services to the individual needs of
clients. For more information about the services
offered by PAM and Baird, please see “Services,
Fees and Compensation” above.
the
arrangements
holdings
see
inequitable
above
Subject to the agreement of PAM, a client may
impose reasonable restrictions on the securities or
types of securities to be held in the client’s
Account. Please
“Services, Fees and
Compensation—Additional Service Information—
Investment Discretion”
for more
information.
In addition to complying with its fiduciary duties
by disclosing this conflict of interest to clients
through this Brochure, Baird generally addresses
posed by
potential
conflicts
performance-based
by
periodically monitoring
and
performance of performance-based fee accounts
and comparing them to accounts not subject to a
performance fee that are also managed using a
similar strategy in an attempt to detect any
possible
treatment. Baird also
attempts to minimize potential conflicts of interest
posed by performance-based fee arrangements
through internal trade allocation procedures that
are designed to make securities allocations to
discretionary client accounts in a manner such
that all such clients receive fair and equitable
treatment over time.
by
clients
providing
Baird participates in wrap fee programs not
described in this Brochure and it provides portfolio
management services in connection with those
programs. Baird receives a portion of the wrap fee
paid
portfolio
for
management services under those wrap fee
programs.
Methods of Analysis, Investment
Strategies and Risk of Loss
Investment Strategies
under management,
As of December 31, 2025, Baird had
approximately $394.0688 billion in regulatory
assets
approximately
$289.4898 billion of which was managed on a
discretionary basis and approximately $104.5790
billion of which was managed on a non-
discretionary basis.
The investment styles, philosophies, strategies,
techniques and methods of analysis that PAM,
investment
Baird, Baird PWM’s home office
professionals, and Other Managers use
in
formulating investment advice for clients vary
widely by Service and the person providing the
advice. A brief description of commonly used
strategies is provided below.
Equity Strategies
Performance-Based Fees and Side-By-Side
Management
PAM does not advise any client accounts that are
subject to performance-based fee arrangements.
Baird advises client accounts not participating in
services described in this Brochure that are
subject to performance-based fee arrangements.
Equity strategies generally have an objective to
provide growth of capital and primarily invest in
equity securities, such as common stocks.
However, these strategies may also invest in
other types of investments, such as fixed income
securities and cash. Equity strategies may invest
in companies of all market capitalization ranges or
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the market relative to their earnings or intrinsic
value, or have high dividend yields. This strategy
is subject to investment style risks.
Growth Strategies
focused,
may
focus on any combination of specific
capitalization ranges, such as large cap, mid cap
or small cap companies. Equity strategies may be
combined with other strategies described below,
such as growth, value, income, economic industry
or sector
international, global, or
geographic region or country focused strategies.
Fixed Income or Bond Strategies
A growth strategy typically invests primarily in
equity securities of growth companies, which are
those that the investment manager believes
exhibit signs of above-average growth relative to
peers or the market, even if the share price is
high relative to earnings or intrinsic value. This
strategy is subject to investment style risks.
Income Strategies
fixed
invest
An income strategy typically invests primarily in
income-producing securities, such as dividend-
income
paying equity securities and
securities. This strategy may
in a
combination of investment grade and high yield
bonds. This type of strategy may also invest in
income-producing, Non-Traditional
yield- or
Assets.
Economic Industry or Sector Focused Strategies
technology,
region or
country
Fixed income or bond strategies generally have
one or more of the following objectives: (1)
provide current income; or (2) preservation of
capital. These strategies primarily invest in fixed
income securities, such as corporate bonds,
municipal securities, mortgage-backed or asset-
backed securities, or government or agency debt
obligations. However, these strategies may also
invest in other types of investments, such as
equity securities or cash. Fixed income strategies
may invest in debt obligations having any credit
rating, maturity or duration, or they may focus on
specific credit ratings, maturities or durations,
such as investment grade, non-rated, or high
yield (“junk”) bonds, or bonds having short-term,
intermediate-term or long-term maturities. Fixed
income strategies may be combined with other
strategies described below, such as economic
industry or sector focused, international, global,
or geographic
focused
strategies.
Balanced Strategies
Economic industry or sector focused strategies
primarily invest in companies in one or more
economic industries or sectors, such as the
telecommunications,
industrial,
materials, or financial sectors. These strategies
alone generally are not intended to satisfy a
client’s entire portfolio diversification needs.
These strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
International Strategies
include companies
ranges,
regions, credit
Generally, international strategies primarily invest
in securities issued by foreign companies, which
in developed and
may
emerging markets. International strategies may
invest in companies of all market capitalization
ranges and in investments having any credit
rating, maturity or duration, or they may focus on
industries or
specific capitalization
sectors, geographic
ratings,
maturities or durations.
region or market
Balanced strategies generally have one or more of
the following objectives: (1) provide current
income; (2) growth of capital/principal or income;
or (3) preservation of capital. These strategies
primarily invest in a mix of equity, fixed income
securities and cash. Balanced strategies may
invest in companies of all market capitalization
ranges and in investments having any credit
rating, maturity or duration, or they may focus on
specific capitalization ranges, credit ratings,
maturities or durations as described above.
Balanced strategies may be combined with other
strategies described below, such as economic
industry or sector focused, international, global,
or geographic
focused
strategies.
Global Strategies
Value Strategies
Generally, global strategies invest in a mix of
securities issued by U.S. and foreign companies,
which may include companies in developed and
emerging markets. Global strategies may invest
in companies of all market capitalization ranges
A value strategy typically invests primarily in
equity securities of value companies, which are
those that the investment manager believes are
out of favor with investors, appear underpriced by
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
ranges,
regions, credit
and in investments having any credit rating,
maturity or duration, or they may focus on
industries or
specific capitalization
ratings,
sectors, geographic
maturities or durations.
Geographic Region or Country Focused Strategies
Geographic region or country focused strategies
primarily invest in companies located a particular
part of the world, such as Latin America, Europe
or Asia, in a group of similarly-situated countries,
such as developed or emerging markets, or one
or more specific countries. These strategies alone
generally are not intended to satisfy a client’s
entire portfolio diversification needs. These
strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
Tactical and Rotation Strategies
than other strategies. The
to
growth
through capital appreciation and/or
income by utilizing an active management style
that shifts the amount of investment made in
different asset classes and market sectors to take
advantage of the manager’s perception of market
pricing anomalies, those market or industry
sectors deemed favorable for investment by the
manager, the current interest rate environment
and/or other macro-economic trends identified by
the manager. Opportunity strategies often involve
the use of other strategies, particularly tactical or
rotation strategies, and will have the risks
associated with those strategies. Opportunity
Strategies may also involve investment in a more-
limited number of companies compared to other
strategies. As a result, a decline in value of one or
a few investments will more adversely impact
performance than if assets were more evenly
invested in a larger number of companies.
Opportunity strategies often experience higher
fluctuations in annual returns and overall market
types of
value
investments used
implement opportunity
strategies vary widely by manager and could
include equity securities, fixed income securities,
Non-Traditional Assets, Alternative Investment
Products and cash.
Tax Management Strategies
underweighting
and
taxable
Tax management strategies involve buying and
selling investments in a manner intended to
reduce the negative impact of U.S. federal income
taxes. They often involve buying or selling
investments to limit taxable investment gains or
to offset
investment gains with
investment losses or selling investments to avoid
recognition of taxable investment gains.
tax management strategy
is
strategies are often
subject
these
strategies
A
typically a
secondary strategy used to achieve a secondary
tax management objective and it is typically
together with other primary
implemented
investment
to achieve
strategies designed
primary investment objectives or goals. However,
managers in certain situations may use a tax
management strategy as the primary investment
strategy or tax management may be their primary
consideration when managing client Accounts,
such as when the manager is transitioning an
Account from one investment strategy to another.
Tactical strategies typically tactically and actively
adjust account allocations to different categories
of investments, such as asset classes, geographic
locations or market sectors, based upon the
manager’s perception of how those investments
will perform in the short-term. Similarly, rotation
strategies
typically actively adjust account
allocations to different market sectors based upon
the manager’s perception of how those market
sectors will perform in the short-term. Tactical
and rotation strategies are often driven by
technical analysis or methodologies and typically
involve
overweighting
account allocations to certain asset classes,
geographic locations or market sectors relative to
an applicable long-term strategic asset allocation,
benchmark index or the market generally. These
strategies often will be focused or concentrated in
one or more asset classes, geographic locations or
market sectors from time to time, and it is likely
that they will have limited or no exposure to one
or more asset classes, geographic locations or
market sectors. For that reason, tactical and
to
rotation
concentration risk. Because the decision-making
for tactical and rotation strategies is based upon
the manager’s short-term market outlook,
accounts pursuing
often
experience higher levels of trading and portfolio
turnover relative to other strategies.
Opportunity or Opportunistic Strategies
Accounts pursuing a tax management strategy in
some instances will be subject to additional or
different risks of loss, which may be material. The
Opportunity strategies will generally be invested
in a manner that seeks to provide long term
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the
strategy, particularly
utilizes
strategy
dividend
reinvestment programs, may also
inadvertently violate wash sales rules. A client’s
investments held in other accounts at Baird or
another firm may be deemed to be offsetting
positions for purposes of the IRS straddle rules,
which will also negatively impact the client’s
ability to deduct losses and will reduce the
intended benefit of the tax management strategy.
holdings of Accounts pursuing tax management
strategies will often differ from the holdings of
similarly-managed accounts that do not utilize
tax
such a
if
management
replacement
securities. Therefore,
the performance of
Accounts utilizing a tax management strategy will
vary from similarly-managed accounts that do not
utilize such a strategy, possibly in a materially
negative manner, and such Accounts may not be
successful in pursuing any other investment
strategies, objectives or goals.
investment strategies, there
resulting
from
Tax management strategies are not intended to,
and likely will not, eliminate a client’s tax
obligations relating to investments in an Account.
Like all
is no
guarantee that the implementation of a tax
management strategy will be successful. A client’s
use of a tax management strategy may not
actually
lower a client’s tax obligations or
otherwise achieve a client’s tax goals.
Managers do not consider the holdings or
transactions in other client accounts (whether
held at Baird or another firm) when implementing
tax management strategies. Managers do not
undertake any responsibility to monitor or verify a
client’s compliance with applicable tax rules, and
they are not responsible for any tax‑related
effects or obligations
the
investments or transactions in a client’s Account.
A client is responsible for ensuring that the
holdings and transactions in the client’s other
accounts at Baird or another firm do not violate
appliable tax rules and bears the risk of such
violations. A client is strongly urged to consult the
client’s tax advisor prior to pursuing a tax
management strategy.
Direct Indexing Strategies
that
involve
the
The effectiveness of tax management strategies
will be reduced if a client’s ability to recognize
losses for tax purposes is disallowed, limited or
deferred under applicable tax rules, such as the
IRS wash sales rules, which disallow losses if
substantially identical securities are purchased by
a client (whether through Baird or another firm)
within 30 days before or after a sale, and IRS
straddle rules, which limit and defer a client’s
ability to claim tax deductions related to the loss
on a sale of an investment in an Account if the
client holds an offsetting position in any account
firm. Some tax
held at Baird or another
management strategies
the sale of
securities at a loss and the reinvestment of the
proceeds into a replacement security that the
to not be “substantially
manager believes
identical” for purposes of the IRS wash sales rule.
A manager’s belief may be incorrect, resulting in
a disallowance of the loss and reducing the
intended benefits of
tax management
strategy.
limitations of
Direct indexing strategies involve investing in a
basket of individual securities, such as stocks,
that seeks to track a selected benchmark index.
Direct indexing strategies may be more costly
than other
track
investment options
benchmark indices, such as mutual funds and
ETFs. Direct indexing strategies also generally
include the use of tax management strategies in
an attempt to enhance Account performance. The
use of tax management strategies will cause an
Account to deviate from the benchmark index,
which will cause the Account’s returns to vary
from that of the benchmark index. The use of tax
management strategies may not be successful
and the performance of Accounts pursuing a
direct index strategy could be materially lower
than the benchmark index. See “Tax Management
Strategies” above for more information about the
risks and
tax management
strategies.
the wash sales
resulting
Alternative Strategies and Complex Strategies
losses. The
rules,
risk of
invest
involved
Alternative Strategies and other Complex
Strategies may
in a wide range of
investments, which may include equity securities,
fixed income securities, Non-Traditional Assets,
Investment Products and cash.
Alternative
Trading activity in a client’s accounts (whether at
Baird or another firm) may also inadvertently
in
violate
disallowed
inadvertent
violations increases as the number of client
accounts and managers
increases
because there is a higher chance of uncoordinated
or conflicting trading activity in those accounts.
Automatic purchases in client accounts, such as
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• Fixed
Income Arbitrage Strategies. Fixed
income arbitrage strategies generally seek to
profit from interest rate, credit spread and other
arbitrage opportunities by investing in fixed
income securities, interest rate instruments and
derivative instruments.
Alternative Strategies and other Complex
Strategies generally involve the use of margin,
leverage, short sales and derivative instruments.
Many Alternative Strategies and other Complex
Strategies have no substantive restrictions on the
types of investments that may be used. Examples
of Alternative Strategies and other Complex
Strategies include the following.
• Relative Value Strategies. Relative value
strategies generally involve the purchase of
traditional assets, such as stocks and bonds,
and Non-Traditional Assets and the use of short
sales and derivative instruments in an attempt
to exploit price differences among securities
that share similar economic or
financial
characteristics.
• Capital Structure Arbitrage Strategies. Capital
structure arbitrage generally involves investing
in multiple levels of a single company’s capital
structure, often taking long and short positions
in a company’s debt or equity in order to
capitalize on perceived mispricings resulting
from market inefficiencies or different pricing
assumptions. This type of strategy typically
involves the use of derivatives and structured
products.
• Long/Short Strategies. Long/short strategies
generally involve the purchase of securities
believed to be undervalued and selling short
securities believed to be overvalued. They may
also involve the use of Non-Traditional Assets,
leverage and derivative instruments.
• Absolute Return, Total Return and Real Return
Strategies. Absolute return, total return and
real return strategies generally involve the
purchase of traditional assets, such as stocks
and bonds, and Non-Traditional Assets in an
attempt to generate performance that has low
correlation to the major equity markets over a
complete market cycle. They may also involve
the use of derivative instruments.
• Event-Driven
• Market Neutral Strategies. Market neutral
strategies generally involve the purchase of
securities and selling securities short in similar
dollar amounts in an attempt to produce returns
that are
independent of general market
performance. They may also involve the use of
Non-Traditional Assets, leverage and derivative
instruments.
events
(such
and
liquidations).
Event-driven
Strategies.
strategies generally involve the use of Non-
Traditional Assets, short sales and derivative
instruments in an attempt to seek arbitrage
opportunities, particularly those triggered by
as mergers,
corporate
restructurings,
These
strategies typically involve the assessment of if,
how and when an announced transaction will be
completed.
• Statistical Arbitrage Strategies. Statistical
Arbitrage is based on the theory that stocks
have a tendency to return to a short-term trend
line. This type of strategy typically involves the
“systematic” or automated trading of securities
based upon where a security is relative to its
trend line.
arbitrage
strategies
involve
in corporate
buy-outs,
restructurings
is
short
securities believed
• Merger Arbitrage/Special Situations Strategies.
Merger
the
purchase and sale of securities of companies
involved
reorganizations and
business combinations, such as mergers,
exchange offers, cash tender offers, spin-offs,
and
leveraged
liquidations. These strategies often
involve
short selling, options trading, and the use of
other derivative instruments.
• Convertible Arbitrage Strategies. Convertible
arbitrage involves the purchase and short sale
of multiple securities of the same company. The
strategy
implemented by purchasing
securities believed to be undervalued and
selling
to be
overvalued. Often, the strategy involves the
purchase of a convertible bond issued by a
company and selling short that company’s
common stock. This strategy may involve the
use of a wide range of derivative instruments.
• Distressed Strategies. Distressed strategies
generally involve the purchase of securities in
companies that are in financial distress, or
companies that are entering into or are already
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in bankruptcy. They may also involve the use of
short sales and derivative instruments.
types of
referred
to as
floating
in
smaller
determined by a reference interest rate, such
as the federal funds rate, which is periodically
investments are
reset. These
rate
sometimes
corporate debt, floating rate loans or floating
rate bank loans. Private debt strategies often
involve the use of leverage and may involve
investment
capitalization,
distressed or bankrupt companies.
• Macro Strategies. Macro strategies generally
involve the purchase of traditional assets, such
as stocks and bonds, and Non-Traditional Assets
and the use of short sales and derivative
instruments in an attempt to profit from
anticipated changes
in securities markets,
commodities markets, currency values, and/or
interest rates.
and
Systematic
• Discretionary
industrial
typically made
strategies
generally
rely
Trading
Strategies. Discretionary
trading strategies
generally attempt to identify and capitalize on
patterns or trends in the markets. Systematic
on
trading
computerized trading systems or models to
identify and capitalize on those patterns or
trends. These strategies often involve the use of
Non-Traditional Assets, short sales, derivative
instruments and significant leverage.
risks
related
• Private Investment Strategies.
o Private Real Estate Strategies. Private real
estate strategies invest in physical properties,
such as office buildings, apartments, retail
facilities. These
centers, and
investments are
through
participation in private REITs. Private real
estate strategies may
focus on specific
types, or
regions, property
geographic
economic sectors. Investments in private real
estate can be illiquid, meaning they may take
time to sell or refinance. Property values can
fluctuate due to market conditions, supply
and demand, and other factors. There are
also
tenant vacancies,
to
property damage, or environmental hazards.
Leverage is often used in private real estate
investments, which can increase potential
returns but also amplifies potential losses.
generally
in
companies
involve
in
o Private
invest
types. Examples of
include,
These
among
utilities,
investments
o Private Equity Strategies. Private equity
equity
strategies
investments
private
transactions. These investments are typically
made through participation in private equity
funds or funds of private equity funds. Private
equity strategies may invest in companies of
all market capitalization ranges or may focus
on any combination of specific capitalization
ranges. They may also focus on companies in
one or more economic industries or sectors or
geographic regions. Some private equity
strategies focus on companies that are newly
formed, in financial distress or already in
bankruptcy. The securities purchased are
typically unregistered and illiquid. Private
equity strategies may also involve the use of
leverage.
Infrastructure Strategies. Private
in
strategies
infrastructure
infrastructure projects and assets and may
involve exposure to a range of economic or
market sectors, geographic locations and
infrastructure
asset
others,
investments
and
telecommunication,
transportation.
are
typically made through participation in private
infrastructure funds. Investments in private
infrastructure strategies are often illiquid.
They may focus on certain sectors, industries,
geographic regions, size ranges or stages of
development or operations, or on certain
types and sizes of investments and may,
therefore, also lack diversification.
typically unrated or
• Leveraged Strategies. Leveraged strategies
generally involve the use of Non-Traditional
Assets, leverage, short sales and derivative
instruments in an attempt to amplify returns or
produce returns that are a multiple of a
benchmark index.
o Private Debt or Private Credit Strategies.
Private debt (also known as private credit)
strategies invest in loans or debt instruments
issued by companies in private transactions.
These investments are typically made through
participation in private debt funds or funds of
private debt funds. The investments involved
are
rated below
investment grade and are illiquid. Oftentimes,
the interest rate paid by the companies is
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as:
short-term
taxable
• Inverse Strategies. Inverse strategies generally
involve the use of Non-Traditional Assets,
leverage, short sales and derivative instruments
in an attempt to produce returns that are the
opposite of a benchmark index.
such
bonds;
intermediate term taxable bonds; long-term
taxable bonds; short-term tax-exempt bonds;
intermediate term tax-exempt bonds; long-term
tax-exempt bonds; high yield fixed income
securities; foreign fixed income securities; and
broad fixed income securities;
and
limited
to,
collateralized
• the Non-Traditional Assets category, which is
comprised of certain asset classes, such as:
commodities
commodity-linked
instruments; and currencies and currency-
linked instruments, and Digital Assets;
• Reinsurance Strategies. Reinsurance investment
strategies generally involve participation in the
reinsurance market through investment in a
variety of insurance-linked securities or other
instruments. Investments may include, but are
not
reinsurance
contracts, industry-loss warranties, catastrophe
bonds, mortality bonds, equity investments in
insurance or
reinsurance companies, and
insurance-linked swaps and other similar
derivative instruments.
• the Alternative Investment Products category
which is comprised of certain asset classes,
such as: hedge funds, private equity funds and
managed futures; and
• cash.
allocation
strategies
have
also
have
varying
Alternative Strategies and other Complex
Strategies are not appropriate for some clients
because they are subject to special risks. See
“Services, Fees and Compensation—Additional
Service Information—Complex Strategies and
Complex
Investment Products” above and
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks—Non-Traditional
Assets and Complex Strategies Risks” below for
more information.
Asset Allocation Strategies
investing, which
and
actively
typically
adjusting
asset
tactical
including the PAM FOCUS
Certain Services,
Investment Management
Program and PAM
Service, make
allocation
available
strategies. Asset allocation strategies involve
investing
following
in one or more of the
categories of assets:
varying
Asset
investment objectives, ranging from growth of
capital to preservation of capital. Asset allocation
strategies
investment
strategies. Some asset allocation strategies use
strategic investment strategies, which involve
investing accounts
in accordance with a
predetermined target allocation to different asset
classes. Some asset allocation strategies use
involves
tactical
tactically
account
allocations to different asset classes based upon
the manager’s perception of how those asset
classes will perform in the short-term. Some asset
allocation strategies involve the use of both
strategic and
investment strategies,
sometimes referred to as dynamic strategies.
Asset allocation strategies may be implemented
using a variety of investment types, such as
individual securities, mutual funds and ETPs. The
amount allocated to an asset class or investment
type varies by strategy, and some strategies may
have little or no allocation to one or more asset
classes or types of investments described above.
companies; U.S.
cap
located
• the equity securities asset category, which is
comprised of certain asset classes, such as,
equity securities issued by: U.S. large cap
growth companies; U.S.
large cap value
companies; U.S. large cap core companies; U.S.
mid cap growth companies; U.S. mid cap value
companies; U.S. mid cap core companies; U.S.
small cap growth companies; U.S. small cap
core
small
value
companies;
in
foreign companies
developed markets; foreign companies located
in emerging markets; U.S. REITs; and foreign
REITs;
Baird uses its Capital Market Assumptions in
developing its proprietary model asset allocation
strategies, including those used by some PAM
Consultants. In determining its Capital Market
Assumptions, Baird conducts an analysis of
different asset classes and the different levels of
risk associated with those investments. That
• the fixed income securities asset category,
which is comprised of certain asset classes,
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involves
that are based upon
Baird’s
projections
analysis
the consideration of past
performance and the use of forward-looking
projections
certain
assumptions made by Baird about how markets
will perform in the future. There is no assurance
that asset classes or markets will perform in
accordance with
or
assumptions. For more information about Baird’s
Capital Market Assumptions, a client should
contact the client’s PAM Consultant.
returns and overall market value. Generally,
under normal market conditions, this strategy will
primarily invest in a mix of equity securities and
fixed income securities, with a bias towards equity
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
equity securities than fixed income securities.
Baird’s most common asset allocation strategies
are described below. A client should note that the
specific investments in an Account following a
particular asset allocation strategy could vary
from the description below for a number of
reasons, including market conditions.
invest
Income with Growth Portfolio. An Income with
Growth Portfolio typically seeks to provide current
income and some growth of capital. Typically, an
Income with Growth Portfolio will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, this strategy will primarily
invest in a mix of fixed income securities and
equity securities, with a bias towards fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
fixed income securities than equity securities.
All Growth Portfolio. An All Growth Portfolio
typically seeks to provide growth of capital.
Typically, an All Growth Portfolio will experience
high fluctuations in annual returns and overall
market value. Under normal market conditions,
this strategy generally invests nearly all of its
assets in equity securities. This strategy may also
invest in other asset classes, such as fixed income
securities, Non-Traditional Assets and cash. This
strategy may also
in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
experience
relatively
Conservative Income Portfolio. A Conservative
Income Portfolio typically seeks to provide current
Income
income. Typically, a Conservative
Portfolio will
small
fluctuations in annual returns and overall market
value. Generally, under normal market conditions,
this strategy will primarily invest in a mix of fixed
income securities, cash and equity securities, with
a significantly higher allocation to fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets.
Generally, under normal market conditions, this
strategy will have a significantly higher allocation
to fixed income securities and cash than equity
securities.
Capital Growth Portfolio. A Capital Growth
Portfolio typically seeks to provide growth of
capital. Typically, a Capital Growth Portfolio will
experience moderately high fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, this strategy will
primarily invest in a mix of equity securities and
fixed income securities, with a significantly higher
allocation to equity securities. This strategy may
also invest in other asset classes, such as Non-
Traditional Assets and cash. This strategy may
also invest in Alternative Investment Products or
may involve the use of leverage, short sales and
derivative instruments. Generally, under normal
market conditions, this strategy will have a
significantly higher allocation to equity securities
than fixed income securities.
Preservation
A
Portfolio.
typically seeks
Growth with Income Portfolio. A Growth with
Income Portfolio
to provide
moderate growth of capital and some current
income. Typically, a Growth with Income Portfolio
will experience moderate fluctuations in annual
Capital
Capital
Preservation Portfolio typically seeks to preserve
capital while generating current income. Typically,
a Capital Preservation Portfolio will experience
relatively small fluctuations in annual returns and
overall market value. Under normal market
conditions, this strategy generally invests nearly
all of its assets in a mix of fixed income securities
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and cash. This strategy may also invest in other
asset classes, such as equity securities and Non-
Traditional Assets.
income
investments
investment
restrictions,
Objectives
and
Some PAM Consultants and investment managers
use asset allocation strategies that include target
asset allocation percentages for equity and/or
in the names or
fixed
descriptions of the strategies (e.g., 80-20, 60-40,
40-60, 20-80, etc.). A client should note that
those percentages are intended to be asset
allocation targets only. There is no guarantee that
Accounts following asset allocation strategies will
be invested strictly in accordance with target
asset allocations. It is likely that the actual
investments in Accounts following those strategies
will vary, sometimes significantly, from the target
asset allocations and may include other asset
classes due to market conditions and the PAM
Consultant’s or investment manager’s assessment
of how to best invest a client’s Accounts. See
“Important Information about Implementation of
Investment
Investment
Strategies” below for more information.
For information about the risks associated with
the asset allocation strategies described above,
see the section of the Brochure entitled “Principal
Risks—Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies” below.
From time to time, the client’s PAM Consultant or
investment manager will
invest the client’s
Account, or recommend that the client invest the
Account, in a manner that is inconsistent with the
investment strategy or
investment objective
selected by the client for the Account when the
client’s PAM Consultant or investment manager
determines that it is appropriate to do so, such as
using defensive strategies in response to adverse
market or other conditions or engaging in tax
management. Similarly, a client’s Account may be
invested in a manner inconsistent with the
investment objective
investment strategy or
selected by the client for the Account in certain
other circumstances, such as when the client’s
Account
is transitioning to a new Service,
investment objective or investment strategy, or
due to other factors, such as market appreciation
or depreciation of the assets in the client’s
Account, deposits and withdrawals made by the
client, and
if any,
imposed by the client. A client’s Account may not
be able to achieve its investment objectives
during any such period of time and the Account
may be subject to different or enhanced risks
than would be the case had the Account been
invested in a manner wholly consistent with the
investment objective or
investment strategy
selected by the client. Clients are encouraged to
discuss with their PAM Consultant on a regular
basis how the Account is being managed or
advised and whether any such conditions exist.
Important Information about Implementation of
Investment Objectives and Investment Strategies
Methods of Analysis
Baird, its home office investment professionals,
and PAM Consultants may use various forms of
investment analyses, including the following:
• Fundamental Analysis. Fundamental analysis
involves an approach to investing through a
detailed analysis of specific companies, such as
their financial statements and financial ratios,
management, competitive advantages and
markets, in an attempt to determine the value
of an investment. Fundamental analysis may
include qualitative and quantitative analyses.
A client should note that, to implement an
investment strategy, a client’s PAM Consultant or
investment manager may use or recommend
mutual funds, ETPs or other Funds that primarily
invest in particular types of securities instead of
direct investment in those types of securities. A
client should also note that the client’s PAM
Consultant or investment manager may use a
strategy not described above or they may use a
strategy with the same or similar name that is
implemented differently. A client should ask the
client’s PAM Consultant or investment manager
for more specific information about the strategy
being used for the client’s Account.
Analysis. Qualitative
• Qualitative
analysis
involves the use of subjective judgment to
analyze factors that may be difficult to quantify
or measure objectively. As it pertains to
managers and investment products, qualitative
analysis may include review of the background
is subject to the risks
A client’s Account
associated with the Account’s particular strategies
and investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
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and experience of a manager or a mutual fund
company.
their
sponsors
(which may
in an attempt
conditions,
investment
• Quantitative Analysis. Quantitative analysis is a
method of evaluating securities by analyzing a
large amount of data through the use of
algorithms or models
to
understand behavior, predict market events,
market prices, etc., and generate an investment
decision. As it pertains to managers and
investment products, quantitative analysis may
include
review of manager performance,
investment style, style consistency, risk, and
risk-adjusted performance.
performance,
• Technical Analysis. Technical analysis is a
method of analyzing past price and volume
patterns and trends in the trading markets to
attempt to predict the direction of both the
overall market and specific investments.
of information and tools may include, among
others, information provided or created by issuers
and
include
information that is reported publicly, provided
directly to Baird, or reported through third party
platforms) and information and tools provided by
third party research firms, which may include
firms affiliated with Baird. PAM relies on both
affiliated and independent, third-party research
and information when analyzing market trends
and
manager
performance, and asset class characteristics and
performance. PAM has built and maintains a
proprietary database of manager characteristics,
including historical
personnel
details, fees, investment philosophy, ownership
and legal history. Although Baird has deemed the
information and tools provided by third party
research firms to be generally reliable, Baird does
not
the
independently verify or guarantee
accuracy of the information or tools used.
(“AI”)
• Top-Down Analysis. Top-down analysis involves
a consideration of certain macroeconomic
trends, such as general economic conditions,
geographic or market sector performance, fiscal
and monetary policy, taxes, or interest rates, to
make investment decisions.
Analysis. Bottom-up
• Bottom-Up
in
formulating
investment,
analysis
involves consideration of factors particular to a
such as business
particular
financials (e.g., balance sheet strength and
cash flows), financial ratios (e.g., price-to-
earnings ratio), and business fundamentals
(e.g., management and product or services
performance) to make investment decisions.
Baird PWM home office investment professionals
and PAM Consultants may use artificial
intelligence
tools, such as machine
learning, predictive analytics and probabilistic
modeling tools, data processing and automation
tools, generative AI tools, visual, speech and
audio tools, specialized domain tools, and other
similar technologies and tools (collectively, “AI
investment advice.
Tools”),
Generally, the use of AI Tools is limited to certain
aspects of Baird’s investment-advice process,
such as assisting with drafting of materials,
automation of workflow processes, and the
organization,
reproduction,
compilation,
summarization, analysis and interpretation of
information. The use of AI Tools is only supportive
of Baird’s investment-advice process and does not
replace the professional judgment of Baird PWM
home office investment professionals or PAM
Consultants. All AI Tool-assisted outputs used in
formulating investment advice are subject to
human
inform
review before such outputs
recommendations or investment decisions.
When providing investment advice to clients, PAM
Consultants utilize research reports and other
research material created by Baird PWM Research
Groups, such as PWM Equity Research, PWM Fixed
Income Research, and Asset Manager Research.
PAM Consultants may also utilize research reports
created by Baird’s
Institutional Equities &
Research Department. It should be noted that
PAM Consultants are not obligated to act in a
manner consistent with those research reports
and they may act in a manner that is contrary to
those reports if they deem it to be in the client’s
best interest.
Baird PWM Research Groups and PAM Consultants
use various third party information and tools
when formulating investment advice. The sources
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations,
deceptive behaviors and other flaws due to the
construction of their underlying models and the
composition of their training data, which can
result in outputs that seem plausible but are in
fact inaccurate, incomplete, or misleading. The
use of AI Tools creates a risk that erroneous
the
information
could negatively
influence
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any such investment product and that the client’s
decision to transfer or select such investment
product is based solely upon the client’s review of
the investment product.
Certain PWM-Managed Portfolios
Baird Recommended Portfolio
investment-advice process. Baird has established
policies and procedures designed to address the
risks posed by AI Tools, which
include
requirements that AI Tools pass a firm-level due
diligence process and that Baird associates obtain
training and independently verify AI Tool outputs.
However, such measures cannot eliminate the
risks posed by AI Tools.
investment
approach
When providing investment advice to clients, PAM
Consultants may also use the model portfolios or
recommended or eligible product lists (described
below) made available by Baird’s PWM Research
Groups, or they may use investment products
that Baird has generally deemed to be “available”
for use in its advisory programs (“Available
Investment Products”). The level of initial and
ongoing evaluation, monitoring and review that
PAM and Baird perform on managers and on
investment products varies. Available Investment
Products generally do not receive the same level
of initial or ongoing evaluation, monitoring or
review by Baird as those managers or products
that are included in a model portfolio or on a
recommended or eligible product list. As a result,
Available Investment Products are subject to
certain risks. See “Portfolio Manager Selection
and Evaluation—Methods of Analysis, Investment
Strategies and Risk of Loss—Principal Risks—
Available Investment Product Risks” below for
more information.
is
The Baird Recommended Portfolio, which
managed by Baird’s PWM Equity Research team,
seeks to outperform the S&P 500 Index by
investing in a diversified core portfolio of 35–50
stocks. The portfolio invests primarily in stocks
with market capitalization greater than or equal to
$10 billion (large cap). The portfolio may also
contain stocks with market caps below $10 billion
but these stocks generally will not represent more
than 35% of the total portfolio. The team’s top–
down
begins with
macroeconomic and market outlooks from Baird’s
Investment Strategy team. This information is
used to underweight or overweight particular
industry sectors compared to the S&P 500 Index.
Individual stocks are selected with an emphasis
on higher quality companies that the team
believes have strong fundamental characteristics
teams, attractive growth
and management
prospects, and
reasonable price-appreciation
expectations. Each stock selected is assigned a
weighting as a percentage of the portfolio. No
single company stock will comprise more than the
greater of 5% of the portfolio or 1.5 times the
stock’s market weight in the S&P 500 index;
provided that a stock will not be removed due to
capital appreciation. Stocks can be sold or
positions reduced for a variety of reasons such as
valuation, a change in company or industry
fundamentals, or a change in industry sector
weighting. The Portfolio is intended as a long-
term investment strategy.
Baird Rising Dividend Portfolio
More specific information about Baird PWM model
portfolios, recommended lists and eligible product
lists is provided below. A client should note that
investment products recommended to the client
or selected for the client’s Account, including
investment managers or products included on a
Baird PWM recommended or eligible product list,
are those which, in Baird’s professional judgment,
may be appropriate to help the client pursue the
client’s financial goals. PAM and Baird do not
represent or guarantee that such investment
managers or products are or will be the best
investment managers or products available.
The Baird Rising Dividend Portfolio, which is
managed by Baird’s PWM Equity Research team,
seeks to provide a core equity strategy with a
portfolio yield above that of the S&P 500 Index.
The team’s top–down investment approach begins
with macroeconomic and market outlooks from
Baird’s Investment Strategy team. The 30–50
stocks in the portfolio are primarily large cap
stocks—as defined by a market capitalization of
$10 billion or greater at the time of investment—
and all are above $5 billion at the time of
investment. The team looks for quality companies
fundamental characteristics and
with strong
Under certain circumstances when requested by a
client, PAM and Baird may allow a client to
transfer from another firm or select an investment
product that is not on a Baird recommended or
eligible product list or that does not qualify as an
Available Investment Product. A client should note
that, unless PAM and Baird otherwise agree in
writing, PAM and Baird do not provide any initial
or ongoing evaluation, monitoring or review of
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those included in the S&P MidCap 400® Index;
and (4) the AQA Small Cap Strategy, which
primarily invests in small cap stocks, generally
those included in the S&P SmallCap 600® Index.
Certain Recommended Lists
Baird’s Recommended Managers List
management, attractive dividend yields, and the
ability to increase their dividends. Companies are
screened for dividend history and consistency,
earnings growth expectations, and balance sheet
quality. Each stock selected
is assigned a
weighting as a percentage of the portfolio. No
single company stock will comprise more than the
greater of 5% of the portfolio or 1.5 times the
stock’s market weight in the S&P 500 index;
provided that a stock will not be removed due to
capital appreciation. A position can be reduced or
removed due to changes in valuation, company
fundamentals or the perceived ability to continue
to raise its dividend in the future—among a
variety of other potential reasons for portfolio
changes including a change in industry sector
weighting. The Portfolio is intended as a long-
term investment strategy.
AQA Portfolios
to
clients
Analysis
When selecting managers and BRM Strategies for
Baird’s Recommended Managers List, Baird often
seeks registered investment advisory firms having
portfolio managers with academic credentials
such as a master’s degree or participation or
completion of the Chartered Financial Analyst
(“CFA”) program. Baird also typically looks for a
portfolio manager with greater than three (3)
years of investment experience focusing on the
particular investment style that is offered by the
portfolio manager. Baird generally looks for
portfolio managers
that have demonstrated
success, that have performance histories showing
sufficient ability to achieve returns in excess of
their respective benchmarks, and that have
investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird
also considers other qualitative and quantitative
factors.
performance.
The
analysis
Baird’s Asset Manager Research Department is
primarily responsible for selecting and evaluating
included on Baird’s
investment managers
selecting
In
Recommended Managers List.
investment managers, Baird’s Asset Manager
Research Department utilizes quantitative and
qualitative measures to evaluate managers based
on the:
• quality and stability of their organization
• soundness and clarity of their investment
philosophy
• reliability and consistency of their investment
process
• competitiveness of their investment
performance
Baird’s Asset Manager Research Department may
also employ the use of computers and third party
software to more readily display information and
assist with the evaluation and analysis.
Baird makes available
certain
(“AQA”)
Automated Quantitative
Portfolios, which are managed by Baird’s PWM
Equity Research team. AQA is an analytical tool
that seeks to identify stocks of companies that
are undervalued by calculating the intrinsic values
for the stocks and comparing the calculated
values to current market prices. Focusing on a
company’s past
financial performance, AQA
analyzes fundamental ratios and trends of the
most recent eight-year history of a company and
each company in its peer group, excluding
estimates of future balance sheet and income
statement
is
quantitative and
ignores certain qualitative
information such as company-specific material
news and events. Stocks are ranked from the
most undervalued to the most overvalued based
on the difference between the values calculated
by AQA and current market prices. The stocks
identified by AQA as being the most undervalued
are then selected for investment. Baird offers the
following four (4) AQA Portfolio strategies, each of
which invest in undervalued stocks identified
using AQA, excluding securities issued by banks,
REITS and insurance companies: (1) the AQA All
Cap Strategy, which primarily invests in stocks
across market capitalizations, generally those
included in the S&P 500®, S&P MidCap 400® or
S&P SmallCap 600® Indices; (2) the AQA Large
Cap Strategy, which primarily invests in large cap
stocks, generally those included in the S&P 500®
Index; (3) the AQA Mid Cap Strategy, which
primarily invests in mid cap stocks, generally
Baird’s initial screening process begins with a
proprietary, multi-factor model that evaluates
managers on different factors including risk-
adjusted performance, consistency of returns and
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performance of a client’s Account could be
negatively impacted. Baird is not monitoring,
evaluating or reviewing the Overlay Manager or
Implementation Manager or the performance of a
client’s Account under those circumstances.
SMA
Strategies
for
Certain SMA Strategies offered by Baird Equity
Asset Management have been selected by Baird
for inclusion on Baird’s Recommended Managers
List. This presents a conflict of interest. However,
the criteria used by Baird in deciding to select
Associated
Baird’s
Recommended Managers List are the same as
those used for unassociated SMA Strategies.
downside protection. These factors are scored
over various time periods and relative to a
specific peer group universe, narrowing the pool
of managers for further evaluation. Baird’s Asset
Manager Research Department then performs a
more in-depth evaluation of managers that are
identified through the initial screening process,
which generally includes a review of the following
factors: stability of the firm/team, the robustness
and repeatability of the investment process, the
portfolio’s past returns pattern and tax-efficiency,
and how the manager adds value. The final
determination of Baird’s Recommended Managers
List
is subject to the approval of Baird’s
Investment Committee.
Baird’s Recommended Mutual Fund List
conference
calls,
that
to
the
for
removal
change
Ongoing manager evaluation generally includes
performance
quarterly
attribution and periodic onsite visits. Material
adverse changes affecting a manager may result
in the manager being placed on “watch” status.
Managers on “watch” status are scrutinized to see
if improvement or degradation is taking place.
Potential causes
from Baird’s
Recommended Managers List include fundamental
changes in the operations of the manager,
turnover in key personnel, substantial changes in
management or ownership, a
in
investment philosophy or style, significant drift
from stated objectives, major legal, regulatory or
compliance difficulties, impairment of financial
condition, sustained underperformance in relation
to its peers, or other adverse changes affecting
the manager that in Baird’s opinion warrants the
manager’s removal.
Baird’s
Asset Manager
Investment Committee
its discretion, decides
is
Baird’s Recommended Mutual Fund List
designed to include mutual funds and ETFs across
numerous asset classes. When selecting funds for
inclusion on the List, Baird generally seeks funds
that have investment managers with tenure of at
least three (3) years and have underlying
investments
fund’s
adhere
market capitalization policy and are consistent
with the manager’s stated investment process
and philosophy. Baird generally looks for funds
that are among the top-performing funds in a
style category in terms of risk-adjusted returns or
that are managed by individuals or firms that
have demonstrated success in other, related asset
classes; that have performance histories showing
sufficient ability to achieve returns in excess of
their respective style index; and that have
investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird’s
Asset Manager Research Department is primarily
responsible
for assisting with selecting and
evaluating funds included on the List. In selecting
funds,
Research
Department utilizes a quantitative and qualitative
evaluation process of the investment managers of
such funds. The process Baird uses for selecting
and removing funds for the Baird Recommended
Fund List is similar to the process Baird uses to
select and remove BRM Strategies described
under “Baird’s Recommended Managers List”
above. Baird’s
is
ultimately responsible for selecting funds included
on the List. The Baird Ultra Short Bond Fund,
Baird Short-Term Bond Fund, Baird Aggregate
Bond Fund, Baird Quality Intermediate Municipal
Bond Fund, Baird Core Intermediate Municipal
Bond Fund, and Baird Mid Cap Growth Fund,
mutual funds affiliated with Baird, have been
If a Model-Traded BRM Strategy is selected for a
client’s Account, it is important to note that
Baird’s selection and ongoing evaluation of a BRM
Strategy is based upon an assumption that the
Recommended Manager’s Model Portfolio will be
fully and faithfully implemented by the Overlay
Manager or Implementation Manager on a
continuous basis. A client should understand that
the Overlay Manager or Implementation Manager
has discretion over the client’s Account and may
invest the client’s Account in a manner that differs
from the Model Portfolio. Baird does not monitor
the Account’s performance nor does it ascertain
whether the Overlay Manager or Implementation
Manager is implementing the Model Portfolio as
provided by the Recommended Manager. If the
Overlay Manager or Implementation Manager, in
to
the exercise of
implement the Model Portfolio differently, the
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inclusion
selected by Baird
in Baird’s
for
Recommended Mutual Fund List. This presents a
conflict of interest. However, the criteria used by
Baird in deciding to select Associated Funds for
Baird’s Recommended Mutual Fund List are the
same as those used for unassociated funds.
Baird’s Recommended Funds of Hedge Fund List
In making
that determination,
ADV Part 2A Brochures). This is followed by an
onsite review, where Baird meets with one or
more principals and analysts to assess how the
FOHF identifies, hires, monitors, and terminates
individual hedge funds. Baird also evaluates how
the FOHF constructs its hedge fund portfolio and
manages risk. At the conclusion of the onsite
review, an investment thesis is presented to and
discussed with a Baird Investment Committee.
The Committee votes on whether to add the FOHF
to Baird’s Recommended Funds of Hedge Fund
List.
the
Committee considers the information presented,
taking into account the merits of the individual
FOHF, how that FOHF compares to other FOHFs
that Baird offers, and the level of expected
demand for the particular FOHF.
and
onsite
Baird’s Recommended Funds of Hedge Fund List
may contain several types of funds of hedge
funds (“FOHFs”) that pursue various Alternative
Strategies or other Complex Strategies. Some
FOHFs primarily use credit-oriented investment
strategies, which Baird classifies as fixed income
diversifiers. Some FOHFs primarily use equity-
oriented investment strategies and are classified
as equity diversifiers. Other FOHFs use a
combination of credit- and equity-oriented
strategies, which Baird views as balanced
diversifiers. In certain circumstances, FOHFs may
be an appropriate substitute for part of a client’s
allocation to traditional high yield fixed income or
equity investments.
changes
After a FOHF is added to Baird’s Recommended
Funds of Hedge Fund List, it is monitored each
quarter,
reviews
subsequent
periodically take place. As part of its quarterly
monitoring, Baird evaluates a FOHF’s assets under
(subscriptions and
management and
flows
redemptions), organizational
(e.g.,
personnel changes or new offerings), recent
changes made to the FOHF portfolio (e.g., hedge
funds added or removed), and reasons for
performance differences between the FOHF and
its benchmark. Subsequent onsite reviews are
similar in nature and scope to the initial on-site
review.
for
the
fund; and
To be added to Baird’s Recommended FOHF List,
following
a FOHF must generally meet the
requirements: the investment advisor to the FOHF
is registered as an Investment Adviser under the
Advisers Act; the fund has stable to growing
assets under management as determined by
Baird, principals of the fund have an appropriate
level of hedge fund management experience and
a sufficient network of contacts in the industry as
determined by to Baird; in Baird’s opinion, the
fund has adequate diversification by number of
hedge funds and type of hedge fund strategy;
effective risk management programs have been
established
the service
providers to the fund (e.g., auditor, administrator,
and legal counsel) are deemed to be reputable in
the judgment of Baird. Baird also seeks FOHFs
that it believes possess one or more unique
attributes that may lead to favorable performance
relative to their peers going forward.
legal documents
Baird may place a FOHF on “watch” status if it has
experienced a material event that, in Baird’s
the FOHF’s
opinion, may negatively affect
performance going forward or possibly lead to the
departure of an important member(s) of the
FOHF. Examples include a large decline in assets
under management, high rate of redemptions,
notable change in the investment or compliance
teams, weakening performance, or regulatory
problems. Any firm that is placed on “watch”
status is evaluated more closely to determine if
the problem is likely to be temporary or long-
term, and whether it can be remedied. Baird will
remove a FOHF from “watch” status and return it
to active status if, in Baird’s opinion, the problem
has been or is in process of being adequately
addressed. However, Baird will terminate a FOHF
from the List if it believes the issue is likely to be
long-term and adversely affect the FOHF’s future
performance.
offering memorandum,
Before adding a prospective FOHF to the List,
Baird’s Asset Manager Research Department
conducts an in-depth due diligence process. The
process begins with a review of the FOHF’s
responses to a due diligence questionnaire and of
marketing and
(such as,
subscription documentation, investor agreements,
and
organizational
documents, and the investment advisor’s Form
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Baird’s Recommended Private Funds Lists
Baird maintains lists of recommended private
Funds (“Recommended Private Funds”), including
a Recommended Funds of Private Equity Funds
List, a Recommended Private Debt Fund List, and
a Recommended Private Real Assets Fund List.
funds,
funds
or
To be added to a Baird Recommended Private
Fund List, a fund must generally meet the
following requirements: the investment advisor to
the fund is registered under the Advisers Act ; the
fund has stable
to growing assets under
management as determined by Baird; principals
of the fund have an appropriate level of applicable
experience and a sufficient network of contacts in
the industry as determined by Baird; effective risk
management programs have been established for
the fund; and the service providers to the fund
(e.g., auditor, administrator, and legal counsel)
are deemed to be reputable in the judgment of
Baird. Baird also seeks funds that it believes
possess one or more unique attributes that may
lead to favorable performance relative to their
peers going forward.
fund
client’s allocation
to
Baird’s Recommended Funds of Private Equity
Funds List contains funds of private equity funds
that pursue certain Alternative Strategies or other
Complex Strategies. These strategies can include
buyout, growth equity, venture capital, special
investments. The
situations or distressed
investments are typically structured in the form of
primary
co-
secondary
investments. Most will be to “middle market”
companies, many of which have above average to
high levels of leverage, or debt relative to equity.
In certain circumstances, funds of private equity
funds may be an appropriate substitute for part of
a
traditional equity
investments.
that pursue
or
Baird’s Recommended Private Debt Fund List
contains private debt funds (also known as
certain
funds)
credit
private
Alternative Strategies
other Complex
Strategies. The private debt funds on Baird’s
Private Debt Funds List generally make first lien,
second lien and unsecured loans, primarily to
middle market companies sponsored by private
equity firms. In certain circumstances, private
debt funds may be an appropriate substitute for
part of a client’s allocation to traditional high yield
fixed income or equity investments.
funds
that
or
the
Before adding a prospective
to a
Recommended Private Fund List, Baird’s Asset
Manager Research Department conducts an in-
depth due diligence process. The process begins
with a review of the fund’s responses to a due
diligence questionnaire (known as a DDQ or RFI)
and of marketing and legal documents (such as,
subscription documentation, investor agreements,
offering memorandum, organizational documents,
and the investment advisor’s Form ADV Part 2A
Brochures). This is followed by an onsite review,
where Baird meets with one or more principals
and analysts to assess how the fund makes
investment decisions. Baird also evaluates how
the fund constructs its portfolio and manages risk.
In addition, Baird may undertake a brief review of
the fund’s third-party service providers. At the
conclusion of the onsite review, an investment
thesis is presented to and discussed with a Baird
Investment Committee. The Committee votes on
whether to add the fund to a Baird Recommended
Private Fund List. In making that determination,
the Committee
information
considers
presented, taking into account the merits of the
individual fund, how that fund compares to other
similar funds that Baird offers, and the level of
expected demand for that particular fund.
utilities,
telecommunication,
The
investments may
with
companies
that
Baird’s Recommended Private Real Assets Fund
List contains private real estate and private
pursue
infrastructure
certain
other Complex
Alternative Strategies
Strategies. These strategies invest in different
real assets and may involve exposure to a range
of economic or market sectors, geographic
types. Examples of
locations and asset
investments may include, among others, real
and
estate,
transportation.
be
structured in the form of asset ownership or
leasing or include direct investment in or joint
ventures
control
infrastructure assets. In certain circumstances,
private real assets funds may be an appropriate
substitute for part of a client’s allocation to
traditional fixed income or equity investments.
After a fund is added to a Baird Recommended
Private Fund List, it is monitored each quarter,
and subsequent onsite reviews periodically take
place. As part of its quarterly monitoring, Baird
evaluates a fund’s assets under management and
fund
flows (subscriptions and redemptions),
organizational changes (e.g., personnel changes
or new offerings), recent changes made to the
portfolio, and reasons for performance differences
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collection of ETPs that may be appropriate to
meet particular client investment goals.
between the fund and its benchmark. Subsequent
onsite reviews are similar in nature and scope to
the initial on-site review.
PWM Stock Opportunities List
yield,
The PWM Stock Opportunities List is comprised of
stocks that Baird’s PWM Equity Research team
believes offer timely investment opportunities
fundamental
based on market, sector, and
analysis. Stocks on the list must be covered by
Baird, Evercore ISI, or Morningstar and are
screened to curb near-term fundamental risk. The
List focuses on large cap and mid/small cap
and
investments with
companies,
speculative investment opportunities.
Managed Futures
Baird may place a Recommended Private Fund on
“watch” status if it has experienced a material
event that, in Baird’s opinion, may negatively
affect the fund’s performance going forward or
possibly lead to the departure of an important
member(s) of the
investment team.
fund’s
Examples include a large decline in assets under
management, high rate of redemptions, notable
change in the investment or compliance teams,
weakening performance, or regulatory problems.
Any fund that is placed on “watch” status is
evaluated more closely to determine if the
problem is likely to be temporary or long-term,
and whether it can be remedied. Baird will
remove a fund from “watch” status and return it
to active status if, in Baird’s opinion, the problem
has been or is in process of being adequately
addressed. However, Baird will remove a fund
from a Recommended Private Fund List if it
believes the issue is likely to be long-term and
adversely affect the fund’s future performance.
Effective March 1, 2018, Baird ceased maintaining
an official list of managed futures funds that are
structured as limited partnerships. Therefore,
Baird does not, and will not in the future, provide
any evaluation, monitoring or review of those
funds or their sponsors. A client’s decision to
invest in, or to maintain an investment in, a
managed futures fund is based solely upon the
client’s own review and evaluation of the fund.
Certain Eligible Product Lists
Structured Products
Annuities
the
is calculated,
strength
ratings
When determining whether to make a structured
product available to Baird clients, Baird reviews
the offering documents for the structured product
and considers: the size of the issuer and issuer’s
credit rating, the maturity of the product, how
interest
the underlying asset
category (e.g., a basket of securities or currencies
or a market index), applicable caps, barriers, and
participation rate, and whether the structured
product has principal protection.
When determining whether to make an annuity
product available to Baird clients, Baird reviews
the offering documents for the product and
considers: the size of the insurer and the insurer’s
credit rating,
insurer’s distribution and
support model, and product specifications and
features of the product. Baird favors highly-rated
insurers and evaluates them by using credit rating
agencies
and
financial
independent third-party research.
Baird’s ETF Focus List
indices,
Baird tends to favor larger-sized issuers of
structured products over smaller-sized issuers
and also tends to favor structured products that
have shorter maturities, less complex payout
structures, underlying assets that are more liquid
or transparent, and offer full or partial principal
protection. If a product does not offer full
principal protection, Baird also considers how
much principal is exposed to loss, whether, in
Baird’s judgment, there is reasonable risk/reward
trade-off for that exposure, as well as the events
that could trigger loss of principal and Baird’s
belief as to the likelihood of the occurrence of
such events.
Baird’s ETF Focus List is designed to encompass
numerous asset classes and varied investment
objectives. Baird generally seeks to include ETPs,
primarily ETFs, with transparent, experienced
sponsors that have stable or growing assets under
management and have demonstrated consistent
strategy performance over time. Baird tends to
favor ETPs that have well-known, diversified
fees and tracking
lower
benchmark
errors, and higher trading liquidity relative to
other ETPs. Inclusion on or exclusion from the
Baird ETF Focus List is not meant to be a buy or
is a
sell recommendation. Rather, the List
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Investment Solutions Department
accuracy of the information contained in the
research and due diligence materials.
the
Programs.
Baird’s
Affiliated Private Equity Funds
Compliance,
Legal,
and
Baird’s
is
primarily responsible for selecting and evaluating
structured products made available to clients
Alternative
under
Investment Committee, which includes members
of Baird’s Investment Solutions, Asset Manager
Research,
Risk
Management Departments, ultimately determines
whether to make a structured product available to
Baird clients.
Available Hedge Funds
Financial
Industry
Activities
Relationships
In addition to Recommended Funds of Private
Equity Funds and Available Private Equity Funds,
Baird makes available to clients private equity
funds that are affiliated with Baird (“Affiliated
Private Equity Funds”). Baird does not subject
Affiliated Private Equity Funds to the criteria
imposed upon Recommended Funds of Private
Equity Funds or Available Private Equity Funds
described above when making them available to
clients, and Baird does not perform any
evaluation, monitoring or review of Affiliated
Private Equity Funds. This presents a potential
conflict of interest. See “Additional Information—
and
Other
Affiliations—Certain
and
Arrangements—Baird and Associated Parties”
below.
Other Funds
Baird makes hedge funds available to clients in
certain Programs sponsored by, affiliated with or
offered by Capital Integration Systems LLC or
CAIS Capital LLC (“CAIS”). An independent third-
party research firm provides research and due
diligence materials to Baird on the hedge funds
available on the CAIS platform (“Available Hedge
Funds”). Clients interested in an Available Hedge
Fund or invested in an Available Hedge Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely
relies upon the independent third-party research
firm to provide an independent analysis of each
Available Hedge Fund, Baird does not conduct its
own research or due diligence on any Available
Hedge Fund, and Baird does not verify the
accuracy of the information contained in the
research and due diligence materials.
Available Private Funds
In certain instances when PAM believes it to be
consistent with a client’s investment goals, PAM
may recommend to the client certain Funds that
are not on a Baird recommended or available
Fund list or offered through CAIS. Baird does not
provide any research or due diligence on such
Funds, but they are reviewed by PAM
in
accordance with its investment process described
below.
Baird Trust Strategies
Baird makes available to clients five (5) portfolio
strategies developed and maintained by Baird
Trust (“Baird Trust Strategies”) described below.
The Baird Trust Strategies invest in a mix of
equity securities and ETFs.
third-party
research
firm
(1)
The Baird Trust Large Cap Equity strategy
invests in a fairly concentrated portfolio of large
cap equity securities. This strategy is intended for
clients seeking investment in large cap companies
as one part of their overall asset allocation. This
strategy is generally not intended to be a
complete investment program.
In addition to Recommended Private Funds, Baird
makes available to clients in certain Programs
other private funds sponsored by, affiliated with,
or offered by CAIS (“Available Private Funds”),
including Available Private Equity Funds, Available
Private Debt Funds, Available Private REITs and
Available Private Infrastructure Funds. When
determining whether to make a fund an Available
Private Fund, Baird utilizes the services of an
independent
that
provides research and due diligence materials to
Baird on the private funds available on the CAIS
platform. Clients interested in an Available Private
Fund or invested in an Available Private Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely
relies upon the independent third-party research
firm to provide an independent analysis of each
Available Private Fund, Baird does not conduct its
own research or due diligence on any Available
Private Fund, and Baird does not verify the
(2)
The Baird Trust Core + Satellite 100
strategy is a diversified portfolio with a 100%
target equity allocation. The strategy uses the
Baird Trust Large Cap Equity strategy as the core
the portfolio while providing
allocation of
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investment
strategies,
such
exposure to satellite asset classes (such as mid
cap and small cap companies) through the use of
ETFs that principally invest in equity securities.
This model does not include fixed income.
certain
as
concentrated investment strategies and margin,
and certain types of investments, such as illiquid
securities. The exact composition of a client
portfolio will be constrained by the client’s legal
and tax considerations and greatly influenced by
the client’s liquidity needs and tolerance for
portfolio fluctuations.
The process by which PAM evaluates a client’s
investment needs and constructs and implements
a client portfolio are described below.
Phase 1: Evaluate
(3)
The Baird Trust Core + Satellite 70/30
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation of the portfolio
while providing exposure to satellite asset classes
(such as mid cap and small cap companies) and
fixed income securities through the use of ETFs
that principally invest in equity securities and
fixed income securities. This strategy has a target
allocation of 70% of its assets to equity securities
and 30% of its assets to fixed income securities.
the
fixed
The Baird Trust Core + Satellite 50/50
(4)
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation portion of the
portfolio while providing exposure to satellite
asset classes (such as mid cap and small cap
companies) and fixed income securities through
the use of ETFs that principally invest in equity
securities and
income securities. This
strategy has a target allocation of 50% of its
assets to equity securities and 50% of its assets
to fixed income securities.
(5)
The Baird Trust Equity Income strategy
primarily invests in dividend paying companies
that Baird Trust believes have the ability to
consistently grow their dividend at attractive rates
over the long‑term.
After gathering pertinent information regarding
the client, such as, tax considerations, liquidity
needs, and investment time horizon, PAM will
recommend a target allocation to one or more
asset classes described above. For some clients,
PAM will develop an Investment Policy Statement
through discussions with
client. The
Investment Policy Statement will set forth the
target asset allocation, set forth allowed and
disallowed assets, and provide a description of the
responsibilities of PAM, client’s other investment
managers, if any, and the client. The Investment
Policy Statement generally will be reviewed at
least annually, and PAM will recommend changes
if necessary to reflect any new circumstances
communicated to PAM by the client, such as a
change in a client’s liquidity needs or investment
time horizon. Generally, any changes will be
discussed with the client before implementation.
Phase 2: Strategy Design
More specific information about the particular
investment strategies and methods of analysis
that Baird uses in connection with each Program
is further described below.
The PAM Investment Process
to
foreign equity securities,
fixed
PAM will compile, with data supplied by the client,
a source of funds document (“Source of Funds”),
listing investment assets to be transferred to
Baird and other significant investment assets
which may not be managed by PAM but which
PAM will consider in constructing the overall
investment portfolio. PAM will review the Source
of Funds with the client to reach agreement on
the total assets available for investment and the
ownership or registration of the same.
inverse
PAM may
using
also
other
When providing advice to clients, PAM generally
recommends and provides
its clients a
diversified portfolio strategy incorporating U.S.
income
and
securities, Non-Traditional Assets, such as real
estate, commodities, currencies, and Alternative
Investment Products, which may include the use
of hedge funds, funds of hedge funds, private
equity funds, funds of private equity funds, REITs,
funds and structured
leveraged or
its
products.
base
recommendations
investment
strategies and investment products based upon a
client’s particular needs. PAM may recommend
Using the client’s target asset allocation, Source
of Funds and Investment Policy Statement, if any,
as guidelines, PAM will construct a recommended
target allocation for client’s portfolio to specific
investments
that will detail asset classes,
investment managers, investment vehicles (i.e.,
SMAs, mutual funds, ETFs, etc.) and target dollar
values for each. The recommended allocation may
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include a series of investment phases to reach the
long term target allocation depending on client
preference, current investments, and market
conditions.
fixed
“passive” or
• Rank and Sort Semifinalists. The investment
selection process has now produced a short list
of candidates; generally, between three and ten
for each asset class. For new or emerging
managers, PAM will typically conduct an onsite
due diligence visit to determine and analyze
more about team structure and strength,
infrastructure, and hold discussions around
philosophy and strategy. PAM then determines
the appropriate investment structure to access
the investment manager(s)—whether it be an
SMA, commingled
institutional class
fund,
mutual fund or ETF—with a view to try and
select the structure that is the most cost
effective for clients.
In constructing the portfolio, PAM considers
suitability of different asset classes (e.g., large
cap value domestic equity, mid cap value
domestic equity small cap value domestic equity,
international equity, fixed income, etc.), the
overall aggregate equity and
income
allocation for the entire portfolio, and use of
index-tracking
“active” and/or
investments. PAM may recommend
the
for
portfolio components from several different asset
classes and a mixture of active and passive
investments.
a
For each recommended asset class, PAM will also
recommend specific investment managers. The
managers may include SMAs, mutual funds, ETFs,
and other investment vehicles. For most asset
classes, PAM will typically recommend more than
one manager in order to further reduce risk from
significant underperformance by
single
manager.
• Finalist Selection. PAM will analyze security
overlap and correlation with other potential
investment managers when determining the
client’s final allocation. Final manager or fund
selection depends on the specific client needs,
which are defined through the investment policy
development and investment recommendation
stages. The managers or funds that are most
appropriate to meet the guidelines of the
client’s Investment Policy Statement, if any, are
then chosen.
The systematic process PAM uses for choosing
investment managers, commingled funds, mutual
funds and ETFs consists of the following steps:
and
economic
The recommended allocation will also include the
fee for each manager, if any, as well as the PAM
Advisory Fee. A weighted-average fee based on
the recommended allocation will also be provided,
but the actual fee paid by a client will vary
depending on
the dollar amounts actually
invested, changes in the value of investments
over time, and other factors.
Phase 3: Implement
• Quantitative Screening. On a quantitative basis,
takes a dynamic view of historical
PAM
time
statistics over various
performance
intervals
conditions. The
approach is two-pronged: (1) assess peer
universe comparisons; and (2) apply index-
based measures, both on an absolute and risk-
adjusted basis. The data is then analyzed using
a proprietary scoring model, which places
particular emphasis on consistent positive
relative performance over the long-term.
and
accounts,
professional
Once the recommended allocation is reviewed
with the client and a final allocation is approved
by the client, PAM will implement the agreed upon
plan. This usually includes setting up various
Baird accounts, transferring assets from outside
accounts to Baird, reconciling assets received
against client-provided information as to the
assets in the outside accounts, liquidation of some
assets, transfers of some assets to investment
managers, and purchase of mutual funds and
ETFs.
• Qualitative Screening. The candidate list is then
further reduced by reviewing broader issues
that help identify superior, stable organizations.
Some examples of the issues examined include:
size of assets under management, growth of
staff
assets
qualifications and turnover, a strong investment
buy and sell discipline, risk controls, and
business, regulatory and legal history.
In order to implement the overall client portfolio
strategy, PAM may utilize one or more of the
combination of different
Services and a
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investment vehicles, such as SMAs, mutual funds
and ETFs.
More specific information about the particular
investment strategies and methods of analysis
that PAM and Baird use in connection with each
Service is further described below.
international and global equity and fixed income
strategies; real estate strategies; commodities
strategies; currency strategies; and Alternative
Strategies. For additional information regarding
the characteristics of the mutual funds and ETPs
used in an ALIGN Portfolio, clients should contact
their PAM Consultant or review the applicable
prospectus.
Program Portfolio Strategies
Baird Advisory Choice Program
The PAM FOCUS Portfolios Program offers model
portfolios that have varying strategic investment
strategies. The PAM FOCUS Portfolios Program
generally accommodates both taxable and tax-
exempt accounts of clients with differing
investment objectives and risk tolerances.
Multiple funds may be used for a particular asset
class (referred to as a “sleeve”).
in
When recommending investment products to
clients under the Baird Advisory Choice Program,
PAM uses the investment process described in the
section “The PAM Investment Process” above.
PAM may also use the investment strategies
described in the section “Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment Strategies” above or the model
portfolios or recommended or eligible product lists
made available by Baird’s PWM Research Groups,
or they may use lists of investment products that
Baird has generally deemed to be “available” for
use
its advisory programs. For more
information about Baird model portfolios,
recommended lists and eligible product lists, see
“Methods of Analysis, Investment Strategies and
Risk of Loss—Methods of Analysis” above.
Generally, under normal market conditions, the
equity security allocation of each PAM FOCUS
Portfolio is designed to be global in nature and
attempts to be diversified across countries,
industry sectors and company capitalization sizes,
with an objective to participate in the total return
potential of the global stock markets. The fixed
income allocation is primarily domestic in nature,
but
is diversified across credit quality and
maturity.
PAM FOCUS Portfolios Program
The PAM FOCUS Portfolios are described below.
Each PAM FOCUS Portfolio provides for specific
levels of investment (or allocation) across the
following asset classes described under the
heading “Investment Strategies—Asset Allocation
Strategies” above.
above,
including
fixed
The amount allocated to each asset class and type
of investment varies by Portfolio. However, some
Portfolios may have little or no allocation to one
or more asset classes or types of investments
described above.
PAM FOCUS All Growth Portfolio. The PAM FOCUS
All Growth Portfolio seeks to provide aggressive
capital. Under normal market
growth of
conditions, this Portfolio generally invests nearly
all of its assets in mutual funds and ETFs that in
turn principally invest in equity securities. This
Portfolio may also invest in other asset classes
income
described
securities, Non-Traditional Assets, Alternative
Investment Products and cash. This Portfolio has
the same risk profile as an All Growth Portfolio
described below.
Each PAM FOCUS Portfolio uses mutual funds and
ETPs, primarily ETFs, in order to implement the
model asset allocation. Depending on the PAM
FOCUS Portfolio chosen, the PAM FOCUS Portfolio
may consist of mutual funds and ETFs that have
various investment objectives and strategies,
including but not limited to, the following: large
cap, mid cap and small cap strategies (which may
include value, growth or core strategies); short-
term, intermediate-term and long-term fixed
income strategies (which may include high yield
corporate bond strategies); balanced strategies;
PAM FOCUS Capital Growth Portfolio. The PAM
FOCUS Capital Growth Portfolio seeks to provide
growth of
capital. Under normal market
conditions, this Portfolio primarily invests its
assets in mutual funds and ETFs that in turn
principally invest in equity securities or fixed
income securities. This Portfolio normally will have
a significantly higher underlying asset allocation
to equity securities than fixed income securities.
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This Portfolio may also invest in other asset
classes described above, including Non-Traditional
Assets, Alternative Investment Products and cash.
This Portfolio has the same risk profile as a
Capital Growth Portfolio.
its
fixed
PAM FOCUS Income with Growth (Tax Exempt)
Portfolio. The PAM FOCUS Income with Growth
(Tax Exempt) Portfolio has the same objective,
underlying investments, target allocations and
risk profile as the PAM FOCUS Income with
Growth Portfolio described above, except that this
Portfolio primarily
income
invests
allocation in mutual funds and ETFs that in turn
principally invest in municipal securities.
that
its
fixed
PAM FOCUS Capital Growth (Tax Exempt)
Portfolio. The PAM FOCUS Capital Growth (Tax
Exempt) Portfolio has
the same objective,
underlying investments, target allocations and
risk profile as the PAM FOCUS Capital Growth
this
Portfolio described above, except
income
invests
Portfolio primarily
allocation in mutual funds and ETFs that in turn
principally invest in municipal securities.
The descriptions of the PAM FOCUS Portfolios are
current as of the date of this Brochure. However,
PAM and Baird may change the objective,
investments, target allocations or risk profile for
any Portfolio at any time. PAM and Baird may also
offer other model portfolios under the Program
from time to time.
An PAM FOCUS Portfolio is subject to the risks
associated with the Portfolio’s particular strategies
and investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
PAM FOCUS Growth with Income Portfolio. The
PAM FOCUS Growth with Income Portfolio seeks
to provide moderate growth of capital and some
current income. Under normal market conditions,
this Portfolio primarily invests its assets in mutual
funds and ETFs that in turn principally invest in
equity securities or fixed income securities. This
Portfolio may also invest in other asset classes
described above, including Non-Traditional Assets,
Alternative Investment Products and cash. This
Portfolio has the same risk profile as a Growth
with Income Portfolio.
The process PAM uses for selecting and removing
funds for the PAM FOCUS Portfolios Program is
similar to the process described under “PAM
Investment Management Service” above. The
PAM FOCUS Portfolios Program may include funds
included on Baird’s Recommended Mutual Fund
List and funds affiliated with Baird.
its
fixed
PAM FOCUS Growth with Income (Tax Exempt)
Portfolio. The PAM FOCUS Growth with Income
(Tax Exempt) Portfolio has the same objective,
underlying investments, target allocations and
risk profile as the PAM FOCUS Growth with
Income Portfolio described above, except that this
income
invests
Portfolio primarily
allocation in mutual funds and ETFs that in turn
principally invest in municipal securities.
The Portfolio asset allocations and the funds
included in the Program are evaluated on an
least quarterly.
ongoing basis, generally at
Portfolios may be modified or rebalanced and
funds may be removed or added as PAM or Baird
determines is appropriate.
PAM Investment Management Service
Under the PAM Investment Management Service,
PAM may use various investment strategies. A
client’s particular investment strategy is typically
determined by PAM in consultation with the client
using the investment process described in the
section “The PAM Investment Process” above.
PAM FOCUS Income with Growth Portfolio. The
PAM FOCUS Income with Growth Portfolio seeks
to provide high current income and some growth
of capital. Under normal market conditions, this
Portfolio primarily invests its assets in mutual
funds and ETFs that in turn principally invest in
fixed income securities or equity securities. This
Portfolio normally will have a higher underlying
asset allocation to fixed income securities than
equity securities. This Portfolio may also invest in
other asset classes described above, including
Non-Traditional Assets, Alternative Investment
Products and cash. This Portfolio has the same
risk profile as an Income with Growth Portfolio.
PAM Consultants, as a group, utilize a variety of
investment styles and strategies, including the
investment strategies described in the sections
“Methods of Analysis, Investment Strategies and
Risk of Loss—Investment Strategies” and “The
PAM Investment Process” above. They may also
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the associated
lists,
see
use the model portfolios or recommended or
eligible product lists made available by Baird’s
PWM Research Groups, or they may use lists of
investment products that Baird has generally
deemed to be “available” for use in its advisory
programs. For more information about Baird
model portfolios, recommended lists and eligible
product
“Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis” above.
the investments in the client’s Account, and each
risk may or may not apply to a client. Clients
should not pursue a strategy or invest in an
investment product unless they are prepared to
accept
risks. Clients are
encouraged to discuss with their PAM Consultant
the risks that apply to them. A client should also
review
the prospectus or other disclosure
document for any security or other investment
product in which the client invests, as it will
contain important information about the risks
associated with investing in such security or other
investment product.
Investment Risk Information
The investment risks of the Services generally
include the following:
investment
strategies,
such
Market Risks. A client’s Account may change in
value due to overall market fluctuations. General
economic conditions, political developments,
international events and other factors may cause
the overall market to decline, which in turn may
reduce the value of the client’s Account regardless
of the relative strength of the securities held in
the Account. Securities prices often vary for
reasons unrelated to matters directly affecting the
issuers of the securities.
PAM manages client assets using investment
strategies and investment products based upon a
client’s particular
investment objectives and
financial goals. PAM may use a wide variety of
investment products to implement the client’s
investment strategy, which
investments are
further described under “Services, Fees and
Compensation—Additional Service Information—
Permitted Investments” above. PAM may also use
certain
as
concentrated investment strategies and margin,
and certain types of investments, such as illiquid
securities and Complex Investment Products,
including REITs, private equity funds, funds of
private equity funds, leveraged or inverse funds
investment
and structured products. These
strategies and products involve special risks and
may not be appropriate for all clients. Please see
“Principal Risks” below for more information.
fluctuate
Principal Risks
client
accounts
about
Management and Securities Selection Risks.
in value
A client’s Account may
differently than, or in the opposite direction as,
the overall market or applicable benchmark
because of the selection of individual securities for
the Account. The judgments made by the persons
managing
the
attractiveness, value and potential appreciation of
particular securities may prove to be incorrect.
For example, while the stock markets may
experience increases in value, the client’s Account
may experience a decline in value due to the
underperformance of the stocks selected for
investment in the client’s Account.
conditions and other
Risk is inherent in any investment product and
PAM and Baird do not guarantee any level of
return on a client’s investments. There is no
assurance that a client’s investment objectives
will be achieved, and a client could lose all or a
portion of the amount invested. The management
of client accounts and recommendations made to
clients are based in part upon the use of forward-
looking projections, which in turn are based upon
certain assumptions about how markets will
perform in the future. There can be no guarantee
that markets will perform in the manner assumed
and the actual performance of markets and a
client’s Account could differ materially from those
assumptions. Also, a client’s Account value may
fluctuate, sometimes dramatically, depending
upon the nature of the client’s investments,
market
factors. By
participating in a Service, a client may be subject
to certain risks, including, but not limited to the
risks described below. The risks discussed below
vary by Service, investment style or strategy, and
Investment Objective and Asset Allocation
Risks. A client’s investment objective and asset
allocation strategies involve the risk that certain
asset classes selected for the client’s Account may
not perform as well as other asset classes during
varying periods. In addition, clients who pursue
more aggressive investment objectives and asset
allocation strategies, while hoping to achieve high
returns, may face greater risk of loss than clients
with more conservative objectives and strategies.
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the same issuer because common stockholders
generally have inferior rights to receive payments
from issuers in comparison with the rights of
preferred stockholders, bondholders and other
creditors.
In developing investment objectives and asset
allocation strategies, clients should carefully
consider their financial situation and needs,
investment goals, investment time horizon and
risk tolerance. A client should inform the client’s
PAM Consultant of these considerations so the
PAM Consultant can assist in determining the
client’s investment objectives and asset allocation
strategies.
Fixed Income Security Risks. Fixed income
securities are subject to certain risks, including
interest rate risk, credit risk and liquidity risk. In
addition, they are subject to maturity risk.
Generally, the longer a bond’s maturity, the
greater the interest rate risk and the higher its
yield. Conversely, the shorter a bond’s maturity,
the lower the interest rate risk and the lower its
yield. Non-rated, split-rated, below investment
grade, and asset-backed securities, including
mortgage-backed securities and CMOs, have
additional, special risks.
Conflicts of Interest Risks. Issuers, advisors or
other sponsors of investment products or their
affiliates may engage in business practices that
conflict with the interests of investors. Among
other things, these business practices can have a
negative impact on the market price of the
investment product. Clients are encouraged to
the prospectus or other disclosure
review
document for the investment product and also
discuss with their PAM Consultant the conflicts of
interest risks that may apply to them.
Stock Market Risks. Equity security prices vary
and may fall, thus reducing the value of a client’s
investments. Certain stocks selected for a client’s
Account may decline in value more than the
overall stock market.
Interest Rate Risk. The value of some
investment products, particularly fixed income
securities, is affected significantly by changes in
interest rates. Generally, when interest rates rise,
the product’s market value declines and when
interest rates decline, its market value rises. In
addition, a rise in interest rates may have a
negative impact on the issuer, which, in turn,
could have a negative impact on the market value
of the investment product.
Equity Securities Risks. Equity securities may
experience sudden, unpredictable drops in value
or long periods of decline in value. This may occur
because of factors that affect the securities
markets in general, such as adverse changes in
economic conditions, the general outlook for
corporate earnings, interest rates or investor
sentiment. Equity securities may also lose value
because of factors affecting an entire industry or
sector, such as increases in production costs, or
factors directly related to a specific company,
such as decisions made by its management.
Common Stock Risks. Common stocks are
susceptible to general stock market fluctuations
and to volatile increases and decreases in value
as market confidence in and perceptions of their
issuers change. These investor perceptions are
based on various and unpredictable
factors
including: expectations regarding government,
economic, monetary and fiscal policies; inflation
and
interest rates; economic expansion or
contraction; and global or regional political,
economic and banking crises. Holders of common
stocks are generally subject to greater risk than
holders of preferred stocks and debt obligations of
Credit Risk. The value of some investment
products, particularly fixed income securities, is
affected by changes in the product’s credit quality
rating or the issuer’s financial condition. If the
credit quality rating or the issuer’s financial
condition declines, so may the value of the
investment product. Issuers may experience
unanticipated financial problems and may be
unable to meet its payment obligations. Municipal
obligations in particular may be adversely affected
by political and economic conditions and
developments (for example, legislation reducing
state aid to local governments.) Bonds receiving
the lowest investment grade rating or a non-
investment grade rating may have speculative
characteristics and, compared to higher grade
debt obligations, may have a weakened capacity
to make principal and interest payments due to
changes in economic conditions or other adverse
circumstances. Ratings agencies such as Moody’s,
Fitch and S&P provide ratings on bonds based on
their analyses of information they deem relevant.
Ratings are essentially opinions or judgments of
the credit quality of an issuer and may prove to
be inaccurate. In addition, there may be a delay
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taxation, or diplomatic developments, which could
affect investment in those countries.
between events or circumstances adversely
affecting the ability of an issuer to pay interest
and/or repay principal and an agency’s decision to
downgrade a security.
Investments
less
liquid
market
depth,
larger companies. Therefore,
in
Emerging Markets Risks.
emerging markets can involve risks in addition to
and greater than those generally associated with
investing in more developed foreign markets. The
extent of economic development, political
stability,
infrastructure,
capitalization, and regulatory oversight can be
less than in more developed markets. Emerging
market economies can be subject to greater
regulatory, and political
social, economic,
uncertainties. All of these factors can make
emerging market securities more volatile and
potentially less liquid than securities issued in
more developed markets.
them more susceptible
Capitalization Size Risks. A client may be
invested in small and mid cap stocks, which are
than
often more volatile and
investments in larger companies. The frequency
and volume of trading in securities of such
companies may be substantially less than is
typical of
the
securities of such companies may be subject to
greater and more abrupt price fluctuations. In
addition, small- and mid-size companies may lack
the management experience, financial resources
and product diversification of larger companies,
to market
making
pressures and business failure.
foreign
the
that
could
compromise
technology
Such
incidents may
or
penalties,
reputational
investigate,
or
remediate
Foreign Issuer and Investment Risks.
issuers, ADRs, Global
Securities of
Depositary Receipts (“GDRs”) and European
Depositary Receipts (“EDRs”), and investments in
foreign markets generally, are subject to certain
inherent risks, such as political or economic
instability of the country of issue, the difficulty of
predicting international trade patterns and the
possibility of imposition of exchange controls.
Such securities may also be subject to greater
fluctuations in price than securities of domestic
corporations. Investors in foreign markets may
face delayed settlements, currency controls and
adverse economic developments as well as higher
overall transaction costs. In addition, fluctuations
in the U.S. dollar’s value versus other currencies
may enhance, erode, reverse gains or widen
losses from investments denominated in foreign
currencies. For instance, foreign governments
may limit or prevent investors from transferring
their capital out of a country. This may affect the
value of a client’s investment in the country that
adopts such currency controls. Exchange rate
fluctuations also may impair an issuer’s ability to
repay U.S. dollar denominated debt, thereby
increasing the credit risk of such debt. In
addition, there may be less publicly available
information about a foreign company than about a
domestic company. Foreign companies generally
are not subject to uniform accounting, auditing
and financial reporting standards comparable to
those applicable to domestic companies. With
respect to certain foreign countries, there is a
confiscatory
possibility of expropriation or
in
the
section
titled
Information Security, Cybersecurity and
Technology-Related Risks. As issuers and their
service providers increasingly rely on digital
Internet, cloud
technologies, such as
computing, and AI‑enabled systems, they face
heightened information security, cybersecurity,
including
and other technology‑related risks,
incidents
the
confidentiality, integrity, or availability of their
systems, data, or
infrastructure.
Technology-related incidents may result from
deliberate adversarial actions (such as cyber
attacks) or unintentional events (such as systems
or human error) and could have a materially
adverse impact on the issuer’s performance and
operations.
involve
unauthorized access, disclosure, use, corruption,
degradation, or destruction of systems or data
(such as
through hacking, malware, social
engineering or theft of digital devices); or the
disruption of systems access to authorized users
(such as through denial of service attacks). Such
events can impede critical functions, compromise
sensitive business and protected customer
information, and may result in financial losses,
business interruptions, impediments to the ability
to process transactions, breaches of applicable
privacy, data protection, or other laws, regulatory
fines
harm,
reimbursement or other remediation costs, and
increased compliance or operational expenses.
Substantial costs may be incurred to prevent,
detect,
future
technology related incidents. Issuers’ increasing
use of AI systems introduces additional risks
“Artificial
discussed
Intelligence Risks” below. Issuers may also rely
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their
own
information
related
incidents
use
protected
incidents,
on third party or cloud based platforms that
present
security,
cybersecurity, and other technology‑related risks.
Similar adverse consequences may arise from
technology
affecting
governmental authorities,
regulatory bodies,
financial market systems, exchanges, brokers-
dealers, banks, insurance companies, custodians,
or other market participants. Although issuers and
their service providers may adopt business
continuity plans, information security controls,
and risk management programs designed to
these
prevent or mitigate such
measures are subject to inherent limitations,
including the possibility that certain risks may not
be identified or fully addressed. As a result, client
Accounts and investments may be negatively
affected.
actions, or operational constraints. AI systems are
vulnerable to cyberattacks or other adversarial
actions that can impair system performance and
integrity and compromise sensitive business and
protected customer information. The impairment
of AI systems or the unauthorized disclosure of
sensitive business or protected information can
result in material disruption and damage to
significant
legal and
business operations,
regulatory
remediation
liabilities, substantial
expenses, and reputational harm. AI systems may
inadvertently
information,
potentially giving rise to intellectual property
infringement claims and substantial damages.
Public concerns regarding fairness, transparency,
and responsible use of AI may reduce demand for
an issuer’s products or services. Failure to use AI
responsibly may harm an issuer’s reputation and
competitive position.
Intelligence Risks.
increasingly use AI systems
issued by
in
fact
inaccurate,
regulatory
scrutiny,
Government Obligation Risks. Client assets
may be invested in securities issued, sponsored or
guaranteed by the U.S. Government, its agencies
and instrumentalities. However, no assurance can
be given that the U.S. Government will provide
financial support to U.S. Government-sponsored
agencies or instrumentalities where it is not
obligated to do so by law. For instance, securities
issued by the Government National Mortgage
Association (“Ginnie Mae”) are supported by the
faith and credit of the United States.
full
Securities
the Federal National
Mortgage Association (“Fannie Mae”) and the
Federal Home Loan Mortgage Corporation
(“Freddie Mac”) have historically been supported
only by the discretionary authority of the U.S.
Government. While the U.S. Government provides
financial support to various U.S. Government-
sponsored agencies and instrumentalities, such as
those listed above, no assurance can be given
that it will always do so.
rely
on
third-party
AI
falling. Since
interest
federal
taxation,
Issuers of
Artificial
investments
in
various aspects of their business operations,
creating competitive market pressures to increase
the development and use of AI systems. Failure to
effectively develop or use AI systems may place
an issuer at a competitive disadvantage. At the
same time, AI systems present significant risks
that could materially affect an issuer’s business
and financial performance. AI Tools rely on
complex models, large datasets, and evolving
algorithms. AI Tools are highly-useful but
complex and fallible systems that can exhibit bias,
hallucinations, deceptive behaviors and other
flaws due to the construction of their underlying
models and the composition of their training data,
which can result in outputs that seem plausible
but are
incomplete, or
misleading. The use of erroneous outputs can
undermine customer trust and expose issuers to
substantial
litigation,
remediation costs, and reputational harm. AI tools
require timely access to high‑quality, compliant
data, and any disruption in data availability can
impair or disable AI Tool functionality. Issuers
systems,
often
infrastructure, and data, which can create vendor
dependency, limit visibility into and validation of
AI model performance, and increase the risk of
disruption in data availability. The regulatory
environment for AI is rapidly evolving and may
involve inconsistent or conflicting requirements
across
jurisdictions. Compliance may require
significant investment, changes to AI systems, or
the discontinuation of certain AI‑enabled features.
Non‑compliance may lead to fines, enforcement
Municipal Securities Risks. Repayment of
municipal securities depends on the ability of the
issuer or project backing such securities to
generate taxes or revenues. Municipal securities
may also decrease in value during times when tax
rates are
income on
municipal securities is normally not subject to
regular
the
income
attractiveness of municipal securities in relation to
other investment alternatives is affected by
changes in federal income tax rates applicable to,
or the continuing federal tax-exempt status of,
such interest income. Any proposed or actual
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in such
for purchases or withdrawals.
redemptions
in
invested in the money market fund would not be
available
In
addition, retail and institutional money market
funds are required to impose redemption fees
(also known as liquidity fees) and suspend
redemptions (also known as redemption gates) in
certain
circumstances. Government money
market funds may also impose redemption fees
those same
and suspend
circumstances. More specific information about
how a money market fund calculates its NAV and
the circumstances under which it will impose a
redemption fee or suspend redemptions is set
forth in the prospectus for that money market
fund.
changes
rates or exempt status,
therefore, can significantly affect the liquidity,
marketability and supply and demand
for
municipal securities, which would in turn affect
Baird’s ability to acquire and dispose of municipal
securities at desirable yield and price levels.
Investment in tax-exempt debt obligations poses
additional risks. In many cases, the IRS has not
ruled on whether the interest received on a tax-
exempt obligation is tax-exempt, and accordingly,
purchases of these municipal securities are based
on the opinion of bond counsel to the issuers at
the time of issuance. Thus, there is a risk that
interest may be taxable on a municipal security
that is otherwise expected to produce tax-exempt
interest.
to
lower
securities,
and/or
to make a market
for
Illiquid Securities and Liquidity Risks.
Liquidity risk is the risk that certain investments
may be difficult or impossible to sell at the time
and price that a client would like to sell. Clients
may have
the price, sell other
investments or forego an investment opportunity,
any of which may have a negative effect on the
management or performance of client accounts.
The liquidity of a particular investment depends
on the strength of demand for the investment,
which is generally related to the willingness of
broker-dealers
the
investment as well as the interest of other
investors to buy the investment. During periods of
economic uncertainty, significant economic and
market downturns and periods in which financial
services firms are unable to commit capital to
make a market in, or otherwise buy, certain
investments, a client may experience challenges
in selling such investments at optimal prices. In
addition, recent regulatory changes applicable to
financial intermediaries that make markets in
debt securities have restricted or made it less
desirable for those financial intermediaries to hold
large inventories of debt securities. Because
market makers provide stability to a market
through their intermediary services, a reduction in
dealer inventories may lead to decreased liquidity
and increased volatility in the fixed income
markets. In the event the client directs Baird to
liquidate an illiquid investment, the client should
understand that Baird may have difficulty finding
a buyer in the market for such investment and
such investment may be held in the Account for a
period of time while Baird attempts to satisfy the
client’s liquidation request.
Money Market Fund Risks. A money market
fund is a type of mutual fund that generally
invests in short-term debt instruments. Many
investors use money market funds to store cash.
There are three primary types of money market
funds: (1) government money market funds
(funds that invest nearly all assets in cash,
government
repurchase
agreements collateralized by cash or government
securities); (2) retail money market funds (funds
that have policies and procedures reasonably
designed to limit beneficial ownership to natural
persons); and (3) institutional money market
funds (funds that permit beneficial ownership by
institutions and natural persons). The rules
governing money market funds vary based on the
type of money market fund. Government and
retail money market funds generally try to keep
their net asset value (NAV) at a stable $1.00 per
share using special pricing and valuation
conventions. Institutional money market funds
are required to calculate their NAV in a manner
such that the NAV will vary based upon the
market value of assets and liabilities of the fund
(also known as a “floating NAV”). An investment
in a money market fund is not insured or
guaranteed by the FDIC or any other government
agency. Although some money market funds seek
to preserve the value of an investment at $1.00
per share, there can be no assurance that will
occur, and it is possible to lose money should the
fund value per share fall. In some circumstances,
money market funds may be forced to cease
operations when the value of a fund drops. In
that event, the fund's holdings may be liquidated
and distributed to the fund's shareholders. This
liquidation process could take time to complete.
During that time, the amounts a client has
Concentration Risks. A client’s Account may
is
consist of a portfolio of securities that
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securities. Modest movements in interest rates
(both increases and decreases) may quickly and
significantly reduce the value of certain types of
these securities. Asset-backed securities are
subject to a number of other risks, including, but
not limited to, market and valuation risks,
liquidity risk, and prepayment risk.
Split-Rated,
and
concentrated in an issuer or group of issuers, an
industry or economic sector or group of related
industries or sectors, or concentrated in limited
asset classes. Client accounts with concentrated
positions are susceptible to greater volatility and
increased risk of loss than an Account that is
diversified across several issuers and industries or
sectors and asset classes. A client should not
engage in strategies using concentration unless
the client is prepared to experience significant
losses in the value of the client’s Account.
Non-Rated,
Below
Investment Grade Securities (High Yield or
“Junk” Bonds) Risks. Investing in securities or
other investment products that are not rated,
split-rated or are below investment grade (also
known as high yield or “junk” bonds) involve
significant, special risks. As a result, they may not
be suitable for some clients. The risks associated
with these investments include, but not limited to,
price volatility risk, credit risk, default risk, and
liquidity risk. Clients investing in securities or
other investment products that are not rated,
split-rated or are below investment grade should
have a high tolerance for risk, including the
willingness and ability to accept significant price
volatility, potential lack of liquidity and potential
loss of their investment.
including equity,
fixed
Frequent Trading and Portfolio Turnover
Risks. Some of the investment strategies offered
to clients in this Brochure may involve frequent or
active trading for client accounts, which could
result in high portfolio turnover. Strategies that
involve frequent or active trading increase the
management and securities selection
risks
because the persons managing the accounts are
making more trading decisions, which may prove
to be incorrect. A portfolio with a high turnover
rate will also incur more transaction costs than
one with a lower rate. Higher transaction costs
may negatively impact the return of the portfolio.
High portfolio turnover may also cause a client to
experience adverse tax consequences due to the
fact that the client may have increased instances
of realized gains and losses and such gains and
losses may commonly be characterized as short
term gains and losses under applicable tax law.
investment
style,
securities
selection
credit
capitalization
risk,
foreign
Mutual Fund Risks. Mutual funds can have
investment objectives and
many different
strategies,
income,
balanced, international, and global strategies, and
strategies that focus on a particular market
capitalization,
economic
industry or sector, or geographic region. Mutual
funds have risks, which may include market risk,
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
rate
risk,
risk,
issuer and
investment style
investment risk, and emerging market risk.
Certain mutual funds pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of mutual fund selected. Also, investment
return and principal value will fluctuate, and
shares, when redeemed, may be worth more or
less than their original cost.
Asset-Backed Securities Risks. Asset-backed
securities are securities secured or backed by
mortgage loans, student loans, automobile loans,
installment sale contracts, credit card receivables
or other assets and are issued by entities such as
commercial banks, trusts, financial companies,
finance subsidiaries of
industrial companies,
savings and loan associations, mortgage banks
and investment banks. These securities represent
interests in pools of assets in which periodic
payments of interest or principal on the securities
are made, thus, in effect passing through periodic
payments made by the individual borrowers on
the assets that underlie the securities, net of any
fees paid to the issuer or guarantor of the
securities. Asset-backed securities are issued in
multiple classes (or tranches) and their relative
payment rights may be structured in many ways.
Asset-backed securities may be subject to greater
risk of default during periods of economic
downturn than other instruments. Asset-backed
securities also can be more sensitive to interest
rate risk than other types of fixed income
Exchange Traded Fund Risks. An ETF is
different from a mutual fund in that an ETF does
not sell its shares directly to public investors and
does not redeem shares from public investors.
Rather, shares of an ETF are commonly purchased
or sold in the secondary market on a securities
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for purposes of making
equity,
securities
selection
credit
capitalization
risk,
foreign
closed-end
securities
include market
selection
credit
capitalization
risk,
foreign
public offering prices. Clients are therefore
cautioned about buying shares of a closed-end
fund in its initial public offering. Closed-end funds
often engage in leverage to raise additional
capital
investments
through borrowings and issuances of senior
securities (such as preferred stock). Such
leverage may present the opportunity to enhance
potential returns but also involve the risk of
exacerbating losses and depreciation in the value
of the underlying securities. Closed-end funds
have other risks, which may include market risk,
risk,
management and
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate
risk,
risk,
risk,
issuer and
investment style
investment risk, and emerging market risk.
Certain
funds pursue Complex
Strategies, which are subject to special risks.
Some closed-end funds are organized as interval
funds, which differ from traditional closed-end
funds in that their shares do not trade on the
secondary market, but instead their shares are
subject to repurchase offers from the fund.
Closed-end funds structured as an interval fund
will, therefore be relatively less liquid. Interval
funds also often impose a redemption fee when
shares are sold back to the fund. The degree of
these and other risks will vary depending on the
type of close-end fund selected.
exchange, like common stocks. An ETF maintains
a net asset value but, based on demand and
other factors, the market price of shares of an
ETF may vary from its net asset value. ETFs
invest in and hold securities and other assets,
such as stocks, bonds, commodities and
currencies, and have stated investment objectives
and principal strategies. ETFs can have many
different investment objectives and strategies,
including
income, balanced,
fixed
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. Many ETFs seek to track the
performance of an index or other underlying
benchmark. Passively managed ETFs will not be
able to replicate exactly the performance of the
indices the ETFs track because the total return
generated by the securities will be reduced by
management fees, transaction costs and other
expenses incurred by the ETF. ETFs have other
risk,
risks, which may
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
risk,
risk,
rate
investment style
issuer and
investment risk, and emerging market risk.
Certain ETFs pursue Complex Strategies, which
are subject to special risks. The degree of these
and other risks will vary depending on the type of
ETF selected.
is selected by
equity,
that
fund
that
Closed-End Fund Risks. Unlike mutual funds
which continuously offer and redeem their shares
on a daily basis at net asset value, closed-end
funds typically raise money by selling a fixed
number of shares of common stock in a single,
one-time offering, much the way a company
issues stock in an initial public offering. Closed-
end funds can have many different investment
objectives and strategies, including equity, fixed
international, and global
income, balanced,
focus on a
strategies, and strategies
particular market capitalization, investment style,
industry or sector, or geographic
economic
shares are not
region. Closed-end
redeemable, meaning
investors cannot
require closed-end funds to buy back their shares,
although closed-end fund shares are listed and
traded on an exchange. For many reasons,
closed-end fund shares often trade at a discount
to their net asset value and the market prices of
closed end fund shares often fall below their
Unit Investment Trust Risks. A UIT is a pooled
investment vehicle
in which a portfolio of
the sponsor and
securities
deposited into the trust for a specified period of
time. The portfolio of a UIT is designed to follow
an investment objective over a specified time
period, although there is no guarantee that the
objective will be met. UITs can have many
different investment objectives and strategies,
including
income, balanced,
fixed
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. UITs are passively managed
and follow a “buy and hold” strategy, meaning
that UITs buy a fixed portfolio of securities and
hold on to that portfolio until their termination
date at which time the portfolio is liquidated with
the net proceeds paid to investors. UITs, thus,
generally have a relatively higher risk of loss than
other funds in the event of adverse changes in
market or economic conditions. UITs have other
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and for extended periods. Growth stocks are often
characterized by high price-to-earnings ratios and
may be more volatile than stocks with lower
price-to-earnings ratios. Value stocks are subject
to the risk that the broader market may not agree
with the manager’s assessment of, or recognize,
the investments’ intrinsic value.
risks, which may
include management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, and emerging market
risk. Certain UITs pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of UIT selected. Also, investment return and
principal value will fluctuate, and units, if and
when redeemed, may be worth more or less than
their original cost.
ESG Considerations Risk. Consideration of ESG
factors in the investment process may cause an
advisor or manager to forgo opportunities to
recommend or invest in certain companies or to
gain exposure to certain industries or regions.
Therefore, there is a risk that, under certain
market conditions, an Account pursuing strategies
that consider ESG factors may underperform
accounts that do not consider such factors. There
are not universally accepted ESG factors and
advisors and managers typically consider them in
their discretion.
an
investment
negative
tax
consequences.
Risks Common to All Funds; Purchase and
Redemption Risks. Funds are generally subject
to the same risks as the securities or other assets
in which they invest. In addition, from time to
time Baird, a PAM Consultant, or an investment
manager may decide to add or remove a Fund to
or from an investment strategy or Service. In
addition, they may decide to increase or decrease
their clients’ account allocations to a Fund. In
general, they will place transactions for all
affected Accounts at one time, which may cause
the Fund to experience relatively large purchases
or
redemptions. Significant purchases and
redemptions may adversely affect the Fund in
question and consequently, a client’s investment.
A Fund receiving large purchase orders may have
difficulty investing the cash, which may have a
negative impact on the Fund’s performance. A
Fund experiencing large redemption orders may
have to sell portfolio securities, which may
negatively impact performance and which may
have
Large
redemptions could also reduce liquidity as the
Fund may suspend or delay redemptions. These
risks are more pronounced with respect to newer
Funds and those with smaller asset sizes.
by
the
Risks Associated with Certain Investment
Strategies
that were not predicted by
can be no assurance
that
Quantitative Strategy Risks. Some investment
managers may employ quantitative investment
methodologies or processes to make investment
decisions. The success of
the quantitative
investment methodologies and processes used by
investment managers depends on the analyses
and assessments that were used in developing
such methodologies and processes, as well as on
the accuracy and reliability of models and data
provided by third parties. Incorrect analyses and
assessments or inaccurate or incomplete models
and data would adversely affect performance.
Additionally,
manager’s
methodologies and processes are predictive in
nature, based on historical outcomes and trends.
Certain low-probability events or factors that are
assigned little weight may occur or prove to be
more likely or may have more relevance than
expected, for short or extended periods of time,
the portfolios
which may adversely affect
generated
investment manager’s
quantitative methodologies and processes. It is
also possible that prices of securities may move in
the
directions
investment manager’s quantitative methodologies
and processes or may fail to move as much as
predicted, for reasons that were not expected.
these
There
methodologies will enable a client to achieve the
client’s objective.
Growth and Value Investment Style Risks.
Investment styles or strategies that focus on
growth stocks may perform better or worse than
styles or strategies that focus on value stocks or
that are broader or more diversified. Similarly,
investment styles or strategies that focus on
value stocks may perform better or worse than
styles or strategies that focus on growth stocks or
that are broader or more diversified. A particular
style of investing may go out of favor at times
Technical Strategy Risks. Some investment
managers and PAM Consultants may employ
technical analysis or investment methodologies to
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or
consuming
commodities. Prices of commodities may also be
affected by factors such as drought, floods,
weather, livestock disease, embargoes, tariffs and
other regulatory developments. The prices of
commodities can also fluctuate widely due to
supply and demand disruptions
in major
producing
regions. Certain
commodities may be produced in a limited
number of countries and may be controlled by a
small number of producers or groups of
producers. As a result, political, economic and
supply related events in such countries could have
a disproportionate impact on the prices of such
commodities. No active trading market may exist
for certain commodities investments, which may
impair the value of the investments.
make investment decisions or recommendations.
The primary risk of using technical analysis is that
past price and volume patterns and trends in the
trading markets cannot predict future prices,
volume patterns or trends. There is no guarantee
that technical investment methods used are
designed properly, are updated with new data as
it becomes available, or can accurately predict
future market or investment performance. In
order for technical investment methods to work,
there must be sufficient data about the markets
available so that trends can be identified and
predictions can be made. A technical method may
fail to identify trends or be able to accurately
predict future prices if a market does not have
sufficient data or trends or if the market behaves
erratically.
and Risk
of
Other Strategy Risks. The risks associated with
other types of investment strategies are described
under the heading “Portfolio Manager Selection
and Evaluation—Methods of Analysis, Investment
Strategies
Loss—Investment
Strategies” above.
Non-Traditional Assets and Complex
Strategies Risks
such as
commodities,
in
that
Currency Risks. Investments in currencies, and
investments in securities or other instruments
denominated in or indexed or linked to currencies,
are subject to certain risks. Those investments
are subject to all of the risks associated with
foreign investing generally. In addition, currency
markets generally are not as regulated as
securities markets. Also, changes in currency
exchange rates could adversely
impact the
investment. Devaluation of a currency by a
country will also have a significant negative
impact on
investment
the value of any
denominated
currency. Currency
investments may also be positively or negatively
affected by a country’s strategies intended to
make its currency stronger or weaker relative to
other currencies.
the
traditional
Non-Traditional Assets Risks. Non-Traditional
Assets,
currencies,
securities indices, interest rates, credit spreads,
private companies, and Digital Assets, are subject
to risks that are different from, and in some
instances, greater than, other assets like stocks
and bonds. Some Non-Traditional Assets are less
transparent and more sensitive to domestic and
foreign political and economic conditions than
more
investments. Non-Traditional
Assets are also generally more difficult to value,
less liquid, and subject to greater volatility
compared to stocks and bonds.
Risks.
Investments
investments
Leverage and Margin Risks. Leveraging
strategies may amplify
impact of any
decrease in the value of underlying securities in
the client’s Account, thereby increasing a client’s
risk of loss. The use of leverage may also increase
an Account’s volatility. Strategies
involving
margin can cause a client to lose more money
than deposited in the client’s margin account. A
client should not engage in strategies involving
leverage or margin unless the client is prepared
to experience significant losses in the value of the
client’s Account.
in
securities.
Commodities
in
commodities markets or a particular sector of the
in
commodities markets, and
securities or other instruments denominated in or
indexed or linked to commodities, are subject to
certain risks. Those investments generally will
subject a client Account to greater volatility than
The
traditional
investments
commodities markets are impacted by a variety of
factors, including changes in overall market
movements, domestic and foreign political and
economic conditions, interest rates, inflation rates
in
and
investment and
trading activities
Short Sales Risks. Short selling runs the risk of
loss if the price of the securities sold short does
not decline below the price at which they were
originally sold. This risk of loss is theoretically
unlimited, as there is no cap on the amount that
the price of a security may appreciate. In
lender may request, or market
addition, a
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with another. As a result, there is no assurance
that hedging transactions will be effective.
conditions may dictate, that securities sold short
be returned to the lender on short notice, which
may result having to buy the securities sold short
at an unfavorable price. A client should not
engage in short sales unless the client is prepared
to experience significant losses in the client’s
Account.
in
the marketplace and
contracts
other
Assets
involve
technological
trading,
settlement,
and
validators, miners,
or
instruments
limited number of
Derivative Instrument Risks. The values of
options, convertible securities, futures, swaps,
forward
derivative
and
instruments is derived from an underlying asset,
such as a security, commodity, currency, or
index. Derivative instruments often have risks
similar to the underlying asset, however, in
certain cases, those risks are greater than the
risks presented by
the underlying asset.
Derivative instruments may experience dramatic
price changes and imperfect correlations between
the price of the derivative and the underlying
asset, which may increase volatility. Derivatives
generally create leverage, and as a result, a small
movement in the underlying asset's value can
result in large change in the value of the
derivative instrument. Derivatives are also subject
to liquidity risk, interest rate risk, market risk,
credit risk, management risk and counterparty
risk. The use of these
is not
appropriate for some clients because they involve
special risks. A client should not invest in these
instruments unless the client is prepared to
experience volatility and significant losses in the
client’s Account.
Digital Assets Risks. Digital Assets are not
appropriate for some clients because they involve
substantial risk of loss including special risks not
present in traditional financial markets. Digital
Assets derive value primarily from the demand for
such assets
their
association with decentralized networks and other
technology. Digital Assets may lack an intrinsic
value and markets
for Digital Assets are
to extreme and sudden price
susceptible
movements and fragmented liquidity. Markets for
Digital Assets continue to evolve, but
lack
certainty regarding the status of regulation and
investor protections. The use and custody of
and
Digital
cybersecurity risks, including the potential for
system outages, protocol
flaws, operational
disruptions, hacking incidents, or failures of
third-party platforms and service providers that
support
storage
infrastructure. Many Digital Assets depend on
external
protocol
developers whose actions or inaction can impact
network stability or asset functionality and affect
value. Market structure risks—such as reliance on
a
trading venues or
counterparties—may impair the ability to transact
or liquidate positions during periods of market
stress. A client should not invest in these
instruments unless the client is prepared to
experience extreme volatility and significant
losses in the client’s Account.
Complex Investment Product Risks
funds have unique
the underlying security or
Options Risks. In purchasing a put or call
option, the purchaser faces the risk of loss of the
premium paid for the option if the market price
moves in a direction opposite to what the
purchaser had expected. In selling or writing an
option, the seller faces significantly more risk. A
seller of a call option faces the risk of significant
loss
if the prevailing market price of the
underlying security or index increases above the
strike price, and a seller of a put option faces the
risk of significant loss if the prevailing market
price of
index
decreased below the strike price.
Hedge Funds and Funds of Hedge Fund
Risks. Hedge funds typically engage in one or
more Complex Strategies, including the use of
Non-Traditional Assets, short sales, leverage and
other derivative instruments. Funds of hedge
funds typically invest substantially all of their
assets in other hedge funds. Hedge funds and
tax
funds of hedge
characteristics. A client should consult with a tax
advisor before investing in those funds. Some
hedge funds and funds of hedge funds are subject
to limited regulation and offer limited disclosure
and transparency. Also, the costs of hedge funds
and funds of hedge funds are typically higher than
other types of funds. Investment advisers or
funds often receive a
managers
or
management
for those
fee
plus
an
incentive
Hedging Risks. When a derivative instrument is
used as a hedge against an opposite position, any
loss on the derivative instrument should be
substantially offset by gains on the hedged
investment, and vice versa. Although hedging can
be an effective way to reduce the investment risk,
it may not always perfectly offset one position
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funds are subject to
to administrative service
limited
compared
short
sales,
other
expect
risks may
securities
include: market
selection
credit
capitalization
risk,
foreign
performance-based fee. Because of the existence
of a performance-based fee, fund managers may
be motivated to make riskier investments that
have the potential for significant growth in value.
Hedge funds and funds of hedge funds are also
subject to a higher risk of incorrect valuations.
Many hedge funds hold investments for which
market quotations are not readily available, which
necessitates the use of “fair value” pricing. Fair
value pricing is an inherently subjective process
and may not accurately reflect the prices that can
actually be obtained upon sale of the assets for
which fair values are used. Investments in hedge
funds and funds of hedge funds also have reduced
liquidity compared to other investments and are
generally subject to a higher risk of volatility.
Investing in hedge funds and funds of hedge
funds involves other special risks, including, but
to, risks associated with Non-
not
Traditional Assets,
leverage,
derivative instruments, and Complex Strategies.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
risk,
risk,
rate
investment style
issuer and
investment risk, and emerging market risk. Hedge
funds and funds of hedge funds are complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in hedge funds or funds
of hedge funds should have a high tolerance for
risk, including the willingness and ability to accept
lack of
significant price volatility, potential
liquidity and potential loss of their investment.
risk,
foreign
investments
consult with a tax advisor before investing in
those funds. Private equity funds and funds of
private equity
limited
limited disclosure and
regulation and offer
transparency. Also, the costs of private equity
funds and funds of private equity funds are
typically higher than other types of
funds.
Investment advisers or managers for those funds
often receive a management fee plus an incentive
fee or carried interest. Private equity funds and
funds of private equity fund are also generally
subject
fees and
portfolio company transaction fees. Because of
the existence of a carried interest, fund managers
may be motivated to make riskier investments
that have the potential for significant growth in
value. Investments in private equity funds and
funds of private equity funds also have reduced
investments.
liquidity
to
Investors
receive
to
should not
distributions from a fund for a number of years.
Private equity investing is very risky. Many
investments made in portfolio companies are not
profitable. In addition, investments made by
private equity funds and funds of private equity
funds may be concentrated in one or more
industries or sectors, geographic
economic
regions, stages of development or operation, or
sizes of companies. Investing in private equity
funds and funds of private equity funds involves
other special risks, including, but not limited to,
dependence upon key personnel and conflicts of
interest risks. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, and emerging market risk.
Private equity funds and funds of private equity
that have
funds are complex
significant, special risks. As a result, they may not
be suitable for some clients. Clients investing in
private equity funds and funds of private equity
funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
in
certain
that may
sectors,
is
inversely correlated
to
Private Equity Funds and Funds of Private
Equity Funds Risks. Private equity funds are
pools of actively managed capital that invest
primarily in private companies with the intent of
creating value in the companies in which they
invest by improving operations, reducing costs,
selling non-core assets and maximizing cash flow.
Private equity funds usually have an investment
focus on
objective or strategy
companies
industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes of investments. Funds of private equity
funds typically invest substantially all of their
assets in other private equity funds. Private
equity funds and funds of private equity funds
have unique tax characteristics. A client should
Reinsurance Fund Risks. Reinsurance funds
invest primarily in insurance-linked securities or
other instruments. A fund’s return on those
investments
the
occurrence of applicable catastrophic or other
events, such as hurricanes, tornados, floods,
earthquakes or other natural disasters, or fires,
explosions, aviation or marine accidents or other
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Rev. 03/27/2026
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
those
events are
in certain sectors,
evaluated
risks
during
risk
as
debt
funds
have
unique
securities
selection
receive a management
transaction
investments
should not
expect
to
non-natural disasters. The occurrence and
severity of
inherently
unpredictable. A fund could lose all or a significant
portion of its investment upon the occurrence of
an applicable event and the occurrence of multiple
events could cause the fund to sustain substantial
losses. In addition, certain investments may
expose a fund to liability in excess of amounts
received in connection with the investment. The
performance of certain insurance-linked securities
is dependent upon underwriting decisions made
by insurance companies associated with those
securities. Thus, the fund is subject to the risk
that those insurance companies may not have
adequately
the
underwriting process. Reinsurance funds may also
be subject to concentration risk as the market for
certain insurance-linked securities is small and
competition to buy insurance-linked securities has
increased in recent years. Due to the nature of a
reinsurance fund’s underlying investments, an
investment in a reinsurance fund is subject to
valuation
fund’s underlying
the
investments may be difficult to accurately and
timely value. Investing in reinsurance funds
involves other special risks, including, but not
limited to, dependence upon key personnel, Non-
Traditional Assets risks, currency risks, leverage
risks, derivative instrument risks and hedging
risks. Other risks may include: market risk,
risk,
management and
investment objective and asset allocation risk,
equity securities risks, fixed income securities
risks, interest rate risk, credit risk, foreign issuer
and investment risks, emerging market risks,
illiquid securities risks, quantitative strategy risks,
and high yield or “junk” bond risks. Reinsurance
funds are complex
that have
significant, special risks. As a result, they may not
be suitable for some clients. Clients investing in
reinsurance funds should have a high tolerance
for risk, including the willingness and ability to
accept significant price volatility, potential lack of
liquidity and potential loss of their investment.
funds
involves special
debt funds generally are subject the same risks as
below investment grade or “junk” bonds. Trading
markets for the investments held by those funds
are also limited and their investments may be
illiquid. Oftentimes, the interest rate paid by the
companies is determined by a reference interest
rate, such as the federal funds rate, which is
periodically reset. These types of investments are
sometimes referred to as floating rate corporate
debt, floating rate loans or floating rate bank
loans. Private debt
funds usually have an
investment objective or strategy that may focus
industries,
on companies
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes, including focusing investments on
smaller capitalization, distressed or bankrupt
companies. Private debt funds commonly use
borrowings or leverage to make investments.
Funds of private debt funds typically invest
substantially all of their assets in other private
debt funds. Private debt funds and funds of
private
tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
debt funds and funds of private debt funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private debt funds and funds of private debt funds
are typically higher than other types of funds.
Investment advisers or managers for those funds
often
fee plus a
performance fee. Private debt funds and funds of
private debt fund are also generally subject to
operational expenses and
fees.
Because of the existence of a performance fee,
fund managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Investments in private debt
funds and funds of private debt funds also have
reduced liquidity compared to other investments.
Investors
receive
distributions from a fund for a number of years.
Private debt investing is very risky. Investments
made by private debt funds and funds of private
debt funds may be concentrated in one or more
economic
industries or sectors, geographic
regions, stages of development or operation, or
sizes. Investing in private debt funds and funds of
risks,
private debt
including, but not limited to, dependence upon
key personnel, conflicts of interest risks, market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
Private Debt Funds (or Private Credit Funds)
and Funds of Private Debt Funds Risks.
Private debt funds (also known as private credit
funds) are pools of actively managed capital that
invest primarily in loans or debt instruments
issued by companies in private transactions.
Sometimes, repayment of the loan is secured by
assets of the companies obtaining the loans.
However, the companies often have low or no
credit ratings. Thus, investments held by private
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Rev. 03/27/2026
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
risk,
foreign
fund
risks, currency
risk, growth
investment style
issuer and
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
risks and
investment
leveraging risks. Private debt funds and funds of
private debt funds are complex investments that
have significant, special risks. As a result, they
may not be suitable for some clients. Clients
investing in private debt funds and funds of
private debt funds should have a high tolerance
for risk, including the willingness and ability to
accept lack of liquidity and potential loss of their
investment.
risk, credit
risk,
foreign
or regions, which subject them to the risk of
deteriorating economic conditions in those areas.
Investing in REITs involves other special risks,
including, but not limited to, real estate portfolio
risk
(including development, environmental,
competition, occupancy and maintenance risk),
liquidity risk, leverage risk, distribution risk,
risk,
capital markets access
interest risk,
counterparty risk, conflicts of
dependence upon key personnel
risk, and
regulatory risk. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, interest
rate
issuer and
investment risk, and emerging market risk. REITs
involve significant, special risks and may not be
suitable for some clients. Clients investing in
REITs should have a high tolerance for risk,
including the willingness and ability to accept
significant price volatility and volatility of regular
distribution amounts, potential lack of liquidity
and potential loss of their investment.
warehouses,
investments. Some may
in properties
industries,
involved
located
improved management
real estate
funds
typically
in which
they are
Real Estate Investment Trusts (“REITs”) and
Private REIT Risks. A REIT is a corporation,
trust or association that owns and typically
operates income-producing real estate or real
estate-related assets. The income-producing real
estate assets owned by a REIT may include office
buildings, shopping malls, multi-family housing,
student housing, hotels, resorts, hospitals and
health care facilities, self-storage facilities, data
centers,
telecommunications
facilities, and mortgages or loans. Many REITs are
registered with the SEC and their common stock
and preferred stock are publicly traded on a stock
exchange. These are known as publicly-traded
REITs. Others may be registered with the SEC but
are not publicly traded. These are known as
private REITs (also known as non-traded or non-
exchange traded REITs). There is no public
trading market for private REITs and the sole
method for disposing of the shares may be limited
to a periodic offer to redeem the shares by the
issuer, if the issuer offers a redemption program.
Private REITs are generally subject to limited
regulation and offer
limited disclosure and
transparency. The shareholders of a REIT are
responsible for paying taxes on the dividends that
they receive and on any capital gains associated
with their investment in the REIT. Dividends paid
by REITs generally are treated as ordinary income
and are not entitled to the reduced tax rates on
other types of corporate dividends. Prices of REIT
securities and trading volumes may be more
volatile that other investments. Many REITs focus
on a particular sector of the real estate market,
such as apartments, student housing, hotels and
hospitality, health care, office buildings, shopping
malls, warehouses, self-storage facilities and the
like. Those REITs are subject to risks associated
with sectors
focused.
Additionally, many REITs may own properties that
are concentrated in a particular geographic region
Private Real Estate Funds and Private Real
Estate Fund of Funds. Private real estate funds
are pools of actively managed capital that directly
invest primarily in investments in real estate and
real estate-related
investments. Private real
estate funds may invest in any number of types of
real estate, such as office, apartment, retail,
lodging, industrial and other real estate and real
focus
estate-related
in certain
investment
sectors or
certain
in
geographic regions or that have certain sizes of
operations or investment requirements. Some
may focus investment on properties the manager
or
sponsor believes are undervalued or
undercapitalized or that require repositioning,
redevelopment,
or
additional capital to reach their full value. Private
real estate funds commonly use borrowings or
leverage to make investments. Trading markets
for investments held by those funds are limited
and their investments may be illiquid. Funds of
private
invest
substantially all of their assets in other private
real estate funds. Private real estate funds and
funds of private real estate funds have unique tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
real estate funds and funds of private real estate
funds are subject to limited regulation and offer
limited disclosure and transparency. Also, the
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Baird PAM Wrap Brochure
Rev. 03/27/2026
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
for those
for those
fees and
should not
expect
to
investing
for
significant growth
reduced
liquidity compared
investments made
by
industries or
risks may
fund
risks, currency
securities
include: market
selection
risk,
foreign
infrastructure
funds
are
costs of private real estate funds and funds of
private real estate funds are typically higher than
other types of funds. Investment advisers or
funds often receive a
managers
management fee plus a performance fee. Private
real estate funds and funds of private real estate
fund are also generally subject to operational
expenses and transaction fees. Because of the
existence of a performance fee, fund managers
may be motivated to make riskier investments
that have the potential for significant growth in
value. Investments in private real estate funds
and funds of private real estate funds also have
reduced liquidity compared to other investments.
Investors
receive
distributions from a fund for a number of years.
Private real estate
is very risky.
Investments made by private real estate funds
and funds of private real estate funds may be
concentrated in properties involved in one or
more economic industries or sectors, geographic
regions, stages of development or operation, or
sizes. Investing in private real estate funds and
funds of private real estate funds involves special
risks, including, but not limited to, dependence
upon key personnel, conflicts of interest risks,
market risk, management and securities selection
risk, investment objective and asset allocation
risk, interest rate risk, credit risk, capitalization
risk, investment style risk, foreign issuer and
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
investment
risks and
leveraging risks. Private real estate funds and
funds of private real estate funds are complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in private real estate
funds and funds of private real estate funds
should have a high tolerance for risk, including
the willingness and ability to accept lack of
liquidity and potential loss of their investment.
development or operations, or on certain types
and sizes of investments. Private infrastructure
funds have unique tax characteristics. A client
should consult with a tax advisor before investing
in those funds. Private infrastructure funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private infrastructure funds are typically higher
than other types of funds. Investment advisers or
managers
funds often receive a
management fee plus an incentive fee. Private
infrastructure funds are also generally subject to
investment
administrative service
transaction fees. Because of the existence of
incentive fees, fund managers may be motivated
investments that have the
to make riskier
potential
in value.
Investments in private infrastructure funds also
have
to other
investments. Investors should not expect to
receive distributions from a fund for a number of
years. Private infrastructure investing is very
risky. Many investments are not profitable. In
addition,
private
infrastructure funds may be concentrated in one
or more economic
sectors,
geographic regions, stages of development or
operation, or sizes of companies. Investing in
private infrastructure funds involves other special
risks, including, but not limited to, dependence
upon key personnel and conflicts of interest risks.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
issuer and
investment style
investment risk, and emerging market risk.
Private
complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in private infrastructure
funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
telecommunication,
Private
utilities,
infrastructure
Private Infrastructure Funds Risks. Private
infrastructure funds are pools of actively managed
capital that invest primarily in infrastructure
projects and assets and may involve exposure to
a
range of economic or market sectors,
geographic locations and asset types. Examples of
infrastructure investments may include, among
and
others,
transportation.
funds
usually have an investment objective or strategy
that may focus on certain sectors, industries,
geographic regions, size ranges or stages of
Exchange Traded Notes Risks. An ETN is a
type of debt security that trades on an exchange
and provides a return linked to the performance
of an underlying benchmark. The underlying
benchmark can be a particular security, bond,
commodity, currency, or other Non-Traditional
Asset type, a group or basket of companies,
securities, commodities, currencies, derivative
instruments, Non-Traditional Asset investments or
other assets, or an index or other benchmark
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
throughout
in managed
currencies,
Assets,
leverage,
securities, fixed income securities, commodities
(such as metals, agricultural products, and energy
products), currencies, interest rates, and indices.
Managed futures often obtain this exposure
through derivative instruments, which may be
traded on U.S. or foreign exchanges or markets.
Managed futures often employ computerized,
systematic and often proprietary trading models
futures
and systems. Investing
involves special risks, including, but not limited
to, liquidity risks and risks associated with
and other Non-
commodities,
derivative
Traditional
instruments and Complex Strategies. Other risks
may include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
foreign issuer and investment risk, and emerging
market risk. Managed futures can be speculative
investments because of the types of investments
they make and they involve significant, special
risks. As a result, they may not be suitable for
some clients. Clients investing in these funds
should have a high tolerance for risk, including
the willingness and ability to accept significant
price volatility, potential lack of liquidity and
potential loss of their investment.
credit
capitalization
risk,
foreign
linked to stocks, market volatility, bonds, interest
rates, Treasury yields, yield curves and spreads,
derivative instruments, strategies, commodities,
currencies or other assets. ETNs trade on
exchanges
the day at prices
determined by the market. Unlike ETFs, issuers of
ETNs do not buy or hold assets to replicate or
approximate the performance of the underlying
benchmark. Also in contrast to ETFs, ETNs also do
not calculate their net asset value, are generally
not redeemable on a daily basis, and are not
registered under the Investment Company Act of
1940. Issuers may also have the right and option
to redeem ETNs. Redemptions are made at the
ETN’s “indicative value” or “closing indicative
value”. An ETN's closing indicative value is
computed by the issuer and is distinct from an
ETN's market price, which is the price at which an
ETN trades in the secondary market. Issuers of
ETNs may also issue and redeem notes as a
means to keep the ETN’s market price in line with
its indicative value, which have caused significant
fluctuations in ETN prices. Investing in ETNs
involves special risks, including, but not limited
to, risks associated with Non-Traditional Assets
and derivative instruments and the risk that the
actual market price for an ETN may vary
significantly from the indicative value computed
by the issuer. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate
risk,
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk. ETNs
are complex investments and involve significant,
special risks. As a result, ETNs may not be
suitable for some clients.
inverse
pools
(typically
structured
Managed Futures Risks. Managed futures are
commodity
as
investment partnerships) managed by a futures
trading adviser that trade speculatively in various
derivative instruments and other investments.
There are significantly higher fees and expenses
associated with investments in managed futures
than other types of funds. Sponsors or managers
for these pools often receive a management fee
plus incentive or performance-based fee. Because
of the existence of a performance-based fee,
managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Managed futures may seek
exposure to different asset classes, such as equity
Leveraged Fund and Inverse Fund Risks.
Leveraged funds and inverse funds may be
structured as ETNs, ETFs or open-end mutual
funds. Leveraged funds seek to deliver multiples
of the performance of the index or benchmark
they track. Inverse funds seek to deliver the
opposite of the performance of the index or
benchmark they track. Leveraged inverse funds
seek to achieve a return that is a multiple of the
inverse performance of the underlying index. Most
leveraged and
funds “reset” daily,
meaning that they are designed to achieve their
stated objectives on a daily basis. Because of the
effects of compounding, volatility and the fund
expenses, the returns of a leveraged or inverse
fund over longer periods of time can differ
significantly from the performance (or inverse of
the performance) of their underlying index or
benchmark during the same period of time. To
achieve their objectives, leveraged and inverse
funds typically employ aggressive investment
techniques, such as the use of leverage, short
sales, swap contracts, futures, options and other
derivative instruments. Investing in leveraged
funds and inverse funds involves special risks,
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
those
funds and they
including, but not limited to, risks associated with
Non-Traditional Assets, short sales, leverage, and
derivative instruments. Other risks may include:
market risk, management and securities selection
risk, investment objective and asset allocation
risk, stock market risk, equity securities risk,
common stock risk, fixed income securities risk,
interest rate risk, credit risk, foreign issuer and
investment risk, and emerging market risk.
Leveraged funds and inverse funds are complex
investments that have an increased risk of loss
compared to other
involve
significant, special risks. As a result, they may not
be suitable for some clients. A client should not
invest in these securities unless the client is
prepared to experience significant losses in the
value of the client’s Account.
risk, capital markets access
Investing
risks may
securities
include: market
selection
growth in value. BDCs commonly use borrowings
or leverage to make investments in portfolio
companies. Adverse interest rate movements can
impact a BDC’s ability to make
negatively
investments. Investments made by BDCs are
typically illiquid, and valuing such investments is
challenging. It is possible that valuations on
investments used are materially different from the
values that BDCs will ultimately receive upon
disposition of
investments. Changing
market and economic conditions affecting a BDC’s
investments may cause significant volatility in the
BDC’s net asset value and stock price. Due to the
nature of BDCs’ investments, securities issued by
BDCs are subject to greater liquidity risk than
other investments. A debt security or preferred
stock issued by a BDC, in many cases, is non-
rated or is rated below investment grade, which
can carry its own risks. Investing in BDCs involves
other special risks, including, but not limited to,
portfolio company credit and investment risk,
risk,
leverage
dependence upon key personnel
risk, and
regulatory risk. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, and
interest rate risk. BDCs can be speculative
investments because of the types of investments
they make and involve significant, special risks.
As a result, BDC investments may not be suitable
for some clients. Clients investing in BDCs should
have a high tolerance for risk, including the
willingness and ability to accept significant price
volatility, potential lack of liquidity and potential
loss of their investment.
risk, credit
risk,
foreign
risk,
emerging market
Structured Products Risks. Structured products
are a hybrid between two asset classes (typically
issued in the form of a CD or note) but instead of
having a pre-determined rate of interest, the
return is linked to the performance of an
underlying asset class, such as single security or
basket or index of securities; a commodity or
basket or index of commodities, including futures;
and a foreign currency or basket of foreign
currencies.
in structured products
involves special risks, including, but not limited
to, risks associated with derivative instruments.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
issuer and
rate
investment
risk,
commodities risk and currency risk. Structured
products are complex investments and involve
special risks. As a result, they may not be suitable
for some clients.
is
Master Limited Partnership Risks. An MLP is a
form of publicly-traded partnership that is taxed
as a partnership. MLPs have unique
tax
characteristics. A client should consult with a tax
advisor before investing in MLPs. An MLP must
generally earn at least 90% of its income from
certain qualifying sources, which includes income
and gains from certain activities involving natural
resources such as oil, natural gas, natural gas
liquids, refined petroleum products, coal, carbon
dioxide and biofuels. An MLP
is generally
structured as a limited partnership or limited
liability company and managed and operated by a
general partner or manager. Owners of an MLP
are called “limited partners” or “unit holders”.
Unit holders own interests or units in the MLP
(“units”) that are traded on a stock exchange.
Business Development Company Risks. A
BDC
closed-end
typically a domestic,
investment company that is operated for the
purpose of making equity and debt investments in
small and developing businesses, as well as
financially troubled businesses. As a result,
investments made by BDCs tend to be risky and
speculative. Investment advisers or managers for
BDCs often receive a management fee plus
incentive or performance-based fee. Because of
the existence of a performance-based
fee,
managers may be motivated to make riskier
investments that have the potential for significant
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risk,
common
stock
to other primary
risks,
risks,
foreign
including, but not
generally include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
risk, and
securities
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, emerging market risks, fixed
income security risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
MLPs make distributions to unit holders of their
available cash flows. Many MLPs focus on a
particular sector or industry. Those MLPs are
subject to risks associated with sectors or
industries in which they are focused. The value of
an investment in an MLP and the amount of
distributions it makes may depend on the prices
of the underlying commodity, such as oil or
natural gas. Many MLPs are sensitive to changes
in the prevailing level of commodity prices. MLPs
have also shown sensitivity to interest rate
movements. Investing in MLPs involves other
limited to,
special risks,
macroeconomic risk, interest rate risk, liquidity
risk, operating risk, capital markets access risk,
growth risk, distribution risk, conflicts of interest
risk, and regulatory risk. MLPs are complex
investments that have significant, special risks. As
a result, MLPs may not be suitable for some
clients. Clients investing in MLPs should have a
high tolerance for risk, including the willingness
and ability to accept potential lack of liquidity and
potential loss of their investment.
information
about
upon
Portfolio’s
Additional
certain
Complex Investment Products and other
investments pursuing Complex Strategies,
including the risks associated with those
investments, is available on Baird’s website
at bairdwealth.com/retailinvestor and on
at www.finra.org/
FINRA’s website
Investors. A client is encouraged to read the
disclosure documents
included on those
websites carefully before investing.
foreign
issuer and
investment
Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies
the headings
Capital Growth Portfolio. A Capital Growth
Portfolio will generally be invested in a manner
that seeks to provide growth of capital. Capital
Growth Portfolios have historically experienced
moderately high fluctuations in annual returns
and overall market value, typically as a result of
changes to market and economic conditions. The
Portfolio’s investments are subject to a risk of
price declines, especially during periods when
stock markets in general are declining. A Capital
Growth Portfolio’s primary risks generally include:
market risk, management and securities selection
risk, investment objective and asset allocation
risk, stock market risk, equity securities risk,
common stock risk, and capitalization risks.
specific
the
Depending
investments, the Portfolio may also be subject to
other primary risks, including investment style
risks,
risks,
emerging market risks, fixed income securities
risk, interest rate risk, credit risk, asset-backed
securities risks, below investment grade (high
yield or “junk” bonds) securities risks, and the
risks described under
“Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
Each Account is subject to the risks associated
with the investments in the Account. Generally,
an Account will be subject to the risks associated
with the portfolio listed below that corresponds to
the investment objective of the Account or the
asset allocation strategy pursued by the Account.
All Growth Portfolio. An All Growth Portfolio will
generally be invested in a manner that seeks to
provide growth of capital. All Growth Portfolios
have historically experienced high fluctuations in
annual returns and overall market value, typically
as a result of changes to market and economic
conditions. The Portfolio’s investments are subject
to a high risk of price declines, especially during
periods when stock markets in general are
declining. An All Growth Portfolio’s primary risks
Growth with Income Portfolio. A Growth with
Income Portfolio will generally be invested in a
manner that seeks to provide moderate growth of
capital and some current income. Growth with
Income Portfolios have historically experienced
moderate fluctuations in annual returns and
overall market value, typically as a result of
changes to market and economic conditions and
interest rates. The Portfolio’s investments are
subject to a risk of price declines, especially
during periods when stock markets in general are
declining or when interest rates are rising. A
Growth with Income Portfolio’s primary risks
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
to other primary
risks,
risks,
foreign
to other primary
risks,
risks,
foreign
generally include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
subject
including
issuer and
investment style
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
investments are subject to risk of price declines,
especially during periods when interest rates are
rising. A Conservative Income Portfolio’s primary
risks generally include: market risk, management
and securities selection risk, investment objective
and asset allocation risk, fixed income securities
risk, interest rate risk, credit risk, money market
fund risk, equity securities risk, and common
stock risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
income. Relative
to
interest
rates are
fixed
risks,
foreign
Capital Preservation Portfolio. A Capital
Preservation Portfolio will generally be invested in
a manner that seeks to preserve capital while
generating current
the
portfolios described above, Capital Preservation
Portfolios have historically experienced smaller
fluctuations in annual returns and overall market
value as a result of changes in stock market
conditions, but have experienced fluctuations in
relation to changes in interest rates and economic
conditions. The Portfolio’s investments are subject
to risk of price declines, especially during periods
when
rising. A Capital
Preservation Portfolio’s primary risks generally
include: market risk, management and securities
selection risk, investment objective and asset
allocation risk,
income securities risk,
interest rate risk, credit risk, and money market
fund risk. Depending upon the Portfolio’s specific
investments, the Portfolio may also be subject to
other primary risks, including foreign issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
Income with Growth Portfolio. An Income with
Growth Portfolio will generally be invested in a
manner that seeks to provide current income and
some growth of capital. Income with Growth
Portfolios have historically experienced moderate
fluctuations in annual returns and overall market
value, typically as a result of changes to interest
rates and market and economic conditions. The
Portfolio’s investments are subject to a risk of
price declines, especially during periods when
interest rates are rising or when stock markets in
general are declining. An Income with Growth
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
fixed income securities risk, interest rate risk,
credit risk, money market fund risk, stock market
risk, equity securities risk, common stock risk,
and capitalization risks. Depending upon the
Portfolio’s specific investments, the Portfolio may
also be subject to other primary risks, including
investment style
issuer and
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
to
to
perception
take advantage of
of market
Conservative Income Portfolio. A Conservative
Income Portfolio will generally be invested in a
manner that seeks to provide current income.
the portfolios described above,
Relative
Conservative Income Portfolios have historically
experienced smaller fluctuations in annual returns
and overall market value as a result of changes in
stock market conditions, but have experienced
fluctuations in relation to changes in interest rates
Portfolio’s
conditions.
and
economic
The
Opportunistic Portfolio. An Opportunistic
Portfolio will generally be invested in a manner
that seeks to provide long term growth through
capital appreciation and/or income by utilizing an
active management style that shifts the amount
of investment made in different asset classes and
market sectors
the
pricing
manager’s
anomalies, those market or industry sectors
deemed favorable for investment by the manager,
the current interest rate environment and/or
other macro-economic trends identified by the
manager to achieve growth while accounting for a
client’s specific short, intermediate and long term
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the
Portfolios
have
that Baird
establishes
for
the
investments made,
less
if an Available
Product
experiences
organizational,
is a higher risk
that
fixed
income
security
Product
that
experiences
investment and/or cash flow needs. Depending
investment strategy used, some
upon
Opportunistic
historically
experienced high fluctuations in annual returns
and overall market value, typically as a result of
changes to market and economic conditions.
Depending upon the investment strategy used
and
the Portfolio’s
investments may be subject to a high risk of price
declines, especially during periods when stock
markets in general are declining. An Opportunistic
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, and capitalization risks. Depending
upon the Portfolio’s specific investments, the
Portfolio may also be subject to other primary
risks, including investment style risks, foreign
issuer and investment risks, emerging market
risks,
risks, below
investment grade (high yield or “junk” bonds)
securities risks, and the risks described under the
headings “Non-Traditional Assets and Complex
Strategies Risks” and “Complex
Investment
Product Risks” above.
the
list of
Investment Products are investment products that
generally do not meet the qualifications and
standards
its
recommended product lists. As a result, there is a
higher likelihood that some Available Investment
Products will have poor performance and will
significantly underperform compared
to an
applicable benchmark
index or peer group.
Available Investment Products are also subject to
significantly
review by Baird
rigorous
compared to recommended investment products.
Thus,
Investment Product
experiences significant performance problems or
if the manager or sponsor of an Available
significant
Investment
management,
operational,
compliance, legal, regulatory or other problems,
the Available
there
Investment Product will be made available (and
will continue to be made available) to clients by
Baird. An investment by a client in an Available
the
Investment
occurrence of any such event could negatively
impact the client’s Account. Available Investment
Products should only be used by a client if the
client wishes to take more responsibility for
monitoring and managing the assets in the
client’s Account,
recommended
products does not contain an investment product
that meets the client’s particular needs, and the
client understands the risks of doing so.
Recent Events
priorities,
changes
in
Global
financial markets have continued to
experience periods of elevated volatility, driven by
a combination of economic, political, and broader
macroeconomic developments. Conditions across
major economies have been influenced by shifting
policy
geopolitical
relationships, and evolving investor expectations.
Additional Considerations. A client should note
that an Account pursuing a particular investment
objective or asset allocation strategy will from
time to time be subject to actual risks that are
higher or lower than, or different from, the risks
described above under certain circumstances. See
“Investment Strategies—Important Information
about Implementation of Investment Objectives
and Investment Strategies” above for more
information. In addition to the specific risks
described above, a client’s Account may be
subject to additional risks, depending upon the
particular investments in the client’s Account. A
client should discuss the risks of particular
investments with the client’s PAM Consultant. A
client should also note that there is no guarantee
as to how an Account will perform in the future. It
is possible that an Account could experience more
dramatic return or market value fluctuations than
occurred in the past.
Available Investment Product Risks
The use of Available Investment Products,
including SMA Strategies made available under
the BSN and DC Programs, are subject to
additional risks compared to the use of Baird
investment products. Available
recommended
Within the United States, the current U.S.
administration has demonstrated
intent on
implementing policy changes through executive
orders and legislation, contributing to a less
certain policy environment. Potential adjustments
to federal programs, regulatory initiatives, and
legislative priorities create additional factors for
markets to assess, which may cause meaningful
inflation reduction
market uncertainty. While
remains a central
for policymakers,
focus
achieving the U.S. Federal Reserve Board’s long
term inflation target of 2% continues to prove
challenging. Although annual price increases have
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
upon the client’s request, provide advice on proxy
voting or what other action the client could take.
Separately Managed Accounts
generally moderated, the price of many goods
and services remains elevated compared to levels
from a few years ago. Leadership changes at the
Federal Reserve and political divisions and discord
add further uncertainty to the economic outlook.
Internationally, geopolitical risks have increased
as the U.S. and Israel are engaged in a military
conflict with Iran. The conflict has disrupted
global trade and caused an increase in the price
of oil. The continuation or escalation of military
strikes could lead to a lengthy period of military
conflict, and Iran’s military attacks and other
hostile actions against other countries present a
risk of widening the conflict. In addition, the war
between Ukraine and Russia is now passing its
fourth anniversary, instability in parts of the
Middle East persist, and relations between the
U.S. and other countries are strained.
instances. For
Under the PAM Recommended Managers Service,
Baird SMA Network Program and Dual Contract
Program, a client may retain the right to vote
proxies with respect to the securities held in the
client’s Account, or, in most instances, the client
may delegate such right to the investment
manager selected to manage the client’s Account
(which may include Baird, the Overlay Manager or
an Implementation Manager). A client may select
either option by making the appropriate election
in the client’s advisory agreement (and in the
case of a dual contract arrangement under the
Dual Contract Program, by providing proper
instructions to the manager directly). Some
managers do not offer proxy voting services in
connection with certain strategies, such as option
strategies. Clients pursuing those strategies will
automatically retain the right to vote proxies in
those
information about a
manager’s voting policies and procedures, clients
should review the manager’s Form ADV Part 2A
Brochure.
Discretionary Services
Rapid advancements in artificial intelligence (AI)
and automation are increasingly influencing global
economic trends, corporate decision making, and
financial market dynamics. Expanding investment
in these technologies is contributing to shifts in
how industries operate, compete, and allocate
resources. The fast pace of technological change,
potential disruptions to existing business models,
and evolving regulatory responses
introduce
additional uncertainty and may contribute to
market volatility.
Under the PAM FOCUS Portfolios Program and the
PAM Investment Management Service, a client
may retain the right to vote proxies with respect
to the securities held in the client’s Account, or a
client may delegate such right to Baird.
Taken together, these developments may have a
significant negative impact upon global economic
conditions and contribute to a heightened risk
environment. As a result, fluctuations in asset
prices may increase, and such volatility could
adversely affect the value of a client’s Account .
If a client retains proxy voting authority, Baird will
forward proxy materials that Baird actually
receives to the client. The client will then be
solely responsible for analyzing the materials and
casting the vote.
Voting Client Securities
Baird Advisory Choice Program and Other
Non-Discretionary Accounts
If a client delegates voting authority to Baird,
Baird will vote proxies solicited by, or with respect
to, securities held in the client’s Account for the
exclusive benefit of the client and in accordance
with policies and procedures adopted by Baird.
Under the Baird Advisory Choice Program and
with respect to any other Accounts over which the
client retains discretionary investment authority,
a client retains the right to vote proxies with
respect to the securities held in such Accounts.
Accordingly, the client is responsible for voting
proxies and otherwise addressing all matters
submitted for consideration by security holders,
and PAM and Baird are under no obligation to
take any action or render any advice regarding
such matters. The client’s PAM Consultant may,
Baird has adopted written policies and procedures
that are reasonably designed to ensure that it
votes client securities in the best interests of
clients. Those procedures address material
conflicts of interest that may arise between
Baird’s interests and those of its clients. Although
a description of Baird’s proxy voting policies and
procedures is provided below, Baird will furnish a
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
copy of its proxy voting policies and procedures to
clients upon their request. Additionally, clients
may obtain information on how Baird actually
voted proxies with respect to the securities held in
their accounts by contacting their PAM Consultant
or by calling (414) 765-3500.
voting policies) up until a certain time prior to the
applicable meeting (the “voting cut-off time”).
Baird’s proxy voting policies are designed to
address situations when additional information
becomes available after the votes are pre-
populated in the system and before the voting
cut-off time. However, there is no guarantee that
all information that could affect Baird’s proxy
voting decision will be received or considered by
Baird prior to a vote being cast.
interests. Baird utilizes
governance
services,
(or
voting
recommendations.
interests of
The proxy voting policies and procedures also
address instances in which Baird’s interests may
appear to conflict with client interests, such as
when Baird or an affiliate of Baird is managing or
administering
to manage or
seeking
administer) a corporate retirement, pension or
employee benefit plan or providing (or seeking to
provide) advisory or other services to a company
whose management is soliciting proxies. In such
instances, there may be a concern that Baird
would be inclined to vote in favor of management
because of Baird’s relationship or pursuit of a
relationship with the company. In situations
where there is a potential conflict of interest,
Baird’s
Proxy Voting Sub-Committee will
determine the nature and materiality of the
conflict. If the conflict is determined to not be
material, the Sub-Committee will vote the proxy
in a manner the Sub-Committee believes is in the
the client and without
best
consideration of any benefit to Baird or its
affiliates. If the potential conflict is determined to
be material, Baird’s Proxy Voting Sub-Committee
will take one of the following steps to address the
potential conflict: (1) cast the vote in accordance
with the recommendations of ISS or other
independent third party; (2) refer the proxy to
the client or to a fiduciary of the client for voting
purposes; (3) suggest that the client engage
another party to determine how the proxy should
be voted; (4) if the matter is not addressed by
ISS, vote in accordance with management’s
recommendation; or (5) abstain from voting.
In situations in which a client has delegated to
Baird voting authority with respect to securities in
the client’s Account, Baird will vote proxies in a
manner that Baird believes is consistent with the
client’s best
an
independent provider of proxy voting and
corporate
currently
Institutional Shareholder Services (“ISS”), to
analyze proxy materials and votes and make
independent
ISS
provides proxy voting guidelines regarding its
position on various matters presented by
companies to their shareholders for consideration.
Baird will typically vote shares in accordance with
the recommendations made by ISS. However,
ISS’s guidelines are not exhaustive, do not
address all potential voting issues, and do not
necessarily correspond with the opinions of PAM
Consultants. In the event the client’s PAM
Consultant believes the ISS recommendation is
not in the best interest of the client, the PAM
Consultant will bring the issue to Baird’s Proxy
Voting Sub-Committee through a proxy challenge
then be
process. The Sub-Committee will
responsible for determining how the vote will be
cast. The decision made by the Proxy Voting Sub-
Committee on the proxy challenge applies to all
advisory accounts managed by
the PAM
Consultant (or team of PAM Consultants), unless
the client has directed Baird to utilize specific
voting guidelines (e.g., Taft-Hartley guidelines).
For those matters for which the independent
proxy voting service does not provide a specific
voting recommendation, each PAM Consultant will
cast the vote in a manner he or she believes is in
the best interest of clients. The votes cast for a
client’s Account may differ from those votes cast
for other Baird clients based on differing views of
PAM Consultants and other Baird portfolio
managers.
Baird uses ISS’s electronic vote management
system to cast votes on behalf of clients. In
connection with Baird’s use of that system, ISS
pre-populates how client votes should be cast
based upon ISS’s voting recommendations. The
system allows Baird to change the pre-populated
vote (to the extent permitted by Baird’s proxy
While Baird uses its best efforts to vote proxies,
there are instances when voting is not practical or
is not, in Baird’s or PAM Consultants’ view, in the
best interest of clients. For example, casting a
vote on a foreign security may involve additional
costs or may prevent, for a period of time, sales
of shares that have been voted. Also, when a
client has entered into a securities lending
program, Baird generally will not seek to recall
the securities on loan for the purpose of voting
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the securities; however, Baird reserves the right
to recall the shares on loan on a best efforts basis
if the client’s PAM Consultant becomes aware of a
proxy proposal where the proxy vote is materially
important to the client’s Account.
or advise clients on other corporate actions, like
tender offers, that are not solicited by a proxy
statement. At a client’s request, Baird will forward
information that Baird actually receives to the
client.
In addition to the services described above, Baird
has engaged ISS for vote execution and record-
keeping services.
Other Proxy Voting Information
client establishes
such managers.
includes
risk
the client’s
tolerance and
Clients wishing to direct particular votes once
they have granted Baird discretionary voting
authority may do so by contacting their PAM
Consultant. However, if Baird has been granted
discretionary voting authority, neither PAM nor
Baird will provide a client with notice that Baird
has received a proxy solicitation, nor will they
consult with the client before casting a vote,
unless the client otherwise directs them to do so.
Client Information Provided to
Portfolio Managers
Under the PAM Recommended Managers Service,
PAM and Baird provide certain information about
the client to the investment managers managing
the client’s Account (which may include the
Overlay Manager or an Implementation Manager)
the advisory
when
the
Such
relationship with
investment
information
lot
tax
objectives and
information for the applicable Account assets.
Under the PAM Recommended Managers Service,
PAM and Baird also provide to the investment
manager a client’s age, investment timeframe,
and liquidity requirements.
Except to the extent a client has delegated proxy
voting authority to Baird, PAM and Baird have no
authority, direct or implicit, and accept no
responsibility for taking any action or rendering
any advice with respect to the voting of proxies
related to securities held in a client’s Accounts.
Unless specifically requested to do so by a client,
PAM and Baird do not generally provide such
information about the client on an ongoing basis
to the investment manager managing the client’s
Account.
Providing Baird Voting Instructions
Baird also generally provides the following to the
client’s manager unless otherwise instructed by a
client: trade confirmations, account statements,
and access to client’s Account on Baird’s system.
their
accounts.
Client Contact with Portfolio Managers
PAM and Baird do not place any restrictions upon
clients who wish to contact or consult with Other
Managers managing
PAM
encourages clients to discuss their accounts with
their PAM Consultant.
As mentioned above, Baird may be the holder of
record for certain securities in a client’s Account.
If the client retains voting authority over such
securities (or delegates such authority to party
other than Baird), and a proxy is solicited with
respect to any such securities, the client (or other
authorized party) will need to provide voting
instructions to Baird. To the extent the client (or
other authorized party) does not provide timely
voting instructions, Baird will vote such securities
to the extent permitted by law and in compliance
with the rules of the New York Stock Exchange
and the SEC relating to such matters.
Legal Proceedings and Corporate Actions
Generally, none of PAM, Baird or any Other
Manager responsible for managing all or a portion
of the assets in a client’s Account will render
advice or take action on a client’s behalf with
respect to securities that are or were held in the
client’s Account, or the issuers thereof, which go
into default or become the subject of legal
proceedings, such as class action claims, defaults
or bankruptcies. Also, they may or may not vote
Additional Information
Disciplinary Information
In April 2016, Baird, without admitting or denying
the findings, consented to the sanctions and
findings of the Financial Industry Regulatory
Authority, Inc. (“FINRA”) that it violated NASD
Conduct Rule 3010, FINRA Rule 3110, and FINRA
Rule 2010, by failing to establish and maintain a
supervisory system and procedures reasonably
designed to ensure that customers who purchased
mutual fund shares received the benefit of
applicable sales charge waivers. In May 2015,
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its
Baird began a review to determine whether Baird
had provided available sales charge waivers to
eligible customers. Based on this review, in May
2015, Baird self-reported to FINRA that various
eligible customers had not received available
sales charge waivers. Baird was found to have
retirement plan and
disadvantaged certain
charitable organization customers
that were
eligible to purchase Class A shares in certain
mutual funds without a front-end sales charge.
The findings also stated that these customers
were instead sold Class A shares with a front-end
sales charge or Class B or C shares with higher
ongoing fees and the potential application of a
contingent deferred sales charge. Baird was
censured and required to pay restitution to
affected customers estimated to be approximately
$2.1 million including interest.
to adopt or
to
designed
provide
to Baird’s clients and
supervisor within
through
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
implement policies and
failed
specific
procedures
information
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. Baird also was ordered to cease
and desist committing or causing any violations
and any future violations of Section 206(4) of the
Advisers Act and Rule 206(4)-7 thereunder and
pay a civil money penalty in the amount of
$250,000.
Initiative.” Under
taken against
the
In July 2016, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that the firm and a
its Private Wealth
firm
Management business did not
reasonably
supervise a former Financial Advisor who misused
a customer’s funds. The findings stated that the
supervisor did not reasonably follow-up on red
flags associated with a trade correction request
submitted by the Financial Advisor that should
have alerted him to the Financial Advisor's misuse
of a customer’s funds. The supervisor also did not
follow certain of Baird’s written supervisory
procedures (“WSPs”) relating to trade corrections.
After the supervisor realized that the Financial
Advisor misused the customer’s funds, Baird
reimbursed the customer for the loss. The
findings also included that Baird 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.
Baird was censured and fined $200,000. The
disciplinary action
firm
supervisor did not relate to PAM or its business
operations.
firms bought
certain of
the
In March 2019, Baird, without admitting or
denying the findings, consented to an order of the
SEC, which found that it violated Sections 206(2)
and 207 of
for making
the Advisers Act
inadequate disclosures to advisory clients about
mutual fund share classes. The order was part of
a voluntary self-reporting program initiated by the
SEC called the “Share Class Selection Disclosure
(or SCSD)
the program,
firms were offered the
investment advisory
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 settlement terms imposed by the
including returning money to affected
SEC,
investment advisory clients. The central issue
identified by the SEC was that, in many cases,
investment advisory
for or
recommended to their investment advisory 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
advisory clients, and the investment advisory
firms did not adequately disclose their receipt of
In September 2016, the SEC announced that
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
subadvisors
practices by
participating in Baird’s wrap fee programs offered
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
fees and/or
the conflict of
$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.
its
12b-1
interest
associated with those 12b-1 paying share classes.
Baird and many other firms self-reported under
into substantially
the program and entered
identical orders. By self-reporting and consenting
to the order, Baird agreed to a censure and to
cease and desist from committing or causing any
violations and future violations of Sections 206(2)
and 207 of the Advisers Act. Baird also agreed to
establish a distribution fund and to deposit into
that fund the improperly disclosed 12b-1 fees
received by Baird plus prejudgment interest,
which will be paid to affected advisory clients.
More information about the order is contained in
Baird’s Form ADV, which is available on the SEC’s
Investment Advisory Public Disclosure website at
https://www.adviserinfo.sec.gov/IAPD/Default.as
px or in the SEC’s press release about the SCSD
Initiative at https://www.sec.gov/news/press-
release/2019-28.
other
reports about an
reports was engaged
to disclose
In June 2019, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that between late
April 2013 and early July 2013 it published
research
issuer without
disclosing that the research analyst who authored
the
in employment
discussions with the issuer that constituted an
actual, material conflict of interest and that the
research analyst’s
the
failure
employment discussions with the issuer in the
research reports made those reports misleading.
Baird was censured and fined $150,000.
the
brokerage
customers
an
it charged
communications. As part of
supervisory
system
training,
In September 2023, Baird entered into an Offer of
Settlement with the SEC, 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
business-related
associates’
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
text and
properly retaining business-related
instant messages
off-channel
and
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.
While Baird had policies and procedures in place
prohibiting such off-channel communications, it
was discovered that certain Baird supervisors
off-channel using non-Baird
communicated
approved methods on their personal devices
about Baird’s broker-dealer and
investment
adviser businesses, and
findings were
reported to the SEC. Baird took steps prior to and
after the SEC’s review, including implementing a
new communication tool designed
for Baird
associates’ personal devices, conducting training,
and periodically requiring requisite associates to
provide an attestation relating to their business-
related
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,
surveillance program,
technology solutions and similar matters related
to off-channel communications.
In August 2022, Baird, without admitting or
denying the findings, consented to the entry of
findings of FINRA, which found that it charged
certain
unfair
its published
commission when
minimum commission amount of $100 on 7,277
retail equity trades and failed to establish and
maintain a
reasonably
designed to prevent charging a customer a
commission that is unreasonable or unfair in
violation of FINRA Rules 3110, 2121, and 2010.
Baird also consented to a censure, a fine in the
amount of $150,000, and the payment of
restitution of $266,481 plus interest. The findings
related to FINRA’s routine examination of Baird in
2020. During that examination, Baird modified its
minimum commission schedule and supervisory
procedures. Baird also took steps to make
payments to the affected customers, which on
average amounted to $36.62 per trade and
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timing
of
state
investment
Financial
Advisors
located
to Baird and PAM Consultants to use, select or
recommend the investment products and services
of Baird and Associated Parties over those of
unassociated parties and those that pay the
greatest level of compensation. Baird addresses
this potential conflict through disclosure in this
Brochure. Further, when acting as fiduciaries,
Baird and PAM Consultants are required to select
or recommend investment products only when
they determine it to be in the client’s best interest
to do so.
In March 2026, Baird entered into an Offer of
Settlement with the Massachusetts Securities
Division to settle a regulatory matter relating to
adviser
the
representative registration approvals for two of
Baird’s
in
Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals
provided investment advisory services before
their Massachusetts registrations were completed
as a form was missing from their application
materials. 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.
Baird Asset Management
Baird’s Asset Management business, Baird
Advisors, Baird Equity Asset Management, and
Chautauqua Capital Management (“CCM”), part of
Baird Equity Asset Management,
provide
investment management services to institutional
clients and Funds. PAM Consultants may refer
clients to Baird Asset Management.
Additional information about Baird’s disciplinary
history is available on the SEC’s website at
www.adviserinfo.sec.gov.
Baird Funds
Other Financial Industry Activities and
Affiliations
Baird’s Broker-Dealer Activities
including
Baird is the investment adviser and principal
underwriter for Baird Funds, Inc. (the “Baird
Funds”). Baird Advisors provides
investment
management, administrative, and other services
to certain Baird Funds investing primarily in fixed
income securities (the “Baird Bond Funds”). Baird
Equity Asset Management and CCM provide
investment management and other services to
certain Baird Funds investing primarily in equity
securities (the “Baird Equity Funds”), and
Greenhouse Funds LLLP, a party related to Baird,
is the investment subadvisor to one of those
Funds, the Baird Equity Opportunity Fund. PAM
Consultants may refer clients to the Baird Funds.
Baird Trust
Baird PWM offers brokerage accounts and related
services to its clients. Baird is also engaged in a
broad range of broker-dealer activities through
other business units,
its Global
Income Capital
Investment Banking, Fixed
Markets (including Baird Public Finance) and
Institutional Equities and Research Departments.
Certain PAM and Baird associates and certain
management persons of Baird are registered, or
have an application pending to register, as
registered representatives and associated persons
of Baird to the extent necessary or appropriate to
perform their job responsibilities.
Certain Relationships and Arrangements
Baird and Associated Parties
including
engaging
Trust
for
for eligible
the
those
amount
the
Baird is affiliated, and may be deemed to be
under common control, with Baird Trust, a
Kentucky-chartered trust company, because both
entities are indirectly wholly owned by BFG. Baird
and PAM Consultants receive compensation from
Baird Trust for referring clients and providing
ongoing relationship management services to
clients
trust
Baird
administration services as described under the
heading “Services, Fees and Compensation—
Additional Service Information—Trust Services
Arrangements” above.
Baird Capital
Baird PWM has relationships or arrangements with
other Baird businesses units and the Associated
Parties described below,
referral
programs that pay special compensation to PAM
referrals. Additional
Consultants
referral programs,
information about
including
referral
of
compensation, is disclosed on Baird’s website at
bairdwealth.com/retailinvestor.
These
relationships or arrangements present a conflict of
interest because they provide a financial incentive
Baird is engaged in a global private equity
business through Baird Capital (“Baird Capital”).
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Sagard
Baird and PAM Consultants may refer clients to
Baird Capital. PAM Consultants who assist in
obtaining a client’s investment in a private equity
fund offered through Baird Capital are eligible for
referral compensation.
Baird has a financial incentive to the extent it
would recommend that a client invest in a
portfolio company owned by a Baird Capital
private equity fund. A list of the portfolio
companies held by Baird Capital private equity
funds is located on Baird Capital’s website located
at https://www.bairdcapital.com/portfolio/baird-
capital-portfolio.aspx.
Baird Global Investment Banking
Baird Institutional Equities and Research
Baird Public Finance
additional
compensation
Sagard-affiliated
its Global
information
Baird’s direct parent corporation, BFC, has a
minority ownership interest (about 5%) in Sagard
Holdings Management, Inc. (“Sagard”) and the
right to appoint a member to Sagard’s board of
directors, which
is currently a management
person of Baird. Baird has agreed to use best
efforts, to the extent consistent with its fiduciary
duties, best
interest obligations, and other
regulatory responsibilities, to offer to clients
investment products managed by affiliates of
Sagard. Baird has an incentive to do so because
not reaching minimum thresholds would give
Sagard a right to redeem BFC’s ownership
interest
in Sagard and reaching significant
thresholds would give BFC the right to increase its
ownership interest. PAM Consultants do not
receive
for
any
investment
recommending
products. Additional
identifying
Sagard-affiliated
investment products will be
provided to clients prior to investment.
municipal
advisory,
55ip
55I, LLC (d/b/a 55ip, “55ip”) uses research and
other services from Riverfront, an affiliate of
Baird, in the development of its portfolios under
the BSN Program, and Riverfront
receives
compensation from 55ip with respect to those
portfolios. Due to its affiliation with Riverfront,
Baird has a financial incentive to favor 55ip
portfolios that use Riverfront services.
Through
Investment Banking,
Institutional Equities and Research, and Public
Finance Businesses, Baird provides investment
securities
banking,
underwriting, stock buyback and related services
to various corporate, municipal, and other issuers
of securities. Baird receives compensation from
such issuers in connection with the services it
provides, and the success of its services generally
depends upon Baird’s ability to sell the securities
of such issuers. Baird may, therefore, have an
incentive to favor the securities of issuers for
which Baird provides such services over the
securities of issuers for which Baird does not
provide such services.
Associated Investment Products and
Services
Baird and PAM Consultants may select or
recommend Associated Investment Products and
Services, including the Associated Funds and
Associated SMA Strategies, listed in Appendix A to
this Brochure.
A PAM Consultant who refers a client to Baird
Investment Banking for a possible transaction in
which Baird Investment Banking earns a financial
advisory or underwriting fee receives a portion of
such fee. A PAM Consultant who refers a client to
Baird Public Finance for a municipal advisory or
underwriting opportunity receives a portion of the
compensation earned by Baird Public Finance on
that opportunity. Baird and PAM Consultants thus
have an incentive to recommend the securities
issued in those offerings. A PAM Consultant who
refers a corporation
to Baird’s Institutional
Equities business for a stock buy-back program
receives a portion of the commissions earned by
Baird’s Institutional Equities business. Baird and
its PAM Consultants may, therefore, have an
incentive to buy, and to recommend that clients
sell, the securities of issuers that are part of
Baird’s buyback services.
Certain Associated Parties are associated with
Baird because BFC, Baird’s parent corporation,
owns some or all of the Associated Parties’ voting
securities. BFC’s parent corporation (and Baird’s
ultimate parent corporation), BFG, may be
deemed to indirectly own or control such voting
securities. Baird is deemed to be under common
control and “affiliated” with an Associated Party
when BFG indirectly owns or controls 25% or
more of such Associated Party’s voting securities
(or of an entity deemed
to control such
Associated Party). Baird considers itself “related”
to an Associated Party when BFG indirectly owns
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird and PAM Consultants do not impose the
same criteria or level of review.
Relationships and Arrangements with
Investment Managers
managers,
including
or controls at least 10% but less than 25% of
such Associated Party’s voting securities (or of an
entity deemed to control such Associated Party).
itself “associated” with an
Baird considers
Associated Party when certain other relationships
or other arrangements exist between Baird and
such Associated Party that might present a
conflict of interest with clients.
An Associated Party receives fees or other
compensation for investment advisory or other
services that it provides to an Associated Fund.
The amount of fees and other compensation paid
by an Associated Fund to an Associated Party is
disclosed in the Associated Fund’s prospectus or
other offering document. An Associated Party also
receives fees from a client for services that it
provides related to the client’s Associated SMA
Strategy. Information about the amount of fees
paid to an Associated Party with respect to an
SMA Strategy is contained in the applicable Baird
Form ADV Part 2A Brochure, the applicable
Program Account Schedule, or in some instances,
the client’s contract with the Associated Party.
Investment
those
participating in the Services, may select Baird, in
its capacity as a broker-dealer, to execute
portfolio trades for their clients, including for
Funds they advise and in which Baird clients
invest. Investment managers may also select
Baird to provide custody, research or other
services. Baird receives compensation for those
services. This may create an incentive for Baird to
favor the investment products and services of
such investment managers. However, Baird is a
fiduciary that is required to act in the best
interest of advisory clients when selecting or
recommending investment managers or their
investment products and services to such clients.
Baird addresses this potential conflict through
disclosure in this Brochure. Baird does not
consider the extent to which an investment
manager directs or is expected to direct trading,
custody or research services to Baird when
investment
the eligibility of an
considering
manager or its investment products or services
for the Services.
Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
Code of Ethics
incentive
to
favor
the
through disclosure
in
Subject to the restrictions described below, Baird
and its affiliates and associates may engage in
securities transactions for their own accounts,
including the same or related securities that are
recommended to or owned by Baird clients. These
transactions may include trading in securities in a
manner that differs from, or is inconsistent with,
the advice given to Baird clients, and the
transactions may occur at or about the same time
that such securities are recommended to or are
purchased or sold for client accounts. This creates
a potential for a conflict between the interest of
clients and the interests of Baird and its affiliates
and associates.
Baird and PAM Consultants have a financial
incentive to use, select or recommend Associated
Investment Products and Services because Baird
and BFG benefit financially if a client utilizes those
investment products and services rather than
unassociated investment products and services,
and PAM Consultants benefit financially from the
overall success of Baird and BFG. Similarly, Baird
and PAM Consultants also generally have a
financial
investment
products and services of Baird over Associated
Parties and to favor those of Associated Parties in
which BFG has a materially greater indirect
ownership interest over those of Associated
Parties in which BFG has a materially lesser
indirect ownership interest. Baird addresses this
potential conflict
this
Brochure. Further, when acting as fiduciaries,
Baird and its PAM Consultants are required to
select or recommend investment products only
when they determine it to be in the client’s best
interest to do so. The criteria used by them in
deciding to select or recommend Associated
Investment Products are generally the same as
those used for unassociated investment products.
However, a client should note that certain
Services and certain categories of investment
products only offer investment products and
services of Associated Parties. In those cases,
To address the potential for conflicts of interest,
Baird has adopted a Code of Ethics (the “Code”)
that applies to
its associates that provide
investment advisory services to clients, including
PAM Consultants, their supervisors, and certain
to non-public
associates who have access
information relating to advisory client accounts
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Accounts and Investments Provide Different
Levels of Compensation
The types of accounts and investment products
to clients provide Baird and PAM
offered
Consultants different levels of compensation.
Baird and PAM Consultants have an incentive to
generate revenues
from client accounts by
selecting and recommending account types and
investment products that will provide them the
greatest level of compensation.
or
by
Baird’s
Recommendations of Associated Investment
Products and Services
the
they will benefit
(“Access Persons”). The Code prohibits Access
Persons from using knowledge about advisory
client account transactions to profit personally,
directly, or indirectly, by trading in his or her
personal accounts. The Code also generally
prohibits Access Persons
from executing a
security transaction for their personal accounts
during a blackout period one business day before
or after the date that a client transaction in that
same security is executed. The Code provides for
certain exceptions deemed appropriate by Baird
management
Compliance
Department. In addition, orders for the accounts
of Access Persons and other Baird associates that
are under discretionary management by Baird
may be aggregated with orders for other Baird
client accounts, so long as the order is executed
as part of a block transaction with client orders. A
copy of the Code is available to clients or
prospective clients upon request.
Arrangements—Associated
Baird and PAM Consultants have an incentive to
use, select or
investment
recommend
products and services of Associated Parties
financially. See
because
“Additional Information—Other Financial Industry
Activities and Affiliations—Certain Relationships
and
Investment
Products and Services” above and “Certain Parties
Associated with Baird” on Baird’s website at
bairdwealth.com/retailinvestor.
Referral Compensation Paid to PAM Consultants
Financial
Industry
Activities
Baird has also implemented certain policies and
procedures relating to Baird’s and its associates’
trading activities that are designed to prevent
them from improperly benefiting from the trading
activities of Baird’s advisory clients. In addition,
Baird’s Compliance Department monitors the
personal trading activities of all of Baird’s
associates providing advisory-related services to
clients.
Relationships
Participation or Interest in Client
Transactions
Investment Advisory Accounts
PAM Consultants receive additional compensation
for referring clients to certain Associated Parties
described above. See “Additional Information—
and
Other
and
Affiliations—Certain
Arrangements—Baird and Associated Parties”
above. PAM Consultants also receive additional
compensation for referring clients to unaffiliated
banks that make loans to clients under Baird’s
Securities-Based Lending Program. See “Services,
Fees and Compensation—Additional Service
Information—Securities-Based Lending Program”
above. Such compensation gives PAM Consultants
an incentive to recommend or refer clients to
those Associated Parties and to recommend that a
client participate in the Securities-Based Lending
Program. For more information about referral
compensation paid to PAM Consultants and
related conflicts of interest, please see “Baird
Referral Programs” on Baird’s website at
bairdwealth.com/retailinvestor.
Ongoing Product Fees
receives ongoing
fees
Asset-based Advisory Fee arrangements create an
incentive for Baird and PAM Consultants to set the
applicable fee rate at a high level and to
encourage clients to add more money into their
accounts. Baird and PAM Consultants also have an
incentive to recommend an investment advisory
account to a client rather than a brokerage
account if the client has, or is expected to have,
lower levels of trading activity in the client’s
account. Select clients may pay a fixed dollar fee,
which presents a conflict in that such fee does not
give the PAM Consultant an incentive to make
recommendations that could benefit the client’s
account, or a performance or incentive fee, which
presents a conflict because it gives the PAM
Consultant an incentive to recommend riskier
investments in order to achieve the level of
performance in the account that would result in
payment of the fee.
Baird
from certain
investment products that are purchased and held
in client Accounts. Those fees, such as distribution
(12b-1) and/or service fees (“12b-1 fees”) from
mutual funds, are based on the value of client
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invested
in
Marketing Support and Revenue Sharing from
Mutual Fund and UIT Sponsors
assets
those products. A PAM
Consultant’s compensation increases as those
fees increase. Thus, Baird and PAM Consultants
have an incentive to use, select or recommend
such products and to recommend such products
that pay the greatest ongoing fees.
Certain mutual funds charge 12b-1 fees, which
are paid to Baird. Baird receives 12b-1 fees on an
ongoing basis as compensation for the services
Baird provides to the applicable mutual fund. The
12b-1 fees paid by a mutual fund are disclosed in
the mutual fund’s prospectus.
Baird generally does not allow mutual funds with
12b-1 fees to be purchased for PAM Service
Accounts. If Baird receives 12b-1 fees from a fund
with respect to a client’s mutual fund investment
in the client’s Account and the client’s Account is
subject to an asset-based fee arrangement, Baird
either: (1) rebates such 12b-1 fees to the client’s
Account if the client is paying an asset-based
Advisory Fee on such investment; or (2) excludes
such fund shares from the calculation of the
client’s asset-based Advisory Fee (sometimes
referred to as “unbillable assets”) for such period
of time that Baird collects and retains the 12b-1
fee. 12b-1 fees rebated to a client’s Account are
estimated based on the average daily balance of
the mutual fund shares in the Account and the
annual rate of the 12b-1 fee paid by the
applicable fund. If any rebated fees remain in a
client’s Account at the time of billing, those
rebated amounts will be included in the Account
assets subject to the Advisory Fee.
Trust
Portfolios
and
Please
see
Baird receives marketing support or revenue
sharing payments (“marketing support”) from the
sponsors and investment advisers of certain
mutual funds. These payments, which are based
on sales of, or client assets invested in, such
funds, are intended to compensate Baird for
providing marketing, distribution and other
services for the mutual funds. Marketing support
is not paid by sponsors or investment advisers of
mutual funds on mutual fund assets held in
investment advisory Retirement Accounts to the
extent prohibited by applicable
law. Baird
received marketing support payments over the
past two calendar years from the sponsors or
investment advisers of Alliance Bernstein Funds,
American Funds, Franklin Templeton Funds,
Goldman Sachs Funds, Hartford Funds, Invesco
Funds, John Hancock Funds, JPMorgan Funds,
Lord Abbett Funds, MFS Funds, PIMCO Funds and
Principal Funds. Baird also generally receives
marketing support related to the sale of units of
UITs. Sponsors of UITs typically make marketing
or concession payments to the firms that sell their
UITs,
including Baird. These payments are
typically calculated as a percentage of the total
volume of sales of the sponsor’s UITs made by
the
firm during a particular period. That
percentage typically increases as higher sales
volume levels are achieved. Descriptions of these
additional payments are provided in a UIT’s
prospectus. UIT sponsors that have paid volume
concessions to Baird over the past two calendar
years include Advisors Asset Management (AAM),
Guggenheim
First
Investments. Receipt of marketing support
payments from sponsors and investment advisers
of mutual funds and UITs provides Baird an
incentive to use, select and recommend such
mutual funds and UITs and to favor mutual funds
and UITs with sponsors or investment advisers
that make the greatest levels of such payments.
Baird does not share these payments with PAM
“Revenue
Consultants.
Sharing/Marketing Support and Other Third Party
Payments” at bairdwealth.com/retailinvestor for
more information.
If Baird receives 12b-1 fees with respect to
mutual fund shares that are designated as
unbillable assets in a client’s Account, Baird will
retain such 12b-1 fees. This presents a conflict of
interest because it provides Baird and its PAM
Consultants an
incentive to use, select or
recommend mutual fund shares that pay greater
12b-1 fees. Baird addresses this conflict by
adopting a Mutual Fund Share Class Policy
described above and by adopting internal policies
that limit the circumstances under which mutual
fund investments in client accounts can be
designated as unbillable assets and 12b-1 fees
can be retained.
Schwab Clearing Arrangement
Baird has a clearing arrangement with Charles
Schwab & Co., Inc. (“Schwab”) whereby Schwab
maintains an omnibus account with certain
mutual fund families for Baird on behalf of Baird
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PAM Consultants Receive Benefits from Product
Providers
Party
Payments”
for
PAM Consultants generally receive non-cash
compensation and other benefits from Baird and
from sponsors of investment products with which
Baird does business. Such non-cash compensation
and other benefits may include invitations to
attend conferences or educational seminars,
payment of related travel, lodging and meal
expenses, and receipt of gifts and entertainment.
For example, PAM Consultants are invited to
educational conferences hosted by sponsors of
mutual funds, annuities and other investment
products, with the costs associated with such
conference (including travel and lodging) paid by
the sponsors. In addition, PAM Consultants hold
client events with some or all of the costs of such
events paid by sponsors of investment products.
Product sponsors may also provide gifts and
entertainment in connection with those or other
events. These benefits present a conflict of
interest in that they give PAM Consultants an
incentive to use, select or recommend investment
products and their sponsors that provide the
greatest levels of such benefits. Please see
“Revenue Sharing/Marketing Support and Other
at
Third
bairdwealth.com/retailinvestor
more
information.
Cash Sweep Program
clients. Under the clearing arrangement, Schwab
provides clearing services for most “no load”
funds and “load” funds held by Baird clients.
Although Baird pays Schwab a fee for its clearing
and omnibus services, Schwab generally passes
through to Baird the shareholder servicing fees
that Schwab receives from the funds. Shareholder
servicing fees are not paid by Schwab on mutual
fund assets held in Retirement Accounts to the
extent prohibited by applicable law. The amount
of the shareholder servicing fees paid to Baird is
based on the value of the client assets invested in
those funds. However, the shareholder servicing
fee rate varies based on the type of fund (load or
no load), the value of client assets in those funds,
and the relationship that Schwab has with those
funds (whether or not Schwab receives payments
from those funds or their sponsors, and the rates
of such payments). As a result, Baird has an
incentive to use, select or recommend mutual
funds from which Baird would receive higher
payments from Schwab. However, Baird generally
does not compensate PAM Consultants based
upon the amounts Baird receives from Schwab
except with respect to amounts attributable to
sales loads and 12b-1 fees that Baird would
otherwise receive directly from a fund if it were
not for the existence of the clearing arrangement
with Schwab. If Baird receives 12b-1 fees from
Schwab with respect to a mutual fund investment
in a client’s Account, Baird rebates or retains such
fees as further described under the heading
“Ongoing Product Fees” above.
Program
Baird
Baird Conference Sponsorships
funds,
the opportunity
Baird has an incentive to have clients participate
and maintain significant balances in Baird’s Cash
Sweep
receives
because
substantial compensation on client cash balances
that are automatically swept into bank deposit
accounts and invested in money market mutual
funds under the program. Please see “Services,
Fees and Compensation—Additional Service
Information—Cash Sweep Program” above for
more detailed information.
Trust Services Arrangements
seminars
supporting Baird
Please
see
firm
and
to
Baird hosts a number of seminars and
conferences for PAM Consultants in any given
year, including Baird’s PWM Symposium, which
gives sponsors of investment products, such as
to make
mutual
presentations at, and contribute money toward
the cost of, such seminars and conferences. This
presents a conflict of interest in that it gives Baird
an incentive to promote or market the sponsors’
investment products in order to persuade them to
and
continue
conferences.
“Revenue
Sharing/Marketing Support and Other Third Party
Payments” at bairdwealth.com/retailinvestor for
more information.
it
Baird and PAM Consultants have an incentive to
recommend that a client retain Baird Trust for the
client’s trust services needs rather than an
unassociated
recommend
arrangements that involve Baird and the PAM
Consultant providing investment advisory services
to the client and Baird Trust only providing trust
administration services because
is more
profitable for them. Please see “Services, Fees
Service
and
Compensation—Additional
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Information—Trust Services Arrangements” above
for more detailed information.
Margin Loans
to
recommend
the compensation paid to PAM Consultants from
brokerage accounts increase as the level of
trading increases, Baird and PAM Consultants
have an incentive to recommend a brokerage
account to a client rather than an investment
advisory Account if the client has, or is expected
to have, significant trading activity in the client’s
account. PAM Consultants also have a financial
certain wealth
incentive
management services, such as financial planning.
Please see “Services, Fees and Compensation—
Advisory Fees—Advisory Fee Payments to Baird,
PAM Consultants and Investment Managers”
above for more detailed information.
fee. Please see
Account Transfers and New Accounts
Loans” above
Baird has an incentive to recommend that a client
use margin because Baird receives interest on
client margin
loans, and Baird and PAM
Consultants also have an incentive to recommend
that a client use margin, because a margin loan
allows the client to make larger and more
securities purchases. It also increases the value of
a client’s Account and thus the Advisory Fee
associated with that Account because the margin
loan is not deducted for purposes of calculating
the
“Services, Fees and
Compensation—Additional Service Information—
for more detailed
Margin
information.
Securities-Based Lending Program
for
Baird and a client’s PAM Consultant have an
incentive to recommend that the client transfer
the client’s accounts to Baird and establish new
accounts with Baird (including IRA rollovers)
because doing so will result in increased revenues
the PAM
to Baird and compensation
Consultant.
PAM
Consultants
receive
Recommendations to Open Different Types of
Accounts
Baird and PAM Consultants have an incentive to
recommend that a client participate in Baird’s
Securities-Based Lending Program because Baird
and
referral
compensation and such loans allow a client to
keep more assets in the client’s Accounts, which
result in more advisory fees for us and paid to the
client’s PAM Consultant. Please see “Services,
Fees and Compensation—Additional Service
Information—Securities-Based Lending Program”
above for more detailed information.
Investment Advisory and Brokerage Account and
Service Recommendations
to
clients
rather
Baird and PAM Consultants have an incentive to
recommend that a client open different types of
accounts with Baird, such as individual accounts,
IRA rollovers, joint accounts, 529 plan accounts
and UGMA/UTMA accounts, because if a client has
different types of accounts with Baird, the client
brings more of the client’s investable assets to
Baird, on which fees can be generated, thereby
increasing Baird’s revenues and the client’s PAM
Consultant’s compensation. Also, if a client has
more account types with Baird, the client is
statistically more likely to maintain the client’s
relationship with Baird and the client’s PAM
Consultant for longer periods of time.
Baird Stock Ownership
Consultant
receive
that
increase
the
Baird and PAM Consultants generally have a
financial incentive to recommend investment
advisory Accounts
than
brokerage accounts because Advisory Fee
is recurring, more predictable and
revenue
typically greater than the revenues Baird earns,
and the compensation PAM Consultants receive,
from brokerage accounts. In addition, because
Advisory Fees are paid by a client regardless of
the trade activity in the client’s advisory Account,
Baird will receive greater revenue, and the client’s
PAM
greater
will
compensation, from a low trade-activity advisory
Account than from a low trade-activity brokerage
account. Baird and PAM Consultants thus have an
incentive to recommend an investment advisory
Account to a client rather than a brokerage
account if the client has, or is expected to have,
lower levels of trading activity in the client’s
account. However, because Baird’s revenues and
Most PAM Consultants own common stock of BFG,
Baird’s ultimate parent, and when offered the
opportunity to buy BFG stock they usually do so.
The amount of BFG stock that a PAM Consultant
may purchase is based in part on the PAM
Consultant’s total production level. A client’s PAM
incentive to make
Consultant thus has an
recommendations
PAM
Consultant’s total production on the client’s
accounts with Baird. Moreover, revenues from
in which PAM
Baird’s PWM department,
Consultants operate, contribute substantially to
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Investment Managers” above for more detailed
information.
Principal Trading
with
Baird,
even
if
BFG’s overall revenues and profitability, and the
performance of BFG’s stock price is largely due to
the profitability of Baird’s PWM department. As a
result, a client’s PAM Consultant’s ownership of
BFG stock creates a financial incentive to make
recommendations to the client that increase the
amount of revenues generated from the client’s
accounts
those
recommendations will not increase the PAM
Consultant’s production, so as to increase the
revenues and profitability of Baird’s PWM
department and thus of BFG, which will serve to
grow the value of the BFG stock. For example,
ownership of BFG stock, the performance of which
is impacted by the success of Associated Parties,
provides a client’s PAM Consultant an incentive to
use, select or recommend Associated Investment
Products and Services to a client even though
such recommendation does not increase the
client’s PAM Consultant’s production.
Other Client Relationships
Information—Trading
for
Baird and PAM Consultants have an incentive to
execute a trade for a client on a principal basis.
The compensation that Baird and PAM Consultants
receive on principal trades, such as a markup or
markdown, is often higher than the compensation
they receive when executing trades as agent,
such as commissions. The compensation received
by Baird and PAM Consultants is in addition to the
asset-based Advisory Fee a client pays on the
client’s advisory Accounts. Thus, Baird and PAM
Consultants have an
incentive to trade as
principal rather than as agent. Principal trades
also allow Baird to sell securities from Baird’s
account that Baird deems undesirable and to buy
securities for Baird’s account that Baird deems
desirable. For more information, please see
“Services, Fees and Compensation—Additional
Client
Service
Accounts—Trade Execution Services Performed by
Baird—Principal Trades” above.
Baird Underwritten Offerings
Certain client accounts overseen by Baird and
PAM Consultants may have similar investment
objectives and strategies but may be subject to
different fee schedules or commission rates. Thus,
Baird and its PAM Consultants have an incentive
to favor client accounts that generate a higher
level of compensation.
Relationships with Issuers of Securities
in companies or
Baird and PAM Consultants have an incentive to
recommend that clients purchase securities in
offerings underwritten by Baird because the
underwriting compensation that Baird and PAM
Consultants will earn on those offerings tends to
be higher than the compensation they would
normally receive if clients were to buy them in the
secondary market, and because the profitability of
underwritten offerings to Baird depends upon
Baird’s ability to sell the securities allocated to
Baird in the offering.
Allocations of IPOs and Other Public Offerings
invest
From time to time, Baird may have proprietary
investments
issuers whose
securities are offered and sold to clients, a PAM
Consultant or another Baird associate may have
significant investments in companies or issuers
whose securities are offered and sold to clients, or
a PAM Consultant or another other Baird associate
(or their spouses, partners or family members)
may have a position as an officer or director of a
company or issuer whose securities are offered
and sold to clients. In such cases, Baird and/or a
client’s PAM Consultant will have an incentive to
in those
recommend that the client
companies.
PAM Consultants have the incentive to favor some
clients over other clients when allocating shares
issued in public offerings, particularly those
clients with larger accounts or accounts that
generate high fees and compensation, as a
reward for their past business or to generate
future business.
PAM Consultants Transferring to Baird
Trade Error Correction
It is Baird’s policy that a client’s account will be
fully compensated for any losses incurred as a
result of a trade error for which Baird is
responsible. If the trade error results in a gain,
the gain may be retained by Baird. For more
A PAM Consultant joining Baird from another firm
has an incentive to recommend that a client to
transfer the client’s accounts from such firm to
Baird because doing so will increase the PAM
Consultant’s compensation. Please see “Services,
Fees and Compensation—Advisory Fees—Advisory
Fee Payments to Baird, PAM Consultants and
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information, please see “Services, Fees and
Compensation—Additional Service Information—
Trading
for Client Accounts—Baird’s Trading
Practices—Trade Error Correction” above.
Baird’s Other Broker-Dealer and Related Activities
A client may choose to hold cash balances in the
client’s eligible accounts as broker-dealer “free
credits.” To the extent a client elects to hold cash
balances as free credits, a client understands that
Baird does not pay interest on such balances and
Baird may benefit from the possession or use in
the ordinary course of its business of any free
credit balances in the client’s accounts, subject to
restrictions imposed by Rule 15c3-3 under the
Exchange Act.
the size of
the order,
The investment advice provided to a client may
be based on the research opinions of Baird’s
research departments. Baird does, and seeks to
do, business with companies covered by those
research departments and as a result, Baird may
have a conflict of interest that could affect the
content of its research reports.
automated
sell
investments
recommended
non-institutional
participants
in
under
“Services,
Fees
Baird and its Associated Parties and associates
may buy or
that are
recommended to or owned by a client for their
own accounts, or they may act as broker or agent
for other clients buying or selling
those
investments. Those transactions may include
buying or selling investments in a manner that
differs from, or is inconsistent with, the advice
given to a client, and those transactions may
occur at or about the same time that such
investments are
to or are
purchased or sold for a client’s account. Baird
may also engage in agency cross transactions and
principal transactions with clients as further
described
and
Compensation—Additional Service Information—
Trading for Client Accounts—Trade Execution
Services Performed by Baird” above.
Baird selects securities trade execution venues
trading
based on
characteristics of the security, speed of execution,
likelihood of price improvement, availability of
efficient
transaction processing,
guaranteed automatic execution levels and other
qualitative factors. Baird receives payment or
liquidity rebates on certain options or equity
securities orders
to some venues
routed
(commonly known as “payment for order flow”).
The existence and amount of payments are
dependent upon the size and type of the routed
order. The
source and amount of any
compensation received by Baird in connection
with payment for order flow will be disclosed to
the
the
transaction upon request. This compensation
gives Baird an incentive to route client orders for
securities transactions to those venues that
provide Baird the greatest levels of compensation,
but Baird’s routing decision is always based upon
obtaining favorable executions for clients rather
than the availability of payment for order flow.
Information about Baird’s order routing practices
at:
available
are
http://www.rwbaird.com/help/account-
disclosures/routing-equity-orders.aspx.
to
“Additional
from
time
Baird and PAM Consultants have an incentive to
favor the securities of issuers for which Baird’s
Global Investment Banking, Fixed Income Capital
Markets (including Baird Public Finance) and
Institutional Equities and Research Departments
provide services due
the compensation
received by Baird and Baird Financial Advisors.
Information—Other Financial
See
Industry Activities
and Affiliations—Certain
Relationships and Arrangements—Baird and
Associated Parties” above.
Baird and its associates, by reason of Baird’s
investment banking or other
broker-dealer,
activities, may
time acquire
to
information deemed confidential, material and
non-public, about corporations or other entities
and their securities. Baird and its associates are
prohibited by applicable law or agreements from
disclosing such information to clients or acting
upon such information with respect to any client
Account. Baird’s other activities thus present a
potential conflict of
interest because such
activities may limit Baird’s ability to advise or
manage client Accounts.
As a registered broker-dealer, Baird effects
transactions in securities on a national exchange
and may receive and retain compensation for
such services, subject to the limitations and
restrictions made applicable to such transactions
by Section 11(a) of the Exchange Act and Rule
11a2-2(T) thereunder.
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Other Conflicts of Interest
from improperly benefiting from the trading
activities of Baird’s advisory clients; and
• address and limit cash and non-cash benefits
provided to PAM Consultants by third parties in
an attempt to avoid any question of propriety or
any conduct inconsistent with Baird’s high
standards of ethics.
Duration Compensation Will Be Received
Baird offers to clients other investment products
and services not described in this Brochure. These
services provide
investment products and
different levels of compensation to Baird and its
PAM Consultants. Baird and its PAM Consultants
have an incentive to favor those investment
products and services that generate a higher level
of compensation than those that generate a lower
level of compensation. For more information
about the other investment products and services
offered by Baird, clients should contact Baird or a
PAM Consultant.
extend beyond
a
client’s
If a client holds any of the investment products
described above, Baird, its Associated Parties and
associates will receive the fees and payments
described above for the duration of the client’s
advisory
In some
relationship with Baird.
circumstances, the receipt of such compensation
advisory
may
relationship with Baird if the client continues to
hold those assets at Baird.
financial
interest or practices
Fees—Advisory
Managers”
and
and
Referrals
and
Other sections of this Brochure also describe
instances when Baird and its PAM Consultants
may recommend to clients, and may buy and sell
for client’s Account, securities in which Baird and
its Associated Parties and associates have a
material
that
present a conflict of
interest. For more
information, please see “Services, Fees and
Compensation—Advisory
Fee
to Baird, PAM Consultants and
Payments
Investment
“Additional
Information—Other Financial Industry Activities
“Additional
and
above,
Affiliations”
Information—Client
Other
Compensation” below.
If Baird, or an Associated Party or associate of
Baird, receives any compensation or benefit
described in this Brochure from or related to a
client’s investment, they will generally retain the
compensation or benefit. Except as otherwise
described above, Baird generally does not rebate
these amounts to a client’s Account or credit the
amount against the Advisory Fees payable by a
client unless such compensation may not be
retained under applicable law or regulation.
Addressing Conflicts
Review of Accounts
Client Account Review
for Baird and
The foregoing activities could create a conflict of
interest with clients. In addition to the measures
described above, Baird addresses conflicts posed
by those activities through disclosure in this
Brochure, the client’s agreements with Baird, the
Client Relationship Booklet and prospectuses,
offering documents or other disclosure documents
provided or made available to clients. Baird has
also adopted a Code of Ethics and other internal
policies and procedures
its
associates that:
• require them to provide investment advice that
is suitable for advisory clients (based upon the
information provided by such clients);
that
• are designed
Client accounts are monitored on a periodic basis
by the client’s PAM Consultant and are subject to
review by the Baird Market Director or PWM
Supervision department supervisor (or his or her
respective designee) responsible for supervising
the client’s PAM Consultant. A client’s PAM
Consultant generally reviews the performance of
the client’s Account at least annually. However,
the client’s PAM Consultant may not review the
performance of a client’s SMAs managed by Other
Managers under the Baird SMA Network Program
or Dual Contract Program. Baird has designated
individuals who are responsible for monitoring a
client’s PAM Consultant with respect to the client
account’s trading activity and attempting to
ascertain whether client accounts within each
composite are being treated equitably.
securities
to ensure
allocations made to discretionary client accounts
are made in a manner such that all such clients
receive fair and equitable treatment over time;
• address Baird’s and its associates’ trading
activities and are designed to prevent them
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Account Statements and Performance
Reports
included in a client’s Account generally do not
exactly mirror the securities included in the index.
performance
comparisons
If Baird provides transaction execution services to
a client, Baird will generally provide the client
with a monthly brokerage account statement
when activity occurs during
that month.
Otherwise, Baird will provide the client with a
quarterly statement if there has not been any
intervening monthly transaction activity.
The benchmarks used by Baird with respect to a
client’s SMA may differ from the benchmarks used
by the manager of the client’s SMA. As a result,
the
in Baird’s
performance reports may differ from reports
provided to clients directly by the investment
manager for the client’s SMA.
A client’s PAM Consultant will provide the client
with a written report on the client’s Account’s
performance as often as the client and the PAM
Consultant may from time to time mutually agree.
Performance reporting may not be available for
Account assets that are not custodied at Baird.
For more information about performance reports
provided by PAM, see “Services, Fees and
Compensation—Description of Advisory Services”
above. PAM or Baird may change or discontinue
performance reporting to a client at any time for
any reason upon notice.
calculation of
Client performance reports usually contain a
portfolio valuation and typically show the asset
allocation of the client’s portfolio, changes in a
client’s portfolio, and account performance
compared to a benchmark market index or indices
(such as the S&P 500® Index or the Bloomberg
U.S.
Intermediate Government/Credit Bond
Index). The benchmark may be a blended
benchmark that combines the returns for two or
more indices.
The performance of investment managers may,
under certain circumstances, be presented to
clients on a “gross” or “gross of fees” basis, which
means the performance results being presented
does not reflect the deduction of Advisory Fees
and other costs that clients have incurred and will
incur when retaining the manager. Had applicable
Advisory Fees and other costs been included in
the performance calculation,
the manager’s
performance results would have been lower than
the performance results presented. Documents
presenting a manager’s performance results on a
gross of
fees basis should contain certain
disclosures about the performance results being
presented. Clients are urged to review carefully
those disclosures because they contain important
information about
the
the
performance results. If a client is presented
performance information for a manager’s strategy
on a gross of fees basis and the client has an
Account managed by that manager pursuant to
that strategy,
the client should obtain a
performance report for the Account and review
that performance information carefully because
the performance report for the Account will reflect
the deduction of applicable Advisory Fees and
other costs.
A client should note that past performance does
not indicate or guarantee future results. None of
PAM, Baird, or investment managers managing
the client’s Account promise or guarantee any
level of investment returns or that the client’s
investment objective will be achieved.
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after
they have
implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. As a result, the performance of a
Model Portfolio, as reported by the Model
Provider, will differ, perhaps in a materially
negative manner, from the actual performance
realized by Baird client Accounts pursuing the
Model Portfolio strategy. See “Additional Service
Information—Trading for Client Accounts—Trading
Practices of Investment Managers” above for
more information.
Benchmarks shown in performance reports are for
informational purposes only. PAM’s selection and
use of benchmarks is not a promise or guarantee
that the performance of a client’s Account will
meet or exceed the stated benchmark. When the
client compares Account performance to the
performance of a market index, the client should
recognize that a market index merely reflects the
performance of a list of unmanaged securities
included in the index and the index performance
does not take into account management fees,
execution costs, and other expenses related to
investing for a client’s Account. The securities
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
including, but not
limited
to,
role
in developing
the
these
fees
to
Client Referrals and Other Compensation
PAM or Baird may provide compensation to
individuals who refer clients in some instances.
When applicable, the compensation paid is a
percentage of the client’s fee payments or the
value of the client’s Account. The amount of
compensation will vary, with the specific level
determined based upon consideration of various
factors
the
individual’s
client
relationship and the assets under management.
Baird may pay
registered
representatives of Baird and its Associated Parties
as well as to unassociated solicitors that have
entered into a written agreement with Baird.
When preparing a client’s Account statements and
performance reports, PAM and Baird generally
rely upon third party sources, such as third party
pricing services. In some instances, such as when
Baird is unable to obtain a price for an asset from
a pricing service, Baird may obtain a price from
its trading desk or it may elect to not price the
asset. Obtaining a price from its trading desk may
present a conflict of interest. In some cases, Baird
obtains prices from the issuers or sponsors of
investment products in the client’s Account when
prices are not otherwise readily available. This
frequently occurs with respect to the valuation of
annuities and Complex Investment Products. If
the assets in the client’s Account are held by a
custodian other than Baird, Baird may also use
valuation information provided by the client’s
third party custodian.
PAM and Baird and Baird’s Associated Parties and
associates may receive certain economic benefits
in connection with providing advisory services to
clients, which are described in the sections
entitled “Services, Fees and Compensation”,
“Account Requirements and Types of Clients”,
“Additional Information—Other Financial Industry
Activities and Affiliations” and
“Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” above.
is unreliable. Valuation data
in a timely manner, resulting
Financial Information
PAM does not require or solicit prepayment of
more than $1,200 in fees per client six months or
more in advance and, thus, has not included a
balance sheet of Baird’s most recent fiscal year.
Neither Baird nor PAM is aware of any financial
condition that is reasonably likely to impair their
ability to meet their contractual commitments to
clients, nor has either been the subject of a
bankruptcy petition at any time during the past
ten years.
PAM and Baird do not conduct a review of
valuation information provided by third party
pricing services, issuers, sponsors, or custodians,
and they do not verify or guarantee the accuracy
of such information. PAM and Baird do not accept
responsibility for valuations provided by third
parties that are inaccurate unless they have a
reason to believe that the source of such
valuations
for
investments, particularly annuities and Complex
Investment Products, may not be provided to PAM
in
or Baird
valuations that are not current. The prices
obtained by PAM and Baird from the third party
pricing services, issuers, sponsors and custodians
may differ from prices that could be obtained
from other sources. Values used in account
statements and performance reports may vary
from prices received in actual transactions and
are not firm bids, offers or guarantees of any type
with respect to the value of assets in an Account,
and the values may be greater than the amount a
client would receive if the securities were actually
sold from the client’s Account.
investment
other
compensation
related
to
to
If a client has assets held by a third party
custodian, the prices shown on a client’s Account
statements provided by the custodian could be
different from the prices shown on statements
and reports provided by PAM or Baird. See
“Services, Fees and Compensation—Additional
Service Information—Custody Services” above for
more information.
Special Considerations for Retirement
Accounts
Each Retirement Account Fiduciary of a client
should understand that PAM or Baird may invest
for the client, recommend that the client invest in,
or make available
to plan
for
participants, Associated Investment Products, that
Baird and its Associated Parties will receive fees
such
or
investments, and that they will retain such
compensation
the extent permitted by
applicable law, rule or regulation, including,
without limitation, Department of Labor (“DOL”)
Prohibited Transaction Exemption (“PTE”) 77-4,
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
DOL PTE 2020-02 or other advisory opinions
issued by the DOL.
management, investment advisory and other
similar fees detailed in the applicable prospectus
or other offering or disclosure documents for the
Associated Investment Product.
that
directed
the
fiduciary
Fiduciary
such Fiduciary
is
that
for complying with all
Parties
from
transactions, and
the duty
broker-dealer,
for
the Associated
and
terminating
monitoring
a
If the client’s Account is a Retirement Account
and if PAM is directed to implement a directed
brokerage arrangement for the Account, each
Retirement Account Fiduciary of the client should
understand:
brokerage
the
arrangement must be for the exclusive benefit of
participants and beneficiaries of the Retirement
Account; and
responsibilities
discussed in ERISA Technical Bulletin 86-1. Each
should also
Retirement Account
solely
understand
responsible
fiduciary
in ERISA Technical
responsibilities discussed
Bulletin 86-1, including, without limitation, the
duty to make an initial determination that the
directed broker-dealer is capable of providing best
execution for the client’s brokerage transactions,
the duty to monitor the services provided by the
directed broker-dealer so as to assure that the
client has received best execution of the client’s
brokerage
to
determine that the commissions paid by the client
and any other fees or costs incurred by the client
are reasonable in relation to the value of the
brokerage and other services received by the
client. The client and each Retirement Account
Fiduciary of the client should also understand that
the client and the client’s Retirement Account
Fiduciaries are solely responsible for engaging a
directed
its
directed
performance
brokerage arrangement, and that PAM and Baird
are not responsible for determining whether a
directed broker-dealer is capable of providing best
execution.
than
the
client
To the extent Baird and its Associated Parties rely
upon PTE 77-4, each Retirement Account
Fiduciary should also understand that when PAM
or Baird invests the assets of a Retirement
Account in an Associated Investment Product that
pays investment advisory fees to Baird or any of
its Associated Parties, Baird and its Associated
Parties will receive such investment advisory fees
in accordance with the terms of DOL PTE 77-4,
and, as required thereby, PAM and Baird will
waive the asset-based Advisory Fees on that
portion of the assets invested in the Associated
Investment Product for such period of time so
invested or Baird will offset the investment
advisory fees received by Baird or any of its
the
Associated
Associated
Investment Product against
the asset-based
Advisory Fee that PAM and Baird charge to the
client. For the purpose of complying with the
terms of DOL PTE 77-4, the client and each
Retirement Account Fiduciary of
the client
acknowledge in the client’s advisory agreement
that: (i) the investment in Associated Investment
Products for the client’s Account is appropriate
because of, among other things, the investment
goals, redeemability, liquidity, and diversification
of those products; (ii) subject to the terms of the
applicable Service, all assets of the client’s
Account may be invested in one or more of the
Associated Investment Products; (iii) the client
and such Retirement Account Fiduciary received
prospectuses or other offering or disclosure
Investment
documents
Products that may be used in connection with the
Account, each of which include a summary of all
fees that may be paid by the Associated
Investment Products to Baird or its Associated
Parties; and (iv) the client received information
concerning
the nature and extent of any
differential between the rate of such Associated
Investment Product fees and the Advisory Fees
payable by the client. The differential between the
fees to be charged by PAM and Baird for the
investment advisory services they provide to the
client and, if applicable, the investment advisory
and other similar fees paid by the Associated
Investment Product to Baird or its Associated
Parties with respect to the services Baird or any of
its Associated Parties provides to the Associated
Investment Product is the difference between the
Advisory Fee disclosed in the client’s advisory
investment
agreement and
the applicable
If a client’s Account is a Retirement Account and if
the client is selecting Associated Investment
Products and Services, each Retirement Account
Fiduciary of the client understands and agrees
that in making such selection: (a) Baird and its
Associated Parties may receive higher aggregate
compensation
selected
if
investment managers, funds or other products
not associated with Baird and thus Baird may
have an incentive to offer Associated Investment
Products and Services; (b) Baird makes available
to the client investment managers, funds and
products not associated with Baird and the client
may obtain additional information about such
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
unassociated investment managers, funds or
products at any time by contacting the client’s
PAM Consultant; and (c) the client is free to
choose another investment option or participate
in another Baird advisory program that does not
use investment managers, funds or products
associated with Baird at any time by contacting
the client’s PAM Consultant. For more information
Investment Products and
about Associated
Services, please see “Additional Information—
Other Financial Industry Activities and Affiliations”
above.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Appendix A
Associated Investment Products and Services
Entity Type
Name
Relationship
Baird Advisors1
Baird Department
Baird Equity Asset Management1
Baird Department
Chautauqua Capital Management1
Baird Department
55I, LLC (d/b/a 55ip, “55ip”)
Associated
Investment Advisor
GAMMA Investing, LLC
Affiliated
Greenhouse Fund GP LLC
Related
Greenhouse Funds LLLP
Related
LoCorr Fund Management, LLC
Related
Reinhart Partners, LLC
Affiliated
Riverfront Investment Group, LLC
Affiliated
Dual Registrant2
Strategas Securities, LLC
Affiliated
Trust Company
Baird Trust Company1
Affiliated
Baird Funds, Inc.1
Affiliated
Bridge Builder Trust (Baird series)
Affiliated
Mutual Fund
Financial Investors Trust (Riverfront series)
Affiliated
LoCorr Investment Trust
Related
Managed Portfolio Series Trust (Reinhart series)
Affiliated
Pace® Select Advisors Trust (Baird Series)
Affiliated
Advisors’ Inner Circle Fund III (Strategas series)
Affiliated
ETF
ALPS ETF Trust (Riverfront Series)
Affiliated
First Trust Exchange-Traded Fund III (Riverfront series)
Affiliated
Automated Quantitative Analysis (AQA®) Portfolio Series
Affiliated
UIT
Dividend Income Trust (DIT) Series
Affiliated
Strategas Trust, Series 1-1
Affiliated
CIT
Reliance Trust Institutional Retirement Trust (Baird/Chautauqua series)
Affiliated
Greenhouse Master Fund LP
Related
Hedge Fund
Greenhouse Onshore Fund LP
Related
Greenhouse Overseas Fund Ltd.
Related
Chautauqua Global Growth Equity QP Fund, LP
Affiliated
Private Fund
Chautauqua International Growth Equity QP Fund, LP
Affiliated
Chautauqua Series Fund, LLC
Affiliated
Appendix A - 1
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Venture Partners Management Company III, LLC
Baird Venture Partners III Limited Partnership
Affiliated
BVP III Affiliates Fund Limited Partnership
BVP III Special Affiliates Limited Partnership
Baird Venture Partners Management Company IV, LLC
Baird Venture Partners IV Limited Partnership
Affiliated
BVP IV Affiliates Fund Limited Partnership
BVP IV Special Affiliates Limited Partnership
Baird Venture Partners Management Company V, LLC
Baird Venture Partners V Limited Partnership
Affiliated
BVP V Affiliates Fund Limited Partnership
BVP V Special Affiliates Fund Limited Partnership
Baird Capital Partners Management Company V, LLC
Baird Capital1,3
Baird Capital Partners V Limited Partnership
Affiliated
Investment Advisor
BCP V Affiliates Fund Limited Partnership
Private Equity Fund
BCP V Special Affiliates Limited Partnership
Baird Capital Management Company, LLC
Baird Venture Partners GP VI, LLC
Baird Venture Partners VI LP
Affiliated
BVP VI Affiliates Fund LP
BVP VI Special Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management I LP
Baird Capital Global Fund I LP
Affiliated
Baird Capital Global Fund I-DE LP
BCGF I Special Affiliates LP
BCGF I Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management II LLC
Baird Capital Global Fund II Limited Partnership
Affiliated
BCGF II Affiliates Fund Limited Partnership
BCGF II Special Affiliates Limited Partnership
Appendix A - 2
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Capital Management Company, LLC
Baird Capital Global GP III LLC
Baird Capital Global Fund III LP
Affiliated
Baird Capital1,3
BCGF III Affiliates Fund LP
Investment Advisor
BCGF III Special Affiliates LP
Private Equity Fund
Baird Capital Partners Europe Limited4
Baird Capital Partners Europe II LP
Affiliated
Baird Capital Partners Europe II Special Affiliates LP
The Growth Fund
Baird Principal Group Management Company I, LLC
Baird Principal Group5
Baird Principal Group Partners Fund I Limited Partnership
Investment Advisor
Baird Principal Group Management Company II, LLC
Affiliated
Private Equity Fund
Baird Principal Group Partners Fund II Limited Partnership
Baird Principal Group Management Company, LLC
Baird Principal Group Partners Fund III, LP
Holding Company
Sagard Holdings Management, Inc.6
Associated
1. Participates in a Baird PWM Referral Program that pays compensation to PAM Consultants for eligible referrals.
2. Registered with the SEC as a broker-dealer and investment advisor.
3. Baird Capital, Baird’s private equity business.
4. Baird Capital Partners Europe Limited, an English limited company, is regulated and authorized by the Financial
Conduct Authority.
5. Baird Principal Group, a group within Baird that has private equity funds only available to Baird employees.
6. Baird has a contractual relationship with and a small minority investment in Sagard Holdings Management, Inc., a
holding company for various financial services businesses whose investment products are made available to clients under
the Services. See “Additional Information—Other Financial Industry Activities and Affiliations—Certain Relationships and
Arrangements—Baird and Associated Parties” above for more information.
Appendix A - 3
Baird PAM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Additional Brochure: BAIRD PRIVATE WEALTH MANAGEMENT (2026-03-27)
View Document Text
Baird Private Wealth Management
Wrap Fee Program Brochure
March 27, 2026
Discretionary Programs
ALIGN Strategic Portfolios
BairdNext Portfolios
Private Investment Management
Russell Model Strategies
Non-Discretionary Program
Baird Advisory Choice
Separate Managed Account Programs
Baird Affiliated Managers
Baird Recommended Managers
Baird SMA Network
Dual Contract
Unified Managed Account Programs
ALIGN UMA Select Portfolios
Unified Advisory Select Portfolios
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue
Milwaukee, WI 53202
1-800-792-2473
rwbaird.com
Member FINRA & SIPC
SEC File No. 801-7571
This wrap fee program brochure (“Brochure”) provides information about the qualifications and
business practices of Robert W. Baird & Co. Incorporated (“Baird”) and Baird Private Wealth
Management, a department of Baird. Clients should carefully consider this information before
becoming a client of Baird. If you have any questions about the contents of this Brochure, please
contact us at the toll-free phone number listed above. The information contained in this Brochure has
not been approved or verified by the United States Securities and Exchange Commission or by any
state securities authority. Additional information about Baird is available on the SEC’s website at
www.adviserinfo.sec.gov.
Material Changes
Robert W. Baird & Co. Incorporated (“Baird”) updated the Form ADV Part 2A wrap fee program brochure for
its Private Wealth Management Department (the “Brochure”) on March 27, 2026. The following summary
discusses the material changes that Baird has made to the Brochure since March 21, 2025, the date of the
last annual update to the Brochure.
• In January 2026, Baird’s direct parent corporation, Baird Financial Corporation (“BFC”), made a
significant minority investment in Reinhart Partners, LLC (“Reinhart”), an investment advisor that offers
investment products and services through the Programs. As a result of the investment transaction, Baird
and Reinhart are affiliated, providing Baird a financial incentive to use, select or recommend Reinhart
investment products and services.
• In September 2025, Baird entered into a strategic partnership with Sagard Holdings Management, Inc.
(“Sagard”). Baird’s direct parent corporation, BFC, acquired a minority ownership interest in Sagard and
the right to appoint a member to Sagard’s board of directors. Baird agreed to use best efforts, consistent
with its fiduciary duties and other regulatory responsibilities, to offer investment products managed or
sponsored by affiliates of Sagard deemed suitable by Baird for its PWM clients, providing Baird a financial
incentive to recommend such investment products. See the Section of the Brochure entitled “Additional
Information—Other Financial
Industry Activities and Affiliations—Certain Relationships and
Arrangements—Baird and Associated Parties” for more information.
• Baird updated its description of the DC Program. The DC Program is designed to accommodate a client
who wishes to independently select an investment manager not available in the Baird Recommended
Managers Program or BSN Program to manage the assets in the client’s Account. The Program is also
designed for a client that wants to independently select a manager and negotiate the manager’s Portfolio
Fee rate directly with the manager. Certain managers offer lower Portfolio Fee rates to clients through
the DC Program compared to the BAM, Baird Recommended Managers, or BSN Programs. A client
considering an SMA Strategy should discuss with client’s Financial Advisor SMA Strategy availability and
the different Portfolio Fee rates, costs, and the types and levels of service provided in connection with
the different Programs. If a client has decided to participate in the DC Program, upon the client’s request,
the client’s Financial Advisor may assist the client with the client’s negotiation with the manager of the
Portfolio Fee rate for the applicable SMA Strategy. The Portfolio Fee negotiated by the client could be
higher or lower than the Portfolio Fee that applies to the same SMA Strategy that is available through
other Programs. The client is ultimately responsible for understanding the differences between the SMA
Programs, deciding to participate in the DC Program, selecting the SMA Strategy, and negotiating and
agreeing to the Portfolio Fee rate.
• For the ALIGN Program, the BairdNext Portfolios Program, the Russell Program, and the UMA Programs,
Baird no longer offers clients the option to rebalance the client’s Account upon Financial Advisor review
after the Account’s allocation to an asset class drifts by 3% or more from the target allocation. Clients
must select one of the following rebalancing options: (1) annually on the Account’s anniversary date;
or (2) quarterly whenever the Account’s allocation to an asset class drifts by 3% or more from the target
allocation.
• Baird updated information about tax management and direct indexing strategies, including the
associated limitations and risks. See the Sections of the Brochure entitled “Services, Fees and
Compensation—Additional Program Information—Tax Management and Values Overlay Services” and
“Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and Risk of
Loss—Investment Strategies” for more information.
• Baird provided additional information about possible tax consequences of a client’s investment activities.
See the Section of the Brochure entitled “Services, Fees and Compensation—Additional Program
Information—Legal and Tax Considerations” for more information.
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Baird PWM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• Baird updated the rates of Portfolio Fees charged by managers under the Programs. See the Section of
the Brochure entitled “Services, Fees and Compensation—Program Fees” for more information.
• Baird updated information about Baird’s regulatory assets under management. See the Section of the
Brochure entitled “Portfolio Manager Selection and Evaluation—Selection and Evaluation—Advisory
Business” for more information.
• Baird updated its disclosures about the research, information and tools used by Baird PWM home office
investment professionals and Baird Financial Advisors when formulating investment advice, which may
include the use of artificial intelligence (“AI”) tools, and the related risks. See the Section of the Brochure
entitled “Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and
Risk of Loss—Methods of Analysis” for more information.
• Baird included a description of the PWM Stock Opportunities List. See the Section of the Brochure entitled
“Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and Risk of
Loss—Methods of Analysis—Certain Eligible Product Lists” for more information.
• Baird now offers four (4) new ALIGN UMA Select Portfolios: the Baird Research Equity ETF Portfolio;
Baird Research Capital Growth ETF (Taxable) Portfolio; Baird Research Growth with Income ETF
(Taxable) Portfolio; and Baird Research Income with Growth ETF (Taxable) Portfolio. See the Section of
the Brochure entitled “Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment
Strategies and Risk of Loss—Program Portfolio Strategies—UMA Programs—ALIGN UMA Select
Portfolios” for more information.
• Baird updated investment risk information related to information security, cybersecurity, and other
technology‑related events, issuers’ use of AI, investments in digital assets, such as cryptocurrencies,
and those associated with recent events, such as those associated with the U.S. administration’s policy
initiatives, inflation, conflicts in Iran and the Middle East, the war between Ukraine and Russia, and the
strain in relationships between the U.S. and other countries. See the Section of the Brochure entitled
“Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and Risk of
Loss—Principal Risks” for more specific information.
• In March 2026, Baird entered into an Offer of Settlement with the Massachusetts Securities Division to
settle a regulatory matter relating to the timing of state investment adviser representative registration
approvals for two of Baird’s Financial Advisors located in Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals provided investment advisory services before their
Massachusetts registrations were completed as a form was missing from their application materials. 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.
• Baird updated information about firms affiliated with, related to, or otherwise associated with Baird. See
the Section of the Brochure entitled “Additional Information—Other Financial Industry Activities and
Affiliations” and Appendix A to the Brochure for more information.
A client should note that the foregoing summary only discusses material changes made to the Brochure since
March 21, 2025. The updated Brochure contains changes that are not listed above.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Table of Contents
Services, Fees and Compensation ................................................................... 2
The Client-Baird Fiduciary Relationship ............................................................ 2
Summary of Services .................................................................................... 2
Discretionary Programs ................................................................................. 5
ALIGN Strategic Portfolios Program ........................................................... 5
BairdNext Portfolios Program .................................................................... 6
Private Investment Management Program .................................................. 7
Russell Model Strategies Program ............................................................. 8
Non-Discretionary Programs .......................................................................... 8
Baird Advisory Choice Program ................................................................. 8
SMA Programs ........................................................................................... 10
Baird Affiliated Managers Program .......................................................... 10
Baird Recommended Managers Program .................................................. 14
Baird SMA Network Program .................................................................. 17
Dual Contract Program .......................................................................... 19
Other SMA Strategy Information ............................................................. 20
UMA Programs ........................................................................................... 21
ALIGN UMA Select Portfolios Program ...................................................... 21
Unified Advisory Select Portfolios Program ............................................... 22
SMA Strategy Information ...................................................................... 26
Additional Program Information .................................................................... 26
Investment Discretion ........................................................................... 26
Trading for Client Accounts .................................................................... 29
Complex Strategies and Complex Investment Products .............................. 35
Permitted Investments .......................................................................... 38
Unsupervised Assets ............................................................................. 39
Special Considerations for the Programs .................................................. 40
Goal Management ................................................................................. 41
Tax Management and Values Overlay Services ......................................... 42
Investment Objectives ........................................................................... 45
Mutual Fund Share Class Policy ............................................................... 46
Custody Services .................................................................................. 47
Cash Sweep Program ............................................................................ 48
Trust Services Arrangements .................................................................. 49
Margin Loans ........................................................................................ 50
Securities-Based Lending Program .......................................................... 51
Other Non-Advisory Services .................................................................. 51
Client Responsibilities ............................................................................ 51
Retirement Accounts ............................................................................. 52
Legal and Tax Considerations ................................................................. 52
Program Fees ............................................................................................. 53
Fee Options and Fee Schedules............................................................... 53
Program Account Minimums ................................................................... 55
Calculation and Payment of Program Fees ................................................ 56
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Baird PWM Wrap Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Obtaining Program Services Separately: Brokerage or
Advisory? Factors to Consider ............................................................. 58
Program Fee Payments to Baird, Financial Advisors and
Investment Managers ........................................................................ 59
Other Fees and Expenses ............................................................................ 61
Cost and Expense Information for Certain Investment Products .................. 61
Additional Account Fees and Charges ...................................................... 62
Other Fees and Charges ........................................................................ 62
Compensation Received by Baird and Baird Financial Advisors ......................... 63
Account Requirements and Types of Clients .................................................. 63
Opening an Account .................................................................................... 63
Certain Account Requirements ..................................................................... 64
Minimum Account Size ........................................................................... 64
Account Contributions and Withdrawals ................................................... 64
Liens and Use of Account Assets as Collateral ........................................... 65
Electronic Delivery of Documents ............................................................ 66
Termination of Accounts .............................................................................. 66
Types of Clients.......................................................................................... 67
Portfolio Manager Selection and Evaluation .................................................. 67
Selection and Evaluation ............................................................................. 67
Baird Affiliated Managers Program .......................................................... 67
Baird Recommended Managers Program .................................................. 67
Baird SMA Network and Dual Contract Programs ....................................... 68
ALIGN, BairdNext Portfolios, PIM and Russell Programs ............................. 68
UMA Programs ...................................................................................... 69
Oversight of the Programs ..................................................................... 71
Performance Calculation .............................................................................. 71
Portfolio Management by Baird and Associated Managers ................................ 72
Advisory Business ....................................................................................... 73
Performance-Based Fees and Side-By-Side Management ................................. 74
Methods of Analysis, Investment Strategies and Risk of Loss ........................... 74
Investment Strategies ........................................................................... 74
Methods of Analysis .............................................................................. 82
Program Portfolio Strategies ................................................................... 90
Principal Risks ..................................................................................... 109
Voting Client Securities .............................................................................. 127
Baird Advisory Choice Program and Other Non-Discretionary
Accounts ......................................................................................... 127
UMA Programs ..................................................................................... 127
Separately Managed Accounts ............................................................... 128
Discretionary Programs ........................................................................ 128
Other Proxy Voting Information ............................................................. 129
Providing Baird Voting Instructions......................................................... 129
Legal Proceedings and Corporate Actions ................................................ 130
Client Information Provided to Portfolio Managers ..................................... 130
Client Contact with Portfolio Managers ....................................................... 130
Additional Information ................................................................................ 130
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Baird PWM Wrap Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Disciplinary Information ............................................................................. 130
Other Financial Industry Activities and Affiliations .......................................... 132
Baird’s Broker-Dealer Activities .............................................................. 132
Certain Relationships and Arrangements ................................................. 132
Relationships and Arrangements with Investment Managers ...................... 135
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading ................................................................................... 135
Code of Ethics ..................................................................................... 135
Participation or Interest in Client Transactions ......................................... 135
Review of Accounts .................................................................................... 142
Client Account Review .......................................................................... 142
Account Statements and Performance Reports ......................................... 142
Client Referrals and Other Compensation ..................................................... 144
Financial Information ................................................................................. 144
Special Considerations for Retirement Accounts ............................................ 144
Associated Investment Products and Services ............................. Appendix A-1
vi
Baird PWM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Private Wealth Management
those
contain
information about
at
that website
associates are deemed to have a
fiduciary
relationship with a client when providing the
investment advisory services that are described in
this Brochure. That means that Baird and its
associates are required to act in the best interest
of the client when providing investment advisory
services. From time to time, Baird or its associates
may engage in certain business practices or may
receive compensation or other benefits that create
a potential for conflict between the interests of
clients and the interests of Baird or its associates.
Baird generally addresses potential conflicts of
interest by disclosing them to clients through
documents provided to clients, including, without
limitation, this Brochure, Brochure supplements
that
individuals
providing investment advice to clients and the
services they provide, and the agreements clients
enter into with Baird. In addition, Baird has
adopted internal policies and procedures for Baird
and its associates that require them to: provide
investment advice that is suitable for advisory
clients (based upon the information provided by
such clients); make full disclosure of all potential,
material conflicts of interest; act with utmost care
and good faith in dealings with advisory clients;
and seek to obtain “best execution” of advisory
client transactions. The specific business practices
that create potential conflicts of interest with
clients and additional measures used by Baird to
address them are discussed in other sections of
this Brochure.
Services, Fees and Compensation
This Brochure describes some of the investment
advisory services that Robert W. Baird & Co.
Incorporated (“Baird”) offers to its clients through
its
(“PWM”)
department. Baird and PWM offer other investment
advisory services not described in this Brochure.
other
Separate brochures describe
investment advisory services and discuss the terms
and conditions, fees and costs and potential
conflicts of interest associated with those services.
This Brochure also references other documents
that contain additional important information about
Baird. Those documents describe the types of
investment products and services that Baird makes
available to clients, including the terms, conditions,
interest
fees, costs, risks, and conflicts of
applicable to those investment products and
services. Those documents are available on Baird’s
bairdwealth.com/retailinvestor.
website
Included on
is Baird’s Client
Relationship Booklet, which contains Baird’s Form
CRS Client Relationship Summary and Baird’s
Client Relationship Details document. The Client
Relationship Booklet also contains an important
disclosure document for retirement investors that
have retirement accounts, which include employee
pension benefit plan accounts that are subject to
the Employee Retirement Income Security Act of
1974, as amended (“ERISA”) and individual
retirement accounts (“IRAs”) that are subject to
the Internal Revenue Code of 1986, as amended
(“IRC”) (collectively, “Retirement Accounts”).
A client should note that registration as an
investment adviser does not imply a certain level
of skill or training.
A client of Baird should have already received a
copy of the Client Relationship Booklet. A client or
prospective client who wishes to obtain a brochure
for another investment advisory service provided
by Baird, or a paper copy of any of the other
documents referenced in this Brochure, including
the Client Relationship Booklet, should contact a
Baird Financial Advisor or call Baird toll-free at 1-
800-792-2473.
The information contained in this Brochure is
current as of the date above and is subject to
change at Baird’s discretion. Please retain this
Brochure for your records.
Summary of Services
This Brochure describes certain
investment
advisory programs and services that Baird PWM
offers to clients (“Programs”) and applies to each
advisory account enrolled
in a Program
(“Account”). The investment advisory services
offered under the Programs generally include
investment advice and consulting services, which
are provided by Baird PWM’s home office
investment professionals or the client’s Baird
Financial Advisor, and, depending upon the
Program that a client selects, the Program may
include portfolio management. The Programs
consist of:
• discretionary programs, whereby a client gives
Baird (including Baird PWM’s home office
The Client-Baird Fiduciary Relationship
Baird
is registered with the Securities and
Exchange Commission (“SEC”) as an investment
adviser under the Investment Advisers Act of 1940,
as amended (the “Advisers Act”). Baird and its
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contracts; one contract with Baird and another
contract with the client’s investment manager.
investment professionals or the client’s Baird
Financial Advisor) full discretionary authority to
manage the client’s Account (“Discretionary
Programs”);
investment
advice
• non-discretionary programs, whereby Baird
provides
and
recommendations but the client retains full
authority with respect to the management of the
client’s Account (“Non-Discretionary Programs”);
The UMA Programs allow a client to invest in a
combination of mutual funds, exchange traded
products (“ETPs”), primarily exchange traded
funds (“ETFs”) and exchange
traded notes
(“ETNs”), SMA Strategies, and groups of mutual
funds and ETFs (referred to as “sleeves”) and other
model portfolios of securities managed by Baird
PWM
(such sleeves and model portfolios
collectively, “PWM-Managed Portfolios”) using a
single Account.
• separately managed account (“SMA”) programs
and services, whereby an investment manager
manages the client’s Account according to a
strategy (each, an “SMA Strategy”) with full
discretionary authority, and Baird provides
additional consulting services to the client
(collectively, “SMA Programs”); and
firm,
Envestnet
The SMA and UMA Programs allow a client to select
among a variety of SMA Strategies offered by third
party investment managers (“Other Managers”),
which may include Other Managers affiliated with,
related to, or otherwise associated with Baird
(“Associated Managers”), or Baird to manage the
client’s Account.
to clients
• unified managed account (“UMA”) Programs,
whereby the client gives Baird and an overlay
management
Asset
Management, Inc. (the “Overlay Manager”),
selected by Baird authority to manage the
client’s Account according to a strategy (each, a
“UMA Strategy”) selected by the client (“UMA
Programs”).
Depending on their particular needs or objectives,
clients may use one or more of these Programs.
The Discretionary Programs
include: ALIGN
Strategic Portfolios; BairdNext Portfolios; Private
Investment Management (“PIM”); and Russell
Model Strategies. The Non-Discretionary Programs
include: Baird Advisory Choice. The SMA Programs
include: Baird Affiliated Managers (“BAM”); Baird
Recommended Managers (“BRM”); Baird SMA
Network (“BSN”); and Dual Contract (“DC”). The
UMA Programs
include: ALIGN UMA Select
Portfolios and Unified Advisory Select (“UAS”)
Portfolios.
Baird has engaged the Overlay Manager to provide
certain subadvisory services
that
participate in certain SMA Programs and the UMA
Programs. The SMA and UMA Programs make
available two types of SMA Strategies: (1)
manager-traded strategies, whereby the manager
itself manages a client’s Account and conducts the
trading to implement the SMA Strategy selected by
the client (a “Manager-Traded Strategy”); and (2)
model-traded strategies, whereby the manager
does not manage a client’s Account (a “Model
Provider”) but instead provides a model portfolio
(“Model Portfolio”) to an overlay management firm,
which may include the Overlay Manager, Baird or
other third party firm (each, an “Implementation
Manager”), that in turn manages a client’s Account
and conducts the trading to implement the SMA
Strategy selected by the client (a “Model-Traded
Strategy”). If a client selects a Model-Traded
Strategy, the Model Provider will provide the Model
Portfolio and updates to the Implementation
Manager, and the Implementation Manager will
manage the client’s Account with full discretionary
authority according to the strategy selected by the
client. Otherwise, if the client selects a Manager-
Traded Strategy, the investment manager will
directly manage the client’s Account with full
discretionary authority as more fully described
below.
Baird is also registered with the SEC as a broker-
dealer under Securities Exchange Act of 1934, as
The SMA Programs are generally offered under a
“single contract” arrangement. Under a single
contract arrangement, a client enters into an
advisory agreement with Baird, and Baird, in turn,
enters into a subadvisory or similar agreement with
the investment manager on the client’s behalf. This
type of arrangement is frequently referred to as a
single contract arrangement because there is only
one contract between the client and Baird; the
client does not have an agreement directly with the
client’s investment manager. Under the Dual
Contract Program, a client has a “dual contract”
two
arrangement, meaning
the client has
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amended (the “Exchange Act”). Baird provides the
Programs described in this Brochure under a “wrap
fee” arrangement. This means that in addition to
the investment advisory services that Baird
provides in connection with each Program, Baird,
in its capacity as broker-dealer, also provides
clients with trade execution, custody and other
standard brokerage services for a single fee
(“Program Fee”). A client should note that the
client may incur costs in addition to the Program
Fee. See “Additional Program
Information—
Trading for Client Accounts” and “Other Fees and
Expenses” below for more information.
tactical
execute
without
Each Program is designed to address different
investment needs of clients. All of the Programs
discussed in this Brochure may not be appropriate
for every client. For example, the Programs may
not be appropriate for clients who have low or no
trading activity, who desire to pay transaction-
based fees, who maintain their accounts invested
in high levels of cash or other concentrated
positions, who do not want ongoing professional
investment advice or account monitoring, who tend
to
the
transactions
recommendation or advice of an advisor, which are
commonly referred to as “unsolicited” transactions,
or who intend to utilize an investment strategy,
product or solution that is not available in a
Program.
and Risk
of
Certain Programs make available asset allocation
investment strategies. Asset allocation strategies
involve investing in one or more categories of
assets, such as equity securities, fixed income
securities, Non-Traditional Assets, Alternative
Investment Products and cash, and one or more
subcategories of assets, called asset classes. Asset
allocation strategies have varying investment
objectives and investment strategies. Some asset
allocation strategies use strategic investment
strategies, which involve investing accounts in
accordance with a predetermined target allocation
to different asset classes. Some asset allocation
strategies use tactical investing, which typically
involves tactically and actively adjusting account
allocations to different asset classes based upon
the manager’s perception of how those asset
classes will perform in the short-term. Some asset
allocation strategies involve the use of both
strategic and
investment strategies,
sometimes referred to as dynamic strategies. Asset
allocation strategies may be implemented using a
variety of investment types, such as individual
securities, mutual funds and ETPs, including ETFs
and ETNs. The amount allocated to an asset class
or investment type varies by strategy, and some
strategies may have little or no allocation to one or
more asset classes or types of investments
described above. See “Portfolio Manager Selection
and Evaluation—Methods of Analysis, Investment
Loss—Investment
Strategies
Strategies—Asset Allocation Strategies” below for
more information.
and bonds
(collectively,
funds, ETFs, unit
Some Programs offer clients the ability to pursue
alternative investment strategies (“Alternative
Strategies”) or other non-traditional or complex
investment strategies that involve special risks not
apparent in more traditional investments like
stocks
“Complex
Strategies”). Similarly, some Programs offer clients
the ability to invest in non-traditional or real assets
(“Non-Traditional Assets”). Some Programs also
offer the ability to invest in investment products
that pursue Alternative Strategies (“Alternative
Investment Products”) or other Complex Strategies
(collectively, “Complex Investment Products”). The
use of these strategies and investment products
involves special risks, and a client should not
engage in a strategy or purchase an investment
product unless the client understands the related
risks. See “Additional Program Information—
Complex Strategies and Complex Investment
Products” and “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Principal Risks” below
for more information.
The Programs make available many different
investment products and services offered by third
parties that are not associated with Baird, such as
mutual
investment trusts
(“UITs”), collective investment trusts (“CITs”),
private equity funds, hedge funds, private funds
and other investment pools (collectively “Funds”).
However, certain investment products and services
managed, advised or sponsored by Baird or other
parties affiliated with, related to, or otherwise
including Associated
associated with Baird,
Managers (“Associated Parties”), have been
selected for inclusion in certain Programs or are
made available
through Program
to clients
Accounts (“Associated Investment Products and
Services”). Associated Investment Products and
Services generally consist Funds managed, advised
or sponsored by Baird or Associated Parties
(“Associated Funds”) and other
investment
products managed, advised or sponsored by Baird
or Associated Parties (collectively, “Associated
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agreement”) if the client has not already done so.
The client’s account agreement authorizes Baird to
execute trades for, and perform related brokerage
and custody services to, the client’s Account. Baird
generally does not permit a client to include assets
in the client’s Account that are held by a third party
custodian or that are otherwise held outside of a
Baird account (“Held-Away Assets”).
Program
has
different
“Additional
Investment Products”), and SMA Strategies
managed or advised by Baird or Associated
Managers (“Associated SMA Strategies”). Baird
and Baird Financial Advisors may use, select or
recommend Associated Investment Products and
Services. This may present a conflict of interest. A
client is free at any time to select investment
products and services that are not associated with
Baird. For specific information about Associated
Parties and Associated Investment Products and
Services, see
Information—Other
Financial Industry Activities and Affiliations” below.
the
Each
structures,
administration, types and levels of service, and
fees and expenses. In particular, a client should
investment advisory services
note that
provided by Baird and its associates, including the
depth of initial and ongoing research, evaluation,
monitoring and review of the investments in a
client’s Account, varies by Program and the
investments selected for the Account.
The foregoing discussion of the Programs is only a
summary. More specific information about the
Programs and the particular investment advisory
services that Baird provides in connection with
each Program are further described below and in
the client’s advisory agreement. Clients are
encouraged to review this Brochure and their
advisory agreement carefully.
the
Discretionary Programs
ALIGN Strategic Portfolios Program
A client’s Baird Financial Advisor will offer or
recommend appropriate Programs, investment
strategies, and investment products and services
based upon a client’s investment profile and an
Account’s investment objective, which establishes
an Account’s investment return objective and risk
tolerance. A client’s
investment profile will
generally include a client’s age, other investments,
tax status,
financial situation and needs,
investment
experience,
investment
goals,
investment time horizon, liquidity needs, risk
tolerance and other relevant information provided
by a client and updated from time to time.
Although a Baird Financial Advisor may offer or
recommend appropriate options, a client will
ultimately select
investment objective,
Programs, investment strategies, and investment
products and services for an Account.
the specific
A client that wishes to participate in a Program will
enter into a client relationship agreement or other
investment advisory agreement with Baird
(“advisory agreement”). The client’s advisory
agreement will contain
terms
applicable to the services selected by the client,
fees payable by the client, and other terms
applicable to the client’s advisory relationship with
Baird. A client should note that the client’s advisory
relationship with Baird does not begin until Baird
enters into the applicable advisory agreement with
the client, which occurs when Baird PWM’s Home
Office has accepted the client’s advisory agreement
and determined that all of the client’s paperwork is
in order. See “Account Requirements and Types of
Clients” below for more information.
Under the ALIGN Strategic Portfolios Program,
Baird manages a client’s Account with
full
discretionary authority according to a proprietary
model strategic asset allocation strategy developed
by Baird (each such model an “ALIGN Strategic
Portfolio”) that is selected by the client. The ALIGN
Strategic Portfolios Program offers model asset
allocation portfolios that have different investment
objectives and use different strategic investment
strategies. Each ALIGN Strategic Portfolio provides
for specific levels of investment across different
asset classes, such as equity securities, fixed
income
Assets,
securities, Non-Traditional
Alternative Investment Products and cash. Each
Portfolio generally uses mutual funds and ETPs,
primarily ETFs, in order to implement the model
asset allocation strategy. The amount allocated to
an asset class or type of investment varies by
Portfolio, and some Portfolios may have little or no
allocation to one or more asset classes or types of
investments described above.
Baird constructs each ALIGN Strategic Portfolio and
adjusts the asset allocation of each ALIGN
As mentioned above, Baird, in its capacity as
broker-dealer, also provides Program clients with
trade execution, custody and other standard
brokerage services. For this reason, a client will
also enter into a client relationship agreement or
other account agreement with Baird (“account
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Information—Other Financial Industry Activities
and Affiliations” below.
in
BairdNext Portfolios Program
Strategic Portfolio from time to time. Baird also
determines the mutual funds and ETPs that are
available
the ALIGN Strategic Portfolios
Program, including the percentage each mutual
fund or ETP comprises in each asset class within an
ALIGN Strategic Portfolio. Baird may make changes
to an ALIGN Strategic Portfolio from time to time
as it deems appropriate and without providing prior
notice to, or obtaining the consent of, a client.
Assets,
Alternative
The ALIGN Strategic Portfolios include certain
element portfolios (“ALIGN Elements Portfolios”)
that are designed for certain specific client
investment preferences, such as clients preferring
passive investment management or tax efficiency,
and clients with smaller accounts. ALIGN Elements
Portfolios do not invest in as many mutual funds or
ETFs compared to other ALIGN Strategic Portfolios
and are therefore comparatively less diversified.
level of
initial and ongoing
Under the BairdNext Portfolios Program, Baird
manages a client’s Account with full discretionary
authority according
to a proprietary model
strategic asset allocation strategy developed by
Baird (each such model, a “BairdNext Portfolio”)
that is selected by the client. The BairdNext
Portfolios Program offers model asset allocation
portfolios that have different investment objectives
and use different strategic investment strategies.
Each BairdNext Portfolio provides for specific levels
of investment across different asset classes, such
as equity securities, fixed income securities, Non-
Investment
Traditional
Products and cash. Each Portfolio generally uses
mutual funds and ETPs, primarily ETFs, in order to
implement the model asset allocation strategy. The
amount allocated to an asset class or type of
investment varies by Portfolio, and some Portfolios
may have little or no allocation to one or more
asset classes or types of investments described
above.
For more specific information about the investment
options made available through the Program and
the
research,
evaluation, monitoring and review performed by
Baird on those investment options, if any, see
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Program Portfolio Strategies—ALIGN
Strategic Portfolios Program” below.
including
Some of the services provided under this Program
may be provided to a client by a Baird Financial
Advisor assigned to the client’s Account. Typically,
a client selects the ALIGN Strategic Portfolio
appropriate for the client’s Account with the
assistance of the client’s Baird Financial Advisor.
Baird constructs each BairdNext Portfolio and
adjusts the asset allocation of each BairdNext
Portfolio from time to time. Baird also determines
the mutual funds and ETPs that are available in the
the
BairdNext Portfolios Program,
percentage each mutual fund or ETP comprises in
each asset class within a BairdNext Portfolio. Baird
may make changes to a BairdNext Portfolio from
time to time as it deems appropriate and without
providing prior notice to, or obtaining the consent
of, a client.
in
Programs”
and
“Additional
The BairdNext Portfolios Program is designed for
clients with smaller accounts and as such does not
invest in as many mutual funds or ETFs compared
to other Programs. Clients that are able to satisfy
applicable account minimums for other Programs
are encouraged to discuss with their Financial
Advisor whether another Program may be a more
appropriate choice for them.
Baird may replace investments in a client’s
Account, rebalance a client’s Account assets to be
consistent with the client’s chosen ALIGN Strategic
Portfolio strategy, change the client’s asset
allocation, or engage
tax management
strategies in certain circumstances. See “Additional
Program Information—Special Considerations for
Program
the
Information—Tax Management” below for more
information.
level of
initial and ongoing
Information about Affiliated
Important
Funds. Some of the mutual funds offered by Baird
Funds, which is affiliated with Baird, have been
selected by Baird for inclusion in certain ALIGN
Strategic Portfolios. This presents a conflict of
interest. For more information, see “Additional
For more specific information about the investment
options made available through the Program and
the
research,
evaluation, monitoring and review performed by
Baird on those investment options, if any, see
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
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Risk of Loss—Program Portfolio Strategies—
BairdNext Portfolios Program” below.
or more customized approach to management of
client accounts. A client makes the final decision as
to which investment strategy is chosen for the
client’s Account. More specific information as to
how the client’s PIM Manager will manage the
client’s Account is provided to the client in
connection with the opening of the Account.
Some of the services provided under this Program
may be provided to a client by a Baird Financial
Advisor assigned to the client’s Account. Typically,
a client selects the BairdNext Portfolio appropriate
for the client’s Account with the assistance of the
client’s Baird Financial Advisor.
in
Programs”
and
“Additional
Baird may replace investments in a client’s
Account, rebalance a client’s Account assets to be
consistent with the client’s chosen BairdNext
Portfolio strategy, change the client’s asset
allocation, or engage
tax management
strategies in certain circumstances. See “Additional
Program Information—Special Considerations for
the
Program
Information—Tax Management” below for more
information.
the
heading
“Additional
A PIM Manager may make investments in various
types of securities, including, but not limited to,
equity securities, fixed income securities, Non-
Traditional Assets, certain Alternative Investment
Products and mutual funds and ETPs that in turn
invest in those investments. All or a portion of the
assets in a client’s Account may be held in cash or
cash equivalents, including securities issued by
money market mutual funds, or may be deposited
interest-bearing bank accounts. Additional
in
information about the types of investments a PIM
Manager may use for client accounts is contained
under
Program
Information—Permitted Investments” below. For
more information about the PIM Program, see
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Program Portfolio Strategies—Private
Investment Management Program” below.
Information about Affiliated
Important
Funds. Some of the mutual funds offered by Baird
Funds, which is affiliated with Baird, have been
selected by Baird for inclusion in certain BairdNext
Portfolios. This presents a conflict of interest. For
more information, see “Additional Information—
Other Financial Industry Activities and Affiliations”
below.
Private Investment Management Program
Baird may remove any PIM Manager or strategy
from the PIM Program at any time and transfer
day-to-day management responsibility of a client’s
Account to another PIM Manager or Baird Financial
Advisor at any time without providing prior notice
to, or obtaining the consent of, a client.
Under the PIM Program, a client grants full
discretionary authority and management of the
client’s Account to Baird and the client’s Baird
Financial Advisor who has been approved by Baird
to manage client accounts in the PIM Program (a
“PIM Manager”).
concentrated and
Program
Important Information about PIM Accounts.
PIM Managers may engage in strategies that
involve:
less diversified
portfolios of securities; leverage; and frequent
trading for client accounts. In addition, PIM
Managers may invest client accounts in illiquid
securities, community bank stocks and Complex
Investment Products. These types of strategies and
investments involve special, sometimes significant,
risks and are not appropriate for all clients. A client
should understand those risks before engaging in
those strategies or investing in those products. See
“Additional
Information—Complex
Strategies and Complex Investment Products” and
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks” below for more
information.
In the PIM Program, a client’s PIM Manager seeks
to meet the client’s particular investment needs by
identifying or developing an investment strategy
based upon guidelines that are jointly established
by the client and the client’s PIM Manager. At the
commencement of services, the client’s PIM
Manager reviews the client’s investment objectives
and risk tolerance. Based upon that review and
other information provided by the client, the PIM
Manager makes a subsequent recommendation to
the client as to which investment strategy the PIM
Manager believes is best suited for the client. Some
PIM Managers use model portfolios, which may
include proprietary model asset allocation portfolio
strategies developed by Baird, or other investment
strategies. Some PIM Managers take a “counseled”
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level of
initial and ongoing
Associated Investment Products are available to
clients under the PIM Program. This presents a
conflict of interest. For more information, see
“Additional Information—Other Financial Industry
Activities and Affiliations” below.
the
research,
evaluation, monitoring and review performed by
Baird on those investment options, if any, see
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Program Portfolio Strategies—Russell
Model Strategies Program” below.
Russell Model Strategies Program
Some of the services provided under this Program
may be provided to a client by a Baird Financial
Advisor assigned to the client’s Account. Typically,
a client selects the Russell Strategy appropriate for
the client’s Account with the assistance of the
client’s Baird Financial Advisor.
See
Baird may rebalance a client’s Account assets to be
consistent with the client’s chosen asset allocation
strategy, change the client’s asset allocation, or
engage in tax management strategies in certain
Program
circumstances.
“Additional
Information—Special Considerations
the
for
Programs” and “Additional Program Information—
Tax Management” below for more information.
Non-Discretionary Programs
Baird Advisory Choice Program
The Baird Advisory Choice Program is a Non-
Discretionary Program whereby Baird provides
advice to a client in connection with the client’s
own management of the client’s Account.
Under the Russell Model Strategies Program (the
“Russell Program”), Baird manages a client’s
Account with full discretionary authority according
to a model asset allocation strategy (a “Russell
Strategy”) developed by Russell Investment
Management, LLC (“Russell”) that is selected by a
client. The Russell Program offers model asset
allocation portfolios that have different investment
objectives and use different strategic and tactical
investment strategies. Each Russell Strategy
provides for specific levels of investment across
different asset classes, such as equity securities,
fixed income securities, Non-Traditional Assets,
Alternative Investment Products and cash. Each
Strategy generally uses mutual funds and ETFs in
order to implement the model asset allocation
strategy. The amount allocated to an asset class or
type of investment varies by Strategy, and some
Strategies may have little or no allocation to one
or more asset classes or types of investments
described above. Each Russell Strategy will
typically invest exclusively or significantly in
mutual
funds or ETFs offered by Russell
Investment Company (the “Russell Funds”),
although some non-Russell Funds may be used.
Some of the services provided under this Program
may be provided to a client by a Baird Financial
Advisor assigned to the client’s Account.
Russell constructs each Russell Strategy and
adjusts the asset allocation of each Strategy from
time to time. Russell also determines the mutual
funds and ETFs, including the Russell Funds, that
are available in each Russell Strategy, including the
percentage each mutual fund and ETF comprises in
each Strategy. From time to time, Russell may
remove mutual funds and ETFs and replace them
with other mutual funds and ETFs.
Some Baird Financial Advisors may recommend
that a client implement a model portfolio in the
client’s Advisory Choice Account. A client
implementing a model portfolio in the client’s
Advisory Choice Account may have the option to
have Baird and the client’s Financial Advisor
rebalance the client’s Advisory Choice Account to
the target asset allocations specified by the model
portfolio at predetermined intervals. Currently,
Baird offers the following rebalance options to
applicable Advisory Choice Accounts: annual,
semi-annual and quarterly.
Baird anticipates that it generally will implement a
Russell Strategy as proposed by Russell. However,
Baird has sole discretionary authority over a
client’s Account invested in a Russell Strategy, and
Baird may implement a Russell Strategy differently
than proposed by Russell or may sell the client’s
investments if Baird determines such action to be
necessary and in the client’s best interest.
For more specific information about the investment
options made available through the Program and
Baird does not have discretionary authority over
the assets in a client’s Baird Advisory Choice
Account, and Baird and the client’s Baird Financial
Advisor cannot purchase or sell any securities or
other investments in the client’s Baird Advisory
Choice Account, including purchases and sales to
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Baird PWM Wrap Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the Account, without
Baird
Advisory
Choice
information about the Baird Advisory Choice
Program, see “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Program Portfolio
Strategies—Baird Advisory Choice Program” below.
rebalance
the client’s
authorization. Ultimately, the client makes the final
decision as to selection of investments for the
Account.
client’s
Furthermore, if a client selects a model portfolio for
the client’s Baird Advisory Choice Account, a client
should understand that the client is ultimately
responsible for: the selection of the model
portfolio, the model portfolio’s implementation,
and the selection of a rebalance option, if any.
A client should ask the client’s Baird Financial
Advisor questions about the investment styles,
philosophies, strategies, analyses and techniques
the client’s Baird Financial Advisor will use in order
to meet the client’s objectives.
is
appropriate.
In making
current
assets,
A client should understand that Baird only provides
a client with certain consulting services and, for
eligible Accounts, Account rebalancing services
under the Baird Advisory Choice Program. The
consulting services that may be available in the
Program from the client’s Financial Advisor include
research, analysis, advice and recommendations
regarding: financial and investment goals and
needs; asset allocation strategies, investment
strategies and investment restrictions; methods
for implementing investment strategies; trends
and expectations regarding securities and other
investments, securities markets, and economic
sectors and industries; and the purchase, holding
and sale of securities and other investments. The
specific consulting services to be provided to a
client will be determined by mutual agreement
between the client and the client’s Financial
Advisor. Baird does not undertake to provide any
other consulting or investment advisory services
under this Program unless Baird agrees to do so in
writing.
in various
Baird or the client’s Financial Advisor will provide
for the client’s
investment recommendations
Account and may recommend the amount, type
and timing with respect to buying, holding,
exchanging, converting and selling securities and
other assets for the client’s Account. Baird or the
recommend
client’s Financial Advisor may
investments
types of securities,
including, but not limited to, equity securities, fixed
income securities, Non-Traditional Assets, certain
Alternative Investment Products and mutual funds
and ETPs that in turn invest in those investments.
All or a portion of the assets in a client’s Account
may be held in cash or cash equivalents, including
securities issued by money market mutual funds,
or may be deposited in interest-bearing bank
accounts. Additional information about the types of
investments Baird or a Financial Advisor may
recommend for client accounts is contained under
the heading “Additional Program Information—
For more
Investments” below.
Permitted
Important Information about Baird Advisory
Choice Accounts. A Baird Advisory Choice
Account provides a fee-based alternative to a
traditional, commission-based brokerage account.
Unlike a traditional brokerage account where a
client is paying for traditional brokerage services,
an Advisory Choice client is also paying for
investment advice and other investment advisory
services above and beyond those available in a
traditional brokerage account. Each client should
determine whether a Baird Advisory Choice
Account
this
determination, a client should carefully consider all
relevant factors, including the client’s investment
objectives, risk tolerance, past and anticipated
trading practices,
current
investments, the value and type of Permitted
Investments to be held in the Account, anticipated
use of other Baird products and services, and the
costs and benefits of the Account. The costs of a
Baird Advisory Choice Account may be more or less
than in an account where the client is charged on
a per-transaction basis. A Baird Advisory Choice
Account may not be appropriate for a client who
anticipates little or no trading activity, a client who
prefers to direct the client’s own investment
strategies and security selection independent of
the advice of Baird or their Financial Advisor or a
client who does not receive or request investment
advisory or other non-trading services from Baird.
A Baird Advisory Choice Account is also not for day
trading or other extreme trading activity, including
excessive options trading or trading in mutual
funds based on market timing. If a client’s Baird
Advisory Choice Account engages in “excessive
trading activity” (herein defined as activity that
would be considered “excessive” by industry
professionals in a non-discretionary, fee-based
program, as determined by Baird in its sole
discretion), Baird may, to the extent permitted by
applicable law, immediately, upon sending notice
to the client, restrict the activity occurring in the
client’s Account, terminate the Account, convert
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Associated Investment Products are available to
clients under the Advisory Choice Program. This
presents a conflict of
interest. For more
information, see “Additional Information—Other
Financial Industry Activities and Affiliations” below.
SMA Programs
Baird Affiliated Managers Program
the Account to a commission-based account, or
charge a higher fee at such rate as Baird, in its sole
discretion, may elect. A client is responsible for
monitoring the client’s Account and determining
the desirability of maintaining the Account as
opposed to maintaining a traditional, commission-
based brokerage account. In addition to Baird
Advisory Choice Accounts and
traditional,
commission-based brokerage accounts, Baird
offers various other advisory programs in which it
has
investment discretion. A client should
periodically reevaluate whether the ongoing use of
this Non-Discretionary Advisory Program is desired
and request a Baird Financial Advisor to explain the
benefits and disadvantages of maintaining a Baird
Advisory Choice Account and the availability of
alternative arrangements.
The BAM Program is a program whereby a client
independently selects Baird or an investment
manager affiliated with Baird to manage the
client’s Account with full discretionary authority
according to a strategy selected by the client. The
BAM Program is designed to accommodate a client
who wishes to select Baird or an investment
manager affiliated with Baird to manage the assets
in the client’s Account instead of an unaffiliated
manager made available in other SMA Programs.
available
on
Baird’s
website
Additional information regarding the differences
between brokerage and advisory relationships can
be found in the “Understanding Brokerage and
Investment Advisory Relationships” document that
is
at
bairdwealth.com/retailinvestor.
it
into a
Under the BAM Program, Baird determines the
investment managers (“BAM Managers”) and their
strategies (“BAM Strategies”) eligible to participate
in the Program. The BAM Strategies and BAM
Managers are not subject to the same evaluation
process or eligibility standards imposed upon on
other SMA Strategies and SMA Managers offered
through other SMA Programs.
A client may terminate a Baird Advisory Choice
traditional,
Account and convert
commission-based brokerage account at any time
by contacting the client’s Baird Financial Advisor.
Baird also has the right, at any time upon notice to
a client, to terminate a client’s Baird Advisory
Choice Account and convert it into commission-
based brokerage account.
and
For more specific information about eligibility
standards imposed upon the managers and SMA
Strategies made available through the BAM
Program, see “Portfolio Manager Selection and
Evaluation—Selection
Evaluation—Baird
Affiliated Managers Program” below.
A client should only participate in the BAM Program
if the client wishes to select Baird or a manager
affiliated with Baird to manage the client’s Account
and the client understands the potential conflicts of
interest presented by the arrangement and the
risks of doing so.
have
varying
Program
BAM Managers
investment
objectives, styles and strategies, and they may
invest a client’s Account in various types of
securities, which will be chosen by the BAM
Manager and which may include mutual funds,
ETFs or other investment products associated with
the manager or Baird.
A client should note that the client’s Baird Advisory
Choice Account may be engaged in strategies that
involve concentrated and less diversified portfolios
of securities, leverage or margin, options, and
frequent trading. In addition, the client’s Baird
Advisory Choice Account may be invested in illiquid
securities and Complex Investment Products.
These types of strategies and investments involve
special, sometimes significant, risks and are not
appropriate
for all clients. A client should
understand those risks before engaging in those
strategies or investing in those products. See
“Additional
Information—Complex
Strategies and Complex Investment Products” and
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks” below for more
information.
The PWM-Managed Portfolios and BAM Strategies
that are offered through the BAM Program are
discussed below.
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Robert W. Baird & Co. Incorporated
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
PWM-Managed Portfolios
of the asset classes described above. The custom
model asset allocation strategy is determined by
the client with the assistance of Baird Equity Asset
Management.
receipts
Under the BAM Program, Baird makes available to
clients the following PWM-Managed Portfolios
managed by Baird PWM’s Research team: the Baird
Recommended Portfolio, the Baird Rising Dividend
Portfolio, and the AQA Portfolios, which are
described under the heading “Portfolio Manager
Selection and Evaluation—Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis—Certain PWM-Managed Portfolios”
below.
BAM SMA Strategies
Baird Equity Asset Management
The CCM Portfolios invest in equity securities of
companies located in different regions around the
world, primarily in developed markets but also in
emerging and less developed markets. Each
Portfolio generally uses common or ordinary
shares, depositary
representing an
ownership interest in ordinary shares, preferred
stocks, in order to implement the strategy. The
CCM Portfolios generally invest in a limited number
of securities, but seek to be diversified in terms of
currencies, regions and economic sectors.
Management
Growth
include mutual
Baird Equity Asset Management may invest a
client’s Baird Equity Asset Management Strategies
Account in various types of securities, which will be
chosen by Baird Equity Asset Management and
funds or other
which may
investment products associated with Baird.
Baird Trust
Under the BAM Program, Baird makes available to
clients certain SMA Strategies offered by Baird
investment
Equity Asset Management, an
management department of Baird, including:
growth investment strategies (the “Baird Equity
Asset
Strategies”);
Specialized Asset Management (“SAM”) portfolio
strategies (the “SAM Strategies”), consisting of
SAM Strategic Portfolio strategies and SAM Custom
Portfolio strategies; and certain International
Growth and Global Growth SMA Strategies offered
by Chautauqua Capital Management (“CCM”), a
part of Baird Equity Asset Management (the “CCM
Portfolios”).
Under the BAM Program, Baird makes available to
clients five (5) portfolio strategies developed and
maintained by Baird Trust Company (“Baird
Trust”), a trust company that is affiliated with Baird
(the “Baird Trust Strategies”) described under the
“Portfolio Manager Selection and
heading
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Methods of Analysis—
Baird Trust Strategies” below. The Baird Trust
Strategies invest in a mix of equity securities and
ETFs.
Baird Equity Asset Management also manages
client portfolios according to other strategies
selected by clients (“Other Baird Equity Asset
Management Strategies”, and with the Baird Equity
Asset Management Growth Strategies and the SAM
Strategies, the “Baird Equity Asset Management
Strategies”).
The SAM Strategic Strategies are model asset
allocation portfolios that have different investment
objectives. Each SAM Strategy provides for specific
levels of investment across different asset classes,
such as equity securities, fixed income securities,
Non-Traditional Assets, Alternative Investment
Products and cash. Each Strategy generally uses
individual securities, mutual funds and ETFs in
order to implement the model asset allocation
strategy. The amount allocated to an asset class or
type of investment varies by Strategy, and some
Strategies may have little or no allocation to one
or more asset classes or types of investments
described above.
In addition, Baird makes available to clients Baird
Trust Custom Portfolio Management℠, which
offers clients a customized approach to investing
and the ability to work directly with an in-house
Baird Trust Portfolio Manager. A client’s Baird Trust
Portfolio Manager and Financial Advisor will work
closely with a client to develop a diversified,
customized investment portfolio, managed to fit a
client’s specific needs. The Baird Trust Portfolio
Manager will determine the investments for a
client’s Account based on a comprehensive
assessment process that includes the client’s
investment objective, time horizon,
financial
situation, and special circumstances. Once the
assessment
is complete, a client’s portfolio
construction begins. Baird Trust Custom Portfolio
Management accounts typically invest in a mix of
A SAM Custom Portfolio provides a client with a
customized level of investment across one or more
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Riverfront
equity securities, fixed income securities, mutual
funds and ETFs, depending upon the needs of a
particular client.
GAMMA
(“GAMMA”), an
for specific
Under the BAM Program, Baird makes available to
clients certain SMA Strategies offered by Riverfront
(“Riverfront”), an
LLC
Investment Group,
investment manager that is affiliated with Baird
(the
“Riverfront Portfolios”). The Riverfront
Portfolio strategies are model asset allocation
portfolios that have different investment objectives
and use different strategic and tactical investment
strategies. Each Riverfront Portfolio provides for
specific levels of investment across different asset
classes, such as equity securities, fixed income
securities, Non-Traditional Assets, Alternative
Investment Products and cash. Each Portfolio
generally uses mutual funds and ETPs, primarily
ETFs and ETNs, in order to implement the model
asset allocation strategy. The amount allocated to
an asset class or type of investment varies by
Portfolio, and some Portfolios may have little or no
allocation to one or more asset classes or types of
investments described above.
Under the BAM Program, Baird makes available to
clients certain SMA Strategies offered by GAMMA
investment
Investing, LLC
manager that is affiliated with Baird (the “GAMMA
Portfolios”). GAMMA offers Custom Indexing
strategies providing
levels of
investment across different asset classes, such as
equity securities, fixed income securities, and cash.
Each Portfolio generally uses stocks and ETFs, in
order to implement the target strategy. When
deemed appropriate, GAMMA’s management may
also involve the use of Alternative Investment
Products. The amount allocated to an asset class
or type of investment varies by Portfolio, and some
Portfolios may have little or no allocation to one or
more asset classes or types of investments
described above.
The Riverfront Portfolio strategies that Riverfront
offers under the Baird Affiliated Managers Program
include Riverfront Asset Allocation Portfolios (also
known as “Advantage Portfolios”); Riverfront ETF
Portfolios (also known as “ETF Advantage
Portfolios”); Riverfront Income ETF Portfolios (also
known as “Income ETF Advantage Portfolios”);
RiverShares Model Portfolios; and Riverfront
Custom Portfolios.
benchmarks. Custom
Strategas
include
thematic
strategies
The GAMMA Custom Indexing strategies that
GAMMA offers under the Baird Affiliated Managers
Program include managed portfolios of individual
securities that seek to deliver similar return and
risk characteristics as an index strategy (“target
strategy”) selected by the client. Custom Indexing
strategies can be benchmarked to any standard or
customized index, or combination of standard or
customized
Indexing
strategies typically invest directly in a subset of the
securities which make up the target strategy. The
investment objective of each Custom Indexing
strategy is to provide exposure to a client selected
market segment or combination of market
segments into an overall asset allocation while
seeking to improve after-tax returns through tax
loss harvesting techniques.
(the
Reinhart
securities using
Under the BAM Program, Baird makes available to
clients certain SMA Strategies offered by Strategas
Asset Management, LLC
(“Strategas”), an
investment manager that is affiliated with Baird
“Strategas Portfolios”). The Strategas
(the
Portfolios
(the
“Strategas Thematic Portfolios”), asset allocation
strategies
“Strategas Asset Allocation
Portfolios”) and fixed income strategies (the
“Strategas Fixed
Income Portfolios”). The
Strategas Thematic Strategies invest principally in
equity
certain proprietary
investment themes, ideas or trends. The Strategas
Asset Allocation Portfolios primarily invest in ETFs
that focus investment in equity and fixed income
securities in a manner that aligns with client goals
and risk preferences over a medium-term time
horizon. Each Portfolio combines Strategas’s
strategic asset allocation outlook with tactical tilts
towards those sectors and investments that it
believes are most favorable for investment. The
Under the BAM Program, Baird makes available to
clients certain SMA Strategies offered by Reinhart
Partners, LLC (“Reinhart”), an investment manager
that
is affiliated with Baird (the “Reinhart
Portfolios”). The Reinhart Portfolio strategies
include: (1) a Genisis Private Market Value strategy
that focuses investment on small- and small/mid-
cap value companies; (2) Mid Cap Private Market
Value strategy that focuses investment on mid-cap
value companies; and (3) a Focused Private Market
Value strategy that concentrates investment in a
limited number mid-cap value companies.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
adviser, and the client also authorizes and directs
such BAM Manager to manage the client’s Account
with full discretionary authority in accordance with
the BAM Strategy selected by the client.
Strategas Fixed Income Strategies are actively
managed, multisector, enhanced total return bond
strategies that seek to maximize return, while
seeking to minimize total return volatility. The
Strategas Fixed Income Strategies primarily invest
in sector-focused ETFs.
Additional Information about the BAM
Program
is
fully and
Clients are urged to review the BAM Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the BAM
Manager, including information about the BAM
Manager’s strategies, the types of investments the
BAM Manager may use for a client’s Account, and
the risks associated with investing in a BAM
Strategy. Such brochures are available upon
request.
If a client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the Overlay Manager will typically
implement the Model Portfolio as proposed by the
Model Provider. However, since the Overlay
Manager has discretionary authority over the
client’s Account, the Overlay Manager may
implement the Model Portfolio differently than
proposed by the Model Provider if the Overlay
Manager determines such action to be necessary
and in the client’s best interest. A client should note
that Baird does not monitor or ascertain whether
faithfully
the Overlay Manager
implementing the Model Portfolio on a continuous
basis. The client should periodically discuss the
Account’s performance with the client’s Financial
Advisor.
Some of the services provided under the BAM
Program may be provided to a client by a Baird
Financial Advisor assigned to the client’s Account,
and the client’s Financial Advisor may provide his
or her own advice and recommendations about
BAM Managers.
If a client participates in the BAM Program, the
client authorizes and directs Baird to appoint the
BAM Manager selected by the client to serve as
sub-adviser to the client’s Account. The client also
authorizes and directs the BAM Manager to manage
client’s Account with full discretionary authority in
accordance with the BAM Strategy selected by the
client.
Certain managers of Model-Traded Strategies
offered through the Overlay Manager have adopted
trade rotation policies that allow them to send
Model Portfolio updates to the Overlay Manager
after they have implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. As a result, the performance of a
Baird client Account pursuing a Model Portfolio
strategy offered by those Model Providers will
differ, perhaps in a materially negative manner,
from the performance of client accounts managed
by those Model Providers. See “Additional Program
Information—Trading for Client Accounts—Trading
Practices of Investment Managers” below for more
information.
does
not
provide
the client’s Account with
Certain BAM Strategies are only made available
through the Overlay Manager. The BAM Strategies
offered through the Overlay Manager consist of
Manager-Traded Strategies and Model-Traded
Strategies. If a client selects a BAM Strategy
offered through the Overlay Manager for the
client’s Account, the client authorizes and directs
Baird to appoint the Overlay Manager to serve as
sub-adviser to the client’s Account. If a client
selects a Model-Traded Strategy offered through
the Overlay Manager for the client’s Account, the
client authorizes and directs the Overlay Manager
to manage
full
discretionary authority in accordance with the BAM
Strategy selected by the client. If a client selects a
Manager-Traded Strategy offered through the
Overlay Manager for the client’s Account, the client
authorizes and directs the Overlay Manager to
appoint the applicable BAM Manager as sub-
If a client’s Account is managed by an Other
Manager under the BAM Program, the client should
understand that: Baird does not manage the
Account and does not otherwise have any influence
over the Other Manager’s investment decisions or
securities selections, and therefore, Baird is not
responsible for the decisions made by the Other
Manager; Baird
any
recommendation or investment advice regarding
the purchase or sale of investment products made
for the client’s Account; and Baird and the client’s
Financial Advisor only provide the client with
certain consulting services, which may include the
client’s Financial Advisor’s assistance with
needs,
client’s
determining
the
financial
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment goals and investment restrictions and
periodically reviewing the manager’s performance.
Baird does not undertake to provide any other
consulting or investment advisory services under
the BAM Program unless Baird agrees to do so in
writing.
Managed Portfolios are Managed by Baird PWM.
Baird Equity Asset Management and CCM are part
of Baird. Baird Trust, GAMMA, Reinhart, Riverfront
and Strategas are affiliated with Baird. This
presents a conflict of
interest. For more
information, see “Additional Information—Other
Financial Industry Activities and Affiliations” below.
A client that participates in the BAM Program is
strongly encouraged to contact the client’s Baird
Financial Advisor or BAM Manager on a periodic
basis to discuss: the Account and its investment
performance; the BAM Manager’s investment
philosophy and style (to determine if the BAM
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information regarding the BAM Manager, described
on the manager’s Form ADV, which is available on
the SEC's website at www.adviser info.sec.gov.
A client’s appointment and continued retention of
a BAM Manager to manage the client’s Account are
based upon the client’s review of the BAM Manager
and its services. In selecting the BAM Strategy, the
client ultimately determines that the strategy to be
used in managing the client’s Account is consistent
with the client’s stated investment objectives and
financial needs and risk tolerance. Once retained
by the client, a BAM Manager will only be removed
from managing the client’s Account upon the BAM
Manager’s removal from the Program by Baird, the
BAM Manager’s withdrawal or the client’s direction
to do so.
Baird Recommended Managers Program
The Baird Recommended Managers Program is a
program whereby a client provides Baird and the
client’s Financial Advisor with discretionary
authority to appoint investment managers to
manage the client’s Account with full discretionary
authority and to terminate or replace investment
managers for the client’s Account. The Baird
Recommended Managers Program is designed for
a client who wishes to have the client’s Account
managed by
investment managers that are
monitored by Baird on an ongoing basis.
the
Under the Baird Recommended Managers Program,
Baird determines
investment managers
(“Recommended Managers”) and their strategies
(“BRM Strategies”) eligible to participate in the
Program through an initial and ongoing evaluation
process.
and
Evaluation—Baird
The BAM Strategies and BAM Managers made
available under the BAM Program are subject to
change or removal at any time in Baird’s sole
discretion. A client’s appointment and continued
retention of a BAM Manager to manage the client’s
Account are based upon the client’s review of the
BAM Manager and its services. In selecting the BAM
Strategy, the client ultimately determines that the
strategy to be used in managing the client’s
Account is consistent with the client’s stated
investment objectives and financial needs and risk
tolerance. Once retained by the client, a BAM
Manager will only be removed from managing the
client’s Account upon the BAM Manager’s removal
from the Program by Baird, the BAM Manager’s
withdrawal or the client’s direction to do so. Under
the terms of the BAM Program, Baird cannot
appoint a replacement manager without client
consent. Given the terms of the BAM Program,
upon the withdrawal or removal of an investment
manager from the BAM Program, a client’s BAM
Program Account will be automatically removed
from the BAM Program and the Account will
become an unmanaged brokerage account, unless
the client provides contrary instructions to Baird.
See “Portfolio Manager Selection and Evaluation—
Affiliated
Selection
Managers Program” below for further information.
Recommended
For more specific information about the managers
and SMA Strategies made available through the
Baird Recommended Managers Program and the
level of initial and ongoing research, evaluation,
monitoring and review performed by Baird on
those managers and SMA Strategies, see “Portfolio
Manager Selection and Evaluation—Selection and
Evaluation—Baird
Managers
Program” below.
Recommended Managers have varying investment
objectives, styles and strategies, and they may
Important
Information about Affiliated
Managers All of the BAM Strategies made
available under the BAM Program are offered by
Baird or a manager affiliated with Baird. PWM-
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
invest a client’s Account in various types of
securities, which will be chosen by
the
Recommended Manager and which may include
mutual funds, ETFs or other investment products
associated with the manager or Baird.
also
authorizes
and
directs
the
investments
full discretionary authority
Account. If a Model-Traded Strategy offered
through an Implementation Manager is selected for
a client’s Account, the client authorizes and directs
the Implementation Manager to manage the
client’s Account with full discretionary authority in
accordance with the selected BRM Strategy. If a
Manager-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to appoint the applicable
Recommended Manager as sub-adviser, and the
client
such
Recommended Manager to manage the client’s
Account with
in
accordance with the selected BRM Strategy.
Clients are urged to review the Recommended
Manager’s Form ADV Part 2A Brochure, which
should contain additional important information
about the Recommended Manager,
including
information about the Recommended Manager’s
strategies,
the
types of
Recommended Manager may use for a client’s
Account, and the risks associated with investing in
a BRM Strategy. Such brochures are available upon
request.
Provider.
However,
has
the
client’s Account,
Some of the services provided under the Baird
Recommended Managers Program will be provided
to a client by a Baird Financial Advisor assigned to
the client’s Account. A client, typically working with
a Baird Financial Advisor, initially selects the
Recommended Manager and BRM Strategy for the
client’s Account. Thereafter, whenever Baird or the
client’s Financial Advisor deems it necessary, Baird
or the client’s Financial Advisor will replace a
Recommended Manager or BRM Strategy with
another Recommended Manager or BRM Strategy
for the client’s Account based upon the list of
Recommended Managers and BRM Strategies that
Baird makes available for the Baird Recommended
Managers Program.
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the Implementation Manager will typically
implement the Model Portfolio as proposed by the
since
Model
the
discretionary
Implementation Manager
authority over
the
Implementation Manager may implement the
Model Portfolio differently than proposed by the
Model Provider if the Implementation Manager
determines such action to be necessary and in the
client’s best interest. A client should note that Baird
does not monitor or ascertain whether a third party
Implementation Manager is fully and faithfully
implementing the Model Portfolio on a continuous
basis. The client should periodically discuss the
Account’s performance with the client’s Financial
Advisor.
the
terms of
If a client participates in the Baird Recommended
Managers Program, the client authorizes and
directs Baird to appoint Recommended Managers
to serve as sub-adviser to the client’s Account and
to otherwise manage the client’s Account in
accordance with
the Baird
Recommended Managers Program. The client also
authorizes and directs
the Recommended
Managers to manage the client’s Account with full
discretionary authority in accordance with the BRM
Strategy selected.
offered
through
Certain managers of Model-Traded Strategies
offered through the Overlay Manager have adopted
trade rotation policies that allow them to send
Model Portfolio updates to the Overlay Manager
after they have implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. As a result, the performance of a
Baird client Account pursuing a Model Portfolio
strategy offered by those Model Providers will
differ, perhaps in a materially negative manner,
from the performance of other client accounts
those Model Providers. See
managed by
for
Information—Trading
“Additional Program
Client Accounts—Trading Practices of Investment
Managers” below for more information.
Certain BRM Strategies are only made available
through Implementation Managers. The BRM
Strategies
Implementation
Managers consist of Manager-Traded Strategies
and Model-Traded Strategies. If a BRM Strategy
offered through an Implementation Manager is
selected for a client’s Account, the client authorizes
and directs Baird to appoint the Implementation
Manager to serve as sub-adviser to the client’s
If a client’s Account is managed by an Other
Manager under the Baird Recommended Managers
Program, the client should understand that,
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Robert W. Baird & Co. Incorporated
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the discretionary
ALIGN 55ip Tax Managed Solutions
recommendation or
notwithstanding
authority
granted to Baird and the client’s Financial Advisor
under the Program: Baird and the client’s Financial
Advisor do not manage the Account and do not
otherwise have any influence over the Other
Manager’s
investment decisions or securities
selections, and therefore, Baird and the client’s
Financial Advisor are not responsible for the
decisions made by the Other Manager; and Baird
and the client’s Financial Advisor do not provide
any
investment advice
regarding the purchase or sale of investment
products made for the client’s Account.
The Baird Recommended Managers Program
makes available ALIGN 55ip Tax Managed
Solutions that are designed for a client that: (1)
desires to have the strategy for the client’s Account
transitioned to an ALIGN Strategic Portfolio
strategy selected by the client (the “Target ALIGN
Strategy”) using tax management strategies that
are intended to reduce the negative impact of U.S.
federal income taxes on an Account resulting from
the transition; (2) seeks investment in an ALIGN
Strategic Portfolio strategy together with enhanced
tax management strategies on an ongoing basis;
or (3) a combination of both services. Baird has
engaged 55I, LLC (d/b/a 55ip, “55ip”) to provide
tax management services on a subadvisory basis
to clients that select ALIGN 55ip Tax Managed
Solutions.
the prior manager and
could
in adverse
From time to time, Baird may remove investment
managers from the Baird Recommended Managers
Program, and Baird may select a replacement
manager to manage the client’s Account. In such
event, Baird, at the direction of the client’s
replacement manager, or the client’s replacement
manager may sell all or a portion of the securities
or other investments in the Account that were
managed by
the
replacement manager will reinvest the cash
proceeds of those sales. Sales of securities or other
investments
tax
result
consequences for the client.
to
invest, with
If a client selects an ALIGN 55ip Tax Managed
Solution for the client’s Account, the client
authorizes and directs Baird to appoint 55ip to
serve as sub-adviser to the client’s Account. The
client also authorizes and directs 55ip to manage
the client’s Account with
full discretionary
authority: (1) to transition the Account holdings to
reflect the target portfolio holdings of the Target
ALIGN Strategy selected by the client using its tax
management strategies; and (2) in accordance
with the selected ALIGN Strategic Portfolio strategy
together with its tax management strategies on an
ongoing basis, as applicable.
Additional information about the ALIGN Strategic
Portfolio strategies is contained under the heading
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Program Portfolio Strategies—ALIGN
Strategic Portfolios Program” below.
If Baird terminates an investment manager from
the Baird Recommended Managers Program, a
full
client authorizes Baird
discretionary authority, the assets in the client’s
Account previously managed by the terminated
investment manager in other securities, including,
but not limited to, mutual funds and ETPs. Baird’s
discretionary authority to make such other
investments will continue until a replacement
investment manager is selected or alternative
arrangements are made for the management of
the client’s assets.
investment strategies, there
Like all
is no
guarantee that 55ip’s implementation of tax
management strategies will be successful, and
when such strategies are used, a client’s Account
may not be successful in pursuing its primary
investment strategies, objectives or goals.
A client who prefers to continue using an
investment manager that has been removed from
the Baird Recommended Managers Program, or
who directs or otherwise requests that a particular
investment manager not recommended by Baird
be selected to manage the client’s Account, will
need to move to another Program, such as the BSN
Program. See “Baird SMA Network Program” below
for more information. Clients who elect to do so will
no longer receive the same level of rigorous
ongoing monitoring, evaluation, or review of that
investment manager from Baird.
Clients are urged to review 55ip’s Form ADV Part
2A Brochure, which should contain additional
important
including
information about 55ip,
information about 55ip’s strategies, the types of
investments 55ip may use for a client’s Account,
and the risks associated with 55ip’s strategies.
Such brochure is available upon request.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
performed by Baird on those managers and SMA
Strategies, if any, see “Portfolio Manager Selection
and Evaluation—Selection and Evaluation—Baird
SMA Network and Dual Contract Programs” below.
A client should note that the time it takes to
transition an Account to a Target ALIGN Strategy
could be significant and involve a period of five (5)
years or more. The actual time can vary greatly by
Account and will depend on a number of factors,
including, but not limited to, the differences
between the holdings of the Account and the
Target ALIGN Portfolio, the tax basis of the Account
holdings, and additions to and withdrawals from
the Account.
A client should only participate in the BSN Program
if the client wishes to take more responsibility for
the Baird
the client’s Account,
monitoring
Recommended Managers Program does not
contain an SMA Strategy that meets the client’s
particular needs, and the client understands the
risks of doing so.
an
BSN Managers have varying investment objectives,
styles and strategies, and they may invest a
client’s Account in various types of securities,
which will be chosen by the BSN Manager and
which may include mutual funds, ETFs or other
investment products associated with the manager
or Baird. Certain managers offer strategies that
exclusively invest in Funds (“Fund Strategist
Portfolios”).
Solutions.
Important
Information about Affiliated
Managers. The Baird Recommended Managers
Program makes available to clients investment
services that are offered by Baird Equity Asset
Management,
investment management
department of Baird. This presents a conflict of
interest. For more information, see “Additional
Information—Other Financial Industry Activities
and Affiliations” below. Baird receives a portion of
the Portfolio Fee paid by clients pursuing ALIGN
for portfolio
55ip Tax Managed Solutions
management services that Baird provides in
connection with
Such
those
compensation provides Baird a financial incentive
to recommend those Solutions.
Baird SMA Network Program
Clients are urged to review the BSN Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the BSN
Manager, including information about the BSN
Manager’s strategies, the types of investments the
BSN Manager may use for a client’s Account, and
the risks associated with investing in a BSN
Strategy. Such brochures are available upon
request.
is designed
The BSN Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
client. The BSN Program
to
accommodate a client who wishes to independently
select an investment manager not available in the
Baird Recommended Managers Program
to
manage the assets in the client’s Account.
Some of the services provided under the BSN
Program may be provided to a client by a Baird
Financial Advisor assigned to the client’s Account,
and the client’s Financial Advisor may provide his
or her own advice and recommendations about
BSN Managers.
to
If a client participates in the BSN Program, the
client authorizes and directs Baird to appoint the
BSN Manager selected by the client to serve as
sub-adviser to the client’s Account. The client also
authorizes and directs the BSN Manager to manage
client’s Account with full discretionary authority in
accordance with the BSN Strategy selected by the
client.
Under the BSN Program, Baird determines the
investment managers (“BSN Managers”) and their
strategies (“BSN Strategies”) eligible to participate
in the Program through a significantly less rigorous
evaluation process compared
the Baird
Recommended Managers Program. However, a
client should note that Baird does not make any
recommendation to clients regarding any BSN
Strategy or any representations regarding a BSN
Manager’s qualifications as an investment adviser
or abilities to manage client assets.
Certain BSN Strategies are only made available
through the Overlay Manager. The BSN Strategies
offered through the Overlay Manager consist of
Manager-Traded Strategies and Model-Traded
Strategies. If a client selects a BSN Strategy
For more specific information about the managers
and SMA Strategies made available through the
BSN Program and the level of initial and ongoing
research, evaluation, monitoring and review
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the client’s Account with
does
not
provide
the
financial
offered through the Overlay Manager for the
client’s Account, the client authorizes and directs
Baird to appoint the Overlay Manager to serve as
sub-adviser to the client’s Account. If a client
selects a Model-Traded Strategy offered through
the Overlay Manager for the client’s Account, the
client authorizes and directs the Overlay Manager
to manage
full
discretionary authority in accordance with the BSN
Strategy selected by the client. If a client selects a
Manager-Traded Strategy offered through the
Overlay Manager for the client’s Account, the client
authorizes and directs the Overlay Manager to
appoint the applicable BSN Manager as sub-
adviser, and the client also authorizes and directs
such BSN Manager to manage the client’s Account
with full discretionary authority in accordance with
the BSN Strategy selected by the client.
If a client’s Account is managed by an Other
Manager under the BSN Program, the client should
understand that: Baird does not manage the
Account and does not otherwise have any influence
over the Other Manager’s investment decisions or
securities selections, and therefore, Baird is not
responsible for the decisions made by the Other
Manager; Baird
any
recommendation or investment advice regarding
the purchase or sale of investment products made
for the client’s Account; and Baird and the client’s
Financial Advisor only provide the client with
certain consulting services, which may include the
client’s Financial Advisor’s assistance with
determining
needs,
client’s
investment goals and investment restrictions and
periodically reviewing the manager’s performance.
Baird does not undertake to provide any other
consulting or investment advisory services under
the BSN Program unless Baird agrees to do so in
writing.
is
fully and
If a client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the Overlay Manager will typically
implement the Model Portfolio as proposed by the
Model Provider. However, since the Overlay
Manager has discretionary authority over the
client’s Account, the Overlay Manager may
implement the Model Portfolio differently than
proposed by the Model Provider if the Overlay
Manager determines such action to be necessary
and in the client’s best interest. A client should note
that Baird does not monitor or ascertain whether
the Overlay Manager
faithfully
implementing the Model Portfolio on a continuous
basis. The client should periodically discuss the
Account’s performance with the client’s Financial
Advisor.
A client that participates in the BSN Program is
strongly encouraged to contact the client’s Baird
Financial Advisor or BSN Manager on a periodic
basis to discuss: the Account and its investment
performance; the BSN Manager’s investment
philosophy and style (to determine if the BSN
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information regarding the BSN Manager, described
on the manager’s Form ADV, which is available on
the SEC's website at www.adviser info.sec.gov.
Certain managers of Model-Traded Strategies
offered through the Overlay Manager have adopted
trade rotation policies that allow them to send
Model Portfolio updates to the Overlay Manager
after they have implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. As a result, the performance of a
Baird client Account pursuing a Model Portfolio
strategy offered by those Model Providers will
differ, perhaps in a materially negative manner,
from the performance of client accounts managed
by those Model Providers. See “Additional Program
Information—Trading for Client Accounts—Trading
Practices of Investment Managers” below for more
information.
for
The BSN Strategies and BSN Managers made
available under the BSN Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the BSN Program,
Baird cannot appoint a replacement manager or
otherwise manage a client’s Account assets. Given
the terms of the BSN Program, upon the
withdrawal or removal of an investment manager
from the BSN Program, a client’s BSN Program
Account will be automatically removed from the
BSN Program and the Account will become an
unmanaged brokerage account, unless the client
provides contrary
instructions to Baird. See
“Portfolio Manager Selection and Evaluation—
Selection and Evaluation—Baird SMA Network and
Dual Contract Programs” below
further
information.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
to
Important Information about
the BSN
Program. Portfolios managed by 55I, LLC (d/b/a
55ip, “55ip”) are made available under the BSN
Program. 55ip uses research and other services
from Riverfront, an affiliate of Baird, in the
development of certain of those portfolios, and
Riverfront receives compensation from 55ip with
respect to those portfolios. This presents a conflict
of interest. For more information, see “Additional
Information—Other Financial Industry Activities
and Affiliations” below.
Under the DC Program, Baird determines the
investment managers (“DC Managers”) and their
strategies (“DC Strategies”) eligible to participate
in the Program through a significantly less rigorous
evaluation process compared
the Baird
Recommended Managers Program. However, a
client should note that Baird does not make any
recommendation to clients regarding any DC
Strategy or any representations regarding a DC
Manager’s qualifications as an investment adviser
or abilities to manage client assets.
For more specific information about the managers
and SMA Strategies made available through the DC
Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those managers and SMA
Strategies, if any, see “Portfolio Manager Selection
and Evaluation—Selection and Evaluation—Baird
SMA Network and Dual Contract Programs” below.
A client should only participate in the DC Program
if the client wishes to take more responsibility for
monitoring
the Baird
the client’s Account,
Recommended Managers Program does not
contain an SMA Strategy that meets the client’s
particular needs, and the client understands the
risks of doing so.
include mutual
DC Managers have varying investment objectives,
styles and strategies, and they may invest a
client’s Account in various types of securities,
which will be chosen by the DC Manager and which
may
funds, ETFs or other
investment products associated with the manager
or Baird.
The BSN Program is designed to accommodate a
client who wishes to independently select an
investment manager that is not available in the
Baird Recommended Managers Program
to
manage the client’s Account. The client assumes
ultimate responsibility for monitoring the client’s
BSN Program Account and the BSN Manager’s
performance. A client’s appointment and continued
retention of a BSN Manager to manage the client’s
Account are based ultimately upon the client’s
independent review of the BSN Manager and the
BSN Manager’s services. The client ultimately
determines that the BSN Strategy to be used in
managing the client’s Account is consistent with
the client’s stated investment objectives and
financial needs and risk tolerance. Once retained
by the client, a BSN Manager will only be removed
from managing the client’s BSN Program Account
upon the manager’s withdrawal, removal from the
BSN Program, or the client’s direction to do so. A
client should carefully consider the foregoing when
deciding to participate in the BSN Program and also
consider whether another Baird Program, such as
the Baird Recommended Managers Program, may
be more appropriate for the client.
Dual Contract Program
is designed
Clients are urged to review the DC Manager’s Form
ADV Part 2A Brochure, which should contain
additional important information about the DC
Manager, including information about the DC
Manager’s strategies, the types of investments the
DC Manager may use for a client’s Account, and the
risks associated with investing in a DC Strategy.
Such brochures are available upon request.
The DC Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
client. The DC Program
to
accommodate a client who wishes to independently
select an investment manager not available in the
Baird Recommended Managers Program or BSN
Program to manage the assets in the client’s
Account. The Program is also designed for a client
that wants to independently select a manager and
negotiate the manager’s Portfolio Fee rate directly
with the manager.
Some of the services provided under the DC
Program may be provided to a client by a Baird
Financial Advisor assigned to the client’s Account,
and the client’s Financial Advisor may provide his
or her own advice and recommendations about DC
Managers.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and
Evaluation—Selection
Baird cannot appoint a replacement manager or
otherwise manage a client’s Account assets. Given
the terms of the DC Program, upon the withdrawal
or removal of an investment manager from the DC
Program, a client’s DC Program Account will be
automatically removed from the DC Program and
the Account will become an unmanaged brokerage
account, unless the client provides contrary
instructions to Baird. See “Portfolio Manager
Selection
and
Evaluation—Baird SMA Network and Dual Contract
Programs” below for more information.
Under the DC Program, DC Managers are offered
to clients through a dual contract arrangement,
and a client will need to enter into a separate
agreement with the DC Manager in addition to the
advisory agreement the client enters into with
Baird. A client participating in the DC Program is
solely responsible for negotiating the client’s
agreement with the client’s DC Manager, and
neither Baird nor its Financial Advisors will
participate or advise a client regarding the terms
of such an agreement, the advisability of entering
into such an agreement, or the retention of the
client’s DC Manager.
Information about
the DC
Important
Program. Other
investment management
departments of Baird and Associated Managers are
available to clients under the DC Program. This
interest. For more
presents a conflict of
information, see “Additional Information—Other
Financial Industry Activities and Affiliations” below.
does
not
provide
the
financial
services.
The
If a client’s Account is managed by an Other
Manager under the DC Program, the client should
understand that: Baird does not manage the
Account and does not otherwise have any influence
over the Other Manager’s investment decisions or
securities selections, and therefore, Baird is not
responsible for the decisions made by the Other
any
Manager; Baird
recommendation or investment advice regarding
the purchase or sale of investment products made
for the client’s Account; and Baird and the client’s
Financial Advisor only provide the client with
certain consulting services, which may include the
client’s Financial Advisor’s assistance with
determining
needs,
client’s
investment goals and investment restrictions and
periodically reviewing the manager’s performance.
Baird does not undertake to provide any other
consulting or investment advisory services under
the DC Program unless Baird agrees to do so in
writing.
the DC Manager’s
The DC Program is designed to accommodate a
client who wishes to independently select an
investment manager. The client assumes ultimate
for monitoring the client’s DC
responsibility
Program Account and
the DC Manager’s
performance. A client’s appointment and continued
retention of a DC Manager to manage the client’s
Account are based ultimately upon the client’s
independent review of the DC Manager and the DC
client ultimately
Manager’s
determines that the DC Strategy to be used in
managing the client’s Account is consistent with
the client’s stated investment objectives and
financial needs and risk tolerance. Once retained
by the client, a DC Manager will only be removed
from managing the client’s DC Program Account
upon the manager’s withdrawal, removal from the
DC Program, or the client’s direction to do so. A
client should carefully consider the foregoing when
deciding to participate in the DC Program and also
consider whether another Baird Program, such as
the Baird Recommended Managers Program, may
be more appropriate for the client.
Other SMA Strategy Information
A client that participates in the DC Program is
strongly encouraged to contact the client’s Baird
Financial Advisor or DC Manager on a periodic basis
to discuss: the Account and its investment
performance;
investment
philosophy and style (to determine if the DC
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information regarding the DC Manager, described
on the manager’s Form ADV, which is available on
the SEC's website at www.adviserinfo.sec.gov.
Certain SMA Strategies are available through
multiple Programs. The overall cost of an SMA
Strategy and the types and levels of service
provided to a client in connection with an SMA
Strategy will vary depending upon the particular
Program selected by the client. Certain managers
offer lower Portfolio Fee rates to clients through the
DC Program compared to the BAM, BRM or BSN
The DC Strategies and DC Managers made
available under the DC Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the DC Program,
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Robert W. Baird & Co. Incorporated
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
used in the ALIGN UMA Select Portfolios Program
from time to time and replace them with other
investment options. Baird may make changes to an
ALIGN UMA Select Portfolio from time to time as it
deems appropriate and without providing prior
notice to, or obtaining the consent of, a client.
Programs. A client considering an SMA Strategy
should discuss with client’s Financial Advisor SMA
Strategy availability and the different Portfolio Fee
rates, costs, and the types and levels of service
provided in connection with the different Programs.
A client is solely responsible for selecting the SMA
Strategy and the Program in which the client’s
Account will participate.
invested
in concentrated and
The ALIGN UMA Select Portfolios Program makes
available: (1) certain mutual funds and ETPs that
Baird determines are eligible for the UMA Programs
through an initial and ongoing evaluation process
(“UMA Recommended Funds”), which may include
Associated Funds; (2) certain BRM Strategies that
Baird determines are eligible for the UMA Programs
through an initial and ongoing evaluation process
(“UMA Recommended SMA Strategies”), which
may include Associated SMA Strategies; and (3)
PWM-Managed Portfolios.
A client should note that certain SMA Strategies
may be
less
diversified portfolios of securities and may involve
the use of leverage, margin, and options. A client
should discuss with the client’s Baird Financial
Advisor the specific strategies and investments
used by a manager. Additional information about
the strategies and investments used by a manager
are available in a manager’s Form ADV Part 2A
Brochure.
level of
initial and ongoing
UMA Programs
ALIGN UMA Select Portfolios Program
For more specific information about the investment
options made available through the Program and
research,
the
evaluation, monitoring and review performed by
Baird on those investment options, if any, see
“Portfolio Manager Selection and Evaluation—
Selection and Evaluation—UMA Programs” and
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Program Portfolio Strategies—UMA
Programs” below.
Investment managers participating in the ALIGN
UMA Select Portfolios Program have varying
investment objectives, styles and strategies, and
they may invest a client’s Account in various types
of securities, which will be chosen by the
investment manager and which may include
mutual funds, ETFs or other investment products
associated with the manager or Baird.
the
investment manager,
Under the ALIGN UMA Select Portfolios Program,
Baird and the Overlay Manager manage a client’s
Account with full discretionary authority according
to a proprietary model asset allocation strategy
developed by Baird (each such model, an “ALIGN
UMA Select Portfolio”) that is selected by the client.
The ALIGN UMA Select Portfolios Program offers
model asset allocation portfolios that have different
investment objectives and use different investment
strategies. Each ALIGN UMA Select Portfolio
provides for specific levels of investment across
different asset classes, such as equity securities,
fixed income securities, Non-Traditional Assets,
Alternative Investment Products and cash. Each
Portfolio generally uses mutual funds, ETPs,
primarily ETFs, and SMA Strategies in order to
implement the model asset allocation strategy. The
amount allocated to an asset class or type of
investment varies by Portfolio, and some Portfolios
may have little or no allocation to one or more
asset classes or types of investments described
above.
the
Clients are urged to review the investment
manager’s Form ADV Part 2A Brochure, which
should contain additional important information
about
including
investment manager’s
information about the
strategies,
the
investments
types of
investment manager may use for a client’s
Account, and the risks associated with investing in
the investment manager’s SMA Strategies. Such
brochures are available upon request.
Some of the services provided under this Program
may be provided to a client by a Baird Financial
Advisor assigned to the client’s Account. Typically,
Baird constructs each ALIGN UMA Select Portfolio
and adjusts the asset allocation of each ALIGN UMA
Select Portfolio from time to time. Baird also
determines the mutual funds, ETPs, or SMA
Strategies that are available in the ALIGN UMA
Select Portfolios Program, including the percentage
each investment comprises in each asset class
within an ALIGN UMA Select Portfolio. Baird may
remove mutual funds, ETPs, or SMA Strategies
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Robert W. Baird & Co. Incorporated
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
a client selects the ALIGN UMA Select Portfolio
appropriate for the client’s Account with the
assistance of the client’s Baird Financial Advisor.
Model Portfolio updates to the Overlay Manager
after they have implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. As a result, the performance of a
Baird client Account pursuing a Model Portfolio
strategy offered by those Model Providers will
differ, perhaps in a materially negative manner,
from the performance of client accounts managed
by those Model Providers. See “Additional Program
Information—Trading for Client Accounts—Trading
Practices of Investment Managers” below for more
information.
full discretionary authority
If a portion of client’s ALIGN UMA Select Portfolios
Account is managed by an Other Manager, the
client should understand that: Baird does not
manage such portion of the Account and does not
otherwise have any influence over the Other
Manager’s
investment decisions or securities
selections, and therefore, Baird is not responsible
for the decisions made by the Other Manager; and
Baird does not provide any recommendation or
investment advice regarding the purchase or sale
of investment products made for such portion of
the client’s Account.
to appoint
Baird has engaged the Overlay Manager to provide
certain subadvisory services in connection with the
ALIGN UMA Select Portfolios Program. The ALIGN
UMA Select Portfolios Program makes both
Manager-Traded Strategies and Model-Traded
Strategies available to clients. If a client selects an
ALIGN UMA Select Portfolio, the client authorizes
and directs Baird to manage the client’s Account
with full discretionary authority in accordance with
the ALIGN UMA Select Portfolio selected by the
client. The client also authorizes and directs Baird
to appoint the Overlay Manager to serve as sub-
adviser to the client’s Account and directs the
Overlay Manager to manage the client’s Account in
accordance with the ALIGN UMA Select Portfolio
selected by the client and the terms of the ALIGN
UMA Select Program. If an ALIGN UMA Select
Portfolio contains a Model-Traded Strategy, the
client authorizes and directs the Overlay Manager
to manage such SMA Strategy within the client’s
Account with
in
accordance with the SMA Strategy. If an ALIGN
UMA Select Portfolio contains a Manager-Traded
Strategy, the client authorizes and directs the
Overlay Manager
the applicable
investment manager as sub-adviser, and the client
also authorizes and directs such investment
manager to manage such SMA Strategy within the
client’s Account with full discretionary authority in
accordance with the SMA Strategy.
for
A client participating in the ALIGN UMA Select
Program gives the Overlay Manager and Baird the
authority to replace investments in a client’s
Account, rebalance a client’s Account assets to be
consistent with the client’s chosen asset allocation
strategy, or engage in tax management strategies
in certain circumstances. See “Additional Program
Information—Special Considerations
the
Programs” and “Additional Program Information—
Tax Management” below for more information.
inclusion
Important
Information about Affiliated
Products. Some of the investment services and
products offered by Riverfront, and mutual funds
offered by the Baird Funds, both of which are
affiliated with Baird, have been selected by Baird
for
in certain ALIGN UMA Select
Portfolios. This presents a conflict of interest. For
more information, see “Additional Information—
Other Financial Industry Activities and Affiliations”
below.
Unified Advisory Select Portfolios Program
If an ALIGN UMA Select Portfolio contains a Model-
Traded Strategy, the Overlay Manager will typically
implement the Model Portfolio as proposed by the
Model Provider. However, since the Overlay
Manager has discretionary authority over the
applicable portion of the client’s Account, the
Overlay Manager may implement the Model
Portfolio differently than proposed by the Model
Provider if the Overlay Manager determines such
action to be necessary and in the client’s best
interest. A client should note that Baird does not
monitor or ascertain whether the Overlay Manager
is fully and faithfully implementing the Model
Portfolio on a continuous basis. The client should
periodically discuss the Account’s performance
with the client’s Financial Advisor.
Under the UAS Portfolios Program, Baird and the
Overlay Manager generally manage a client’s
Account on a non-discretionary basis according to
a custom model asset allocation strategy (each
Certain managers of Model-Traded Strategies
offered through the Overlay Manager have adopted
trade rotation policies that allow them to send
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
to
compared
the UMA Recommended SMA
Strategies (“UAS Available SMA Strategies”), which
may include Associated SMA Strategies.
Assets,
Alternative
such model, a “UAS Portfolio”) that is selected by
the client. UAS Portfolios involve the use of various
different investment strategies because they are
customized for each client. A UAS Portfolio
provides a client with a customized level of
investment across different asset classes, such as
equity securities, fixed income securities, Non-
Traditional
Investment
Products and cash. To implement the asset
allocation strategy, a client selects the investments
for the Account from among those mutual funds,
ETPs, SMA Strategies and PWM-Managed Portfolios
that Baird has determined are eligible for use in the
Program.
qualifications
as
If a client has not selected the discretionary
management option of the UAS Program, the client
should note that: (1) the UAS Available Funds and
UAS Available SMA Strategies are made available
to accommodate a client who wishes
to
independently select investments that are not on a
Baird recommended list for the client’s Account;
(2) Baird does not make any recommendation to
clients regarding any UAS Available Fund or UAS
Available SMA Strategy and Baird does not select
any investments for the client’s UAS Program
Account; and (3) Baird does not make any
representation to clients regarding any UAS
an
Available Manager’s
investment adviser or abilities to manage client
assets.
The UAS Portfolios Program also makes available a
discretionary management option, whereby a
client grants discretionary investment authority
over the client’s UAS Program Account to Baird and
a Financial Advisor who has been approved by
Baird to manage client accounts in the UAS
Portfolios Program (a “UAS Manager”). If a client
selects that option, a client grants full discretionary
authority and management of the client’s Account
to Baird and the client’s UAS Manager. A client’s
UAS Manager will manage the client’s Account on
a discretionary basis according to the UAS Portfolio
strategy selected by the client by investing Account
assets in various mutual funds, ETPs, SMA
Strategies and PWM-Managed Portfolios that Baird
has determined are eligible for use in the Program.
Funds, which may
If a client has selected the discretionary option of
the UAS Program, the client should note that Baird
or the client’s UAS Manager may use their
discretionary authority to invest the client’s UAS
Account in Associated Funds or Associated SMA
Strategies, or to the extent required by applicable
law or regulation, they may recommend, and
request the client’s consent to, such investment.
The client’s UAS Manager may also use the UAS
Manager’s discretionary authority to invest the
client’s UAS Account in UAS Available Funds and
UAS Available SMA Strategies if the UAS Manager
believes such investments are consistent with the
client’s investment objectives, risk tolerance and in
the client’s best interest.
The UAS Portfolios Program makes available two
categories of mutual funds and ETPs: (1) UMA
Recommended
include
Associated Funds, that Baird determines are
eligible for the UMA Programs through an initial and
ongoing evaluation process; and (2) certain other
mutual funds and ETPs that Baird makes available
under the UAS Program through a significantly less
rigorous evaluation process compared to the UMA
Recommended Funds (“UAS Available Funds”),
which may include Associated Funds.
Similarly, the UAS Portfolios Program makes
available two categories of SMA Strategies: (1)
UMA Recommended SMA Strategies, which may
include Associated SMA Strategies, that Baird
determines are eligible for the UMA Programs
through an initial and ongoing evaluation process;
and (2) certain SMA Strategies made available by
certain managers (“UAS Available Managers”)
through the Overlay Manager that Baird makes
available under the UAS Program through a
less rigorous evaluation process
significantly
When Associated Funds are included in the UMA
Recommended Funds lineup, and when Associated
the UMA
included
SMA Strategies are
in
Recommended SMA Strategies
lineup, those
Associated Funds and Associated SMA Strategies
are subject to the same eligibility standards that
are imposed upon mutual funds, ETFs and SMA
Strategies that are not associated with Baird.
However, when Associated Funds are included in
the UAS Available Funds lineup, and when
Associated SMA Strategies are included in the UAS
Available SMA Strategies lineup, those Associated
Funds and Associated SMA Strategies are not
subject to the same eligibility standards that are
imposed upon mutual funds, ETFs and SMA
Strategies that are not associated with Baird. To be
included in the UAS Available Fund lineup or the
UAS Available SMA Strategy lineup, an Associated
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
level of
initial and ongoing
client has
Some of the services provided under this Program
may be provided to a client by a Baird Financial
Advisor assigned to the client’s Account. Typically,
a client develops and selects the UAS Portfolio
appropriate for the client’s Account with the
assistance of the client’s Baird Financial Advisor. If
the
the discretionary
selected
management option of the Program, Baird and the
Financial Advisor, acting as UAS Manager, will
manage the client’s Account.
Fund or Associated SMA Strategy, respectively,
only needs to meet certain limited criteria. For
more specific information about the investment
options made available through the Program and
the
research,
evaluation, monitoring and review performed by
Baird on those investment options, if any, see
“Portfolio Manager Selection and Evaluation—
Selection and Evaluation—UMA Programs” and
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Program Portfolio Strategies—UMA
Programs” below.
the
A client retaining discretion over the client’s UAS
Program Account should only select UAS Available
Funds or UAS Available SMA Strategies if the client
wishes to take more responsibility for managing
and monitoring the client’s UAS Program Account,
the UMA Recommended Funds and UMA
Recommended SMA Strategies do not meet the
client
client’s particular needs, and
understands the risks of doing so.
full discretionary authority
investment
in
Baird may allow a client to transfer to a UAS
Account from another account a Fund that is not a
UMA Recommended Fund or UAS Available Fund in
certain circumstances, such as when the client has
significant unrealized capital gains related to the
client’s
the Fund. Additional
purchases of such Fund while held in a UAS
Account will not be permitted.
Investment managers participating in the UAS
Portfolios Program have varying
investment
objectives, styles and strategies, and they may
invest a client’s Account in various types of
securities, which will be chosen by the investment
manager and which may include mutual funds,
ETFs or other investment products associated with
the manager or Baird.
Baird has engaged the Overlay Manager to provide
certain subadvisory services in connection with the
UAS Select Portfolios Program. The UAS Portfolios
Program makes both Manager-Traded Strategies
and Model-Traded Strategies available to clients. If
a client selects a UAS Portfolio, the client
authorizes and directs Baird to manage the client’s
Account in accordance with the UAS Portfolio
selected by the client and the terms of the UAS
Program. The client also authorizes and directs
Baird to appoint the Overlay Manager to serve as
sub-adviser to the client’s Account and directs the
Overlay Manager to manage the client’s Account in
accordance with the UAS Portfolio selected by the
client and the terms of the UAS Program. If a UAS
Portfolio contains a Model-Traded Strategy, the
client authorizes and directs the Overlay Manager
to manage such SMA Strategy within the client’s
Account with
in
accordance with the SMA Strategy. If a UAS
Portfolio contains a Manager-Traded Strategy, the
client authorizes and directs the Overlay Manager
to appoint the applicable investment manager as
sub-adviser, and the client also authorizes and
directs such investment manager to manage such
SMA Strategy within the client’s Account with full
discretionary authority in accordance with the SMA
Strategy. If a UAS Portfolio contains a PWM-
Managed Portfolio, the client authorizes and directs
Baird to manage such PWM-Managed Portfolio
within the client’s Account with full discretionary
authority in accordance with the PWM-Managed
Portfolio.
the
investment manager,
the
Clients are urged to review the investment
manager’s Form ADV Part 2A Brochure, which
should contain additional important information
about
including
investment manager’s
information about the
strategies,
the
investments
types of
investment manager may use for a client’s
Account, and the risks associated with investing in
the investment manager’s SMA Strategies. Such
brochures are available upon request.
If a UAS Portfolio contains a Model-Traded
Strategy, the Overlay Manager will typically
implement the Model Portfolio as proposed by the
Model Provider. However, since the Overlay
Manager has discretionary authority over the
applicable portion of the client’s Account, the
Overlay Manager may implement the Model
Portfolio differently than proposed by the Model
Provider if the Overlay Manager determines such
action to be necessary and in the client’s best
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
interest. A client should note that Baird does not
monitor or ascertain whether the Overlay Manager
is fully and faithfully implementing the Model
Portfolio on a continuous basis. The client should
periodically discuss the Account’s performance
with the client’s Financial Advisor.
on
the
SEC's
website
remains appropriate for the client); any potential
conflicts of
investment
interest; and any
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information regarding the investment manager,
described on the manager’s Form ADV, which is
available
at
www.adviserinfo.sec.gov.
Baird constructs each PWM-Managed Portfolio and
may make changes to a PWM-Managed Portfolio
from time to time as it deems appropriate and
without providing prior notice to, or obtaining the
consent of, a client.
Certain managers of Model-Traded Strategies
offered through the Overlay Manager have adopted
trade rotation policies that allow them to send
Model Portfolio updates to the Overlay Manager
after they have implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. As a result, the performance of a
Baird client Account pursuing a Model Portfolio
strategy offered by those Model Providers will
differ, perhaps in a materially negative manner,
from the performance of client accounts managed
by those Model Providers. See “Additional Program
Information—Trading for Client Accounts—Trading
Practices of Investment Managers” below for more
information.
See
A client participating in the UAS Portfolios Program
gives the Overlay Manager and Baird the authority
to replace investments in a client’s Account,
rebalance a client’s Account assets to be consistent
with the client’s chosen asset allocation strategy,
or engage in tax management strategies in certain
Program
circumstances.
“Additional
Information—Special Considerations
the
for
Programs” and “Additional Program Information—
Tax Management” below for more information.
full discretionary authority
If a client has not selected the discretionary
management option of the Program, the client
retains discretionary authority over the selection of
mutual funds, ETFs, SMA Strategies and PWM-
Managed Portfolios for the Account. However, by
selecting an SMA Strategy or PWM-Managed
Portfolio, the client authorizes and directs Baird,
the Overlay Manager and the client’s investment
manager, as applicable, to manage each SMA
Strategy or PWM-Managed Portfolio portion of the
Account with
in
accordance with the SMA Strategy or PWM-
Managed Portfolio selected by the client.
the
financial
If a portion of client’s UAS Program Account is
managed by an Other Manager, the client should
understand that: Baird does not manage such
portion of the Account and does not otherwise have
any influence over the Other Manager’s investment
decisions or securities selections, and therefore,
Baird is not responsible for the decisions made by
the Other Manager; and Baird does not provide any
recommendation or investment advice regarding
the purchase or sale of investment products made
for such portion of the client’s Account; and if the
the discretionary
selected
client has not
management option of the Program, Baird and the
client’s Financial Advisor only provide the client
with certain consulting services, which may include
the client’s Financial Advisor’s assistance with
determining
needs,
client’s
investment goals and investment restrictions and
periodically reviewing the manager’s performance.
Baird does not undertake to provide any other
consulting or investment advisory services under
this Program unless Baird agrees to do so in
writing.
If a client has selected
the discretionary
management option of the UAS Portfolios Program,
the client should note that Baird may remove any
UAS Manager or strategy from the UAS Portfolios
Program at any time and transfer day-to-day
management responsibility of a client’s Account to
another UAS Manager or Baird Financial Advisor at
any time without providing prior notice to, or
obtaining the consent of, a client.
performance;
the
the UAS
Important Information about
Portfolios Program. Associated
Investment
Products and Services are available to clients under
A client that selects a UAS Available SMA Strategy
is strongly encouraged to contact the client’s Baird
Financial Advisor or investment manager on a
periodic basis to discuss: the Account and its
investment
investment
manager’s investment philosophy and style (to
determine if the UAS Available SMA Strategy
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the UAS Portfolios Program. This presents a conflict
of interest. For more information, see “Additional
Information—Other Financial Industry Activities
and Affiliations” below.
diversified portfolios of securities and may involve
the use of leverage, margin, and options. A client
should discuss with the client’s Baird Financial
Advisor the specific strategies and investments
used by a manager. Additional information about
the strategies and investments used by a manager
are available in a manager’s Form ADV Part 2A
Brochure.
Additional Program Information
Investment Discretion
Investment Selection and Trading
Authorizations
A client
retains complete discretion over
investment selection and trading decisions with
respect to assets in a client’s Non-Discretionary
Program Accounts, and Baird will only execute
transactions for such Accounts pursuant to the
client’s instruction or authorization.
If a client’s Account participates in a Discretionary
Program, the client’s advisory agreement provides
Baird and the client’s Financial Advisor, as
applicable, discretionary authority to manage the
assets in the client’s Account in accordance with
the terms of the Program selected by the client.
If a client has not selected the discretionary
management option of the UAS Program, it is
important to note that: the UAS Available Funds
and UAS Available SMA Strategies are made
available to accommodate a client who wishes to
independently select investments that are not on a
Baird recommended list for the client’s Account;
the client assumes ultimate responsibility for
monitoring each UAS Available Fund and UAS
Available SMA Strategy and
the manager’s
performance; the client’s selection and continued
holding of a UAS Available Fund or a UAS Available
SMA Strategy are based ultimately upon the
client’s independent review of such investment;
the client ultimately determines that each UAS
Available Fund and UAS Available SMA Strategy in
the client’s Account is consistent with the client’s
stated investment objectives and financial needs
and risk tolerance; and once an investment is
made by the client, the investment will only be
removed from the client’s Account upon the
manager’s withdrawal, removal of the investment
from the Program, or the client’s direction to do so.
A client should carefully consider the foregoing
when deciding to select a UAS Available Fund or
UAS Available SMA Strategy or when deciding to
participate in the UAS Program and also consider
whether another mutual fund, ETF, SMA Strategy
or Baird Program may be more appropriate for the
client.
an
investment manager
SMA Strategy Information
If a client’s Account participates in the Baird
Recommended Managers Program, the client’s
advisory agreement provides Baird and the client’s
Financial Advisor discretionary authority to appoint
investment managers to manage the client’s
Account and to terminate or replace investment
managers for the client’s Account for any reason
without prior notice to the client. If Baird
terminates
from
management of a client’s Baird Recommended
Managers Program Account, the client’s advisory
agreement provides Baird discretionary authority
to manage the assets in the client’s Account until a
replacement investment manager is selected or
alternative arrangements are made
for the
management of the client’s assets.
include
Certain SMA Strategies are available through
multiple Programs. The overall cost of an SMA
Strategy and the types and levels of service
provided to a client in connection with an SMA
Strategy will vary depending upon the particular
Program selected by the client. A client considering
an SMA Strategy should discuss with client’s
Financial Advisor SMA Strategy availability and the
different Portfolio Fee rates, costs, and the types
and levels of service provided in connection with
the different Programs. A client
is solely
responsible for selecting the SMA Strategy and the
Program
in which the client’s Account will
participate.
If a client’s Account participates in an SMA
Program, the client’s advisory agreement provides
the investment manager selected to manage the
an
client’s Account, which may
Implementation Manager, discretionary authority
to manage the assets in the client’s Account in
accordance with the terms of the SMA Program
selected by the client.
A client should note that certain SMA Strategies
less
may be
invested
in concentrated and
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
If a client’s Account participates in a UMA Program,
the client provides Baird, the client’s UAS Manager,
the Overlay Manager and the client’s investment
manager, as applicable, discretionary authority to
manage the assets in the client’s Account in
accordance with the terms of the UMA Program
selected by the client.
Other Manager and cannot purchase or sell such
assets without the consent of the client or such
Other Manager. The investment manager for a
client’s SMAs or UMAs may initiate securities
transactions through Baird, in its capacity as
broker-dealer, as further described under the
heading “Trading for Client Accounts” below,
subject to the manager’s duty to seek to obtain
best execution, or unless a client has provided
other instructions in writing. Baird, as broker-
dealer, will rely upon any such instructions of any
investment managers selected to manage the
client’s Account.
If a client participates in an SMA or UMA Program,
the client authorizes Baird to share client’s
information with the Overlay Manager and any
Implementation Manager
Other Manager or
managing the client’s Account. The client also
authorizes and directs Baird to transmit to the
Overlay Manager and any such Other Manager or
Implementation Manager any instructions that the
client may provide to Baird to the extent necessary
to carry out the client’s instructions.
Client Investment Restrictions
The Discretionary, SMA and UMA Programs offer a
client the ability to impose reasonable investment
restrictions on the management of an Account,
including the designation of particular securities or
types of securities that should not be purchased for
the client’s Account, but a client may not require
that particular funds or securities (or types) be
purchased for the client’s Account. Reasonable
investment restrictions requested by a client will
apply only to those assets over which Baird or a
client’s investment manager has discretion.
clients a
If a client grants discretionary authority over the
client’s Account to Baird, the client’s Financial
Advisor or the client’s investment manager, the
client’s advisory agreement authorizes Baird, the
the client’s
client’s Financial Advisor and
investment manager, as applicable, to manage the
client’s Account and to make investment decisions
for the client’s Account, with the authority to
determine the amount, type and timing for buying,
holding, exchanging, converting and selling
securities and other assets for the client’s Account,
subject to the terms of the Program selected by the
client. The client’s advisory agreement also grants
to Baird, the client’s Financial Advisor and the
client’s
investment manager, as applicable,
complete and unlimited trading authorization and
appoints them as the client’s agents and attorneys-
in-fact to manage the assets in the client’s Account
on the client’s behalf, subject to the terms of the
Program selected by the client. Pursuant to such
authorization and powers of attorney, Baird, the
client’s Financial Advisor and
the client’s
investment manager may, in their sole discretion
and at the client’s risk, purchase, sell, exchange,
convert and otherwise trade the securities and
other assets in the client’s Account, as well as
arrange for delivery and payment in connection
with the above, and act on the client’s behalf in all
matters necessary or incidental to the handling of
the client’s Account without prior notice to the
client. Such trading authorizations and powers of
attorney, whether granted to Baird, the client’s
Financial Advisor or the client’s
investment
manager, shall remain in full force and effect until
terminated by the client, the client’s investment
manager or Baird.
Certain Programs offer
socially
responsible investing (“SRI”) service, which assists
a client in restricting investments to those that are
consistent with the client’s social investment
guidelines or objectives. Clients electing the SRI
service generally bear the cost of the SRI service
as it is generally included in the Program Fee.
In the event that a client’s Account is restricted
from investing in certain securities, Baird or the
client’s investment manager, as applicable, will
select such other replacement securities, if any, as
they deem appropriate. Accounts with investment
restrictions may perform differently from accounts
without restrictions and performance may be
poorer. In addition, in the event there is a change
Orders for the purchase and sale of securities in a
client’s Discretionary Program Accounts will
generally be executed by Baird, in its capacity as
broker-dealer, as further described under the
heading “Trading for Client Accounts” below,
unless Baird’s duty to seek to obtain best execution
otherwise requires or unless the client has provided
other instructions to Baird in writing. Baird does
not have discretionary authority over the assets in
a client’s SMAs or UMAs that are managed by an
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
The Programs allow Other Managers, including
Associated Managers, to use the discretionary
authority granted to them by a client to invest the
client’s Account in investment products managed
or sponsored by the Other Manager or any of its
associated firms, which may include Baird. The
Other Manager or its associated firms receive
investment management or advisory fees or other
compensation from such products for the services
they provide, the amount of which generally
increases when clients invest in such products.
in the classification or credit rating of a security
held in the client’s Account, a client’s investment
restrictions may
force Baird or the client’s
investment manager to sell such security at an
inopportune time, possibly negatively impacting
Account performance and causing the client’s
Account to realize taxable gains or losses, which
could be significant. A client should also be aware
that, if the client’s Account holds any investment
vehicle (such as a mutual fund or ETF), any
investment restrictions the client places on the
client’s Account may not flow through to the
securities owned by that investment vehicle.
Should a client wish to impose or modify existing
restrictions, or the client’s financial condition or
investment objectives have changed, the client
should contact the client’s Financial Advisor.
Associated Investment Products
in Associated
from Associated
By signing an advisory agreement with Baird or
participating in a Program, a client consents to
each Other Manager, including each Associated
Manager, managing client’s Account investing all or
a portion of the client’s Account in investment
products managed or sponsored by the Other
Manager or any of its associated firms, which may
include Baird. Each Other Manager is responsible
for providing to the client information about the
amount of fees received by the Other Manager and
its associated firms and the criteria used by the
Other Manager in deciding to invest in products
managed or sponsored by the Other Manager or
any of its associated firms. A client should contact
the Other Manager and review the Other Manager’s
Form ADV Part 2A Brochure for more information.
A client’s consent may be revoked at any time.
Investment Policy Statements
website
The Programs allow Baird to use the discretionary
authority granted to it by a client to invest the
client’s Account
Investment
Products. Baird and Associated Parties receive
investment management or advisory fees or other
Investment
compensation
Products for the services they provide, the amount
of which generally increases when clients invest in
such products. The amount of fees or other
compensation received by Baird and Associated
Parties is generally described in the prospectus or
other offering or disclosure documents for the
investment product. Additional information is also
available
at
Baird’s
on
bairdwealth.com/retailinvestor.
Baird and its associates will not review, monitor,
accept or adhere to an investment policy statement
or similar document that was not prepared by
Baird, unless Baird otherwise specifically agrees to
do so in writing. Adherence to any such investment
policy statement or similar document is solely a
client’s responsibility.
Conversion, Exchange or Sale of Certain
Investments
By signing an advisory agreement with Baird or
participating in a Program, a client consents to
Baird investing all or a portion of the client’s
Account in Associated Investment Products. Baird
will use its discretionary authority to invest the
client’s Account in Associated Investment Products
when it determines it to be in the client’s best
interest to do so. Generally, the criteria used by it
in deciding to invest in Associated Investment
Products are the same as those used in deciding to
invest a client’s assets in investment products
unassociated with Baird. For more information
about the criteria used by Baird, clients should
review the section of the Brochure entitled
“Portfolio Manager Selection and Evaluation”
below. A client’s consent may be revoked at any
time.
By participating in a Program, a client authorizes
Baird to convert or exchange any shares of Funds,
such as mutual funds, ETFs, closed-end funds,
UITs, Complex Investment Products, and other
similar investment pools, held in the client’s
Account to a class of shares of the same fund, such
as advisory class shares, institutional class shares,
financial intermediary class shares, or another
class of shares primarily designed for use in
advisory programs (collectively, “Advisory Class
Shares”), to the extent made available by the
mutual fund or other Fund in accordance with
policies established by Baird from time to time,
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
including, without limitation the Mutual Fund Share
Class Policy that is described below.
expects that it will generally execute trade orders,
as broker-dealer, for Non-Discretionary Accounts
and the client’s Accounts that are directly managed
by Baird.
A client should understand that the client may not
hold Advisory Class Shares in a non-Advisory
Account and that the client may not be able to hold
certain Advisory Class Shares in an account held at
another firm. Upon the termination of a Program
for an Account or the closure of an Account for any
reason, Baird may convert or exchange the
Advisory Class Shares held in the Account to an
appropriate non-Advisory Class Shares issued by
the same fund, or, if an appropriate non-Advisory
Class Shares is not available, Baird may redeem or
sell such Advisory Class Shares.
However, in some instances, circumstances may
arise that may require Baird, in compliance with its
best execution obligations to a client, to place a
client’s trade order with a firm other than Baird. If
Baird places trade orders for the client’s Account
for execution by a firm other than Baird, and the
other firm imposes a commission or equivalent fee
on the trade (including a commission imbedded in
the price of the investment), the client will incur
trading costs in addition to the Program Fee.
Trading for Client Accounts
Trade Aggregation, Allocation and Rotation
Practices
Baird’s Trading Practices
Placement of Client Trade Orders
trade orders
Baird may aggregate contemporaneous buy and
sell orders for the accounts over which it has
discretionary authority (a practice also known as
bunching trades or block transactions). This
practice may enable Baird to obtain more favorable
execution, including better pricing and enhanced
investment opportunities, than would otherwise be
available if orders were not aggregated. Using
block transactions may also assist Baird in
potentially avoiding an adverse effect on the price
of a security that could result from simultaneously
placing a number of separate, successive or
competing client orders.
financial
responsibility,
and
Baird will select the broker-dealers that will
for Non-Discretionary
execute
Accounts and with respect to Accounts that are
managed directly by Baird unless the client has
provided instructions to Baird to the contrary. As
investment adviser, Baird has an obligation to seek
“best execution” of client trade orders. “Best
execution” means that Baird must place client
trade orders with those broker-dealers that Baird
believes are capable of providing the best
qualitative execution of client trade orders under
the circumstances, taking into account the full
range and quality of the services offered by the
broker-dealer, including the value of the research
provided (if any), the broker-dealer’s execution
capabilities, the cost of the trade, the broker-
dealer’s
its
responsiveness to Baird. It is important to note
that Baird’s best execution obligation does not
require Baird to solicit competitive bids for each
transaction or to seek the lowest available cost of
trade orders, so long as Baird reasonably believes
that the broker-dealer selected can be reasonably
expected to provide clients with the best qualitative
execution under the circumstances.
into
consideration
account
Baird generally aggregates buy and sell orders
when executing trades for client account assets
under its direct discretionary management when it
has the opportunity to do so. When utilizing block
transactions, Baird generally aggregates a client’s
trade orders with trade orders for clients who are
participating in the same Program and pursuing the
same model portfolio or strategy. In some cases,
Baird may aggregate a client’s trade orders with
trade orders for other advisory clients who are not
participants in the Programs described in this
Brochure. However, Baird determines whether or
not to utilize block transactions for a client in its
sole discretion and Baird’s decision is subject to its
duty to seek best execution. In determining the
amount to be allocated to an account, if any, Baird
specific
takes
investment restrictions, undesirable position size,
account portfolio weightings, client tax status,
client cash positions and client preferences.
Because a client does not pay commissions to Baird
when Baird, acting as broker-dealer, executes a
client’s trade orders, and because a client may
incur commission costs in addition to the Program
Fee if trade orders were to be executed by another
broker-dealer firm, clients generally receive a cost
advantage whenever Baird executes client
transactions. For this reason, and given Baird’s
execution capabilities as broker-dealer, Baird
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
for
All advisory clients participating
in a block
transaction will receive the same execution price
for the security bought or sold. Average prices may
be used when allocating purchases and sales to a
client’s Account because such securities may be
purchased and sold at different prices in a series of
block transactions. As a result, the average price
received by a client may be higher or lower than
the price the client may have received had the
transaction been effected
client
the
independently from the block transaction.
aggregated trade order will be allocated to client
accounts. In those instances when an aggregated
trade order for fixed income securities is placed
prior to determining client allocations or when such
trade order is only partially filled, Baird or the
Financial Advisor will seek to allocate trades in
manner intended to be fair and equitable to
applicable clients over time. Furthermore, when a
trade order for fixed income securities is only
partially filled, Baird and its Financial Advisors may
place orders for other fixed income securities that
have similar characteristics, such as issuer name,
structure, credit rating, or market sector.
in
Because Baird is unable to buy or sell any security
for a client’s Non-Discretionary Accounts without
the client’s authorization, Baird generally does not
aggregate or bunch trades for those Accounts with
the same or similar trades for other client
accounts. Because similar orders for the client and
Baird’s other clients may be placed and filled at
different times, the client may buy or sell securities
at prices that are different from the prices obtained
by other clients who received the same or similar
advice from Baird or the client’s Baird Financial
Advisor.
Directed Brokerage Arrangements
the
The amount of securities available
marketplace, at a particular price at a particular
time, may not satisfy the needs of all clients
participating in a block transaction and may be
insufficient to provide full allocation across all client
accounts. To address this possibility, Baird has
adopted trade allocation policies and procedures
that are designed to make securities allocations to
discretionary client accounts in a manner such that
all such clients receive fair and equitable treatment
over time. If a block transaction cannot be
executed in full at the same price or time, the
securities actually purchased or sold by the close
of each business day will generally be allocated pro
rata among the clients participating in the block
transaction. However, Baird may also make
random allocations to client accounts in certain
circumstances, such as when Baird deems a partial
fill for the total block order to be low. Adjustments
may also be made to avoid a nominal allocation to
client accounts.
considers
that
to
directed
When Baird is not able to aggregate trades, Baird
generally uses a trade rotation process that is
designed to be fair and equitable to its advisory
clients over time. However, a client should be
aware that Baird’s trade rotation practices may at
times result in a transaction being effected for the
client’s Account that occurs near or at the end of
the rotation and, in such event, client’s trade
orders will significantly bear the market price
impact, if any, of those trades executed earlier in
the rotation, and, as a result, the client may
receive a less favorable net price for the applicable
trade.
reviewing
In some cases, a client may direct Baird to use a
particular broker-dealer for execution of the
client’s trade orders (a “directed brokerage
arrangement”), and Baird may agree to the
arrangement. This may occur when a client’s
Account is held at another broker-dealer firm and
a client directs Baird to execute trades through
such firm, or when a client’s Retirement Account or
other account is maintained on a platform operated
and managed by a third party and trades must be
executed through that platform. A client should
such
Baird
understand
arrangements
brokerage
be
arrangements. A client should also understand that
if the client has a directed brokerage arrangement,
Baird may be unable to achieve best execution for
the client’s transactions. A client should note that
any costs related to the directed brokerage
arrangement are not included in the Program Fee
and that the client will be solely responsible for
the
monitoring, evaluating and
arrangement with the directed broker-dealer and
paying any commissions or markups or markdowns
or other costs imposed by the directed broker-
dealer. A client should also note that Baird
generally will not aggregate the client’s directed
Notwithstanding the foregoing, if an aggregated
trade order involves fixed income securities, Baird
and its Financial Advisors may allocate the
securities based on the needs of client accounts. In
addition, Baird and its Financial Advisors will at
times place aggregated trade orders for fixed
income securities prior to determining how the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
reference
In such cases, because Baird is acting as
investment adviser for both buyer and seller, Baird
is subject to potentially conflicting interests in
causing (or recommending) the transactions. Also,
because Baird is acting as investment adviser for
both buyer and seller, transaction prices may be
determined more by
to market
information or dealer indications for the securities
involved, and less through the type of independent
arms-length negotiation that might otherwise
occur. Baird has adopted internal policies and
procedures that require Baird and its Financial
Advisors to obtain approval of Baird’s Compliance
Department before affecting a cross trade.
brokerage trade orders with orders for other Baird
clients. As a result, a client’s transaction costs may
be higher because the client will not benefit from
any volume discounts or other reduced transaction
costs that Baird may obtain for its other clients. A
client should further note that Baird generally will
not include such client trade orders in its trade
rotation process and that Baird will generally place
the client’s trade orders with the directed broker-
dealer after Baird completes its trading for other
Baird client accounts. The client’s trade orders will
significantly bear the market price impact, if any,
of those trades executed earlier in Baird’s rotation.
As a result, the client may receive a less favorable
net price for the trade.
Trade Error Correction
continue
the
directed
If a client directs Baird to use a particular broker-
dealer, and if the particular broker-dealer referred
the client to Baird or if the particular broker-dealer
refers other clients to Baird in the future, Baird may
benefit
from the client’s directed brokerage
arrangement. Because of these potential benefits,
Baird may have an economic interest in having the
client
brokerage
arrangement. The benefits that Baird receives
conflict with the client’s interest in having Baird
recommend that the client utilize another broker-
dealer to execute some or all transactions for the
client’s Account.
Before directing Baird to use a particular broker-
dealer, a client should carefully consider the
possible costs or disadvantages of directed
brokerage arrangements.
It is Baird’s policy that if there is a trade error for
which Baird is responsible, Baird will take actions,
based on the facts and circumstances surrounding
the error, to put the client’s Account in the position
that it would have been in as if the error had not
occurred, including by adjusting or reversing the
transaction, entering an offsetting transaction, or
other methods that may be deemed appropriate by
Baird. Errors caused by Baird will be corrected at
no cost to client’s Account, with the client’s Account
not recognizing any loss from the error. Baird may
net gains and losses from a single error event
involving more than one transaction in a security
or transactions in multiple securities. The client’s
Account will be fully compensated for any losses
incurred as a result of an error event. If the trade
error results in a gain, the gain may be retained by
Baird but such gain is not given to or shared with
any Baird associate.
Cross Trading Involving Advisory Accounts
Baird offers many services and, from time to time,
may have other clients in other programs trading
in opposition to a client. To avoid favoring one
client over another client, Baird attempts to use
objective market data in the correction of any
trading errors.
of
If a client’s Account is managed by an Other
Manager, the client should review the Other
Manager’s Brochure and contact
the Other
Manager for information about how the Other
Manager corrects trade errors.
Non-Discretionary
the purchase of
Trading Practices of Investment Managers
Baird PWM generally does not in engage in cross
transactions, including agency cross transactions,
except in limited instances such as when clients
buy or sell variable rate demand obligations which
are also known as “put bonds”. When Baird
believes that the transaction is consistent with
each client’s best interest, Baird, acting as
investment manager, may cause (or in the case of
Non-Discretionary accounts, recommend) the sale
of securities from the account of an advisory client
while at or about the same time causing (or, in the
accounts,
case
the same
recommending)
securities for the account of another Baird advisory
client. Such transactions may have the benefit of
reducing transaction and market impact costs.
If a client’s Account or a portion thereof is managed
by an investment manager, the client should note
that, like Baird, such investment manager has a
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
duty to seek best execution for the client’s
Account.
same
reasons described above,
in
Investment managers may participate in other
wrap fee programs sponsored by firms other than
Baird. In addition, investment managers may
manage institutional and other accounts not part
of a wrap fee program. In the event an investment
manager purchases or sells a security for all
accounts using a particular SMA Strategy offered
by the investment manager, the investment
manager may have to potentially effect similar
transactions through a number of different broker-
dealers. In some cases, to address this situation,
investment managers may decide to aggregate all
such client transactions into a block trade that is
executed through one broker-dealer. This practice
may enable the investment manager to obtain
more favorable execution, including better pricing
and enhanced investment opportunities, than
would otherwise be available if orders were not
aggregated. Using block transactions may also
assist the investment manager in potentially
avoiding an adverse effect on the price of a security
that could result from simultaneously placing a
number of separate, successive or competing client
orders. However, as it pertains to Baird Program
clients, this practice may result in “trading away”
from Baird, which is more fully described below.
Baird a list of Model Providers that have such trade
rotation policies, which list is available on Baird’s
website at bairdwealth.com/retailinvestor. A Baird
client should understand that an Account pursuing
a Model Portfolio strategy offered by those Model
Providers will have trades executed for the client’s
Account at the end of the Model Provider’s trade
rotation on a regular and consistent basis. As a
result, trade orders for such an Account will
significantly bear the market price impact, if any,
of those trades executed earlier in the Model
Provider’s rotation and the performance of the
Account will differ, perhaps in a materially negative
manner, from the performance of client accounts
managed by the Model Provider. In addition and for
the
the
performance of a Model Portfolio, as reported by
the Model Provider, will differ, perhaps in a
materially negative manner, from the actual
performance realized by Baird client Accounts
pursuing the Model Portfolio strategy. Baird does
not make or control any investment manager’s
trade rotation policies, and Baird does not monitor,
evaluate or review any investment manager’s
compliance with the manager’s trade rotation
policies or whether such trade rotation policies
inequitable performance of client
result
Accounts. A client selecting a Model Portfolio
offered by such a Model Provider is urged to obtain
a copy of the Model Provider’s Form ADV Part 2A
Brochure and review the description of the Model
Provider’s trade rotation policy contained in that
document. A copy of a Model Provider’s Brochure
can be obtained by contacting a Baird Financial
Advisor. A client should also monitor
the
performance of an Account pursuing such a Model
Portfolio strategy and compare that performance
with the performance reported for the Model
Portfolio by the Model Provider. A client should
discuss questions about Account performance or
the Model Provider’s trade rotation policy with the
client’s Financial Advisor.
Alternatively, an investment manager may utilize a
trade rotation process where one group of clients
may have a transaction effected before or after
another group of the investment manager’s clients.
A client should be aware that an investment
manager’s trade rotation practices may at times
result in a transaction being effected for the client’s
Account that occurs near or at the end of the
investment manager’s rotation and, in such event,
client’s trade orders will significantly bear the
market price impact, if any, of those trades
executed earlier in the investment manager’s
rotation, and, as a result, the client may receive a
less favorable net price for the trade. Additional
information regarding an investment manager’s
trade rotation policies, if any, is available in the
investment manager’s Form ADV Part 2A Brochure.
Because a client does not pay commissions to Baird
when Baird, acting as broker-dealer, executes a
client’s trade orders, and because a client generally
would incur trading costs in addition to the
Program Fee if trade orders were to be executed
by another broker-dealer firm, clients generally
receive a cost advantage whenever Baird executes
Program client transactions. For this reason, and
given Baird’s execution capabilities as broker-
dealer, investment managers may determine that
placing trade orders for the client’s Account with
Baird is the most favorable option for the client.
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after they
have implemented the Model Portfolio updates for
client accounts managed by them or after they
have otherwise completed trading for those
accounts. The Overlay Manager has provided to
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
A client should contact the client’s Baird Financial
Advisor or investment manager if the client would
like to obtain specific information about trade
aways and the amount of commissions or other
costs, if any, the client incurred in connection with
step out trades.
However, investment managers may place a
client’s trade orders with a broker-dealer firm other
than Baird if the manager determines that it must
do so to comply with its best execution obligations.
This practice is frequently referred to as “trading
away” and these types of trades are frequently
called “step out trades”. A client’s trade order so
executed is then cleared and settled through Baird
in what is frequently referred to as a “step in”.
In some instances, step out trades are executed by
the other firm without any additional commission
or markup or markdown, but in other instances,
the executing firm may impose a commission or a
markup or markdown on the trade. If a client’s
investment manager places trade orders for the
client’s Account with a firm other than Baird, and
the other firm imposes a commission or equivalent
fee on the trade (including a commission imbedded
in the price of the investment), the client will incur
trading costs in addition to the Program Fee.
A client should note that each investment manager
is solely responsible for ensuring that it complies
with its best execution obligations to the client. A
client should review the manager’s trading for the
client’s Account because Baird does not monitor,
review or evaluate whether the manager is
complying with its best execution obligations to the
client. A client should review the manager’s Form
ADV Part 2A Brochure, inquire about the manager’s
trading practices, and consider that information
carefully, before selecting a manager. In particular,
the client should carefully consider any additional
trading costs the client may incur before selecting
a manager to manage the client’s Account.
A client should note that the client’s advisory
agreement permits Baird to trade as principal on
orders received from Other Managers. See “Trade
Execution Services Performed by Baird—Principal
Transactions” below for more information.
Trade Execution Services Performed by Baird
broker-dealer
firm
imposes
If Baird provides trade execution services for a
client’s Account, Baird will generally act as agent
when routing client trade orders for execution.
However, Baird may cross trades between client
accounts or may act as principal for its own account
in certain circumstances to the extent permitted by
applicable law as is more fully described below.
Some managers have historically placed nearly all
client trades with broker-dealer firms other than
Baird for execution. Some managers have placed
nearly all or all client trades resulting from changes
to their model portfolios or strategies with firms
other than Baird. Similarly, some managers have
frequently placed client trade orders for fixed
income, foreign and small cap securities with firms
other than Baird. In some cases, the other
executing
a
commission or markup or markdown (which is
embedded in the price of the security) for
executing the trade. As a result, these types of
managers and their strategies could be more costly
to a client than managers that primarily place client
trade orders with Baird for execution.
is based solely upon
independently verified
A client should understand that certain securities,
such as securities traded over-the-counter and
fixed income securities, are primarily traded in
dealer markets. When Baird purchases or sells
these types of securities for client accounts, it
generally does so through broker-dealer firms
acting as a dealer or principal. Dealers executing
principal trades typically
include a markup,
markdown or spread in the net price at which
transactions are executed. A client bears such
costs in addition to the Program Fee.
Agency Cross Transactions
A list of managers that have informed Baird that
they have traded away from Baird during 2024 -
2025 and general information about the additional
cost of those trades (if any) is available on Baird’s
website at bairdwealth.com/retailinvestor. The
information about each manager provided on
Baird’s website
the
information provided to Baird by such manager.
Baird has not
the
information, and as a result, none of Baird or any
of its Associated Parties or associates makes any
representation as to the accuracy of any such
information.
Baird PWM generally does not in engage in agency
cross transactions, except in limited instances.
However, in certain circumstances and to the
extent permitted by applicable law and regulation,
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
realize profits
Baird and its Financial Advisors may effect “agency
cross” transactions with respect to a client’s
Account. An “agency cross” transaction is a
transaction in which Baird or its affiliates act as
broker for the party or parties on both sides of the
transaction. As compensation
for brokerage
services, Baird may receive compensation from
parties on both sides of an agency cross
transaction, the amount of which may vary. Baird
Financial Advisors may receive compensation from
Baird related to agency cross
transactions.
Therefore, Baird and its Financial Advisors may
loyalties and
have a conflicting division of
responsibilities. However, in all cases, Baird and its
Financial Advisors will seek to obtain the best
execution for each respective advisory client and
will effect agency cross transactions only in
accordance with the requirements of Rule 206(3)-
2 under the Advisers Act. Furthermore, Baird will
comply with additional regulations applicable to
Retirement Accounts.
to
effect
“agency
Where applicable, a client’s advisory agreement
discusses agency cross transactions and authorizes
Baird and its Financial Advisors to effect agency
cross transactions for a client’s Account. A client’s
its Financial
authorization to Baird and
Advisors
cross”
transactions
is given pursuant to Rule
206(3)-2 under the Advisers Act and may be
revoked at any time by the client in client’s
sole discretion by notifying the client’s Baird
Financial Advisor in writing.
Baird may
from principal
transactions with a client based on the difference
between the price Baird paid for the security and
the price at which Baird sold the security, which
may include a markup, markdown or spread from
the prevailing market price, an underwriting fee,
selling dealer concession, or other incentive to
execute the transaction. Baird Financial Advisors
may receive compensation from Baird related to
principal trades of securities underwritten by Baird.
Any compensation received by Baird or a Financial
Advisor in a principal transaction is in addition to
the Program Fee paid by the client. Principal trades
also allow Baird to sell securities from its account
that it deems undesirable and to buy securities for
its account that it deem desirable. Thus, in trading
as principal with a client, Baird and its Financial
Advisors will have potentially conflicting division of
loyalties and responsibilities regarding their own
interests and the interests of the client. This
potential compensation may give Baird and its
Financial Advisors an incentive to recommend a
transaction in which Baird and its Financial
Advisors act as principal over other transactions.
Nonetheless, Baird and its Financial Advisors have
a fiduciary duty to act in the client’s best interest
and to seek best execution for advisory clients.
Baird addresses this conflict through disclosure in
this Brochure. Furthermore, Baird has adopted
internal procedures that require Baird and its
Financial Advisors, when acting in a principal
capacity, to disclose all material information
regarding Baird’s interest in the transaction, and
obtain the client’s approval of the transaction prior
to settlement.
Principal Transactions
transactions, and each
A client’s advisory agreement discloses, where
applicable, the possibility of Baird’s role in potential
principal
transaction
confirmation sent to Baird clients discloses the
capacity in which Baird served in the transaction
and whether Baird is a market maker in each
security the client bought or sold.
transactions.
Riskless
Subject to the requirements of applicable law,
Baird and its Financial Advisors may execute
transactions for a client’s Account while acting as
principal for Baird’s own account. Baird and its
Financial Advisors act as principal when they sell a
security from Baird’s inventory to a client or they
purchase a security from a client for Baird’s
inventory. Baird and its Financial Advisors also act
as principal when they sell new issue securities to
clients in securities offerings underwritten by
Baird. Baird also acts as principal in riskless
principal
principal
transactions refer to transactions in which Baird,
after having received a client’s order, executes an
identical order in the marketplace to fill the client’s
order while acting as principal. Baird and its
Financial Advisors commonly engage in principal
trades with clients in the Baird Advisory Choice
Program.
To the extent permitted by applicable law and
regulation, if a client’s Account participates in a
Non-Discretionary Program or other non-
discretionary service, or if the Account is managed
by an Other Manager, the client’s advisory
agreement provides Baird and
its Financial
Advisors with a blanket authorization to act as
principal for Baird’s own account in selling any
security to, or purchasing any security from, the
client’s Account. With this authorization, Baird and
its Financial Advisors may effect any and all
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
principal transactions with the client’s Account
without having
to provide specific written
disclosures or obtain written client consent prior to
completion of each proposed principal trade,
subject to the requirements of an exemptive order
issued by the SEC to Baird (Rel. No. IA-4596) and
other applicable
regulation. This
law and
authorization to enable Baird and its Financial
Advisors to trade as principal with a client’s
Account may be revoked at any time by the
client in client’s sole discretion by notifying
the client’s Baird Financial Advisor in writing.
“Digital Assets”) may be used for diversification
purposes. They may also be used to try to reduce
market and inflation risk. The performance of Non-
Traditional Assets may not correspond to the
performance of the stock markets generally, and
investments
in Non-Traditional Assets will
generally impact an account’s returns differently
than more traditional investments like stocks or
bonds. Non-Traditional Assets are subject to risks
that are different from, and in some instances,
greater than, other assets like stocks and bonds.
Non-Traditional Assets are generally more difficult
to value, less liquid, and subject to greater
volatility compared to stocks and bonds.
Complex Strategies and Complex Investment
Products
Margin and Leverage
Margin
in
Strategies
invest
in
Margin involves borrowing money from a firm, such
as Baird, to buy securities or other property. If a
client wishes to pay for securities by borrowing part
of the purchase price from Baird, a client must
open a margin account with Baird, and Baird may
provide the client with a margin loan. Securities
held in a client’s margin account are used as Baird’s
collateral for the margin loan. The value of the
the margin account must be
collateral
maintained at a certain level relative to the margin
loan for the duration of the loan. If the securities
in the margin account decline in value, so does the
value of the collateral supporting the margin loan,
and as a result, Baird may take action, such as
issue a margin call and sell securities in the
account.
Leverage
is contained under
Leverage generally attempts to obtain investment
exposure in excess of available assets through the
use of borrowings, short sales and other derivative
leverage can potentially
instruments. While
enhance returns, it can also exacerbate losses if
changes in the markets, or the values of the
investments subject to the leverage, are adverse
to the strategy being pursued. The use of leverage
may also increase an Account’s volatility.
Some Programs offer clients the ability to pursue
Alternative Strategies or other Complex Strategies
that involve special risks not apparent in more
traditional investments like stocks and bonds.
Complex Strategies may be pursued in multiple
ways, including by investing in alternative mutual
funds, ETFs, hedge funds, managed futures,
private equity funds and SMAs managed by third
party managers. Some Complex Strategies invest
in Non-Traditional Assets, such as real estate,
commodities (which may include metals, mining,
energy and agricultural products), currencies,
movements in securities indices, credit spreads
and interest rates, and venture capital and buyout
investments in private companies. Some Complex
Strategies engage in the use of margin or leverage
or selling securities short (“short sales”). Some
Complex
derivative
instruments such as options, convertible securities,
futures, swaps, or forward contracts. Complex
Investment Products generally engage in one or
more Complex Strategies. Additional information
about Alternative Strategies and Complex
Strategies
the heading
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Investment Strategies—Alternative
Strategies and Complex Strategies” below.
Additional information about Complex Strategies
and Complex Investment Products, generally, is
provided below.
Short Sales
to benefit
Non-Traditional Assets
currencies,
securities
tokens
Short selling attempts
from an
anticipated decline in the market value of a
security. To affect a short sale, a client sells a
security the client does not own. When a client sells
a security short, Baird borrows the security from a
lender and makes delivery to the buyer on the
client’s behalf. Because short sales involve an
Non-Traditional Assets, such as investments in
commodities,
indices,
interest rates, credit spreads, private companies,
and digital assets, such as cryptocurrencies, non-
stablecoins, and
(“NFTs”),
fungible
(collectively,
tokenized
investment products
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
expiration of the option. The premium paid to the
seller (writer) for the option is in consideration for
the underlying obligations imposed on the seller
should the option be exercised. With a put option,
the purchaser has the right to sell, and the seller
has the obligation to buy, the underlying security
or index at the exercise price prior to expiration of
the option.
extension of credit from Baird to the client, a client
must use a margin account. A client must also
eventually purchase the same shares sold short
and return them back to the lender. It is possible
that the prices of securities that a client sells short
may increase in value, in which case the client may
lose money on the short position. Short selling thus
runs the risk of loss if the price of the securities
sold short does not decline below the price at which
they were originally sold. This risk of loss is
theoretically unlimited, as there is no cap on the
amount that the price of a security may appreciate.
Clients should note that investment managers
managing a client’s Account or
investment
products in the client’s Account may also engage in
short sales. Thus, a client’s Account will be subject
to short sales risks if the investment manager
managing the client’s Account or an investment
product in the client’s Account engages in short
sales.
Options and Other Derivative Instruments
Derivative Instruments
instruments,
In buying a call option, the purchaser expects that
the market value of the underlying security or
index will appreciate, which would enable the
purchaser of a call to buy the underlying security
or index at a strike price lower than the prevailing
market price. The purchaser of the call option
makes a profit if the prevailing market price is
greater than the sum of the strike price plus the
premium paid for the option. The seller of a call
option earns income in the form of the premium
received from the purchaser for the option and
expects that the market value of the underlying
security or index will depreciate such that the
option will expire without being exercised. The
seller of a call option makes a profit if the prevailing
market price of the underlying security or index is
less than the sum of the strike price plus the
premium received.
traditional
investments.
Investing
involves
Derivatives
such as options,
convertible securities, futures, swaps, and forward
contracts are financial contracts that derive value
based upon the value of an underlying asset, such
as a security, commodity, currency, or index.
Derivative instruments may be used as a substitute
for taking a position in the underlying asset.
Derivative instruments may also be used to try to
hedge or reduce exposure to other risks. They may
also be used to make speculative investments on
the movement of the value of an underlying asset.
The use of derivative instruments involves risks
different from, or possibly greater than, the risks
associated with investing directly in securities and
other
in
leverage.
derivatives also generally
Derivatives are also generally less liquid, and
subject to greater volatility compared to stocks and
bonds.
Options
In buying a put option, the purchaser expects that
the market value of the underlying security or
index will depreciate, which would enable the
purchaser of a put to sell the underlying security or
index at a strike price higher than the prevailing
market price. The purchaser of the put option
makes a profit if the prevailing market price is less
than the sum of the strike price and the premium
paid for the option. The seller of a put option earns
income in the form of the premium received from
the purchaser for the option and expects that the
market value of the underlying security or index
will appreciate such that the option will expire
without being exercised. The seller of a put option
makes a profit if the prevailing market price of the
underlying security or index is greater than the
difference between the strike price and the
premium.
Options transactions may involve the buying or
writing of puts or calls on securities. In some cases,
Baird may require clients to open a margin account
to engage in options trading.
With a call option, the purchaser has the right to
buy, and the seller (writer) the obligation to sell,
the underlying security or index at a predetermined
price (i.e., the exercise or strike price) prior to
In purchasing a put or call option, the purchaser
faces the risk of loss of the premium paid for the
option if the market price moves in a direction
opposite to what the purchaser had expected. In
selling or writing an option, the seller faces
significantly more risk. A seller of a call option faces
the risk of significant loss if the prevailing market
price of the underlying security or index increases
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
above the strike price, and a seller of a put option
faces the risk of significant loss if the prevailing
market price of the underlying security or index
decreased below the strike price.
Clients should note that investment managers
managing a client’s Account or
investment
products in the client’s Account may also engage in
options transactions. Thus, a client’s Account will
be subject to options risks if the investment
manager managing the client’s Account or an
investment product in the client’s Account engages
in options transactions.
Complex Investment Products
of
Products
include
limit to the amount borrowed securities can rise in
value. See “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Principal Risks” below
for more information. Before using those types of
strategies or products, a client is strongly urged to
discuss them with the client’s Financial Advisor and
any investment manager managing the client’s
Account. A client should also carefully review the
client’s agreements with Baird and related
disclosure documents, which the client should have
received when opening the Account. Additional
information about Complex Strategies and
Complex Investment Products is provided under
the heading “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies
Loss—Investment
and Risk
Strategies—Alternative Strategies and Complex
Strategies” below and on Baird’s website at
bairdwealth.com/retailinvestor.
futures, but also
ETNs,
business
in
A client assumes responsibility for engaging in
Complex Strategies and investing in Complex
Investment Products. If a client determines that
the client no longer wants to engage in those
strategies or invest in those products, the client is
responsible for notifying the client’s Financial
Advisor and any investment manager managing
the client’s Account. Baird is not responsible for
any losses resulting from any Other Manager’s
implementing any such
failure or delay
instructions.
Complex Investment Products typically invest
primarily in Non-Traditional Assets or engage in
one or more Complex Strategies. Complex
Investment
Alternative
Investment Products, such as hedge funds, funds
of hedge funds, private equity funds, funds of
private equity funds, private debt funds, and
managed
include other
investments
pursuing Complex Strategies,
including but not limited to, exchange or swap
funds, leveraged funds, inverse funds, and other
special situation funds, structured certificates of
(“structured
deposit and
structured notes
products”),
development
companies (“BDCs”), real estate investment trusts
limited partnerships
(“REITs”), and master
(“MLPs”).
thereby making
In addition, a client should be aware that more
traditional investments, such as mutual funds,
ETFs, UITs and variable annuities may also pursue
Complex Strategies,
them
Complex Investment Products. A client should
carefully review the prospectus or other offering
document for each investment and understand the
strategy being pursued before deciding to invest.
More detailed information about mutual funds,
ETFs, UITs and variable annuities is available on
Baird’s website at bairdwealth.com/retailinvestor.
The use of Complex Strategies or Complex
Investment Products has a unique impact upon the
calculation of a client’s asset-based Program Fee.
See “Program Fees—Calculation and Payment of
Program Fees” below for more information. A client
should also understand that Baird and the client’s
Financial Advisor have a financial incentive to use,
select or recommend certain Complex Strategies or
Complex Investment Products, including margin
and short sales. See “Additional Information—Code
of Ethics, Participation or Interest in Client
Transactions and Personal Trading” below.
Additional Important Information
losses
in
The use of Complex Strategies or Complex
Investment Products is not appropriate for some
clients because they involve special risks. A client
should not engage in those strategies or invest in
those products unless the client is prepared to
experience significant
the client’s
Account. This is especially true for short selling,
which can result in unlimited losses as there is no
As a creditor, Baird may have interests that are
adverse to a client. Neither Baird nor its Financial
Advisors will act as investment adviser to a client
with respect to the liquidation of securities held in
an Account to meet a call on a margin loan. Any
such sale of assets will be executed in Baird’s
capacity as broker-dealer and creditor and may, as
permitted by law, result in executions on a
principal basis.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Permitted Investments
access
for
investment
(“CMOs”));
convertible
their
(“CDs”)
• fixed income securities, including but not limited
to, debt securities issued by domestic and foreign
corporations and other entities; preferred stocks,
asset-backed securities (including mortgage-
backed securities and collateralized mortgage
obligations
debt
securities; obligations issued by U.S., state, or
foreign governments or
agencies,
instrumentalities, or authorities, such as
securities issued by the U.S. Treasury, federal
government agencies or federal government-
sponsored enterprises (“Agency securities”), or
foreign governments; municipal securities;
money market mutual funds; certificates of
deposit
(primary or secondary);
commercial paper;
Under the Discretionary, Non-Discretionary and
UMA Programs, Baird determines the asset
categories and investment products that clients
may
(“Permitted
Investments”) and those that are not permitted in
Program Accounts (“Unpermitted Investments”).
Permitted Investments vary by Program. Although
Baird determines the Permitted Investments under
those Programs, the level of initial and ongoing
evaluation, monitoring and review that Baird and
its Financial Advisors perform on Permitted
Investments varies. For more information, see the
descriptions of each Program under “Services, Fees
and Compensation” above and under “Portfolio
Manager Selection and Evaluation—Methods of
Analysis, Investment Strategies and Risk of Loss—
Program Portfolio Strategies” below.
• rights or warrants on equity securities, and
written covered call and written cash secured put
equity options;
Baird may add Permitted Investments or restrict
client access to a Permitted Investment at any time
in its sole discretion.
Some Permitted Investments contain restrictions
that limit their use, and clients will not be
permitted to purchase or hold such investments
outside of an Account. See “Account Requirements
and Types of Clients” below for more information.
In certain limited instances, Baird may allow a
client to hold an investment in an Account that is
an Unpermitted Investment.
• open-end mutual funds shares that Baird has
selected for use in the Program, which generally
includes only those funds with which Baird has a
selling agreement and only those funds that are
no-load, load-waived, or institutional are allowed
that were originally
for purchase; shares
purchased in a Baird brokerage account and not
sold when transitioned to an advisory account
will held in the account as non-billable assets
when the original purchase was subject to a
front-end sales charge (typically 36 months) or
until the Contingent Deferred Sales Charge
(CDSC) expires (typically 13 months) if subject
to a back-end sales charge after which time they
will be converted to the appropriate advisory
share class and become billable assets;
for use
in
ALIGN, BairdNext Portfolios and UMA
Programs. The ALIGN, BairdNext Portfolios and
UMA Programs generally only permit investments
in certain mutual funds and ETPs, and with respect
to UMA Portfolios, SMA Strategies and PWM-
Managed Portfolios, that Baird has selected for use
in those Programs. For more information, see the
descriptions of each Program under “Services, Fees
and Compensation” above.
• closed-end funds, ETFs, and UITs that have cost
fee-based
structures designed
investment advisory programs; UITs originally
purchased in a brokerage account and not sold
when transitioned to an advisory account will be
held as non-billable assets until the UIT
termination date at which time they will be
liquidated and the proceeds are billable;
Baird Advisory Choice Program. Permitted
Investments for the Baird Advisory Choice Program
generally include, but are not limited to, the
following types of investments:
• BDCs, publicly-traded REITs, certain non
publicly-traded (or private) REITs, and MLPs
(which may be organized as limited liability
companies (“LLCs”));
• equity securities, including, but not limited to,
common stocks, American Depositary Receipts
(“ADRs”), and ordinary shares, including whether
exchange-traded, or over-the-counter traded;
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• put options;
• ETNs, opportunity zone funds, and other special
situation mutual funds, and exchange or swap
funds;
• hedge funds, funds of hedge funds, private
equity funds, funds of private equity funds
structured products, private debt
funds,
opportunity zone funds, interval funds and
managed futures; and
• certain hedge funds, funds of hedge funds,
private equity funds, funds of private equity
funds, structured products, private debt funds
and managed futures that Baird has selected for
use in the Program;
• variable annuities.
for use
fee-based
• variable annuities that have cost structures
designed
investment
in
advisory programs; and
• cash and cash equivalents.
SMA Programs. Investment products under the
SMA Programs are selected solely by
the
investment manager providing services to the
client. The investment products used by an
investment manager may include products that
Baird does not permit to be used in connection with
the other Programs described above. A client
should review the investment manager’s Form ADV
Part 2A Brochure for more information.
for the Baird
The Unpermitted Investments
Advisory Choice Program generally include, but are
not limited to:
• Class B or Class C shares offered by mutual funds
or any other class of mutual fund shares that
impose a contingent deferred or level sales
charge (back-end or level load);
Russell Program. The Russell Program generally
only permits investments in mutual funds and ETFs
selected by Russell, which will exclusively or
substantially consist of Russell Funds, although
non-Russell Funds may be used.
• inverse funds;
Unsupervised Assets
• UITs that impose an initial or deferred sales
charge (load);
• most private REITs and other real estate
interests, and MLPs and LLC units that are not
publicly-traded;
in
fee-based
• all annuities and insurance products, except for
variable annuities that have cost structures
designed
investment
for use
advisory programs;
• commodities, futures or options on commodities,
and commodity pools; and
purpose
acquisition
• private investment funds, “blank check” or
companies
special
(“SPACs”), and Complex Investment Products
that Baird has not selected for use in the
Program.
adviser with
respect
to
PIM Program. Permitted
Investments and
Unpermitted Investments for the PIM Program are
generally the same as the Baird Advisory Choice
Program, except the following types of investments
are generally not permitted for PIM Accounts:
Under certain circumstances, Baird, in its sole
discretion, may accept a client request to hold an
asset in an Account that is not included in the
investment advisory services provided by Baird or
a Baird Financial Advisor or otherwise monitored,
overseen or supervised by them (an “Unsupervised
Asset”). For example, if Baird permits a client to
hold an Unpermitted Investment in an Account, the
asset is typically also considered an Unsupervised
Asset. Baird, in its sole discretion, may also
designate an asset that is otherwise a Permitted
Investment as an Unsupervised Asset under
certain circumstances, such as when a client
acquires the asset in an unsolicited transaction,
transfers the asset from an account held at another
firm or Baird brokerage account, or continues to
hold the asset against Baird’s or the client’s
Financial Advisor’s recommendation. If a client
holds an Unsupervised Asset in an Account, the
client should understand that the Unsupervised
Asset may not be included in performance reports
provided to the client and that Baird and its
Financial Advisors do not manage, provide
investment advice, or otherwise act as an
investment
the
Unsupervised Asset, even if the Unsupervised
Asset is included in account statements or
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
to minimize potential negative tax consequences
on a client, Baird may delay investing assets in a
new ALIGN Strategic Program Account when the
Account is opened shortly before a scheduled
mutual fund distribution date.
Asset Allocation Changes and Rebalancing
fees
upon
Accounts
performance reports provided to the client.
Because Baird and its Financial Advisors do not
manage or provide investment advisory services
regarding Unsupervised Assets, no asset-based
Program Fee is charged on Unsupervised Assets.
While Unsupervised Assets are not subject to the
asset-based Program Fee, Baird may impose
additional
holding
Unsupervised Assets. See “Other Fees and
Expenses” below for more information. A client
should also understand
that holding an
Unsupervised Asset in an Account may increase the
risk of trade errors, overinvestment, and negative
Account performance. A client should consult the
client’s Financial Advisor for further information.
Special Considerations for the Programs
ALIGN, BairdNext Portfolios, Russell, SMA
and UMA Clients
If a client’s Account participates in an ALIGN
Program, the BairdNext Portfolios Program, the
Russell Program, or a UMA Program, the client
authorizes Baird to rebalance the client’s Account
assets to be consistent with the client’s chosen
target asset allocation strategy in accordance with
the rebalance option selected by the client. When
Baird rebalances a client’s Account, all or only a
portion of, the Account may be traded. The
rebalance options made available under a Program
may change at any time in Baird’s discretion and
may be different from the rebalance options made
available in another Program.
Selection of Investment Options
for
the ALIGN
Current rebalancing options
Program, the BairdNext Portfolios Program, the
Russell Program, and the UMA Program include:
(1) annually on the Account’s anniversary date; or
(2) quarterly whenever the Account’s allocation to
an asset class drifts by 3% or more from the target
allocation.
Baird solely determines the investment options
made available to a client under the ALIGN,
BairdNext Portfolios, Russell and UMA Programs.
ALIGN, BairdNext Portfolios, Russell and UMA
Program Accounts will generally be invested in
mutual funds or ETPs, and, with respect to UMA
Portfolios, SMA Strategies or PWM-Managed
Portfolios. If Baird has discretion over a client’s
Account (or a portion thereof), Baird may invest
such Account (or such portion of an Account over
which Baird has discretion) in any investment
product it deems appropriate for the client’s
Accounts participating in those Programs.
Replacement of Investment Options
Baird, at times, may adjust its typical rebalancing
of a client Account based on certain tax
considerations. For example, Baird will generally
not rebalance an Account, particularly during the
fourth calendar quarter, to the extent doing so
would be inconsistent with its implementation of
tax management services for the Account as
described above. For more specific, current
information about the frequency and conditions
under which a particular Account will be
rebalanced, a client should contact the client’s
Baird Financial Advisor.
From time to time, Baird may remove mutual
funds, ETPs, SMA Strategies and PWM-Managed
Portfolios, from the ALIGN, BairdNext Portfolios,
Russell or UMA Programs, and Baird may replace
them with other mutual funds, ETPs, or SMA
Strategies or PWM-Managed Portfolios, as it deems
appropriate. If a client’s Account participates in
those Programs, Baird may replace any such
investments in the client’s Account whenever Baird
removes the
from those
investment option
Programs. Baird may make such replacement in
the client’s Account without providing prior notice
to, or obtaining the consent of, the client.
Timing of Investment
Baird reserves the right to delay or stop the
rebalancing of a client's Account if Baird believes it
is in the client’s best interest to do so. For example,
Baird oftentimes delays rebalancing when doing so
would cause the client’s Account to recognize
taxable gains in the fourth quarter or have other
negative tax consequences on the client’s Account.
The rebalancing of a client Account may be delayed
or negatively
impacted by market events,
operational limitations or other conditions beyond
Baird’s control.
In certain instances, Baird may delay investing
client assets when Baird determines it is in the
client’s best interest to do so. For example, in order
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
With respect to the ALIGN Strategic Portfolios
Program, the BairdNext Portfolios Program, the
ALIGN UMA Select Portfolios Program, and the
Russell Program, and with respect to PWM-
Managed Models in the UAS Portfolios Program,
Baird may also change a client’s asset allocation for
any reason, which may include, but shall not be
limited to, updates made by Baird to the target
asset allocations of its model portfolio strategies or
changes in market conditions, Baird’s opinion on
the future performance of particular asset classes
or the client’s financial circumstances.
Any rebalance of a client’s Account or other change
in asset allocation may result in taxable gains or
losses.
together, will be managed or advised by Baird and
client’s Financial Advisor in such a way so as to
seek to achieve a single, overall goal or investment
objective (“Goal Management Objective”) chosen
by the client. Each individual Account included in a
Goal Management Plan will also be managed or
advised by Baird and client’s Financial Advisor in
accordance with the terms of the applicable
Advisory Program and any investment strategy or
objective applicable to the Account. However, to
the extent consistent with the terms applicable to
an Account included in a Goal Management Plan,
each individual Account included in the Goal
Management Plan may be managed or advised in
any manner believed by Baird or the client’s
Financial Advisor to be necessary or appropriate for
the Goal Management Accounts, taken together, to
seek to achieve the Goal Management Objective.
Overlay Manager
be
performed
Under the ALIGN or UMA Programs, asset
allocation changes, rebalancing, and other changes
described
or
above may
implemented by the Overlay Manager.
Income;
and
(6)
Third Party Information
reliable,
limited
Strategies—Asset
The Goal Management Objectives that Baird makes
available to clients as part of Goal Management
include: (1) All Growth; (2) Capital Growth; (3)
Growth with Income; (4) Income with Growth; (5)
Conservative
Capital
Preservation. A description of those objectives is
contained under the heading “Portfolio Manager
Selection and Evaluation—Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment
Allocation
Strategies” below.
information
When providing services to a client, Baird and its
Financial Advisors rely on information provided by
third parties and other external sources believed to
be
to,
including, but not
information provided by investment managers.
Baird and its Financial Advisors assume that all
is accurate, complete and
such
current. Baird and its Financial Advisors do not
conduct an in-depth review of, or verify, such
information, and they do not guarantee the
accuracy of the information used. See “Portfolio
Manager Selection and Evaluation—Performance
Calculation” and “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Methods of Analysis”
below for more information.
Goal Management
In certain circumstances, clients that are part of
the same household may include their eligible
Advisory Accounts in the same Goal Management
Plan (a “Household Goal Management Plan”). It is
the client’s sole responsibility to notify Baird that
the client is part of a household so that Baird is
aware of the client’s eligibility for a Household Goal
Management Plan. It is also the client’s sole
responsibility to notify Baird whenever the client
ceases to be part of a household if an Account is
part of a Household Goal Management Plan. Failure
to do so could have a materially negative impact
on applicable Accounts.
Baird makes available to clients an optional goal
management service (“Goal Management”). Goal
Management provides clients the ability to set a
single, overall investment objective for all or a
portion of assets selected by the client with the
flexibility of using multiple, eligible Advisory
Accounts that may have different investment
strategies or objectives. If a client elects to have
Baird implement a plan of Goal Management (a
“Goal Management Plan”) using two or more
eligible Advisory Accounts (“Goal Management
Accounts”), the Goal Management Accounts, taken
An Account will be removed
from a Goal
Management Plan: (1) upon request or consent of
the client, (2) if the Account ceases to be an eligible
Advisory Account, (3) in the event the Account is
part of a Household Goal Management Plan, if the
client notifies Baird that the client ceases to be a
member of the applicable household, or (4) upon
written notice from Baird that it is no longer able
to manage the Account according to the Goal
Management Plan.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
for all
Tax management services are provided solely
based upon the direction and information provided
by a client. The offering and performance of tax
management services to a client’s Account does
not constitute tax advice. A client is ultimately
responsible
tax-related consequences
resulting from the client’s decision to enroll in a
Program or select a manager that utilizes tax
management services.
Given the nature of Goal Management, a client
enrolling Accounts in a Goal Management Plan
should understand that each Account enrolled in a
Goal Management Plan may not be invested in a
manner such that the individual Account alone
would be able to achieve the Goal Management
Objective. It is likely that one or more Accounts
included in a Goal Management Plan, taken alone,
will be managed or advised differently and will be
subject to greater or enhanced risks than would be
the case if the Account alone had the same
objective as the Goal Management Objective. Such
enhanced risks include, without limitation, market
risks, investment objective and asset allocation
risks, capitalization risks, investment style risks,
illiquid securities and liquidity risks, concentration
risks, frequent trading and portfolio turnover risks,
Non-Traditional Assets and Complex Strategies
risks, and Complex Investment Product risks.
include eligible Advisory Accounts
Tax management strategies are not intended to,
and likely will not, eliminate a client’s U.S. federal
income tax obligations relating to investments in
an Account. Like all investment strategies, there is
no guarantee that the implementation of a tax
management strategy will be successful. A client’s
use of a tax management strategy may not actually
lower a client’s tax obligations or otherwise achieve
a client’s tax goals. The effectiveness of tax
managed strategies and services may be
negatively impacted by applicable tax rules, such
as the IRS wash sales rules and straddle rules,
which will disallow, limit or defer a client’s ability
to recognize losses in an Account for tax purposes
in specified circumstances. Tax management
strategies and services also involve special risks.
See “Additional Program Information—Legal and
Tax Considerations” and “Portfolio Manager
Selection and Evaluation—Methods of Analysis,
Investment Strategies and Risk of Loss—
Management
Strategies—Tax
Investment
Strategies” below for more information.
A client should note, particularly if the client elects
in a
to
Household Goal Management Plan, that: if an
Account is removed from a Goal Management Plan
for any reason, including if the client ceases to be
a member of the same household, the Program and
strategy for the Account removed from the Goal
Management Plan will remain unchanged unless a
change is requested by the client; further, the
Account removed from the Goal Management Plan
will not be allocated assets from other Accounts
included in the Goal Management Plan unless the
client and all other applicable clients, if any,
consent and direct Baird to do so and then only to
the extent permitted by applicable law; and Baird
will have no liability for implementing a Goal
Management Plan as requested by the client.
Tax Management and Values Overlay
Services
A client should understand the terms of the tax
management services that will be implemented,
including the associated limitations, risks and
additional costs, if any, before enrolling an Account
in a Program or selecting a manager for that
Account. A client is strongly urged to consult with
the client’s tax advisor about potential tax
implications before enrolling an Account in a
Program or selecting a manager for that Account.
A client is also encouraged to discuss the client’s
tax management needs with the client’s Baird
Financial Advisor.
Baird Tax Management Strategies
Many Programs and managers make available tax
management strategies and services that are
intended to reduce the negative impact of U.S.
federal income taxes on an Account and enhance
trading
Account performance by selectively
investments in the Account to recognize or avoid
investment gains and losses.
implements certain
Certain Programs and managers include tax
management services as a default feature of the
Program or the manager’s services. A client that
wishes to opt an Account out of participation in a
tax management service should contact the client’s
Baird Financial Advisor.
As a default feature of the ALIGN Strategic
Portfolios, the BairdNext Portfolios, the Russell
Model Strategies and the UMA Programs, the Baird
PWM Home Office
tax
management
investment strategies described
below (“Baird TM Strategies”) for each non-
Retirement Account enrolled in one of those
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Programs unless the client opts out by contacting
the client’s Baird Financial Advisor.
applicable, believes are not “substantially identical”
for purposes of the IRS wash sales rules.
Replacement securities may
include, without
limitation, ETFs, cash, cash equivalents or other
securities. Unless the client instructs otherwise,
investment in replacement securities will be made
on a temporary basis and generally only for the
duration of any applicable IRS wash sale rule
period, currently 30 days after the sale, and within
a reasonable time thereafter, the proceeds will be
reinvested in a manner consistent with the way the
Account was invested prior to the employment of
the tax harvesting strategy.
the
implementation of
the
Certain Baird Financial Advisors also offer tax
management
investment strategies (“FA TM
Strategies”), described below, to non-Retirement
Accounts enrolled in Baird Financial Advisor-
directed Programs, including the Advisory Choice,
PIM, and UAS Programs. A client is encouraged to
ask the client’s Baird Financial Advisor if FA TM
Strategies will be used if the Account is enrolled in
a Program. PIM Managers and UAS Managers who
offer FA TM Strategies will generally implement
such strategies for Accounts they manage on a
discretionary basis unless a client opts out by
contacting the client’s Baird Financial Advisor. The
Baird PWM Home Office will assist with the
implementation of the FA TM Strategies.
Generally,
tax
harvesting strategy is limited to open end mutual
fund and ETF positions with unrealized capital
losses over $1,000 for U.S. federal income tax
purposes, unless Baird and the client otherwise
agree.
investment strategy designed
Baird Capital Gains Avoidance Strategy
Each Baird TM Strategy and FA TM Strategy is a
secondary
to
achieve a secondary objective of an Account to
reduce the negative impact of U.S. federal income
taxes and each such strategy is implemented
together with the other primary investment
strategies for the Account that are designed to
achieve the client’s primary investment objectives
or goals.
The Baird TM Strategies and FA TM Strategies
features are not available to Retirement Accounts.
for
capital
gains
Baird Tax Harvesting Strategy
(or
recommend
A capital gains avoidance strategy seeks to avoid
capital gains attributable to an investment in the
Account for U.S. federal income tax purposes by
selling the investment before the capital gain is
distributed by the issuer. When implementing a
capital gains avoidance strategy, the Baird PWM
Home Office or the Baird Financial Advisor, as
applicable, periodically, but at least annually,
monitors the issuers of investments held in the
Account
distributions
announcements and capital gains avoidance
opportunities. When an opportunity is identified,
the Baird PWM Home Office or the Baird Financial
Advisor, as applicable, sells (or recommends the
sale of) such securities in the client’s Account
identified as part of the monitoring process in order
for the Account to avoid a capital gain distribution
made by the issuer. The Baird PWM Home Office or
the Baird Financial Advisor will then reinvest (or
recommend the reinvestment of) the proceeds of
such sale in cash until the capital gain distribution
has been paid by the issuer, and then the securities
will be purchased again. If the securities are sold
at a loss, then Baird PWM or the Baird Financial
Advisor may employ
the
employment of) the tax harvesting strategy
described above.
Generally, the capital gains avoidance strategy is
limited to open end mutual fund positions in a
client Account, and a mutual fund position will be
included in the implementation of the strategy only
A tax harvesting strategy seeks to improve the
value of an Account, on a post U.S. federal income
tax basis, by offsetting capital losses in the Account
with capital gains. This strategy is oftentimes
referred to a “tax harvesting” or “tax loss
harvesting”. When implementing a tax harvesting
strategy, the Baird PWM Home Office or the Baird
Financial Advisor, as applicable, periodically, but at
least annually, conducts an assessment of the
Account to identify capital losses for tax harvesting
opportunities. When an opportunity is identified,
the Baird PWM Home Office or the Baird Financial
Advisor, as applicable, sells (or recommends the
sale of) certain securities in the client’s Account in
order for the Account to recognize the unrealized
capital losses identified as part of the assessment
process. The Baird PWM Home Office or the Baird
Financial Advisor will then reinvest (or recommend
the reinvestment of) the proceeds of such sale in
one or more replacement securities that the Baird
PWM Home Office or the Baird Financial Advisor, as
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
A client should also note that when normal trading
activity is resumed for the client’s Account, such
activity could generate taxable gains or losses.
Third Party Manager Tax Management
Services
if the potential net U.S. federal income tax benefit
to the Account related to such position is estimated
by Baird to be $1,000 or more. For purposes of
calculating the $1,000 threshold, the Account’s
current unrealized gain or loss in each mutual fund
position is analyzed in light of the applicable
amount of capital gains distribution announced by
the mutual fund company.
Baird’s capital gains avoidance strategies are
generally not available to UMA Accounts and are
not an automatic feature of those Accounts.
Some investment managers participating in the
SMA and UMA Programs offer tax management
services and others do not. A client should consult
the client’s Baird Financial Advisor or review the
investment manager’s Form ADV Part 2A Brochure
for specific information.
Client-Directed Tax Management Strategies
Additional Important Information about Baird’s
Tax Management Strategies.
A client may direct Baird, and Baird may agree, to
implement an investment strategy designed by the
client or client’s tax advisors for the client’s specific
tax purposes (a “client-designed strategy”). Baird
does not undertake any responsibility for the
development, evaluation or efficacy of any client-
designed strategy.
remain
following
Overlay Manager Tax Overlay and Values
Overlay Services (UMA Programs Only)
The implementation of a tax management strategy
is based upon Baird’s or the Baird Financial
Advisor’s, as applicable, estimates of capital gains
and losses associated with investments in client’s
Account and information provided to them by third
parties, such as issuers of securities. Capital losses
the
in an Account
will
implementation of a tax harvesting strategy, and
the Account will realize capital gains following the
implementation of a capital gains avoidance
the extent such estimates or
to
strategy,
information are incorrect.
The implementation of the tax harvesting strategy
and capital gains avoidance strategy (or the
recommendation to implement a strategy) is done
in the sole discretion of the Baird PWM Home Office
or Baird Financial Advisor, as applicable, and
securities may be excluded from implementation of
such strategies for a number of reasons, including
without limitation, the length of time the security
has been in the Account, the lack of a replacement
security acceptable to Baird or the Baird Financial
Advisor, withdrawal and deposit activity in the
Account, market conditions deemed unfavorable
by Baird or the Baird Financial Advisor, or if doing
so would, in Baird’s or the Baird Financial Advisor’s
judgment, negatively impact management of the
Account.
The tax harvesting and capital gains avoidance
strategies are provided by Baird and Baird Financial
Advisors on an Account-by-Account basis. When
employing such strategies for a client Account,
Baird does not monitor or consider the trading
activity in any other client account, including any
account held at Baird or another firm.
The Overlay Manager offers an optional tax overlay
service and a values overlay service in connection
with the UMA Programs. The Overlay Manager’s tax
overlay service seeks to consider tax implications
that may detract from the client’s after-tax returns.
The Overlay Manager’s values overlay service
provides a client the opportunity to restrict
investments in companies that derive revenues
from certain business areas or that are involved in
certain business activities that the client may find
objectionable. A client that wishes to enroll in one
or more of those services can do so by contacting
the client’s Baird Financial Advisor. These services
provided by the Overlay Manager may involve
direct indexing strategies (also known as direct
index investing), whereby a client owns the
individual securities that are constituents of a
selected benchmark index instead of a pooled
investment vehicle, such as a mutual fund or ETF,
which presents certain risks and may not be
appropriate
for certain clients. The Overlay
Manager charges an additional fee for tax and
values overlay services. The cost of tax and values
overlay services are generally the same whether
the client enrolls in one or both services. The
amount of the tax or values overlay fee will be
disclosed to a client prior to enrolling an Account in
the service. Additional information about the
Overlay Manager’s tax overlay services, including
the risks associated with those services, is
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
contained in a document entitled “Important
Additional Information About Tax Overlay Services
Provided by Envestnet Asset Management, Inc.”
and is available upon request.
moderate fluctuations in annual returns and overall
market value. Generally, under normal market
conditions, such an Account will primarily invest in
a mix of equity securities and fixed income
securities, with a bias towards equity securities.
Such an Account may also hold other types of
investments.
If a client selects tax overlay or values overlay
services, the client should understand that Baird
in
does not determine the strategies used
connection with such services, implement any such
strategies, or otherwise have any influence over
the Overlay Manager’s investment decisions, and
therefore, Baird is not responsible for the tax
overlay or values overlay services provided by the
Overlay Manager.
Investment Objectives
Income with Growth. An Income with Growth
investment objective typically seeks to provide
current income and some growth of capital.
Typically, an Account pursuing an Income with
investment objective will experience
Growth
moderate fluctuations in annual returns and overall
market value. Generally, under normal market
conditions, such an Account will primarily invest in
a mix of fixed income securities and equity
securities, with a bias towards fixed income
securities. Such an Account may also hold other
types of investments.
for
the Account. The
Generally, every Account will have one of the
investment objectives described below. Although a
Baird Financial Advisor may recommend an
investment objective for an Account based upon
the information provided by a client, the client is
ultimately responsible for selecting the investment
objective
investment
objective will determine, in part, and limit the
Programs, investment products and services that
will be made available to the Account.
Conservative Income. A Conservative Income
investment objective typically seeks to provide
current income. Typically, an Account pursuing a
Conservative Income investment objective will
experience relatively small fluctuations in annual
returns and overall market value. Generally, under
normal market conditions, such an Account will
primarily invest in a mix of fixed income securities,
cash and equity securities, with a significantly
higher allocation to fixed income securities. Such
an Account may also hold other types of
investments.
All Growth. An All Growth investment objective
typically seeks to provide growth of capital.
Typically, an Account pursuing an All Growth
investment objective will experience high
fluctuations in annual returns and overall market
value. Under normal market conditions, such an
Account generally invests nearly all of its assets in
equity securities. Such an Account may also hold
other types of investments.
Capital Preservation. A Capital Preservation
investment objective typically seeks to preserve
capital while generating current income. Typically,
an Account pursuing a Capital Preservation
investment objective will experience relatively
small fluctuations in annual returns and overall
market value. Under normal market conditions,
such an Account generally invests nearly all of its
assets in a mix of fixed income securities and cash.
Such an Account may also hold other types of
investments.
Capital Growth. A Capital Growth investment
objective typically seeks to provide growth of
capital. Typically, an Account pursuing a Capital
Growth
investment objective will experience
moderately high fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of equity securities and fixed income
securities, with a significantly higher allocation to
equity securities. Such an Account may also hold
other types of investments.
Opportunistic. An Opportunistic
investment
objective typically seeks to provide long term
growth through capital appreciation and/or income
by utilizing an active management style that shifts
the percentage of assets held
in various
investment categories to take advantage of the
manager’s perception of market pricing anomalies,
market sectors deemed favorable for investment
Growth with Income. A Growth with Income
investment objective typically seeks to provide
moderate growth of capital and some current
income. Typically, an Account pursuing a Growth
with Income investment objective will experience
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
for
a
client’s
specific
Selection and Evaluation—Methods of Analysis,
Investment Strategies and Risk of Loss—Principal
Risks—Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies” below.
Mutual Fund Share Class Policy
investment
objective
by the manager, the current
interest rate
environment or other macro-economic trends
identified by the manager to achieve growth while
short,
accounting
intermediate and long term investment and/or
cash flow needs. Depending upon the investment
strategy used, an Account pursuing an
Opportunistic
could
experience high fluctuations in annual returns and
overall market value. The types of investments in
which such an Account may invest will also vary
widely, depending upon the particular investment
strategy used.
account
allocations
investments based upon
in
index or
investments
Tactical. A tactical investment objective seeks to
provide long-term growth by tactically and actively
adjusting
to different
the
categories of
manager’s perception of how those investment
categories will perform
the short-term.
Strategies used to implement a tactical investment
objective typically involve underweighting and
overweighting account allocations to certain asset
classes, geographic locations or market sectors
relative to an applicable long-term strategic asset
allocation, benchmark
the market
generally. Accounts with a tactical investment
objective may have
focused or
concentrated in certain asset classes, geographic
locations or market sectors and they often
experience higher levels of trading and portfolio
turnover relative to accounts with other investment
objectives.
A
Tax-Managed
The
Tax-Managed.
investment
objective indicates that the account is transitioning
from one investment strategy to another using one
or more tax management strategies or tax
management
primary
considerations.
investment strategy or consideration for Accounts
with a Tax-Managed investment objective will
involve tax management, and such accounts may
not be successful in pursuing any other investment
strategies, objectives or goals.
is subject
to an asset-based
Goal. A Goal investment objective indicates that
the Account is a Goal Management Account that is
part of a Goal Management Plan and the Account
will be managed or advised in accordance with the
applicable Goal Management Objective.
under
the
heading
Most mutual funds offer different share classes.
While each share class of a given mutual fund has
the same underlying investments, those share
classes have different fees, costs and investment
minimums, and they provide different levels of
compensation to Baird. In an effort to provide
clients with appropriate low cost mutual fund
investment options for their fee-based investment
advisory accounts, Baird has established a mutual
fund share class policy (“Share Class Policy”) for
certain Baird Financial Advisor-directed Programs,
including the Advisory Choice, PIM, and UAS
Programs (the “Share Class Policy Programs”).
Typically, only one share class of a given mutual
fund family will be made available for purchase by
clients in the Share Class Policy Programs pursuant
to the Share Class Policy (the “Approved Share
Class”). When selecting the Approved Share Class
for a mutual fund family, Baird endeavors to select
the share class with the lowest expense ratio,
based upon the average expense ratio of the class
across all mutual funds in the mutual fund family,
that are widely available for trading on the mutual
fund trading platform of Charles Schwab & Co., Inc.
(“Schwab”). In selecting the share class for a
mutual fund family to be made available for
purchase by clients in the Share Class Policy
Programs, Baird considers a number of factors,
including the number of funds within the fund
family that offer the share class, client positions in
and demand for those funds, and the availability of
the share classes and funds for purchase on the
Schwab mutual fund trading platform. Generally,
share classes designed for retirement plans and
those that pay a distribution (12b-1) fee to Baird
will not be permitted in those Programs, or, if such
share classes are permitted and the client’s
Account
fee
arrangement, Baird will either: (1) rebate the
distribution (12b-1) fees to a client if the client is
paying an asset-based Program Fee on such
investment; or (2) exclude such fund shares from
the calculation of the client’s asset-based Program
Fee (sometimes referred to as “unbillable assets”)
for such period of time that Baird collects and
retains the distribution (12b-1) fee as further
described
“Additional
Information—Code of Ethics, Participation or
For information about the risks associated with the
investment objectives described above, see the
section of the Brochure entitled “Portfolio Manager
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Interest
The Share Class Policy does not apply to the
portion of a UAS Account managed by third party
managers. Third party managers are responsible
for establishing their own criteria for selecting
investments, including mutual funds, if any.
Custody Services
Interest in Client Transactions and Personal
Trading—Participation or
in Client
Transactions—Investment Product Selling or
Servicing—Mutual Funds” below. Clients should
note that the Approved Share Class for a mutual
fund family is based upon the average expense
ratio for the class across all mutual funds in the
fund family and not on a fund-by-fund basis.
Further, the expenses of every mutual fund can
and will vary over time. Therefore, while Baird has
endeavored to select the lowest cost share classes
as described above, in some instances, the
Approved Share Class is not the least expensive
share class for a particular mutual fund. Clients
may be able to obtain a less expensive share class
in other Programs or at another firm.
Each Program generally requires clients to custody
their Account assets at Baird. If Baird is the
custodian of a client’s assets, Baird will provide
certain custody services, including holding the
client’s Account assets, crediting contributions and
interest and dividends received on securities held
in a client’s Account, and making or “debiting”
distributions from the Account. Information about
account statements and performance reports, if
any, that Baird provides to clients is contained
under
the heading “Additional Information—
Review of Accounts” below.
payments,
revenue
sharing
As custodian, Baird may hold a client’s Account
assets in nominee or “street” name, a practice that
refers to securities and assets being registered in
Baird’s name or in a name that Baird designates,
rather than in a client’s name directly. Baird will be
the holder of record in those instances.
Baird may utilize one or more subcustodians to
provide for the custody of a client’s assets in
certain circumstances. For instance, Baird utilizes
subcustodians to maintain custody of certain client
assets participating in the Cash Sweep Program
(described below) and securities that are traded on
foreign exchanges.
Interest
Baird receives certain compensation from mutual
fund families in the form of distribution (12b-1)
fees, shareholder servicing fees, transfer agency
fees, networking fees, accounting fees, marketing
and
support
administration fees. The amount of compensation
paid to Baird generally varies based upon the share
class of the applicable mutual fund purchased by
clients. Because the compensation that Baird
receives from certain mutual funds is based upon
share class purchased by clients, Baird has a
financial incentive to make available to clients
those share classes that provide Baird greater
compensation, which, in many instances, would
cause clients investing in those share classes to
incur higher ongoing costs relative to other share
classes made available by the fund families. This
presents a conflict of interest. Baird addresses this
conflict through the Share Class Policy described
above and through disclosure in this Brochure. For
more information about the compensation that
Baird receives from mutual funds, see “Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading—Participation or
in Client
Transactions—Investment Product Selling and
Servicing—Mutual Funds” below.
subject
to
Shares of mutual funds held in client Accounts that
do not meet the requirements of the Share Class
Policy will generally be converted to the applicable
certain
Approved Share Class
restrictions. The Share Class Policy is subject to
change at Baird’s discretion without notice to
clients. Additional information about the Share
Class Policy is available on Baird’s website at
bairdwealth.com/retailinvestor.
Baird in its sole discretion may accept Held-Away
Assets into a client’s Account, including assets that
are held by another custodian (a “third party
custodian”). A client who uses a third party
custodian to hold Account assets does so at the
client’s risk. A client should understand that Baird
does not monitor, evaluate or review any third
party custodian. The client should also understand
that the client will pay a custody fee to the third
party custodian in addition to the Program Fee.
Baird may also impose additional fees on Accounts
with assets held by a third party custodian due to
the increase in resources needed to administer
those Accounts. Further, such third party custody
arrangements may limit the Programs made
available to the client. In addition, a client should
understand that: (a) each third party custodian has
exclusive control over the investment options
the
made available
to client Accounts on
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the program
subject to the terms and conditions of the program.
By using multiple participating banks as opposed
to a single bank, the Bank Sweep Feature seeks to
provide FDIC insurance protection for a client’s
cash balances of up to an aggregate deposit limit
(currently,
determined under
$2,500,000
types and
for most account
$5,000,000 for joint accounts). A client receives
interest on cash balances in deposit accounts under
the Bank Sweep Feature at tiered rates that are
based on the aggregate value of the accounts
within the client’s household. The applicable client
household tier values are: less than $1 million; at
least $1 million but less than $2 million; at least $2
million but less than $5 million; and $5 million are
more. Current rate information is available at
rwbaird.com/cashsweeps. Each deposit account at
a bank constitutes a direct obligation of the bank
and is not directly or indirectly Baird’s obligation.
custodian’s platform; (b) Baird has no authority or
ability to add to, or remove from, a custodian’s
platform any investment option; (c) any advice
given by Baird or the client’s Financial Advisor with
respect to the Account is inherently limited by the
options available through a custodian’s platform;
(d) Baird or the client’s Financial Advisor may have
provided different investment advice with respect
to the Account had they not been limited to the
investment options made available through the
custodian’s platform; and (e) certain investments,
such as mutual fund shares, could be more or less
expensive than if the investment was obtained
from Baird or another firm. A client should further
note that Baird generally does not provide
performance review or reporting for Held-Away
Assets. In addition, a client who uses a third party
custodian is not eligible for cash sweep services
offered by Baird. Clients using a third party
custodian are encouraged to establish appropriate
cash sweep arrangements.
A client who uses a third party custodian authorizes
Baird to give instructions to the client’s custodian
for all actions necessary or incidental to the
purchase, sale, exchange, and delivery of
securities held in the client’s Account. Also, the
client will receive account statements directly from
the client’s selected custodian. A client should
carefully review those account statements and
compare them with any statements provided by
Baird. A client should note that the prices shown
on a client’s Account statements provided by the
custodian could be different from the prices shown
on statements and reports provided by Baird due
to a variety of factors, including the use of different
valuation sources and accounting methods (e.g.,
trade or settlement date accounting) by the
custodian and Baird.
Cash Sweep Program
Any aggregate cash balances held by a client in
excess of the applicable aggregate deposit limit are
automatically invested in shares of a money
market mutual fund that Baird makes available in
the Money Market Fund feature of the program.
Cash held in employee benefit plan accounts,
employee health and welfare plan accounts, donor
advised fund accounts, and SEP and SIMPLE IRAs
will be automatically invested or swept into a
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the program. In addition, clients with aggregate
cash balances of $5 million or more across all of
their accounts with Baird within the same
household may opt out of the Bank Sweep Feature
and instead have all of their cash balances
automatically swept into an institutional money
market mutual fund that Baird makes available
under the Money Market Fund Feature of the
program. More information about the Money
Market Fund Feature of Baird’s Cash Sweep
Program is available at rwbaird.com/cashsweeps.
Baird maintains a Cash Sweep Program that is
intended for clients who want to earn interest and
receive FDIC insurance protection on their cash
time while awaiting
over short periods of
investment. If a client participates in Baird’s Cash
Sweep Program, uninvested cash in the client’s
accounts will be automatically deposited or swept,
on a daily basis, into one or more FDIC-insured
deposit accounts at participating banks (the “Bank
Sweep Feature”) or, under certain conditions, will
be automatically invested in shares of a money
market mutual fund that Baird makes available in
the program (the “Money Market Fund Feature”),
The Bank Sweep Feature seeks to provide FDIC
insurance protection for a client’s cash balances up
to an aggregate deposit limit determined under the
program. Any deposits, including CDs, that a client
maintains, directly or
indirectly through an
intermediary (such as us or another broker), with
a bank participating in the Cash Sweep Program in
the same capacity with the bank will be aggregated
with the client’s cash balances deposited with the
bank under the Cash Sweep Program for purposes
of calculating the $250,000 FDIC insurance limit.
Total deposits exceeding $250,000 at a bank may
48
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
those assets, and the compensation paid by the
banks or money market funds related to those
assets, which compensates Baird for the services
Baird provides to the banks and funds and for
Baird’s efforts in maintaining the Cash Sweep
Program. The compensation that Baird receives
from the Cash Sweep Program gives Baird a
financial incentive to recommend that a client
participate in the Cash Sweep Program and
maintain high levels of uninvested cash balances in
the client’s accounts.
not be fully insured by the FDIC. A client is
responsible for monitoring the total amount of
other deposits that the client has with a bank
outside the Cash Sweep Program in order to
determine
insurance
the extent of deposit
coverage available. Baird is not responsible for any
insured or uninsured portion of a client’s deposits
at a bank. Cash invested in a money market mutual
fund under the Money Market Fund Feature is not
FDIC insured, but is protected by Securities
Investor Protection Corporation (“SIPC”) coverage
up to applicable limits.
receives
compensation
for
As an alternative to the Cash Sweep Program,
Baird makes available other money market mutual
funds and other cash alternatives in which a client
may invest, often at a higher yield, although these
investments do not have an automatic sweep
feature. In addition, instead of maintaining cash
balances in an advisory Account, a client has the
option to maintain such cash balances in a
brokerage account that is not subject to an asset-
based Program Fee.
A client should understand that the Cash Sweep
Program is an ancillary account service and it is not
nor is it part of any advisory program or
investment advisory service. Baird does not act as
investment adviser or a fiduciary to a client in
connection with
the Cash Sweep Program.
However, a client should note that the amount of
the client’s advisory Account dedicated to cash and
cash equivalents is part of the overall investment
allocation advice provided to the client and thus the
amount of such cash and cash equivalents included
in the calculation of the Program Fee for the client’s
advisory Account.
on
website
More detailed information about the Cash Sweep
Program and the compensation Baird receives is
at
Baird’s
available
www.rwbaird.com/cashsweeps. A
client also
receives information about the compensation Baird
receives from the Cash Sweep Program through a
client’s account statements.
Trust Services Arrangements
Baird maintains an alliance with
certain
institutions, both non-affiliated and affiliated,
including Baird Trust Company (“Baird Trust”), that
provide trust administration services, including
trust administration, custody, tax reporting and
recordkeeping. Baird Financial Advisors at times
refer clients seeking trust administration services
to institutions that are members of the alliance.
Baird
the
administrative, accounting and other services that
Baird provides under the program, which is paid
out of the aggregate interest that is paid by the
participating banks on the aggregate client
balances in the deposit accounts participating in
the Bank Sweep Feature. Baird’s annual rate of
compensation may be up to 3.60% of the
for clients with
aggregate client balances
household account values of less than $1,000,000,
2.45% for clients with household account values of
$1,000,000 but less than $2,000,000, 2.00% for
clients with household account values of
$2,000,000 but less than $5,000,000, and 1.75%
for clients with household account values of
$5,000,000 or more. In a lower interest rate
environment Baird’s annual rate of compensation
will be less. For fee-based investment advisory IRA
accounts participating in the Bank Sweep Feature,
Baird’s compensation is a monthly per account fee
(which is the same regardless of client balances in
bank deposit accounts). The per account fee for
these advisory IRA accounts is generally paid out
of the interest that the banks pay on aggregate
client balances in the deposit accounts, and the per
account fee varies based on the applicable Fed
Funds Target Rate but in no event will it exceed
$19.00 per month. Baird also receives an annual
rate of compensation of up to 0.50% of the
aggregate client balances automatically invested
into money market mutual funds under the Money
Market Fund Feature. A client should note that the
client will be charged the asset-based Program Fee
on the value of all of the assets in the client’s
Accounts, including cash that is swept into a bank
deposit account or invested into a money market
mutual fund under the Cash Sweep Program. As a
result, Baird receives two layers of fees on a
client’s assets swept or invested in the Cash Sweep
Program: the Program Fee, which compensates
Baird for the investment advice, trading and
custody services provided to the client related to
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
its
Margin Loans
Subject to
fiduciary duties, the trustee
oftentimes retains Baird to provide investment
advisory services to the client trust. A client should
understand that any such referral for trust services
under the Trust Alliance Program made by Baird
and its Financial Advisors is an ancillary account
service and it is not an, nor is it part of any,
Advisory Program or investment advisory service.
They do not act as investment adviser or a
fiduciary to the client when making such a referral
and they will not provide advice on or oversee any
such trust services arrangement. Baird has a
financial incentive to recommend that clients use
Baird Trust, an affiliate, over other non-affiliated
trust companies. As a result of this affiliation, Baird
Trust also has a financial incentive to retain Baird
to provide investment advisory or other services on
behalf of the client. In addition, Baird and Baird
Financial Advisors have a financial incentive to
recommend arrangements that involve Baird and
the Baird Financial Advisor providing investment
advisory services to the client and the trust
company only providing trust administration
services compared to an arrangement whereby a
trust company would provide both investment
advisory and trust administration services because
it is more profitable to Baird and the Baird Financial
Advisor.
Baird
Trust
generally
Margin involves borrowing money from Baird using
eligible securities as collateral, including for the
purpose of buying securities. If a client uses
margin, the client will pay Baird interest on the
amount the client borrows. The rate of interest that
a client pays on a margin loan will be at a base rate
determined by Baird plus or minus a specified
percentage that varies based on the outstanding
debit balance of the margin loan and the client’s
household account value. Interest rates are lower
for larger debit balances and those with higher
household account balances. As a result, rates will
vary. To determine the actual interest rate that
may apply to a client’s margin loan, visit Baird’s
website at rwbaird.com/loanrates or contact a
Baird Financial Advisor. Because a client will pay
interest to Baird on the outstanding balance of the
client’s margin loan, Baird has an incentive to
recommend to the client investment products and
services that involve the use of margin. Baird and
Baird Financial Advisors also have an incentive to
recommend investment products and services that
involve the use of margin, because a margin loan
allows a client to make larger securities purchases
and retain assets in the client’s Accounts that pay
an ongoing asset-based Program Fee instead of
liquidating them to fund a cash need, which
increases the asset-based fees Baird earns on a
client’s Accounts. A client should note that any
margin balance (i.e., the outstanding amounts of
the margin loan the client owes to Baird) in the
client’s advisory Accounts will not be applied to
reduce the client’s billable account value in
calculating the client’s asset-based Program Fee,
which gives Baird and Baird Financial Advisors
further incentive to recommend client use of
margin instead of liquidating assets to fund a cash
need. Because the interest Baird receives and fees
Baird earns on a client’s Accounts increase as the
amount of the client’s margin loan increases, Baird
and Baird Financial Advisors also have an incentive
to recommend that the client continue to maintain
a margin loan balance with Baird at high levels.
Baird has the right to lend the securities a client
pledges as collateral for the client’s margin loan,
and Baird receives additional compensation for
lending those securities, which provides Baird a
further incentive to recommend margin to a client.
In addition, outside of the Trust Alliance Program,
Baird Financial Advisors may refer a client to Baird
Trust to provide investment management and trust
administration services to the client. If a client
enters into such a relationship with Baird Trust,
Baird and the client’s Baird Financial Advisor
typically provide ongoing relationship management
services.
provides
compensation to Baird and the client’s Baird
Financial Advisor for the referral and providing
ongoing services, which may be up to 50% of the
ongoing fees that a client pays to Baird Trust, and
which is credited to the client’s Baird Financial
Advisor for purposes of determining the Financial
Advisor’s compensation. The compensation paid to
Baird and a client’s Baird Financial Advisor does not
increase the fees that the client pays to Baird Trust.
Due to Baird’s affiliation with Baird Trust and the
compensation paid to Baird and Baird Financial
Advisors, Baird and Baird Financial Advisors have a
financial incentive to favor Baird Trust over other
trust companies.
A client should note that Baird’s margin loan
program is generally intended to be used to fund
additional purchases of securities or short-term
liquidity needs. If a client wishes to obtain a loan
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Baird PWM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
for some other purpose, a client should instead
consider whether the client is eligible for Baird’s
Securities-Based Lending Program, which involves
clients obtaining loans from third-party lenders for
general use purposes. Baird and Baird Financial
Advisors have a conflict to the extent they would
recommend that a client use the Baird margin loan
program instead of the Securities-Based Lending
Program because a client pays interest and other
fees to Baird instead of a third-party lender.
Additional important information about margin,
including the risks and margin interest rates that
apply, is set forth in the “Margin” section of Baird’s
website at bairdwealth.com/retailinvestor.
Securities-Based Lending Program
lending
is set
Advisors receive a referral fee if a client obtains a
loan from a third party lender under Baird’s
Securities-Based Lending Program, Baird and Baird
Financial Advisors have an incentive to recommend
that a client obtain loans under that program. Baird
and Baird Financial Advisors will continue to
receive compensation on assets held in a client’s
accounts that are collateral for such loans,
including Program Fees on such assets if those
assets are in the client’s advisory Account. As a
result, Baird and Baird Financial Advisors have a
financial incentive to recommend that a client
obtain a loan under the program to provide for the
client’s needs instead of liquidating assets in the
client’s accounts with Baird because a decline in
the amounts the client has in the client’s accounts
will result in lower revenues to Baird and
compensation paid to the client’s Baird Financial
Advisor. Additional important information about
securities-based
forth in the
“Securities-Based Lending Program” section of
Baird’s website at bairdwealth.com/retailinvestor.
A client should understand that any referral made
by Baird and its Financial Advisors under the
Securities-Based Lending Program is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
oversee any such lending arrangement.
Other Non-Advisory Services
Certain Baird associates from time to time may
provide clients with tax return preparation, bill pay
or related services. In some instances, the fee for
those services may be bundled with the Program
Fee. A client should understand that the provision
of such services is separate from, and not related
to, the Programs offered under this Brochure and
will be governed by an agreement separate from
the client’s advisory agreement with Baird. A client
should understand that Baird and its associates do
not act as investment advisor or fiduciary to the
client when providing tax return preparation, bill
pay or related non-advisory services to the client.
Client Responsibilities
Baird offers clients an opportunity to borrow money
from a third party lender under Baird’s Securities-
Based Lending Program. These loans, if made, can
be used for any personal or business purpose other
than to purchase, carry or trade securities, or to
repay margin debt. These loans are secured by the
investments and other assets in the client’s
accounts with Baird. A client will pay interest on
the outstanding balance of the client’s loan. The
rates of interest charged by the bank depends on
many factors, such as the prevailing interest rate
environment, the amount of the loan or line of
credit, a client’s creditworthiness, and
the
aggregate assets in a client’s Baird accounts in the
client’s household
(“relationship size”). The
interest rates are based on a benchmark rate, plus
an applicable percentage that varies based on the
approved loan amount and the relationship size.
Rates are generally higher for smaller loans and
relationship sizes and lower for larger loans and
relationship sizes. The interest rate that will apply
to a client’s loan will be set forth in the loan
agreement the client enters into with the bank.
Baird receives an ongoing administrative fee from
the bank, at an annual rate of up to 2.50% of the
outstanding balance under a client’s loan, which is
paid by the bank out of the interest the client pays
to the bank. A client’s Baird Financial Advisor
typically receives an ongoing referral fee at an
annual rate of up to 0.25% of the outstanding
balance of the client’s loan, which is paid out of
Baird’s administrative fee. A client should note that
Baird and Baird Financial Advisors will continue to
receive compensation on assets held in the client’s
accounts that serve as collateral for the client’s
loans, including Program Fees. Because Baird
receives an administrative fee and Baird Financial
A client is responsible for providing information to
Baird and the client’s Baird Financial Advisor
reasonably requested by them in order to provide
the services selected by the client. Baird, the
client’s Baird Financial Advisor and investment
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
from other
investment products will be treated as partners for
U.S. federal income tax purposes, which has tax
implications different
types of
investments, including Schedule K-1 reporting.
Investments
and
taxable
is
responsible
for
any
Clients with tax-exempt Accounts, such as certain
Retirement Accounts or charitable or religious
organization Accounts, should be aware that some
investments, such as some Non-Traditional Assets,
Complex
Alternative
Investments, may produce
income,
referred to as unrelated business taxable income
(“UBTI”). In such circumstances, such clients will
be required to pay tax on the UBTI produced by the
tax-exempt Accounts.
managers, if any, will rely on this information when
providing services to the client. A client is also
responsible for promptly informing the client’s
Baird Financial Advisor of any significant life
changes (e.g., change in marital status, significant
health issue, or change in employment) or if there
is any change to the client’s investment objectives,
risk tolerance, financial circumstances, investment
needs, or other circumstances that may affect the
manner in which the client’s assets are invested.
None of Baird, the client’s Baird Financial Advisor
or any investment manager managing a client’s
adverse
Account
consequence arising out of the client’s failure to
promptly inform the client’s Baird Financial Advisor
of any such changes. Since investment goals and
financial circumstances change over time, a client
should review the client’s participation in a
Program with the client’s Baird Financial Advisor at
least annually.
Retirement Accounts
legal advice
A client’s ability to recognize losses in an Account
for tax purposes may be disallowed, limited or
deferred by applicable tax rules. For example, IRS
wash sales rules will disallow a client’s tax
deductions for a loss in an Account related to the
sale of an investment if the client purchases
(whether through Baird or another firm) a
“substantially identical” investment within the
wash sale period (currently 30 days before or 30
days after the date of the sale). Similarly, IRS
straddle rules limit and defer a client’s ability to
claim tax deductions related to the loss on a sale
of an investment in an Account if the client holds
an offsetting position in any account held at Baird
or another firm.
to
clients.
The
Additional laws, regulations and other conditions
apply to Retirement Accounts. Each owner,
trustee, plan
sponsor, adopting employer,
responsible plan fiduciary, named fiduciary, or
other fiduciary acting on behalf of a Retirement
Account (“Retirement Account Fiduciary”) should
understand that Baird and its associates do not
provide
regarding Retirement
Accounts. A Retirement Account Fiduciary is urged
to consult with his or her own legal advisor about
the laws and regulations that may apply to
Retirement Accounts. ERISA and the IRC prohibit
Baird from offering certain types of investment
products and services to Retirement Accounts.
Legal and Tax Considerations
A client’s investment activities may have legal and
tax consequences to the client.
purchases,
sales,
The investment strategies used for a client’s
Account and transactions in a client’s Account,
liquidations,
including
redemptions, and rebalancing transactions, may
cause the client to realize gains or losses for
income
tax purposes. Funds often make
distributions of income and capital gains to
investors, which may cause the client to realize
income for tax purposes.
Baird and its associates do not offer legal or tax
advice
information,
recommendations, and services provided by Baird
and its associates to clients through the Programs,
including, without limitation, tax management
strategies, do not constitute tax advice. A client is
responsible for understanding the tax implications
of the investment activities in the client’s accounts
(whether held at Baird or another firm) and
complying with applicable tax rules. A client is
strongly urged to consult with the client’s tax
advisor about potential tax implications before
making investment or trading decisions. Baird and
its associates do not undertake any responsibility
to monitor or verify a client’s compliance with
applicable tax rules, and they are not responsible
for any tax‑related effects or obligations resulting
from the investments or transactions in a client’s
Account.
Certain investment products, such as Alternative
Investments and Complex Investments, are
classified as partnerships. Clients invested in such
52
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Program Fees
Fee Options and Fee Schedules
other services provided by Baird and the manager
to the client’s Account, which may
include
departments or affiliates of Baird. If a client has a
Unified Advice Fee Arrangement, the client’s
Program Fee rate will be equal to the sum of the
applicable Advice Fee rate and the applicable
Portfolio Fee rate, if any.
A client’s advisory agreement will set forth the
actual compensation the client will pay to Baird. In
most instances, a client pays an ongoing Program
Fee based upon the value of assets in the client’s
Account (an “asset-based fee”), although other
options, such as a flat fee, may be available.
Asset-Based Fee Arrangements
Clients with a Unified Advice Fee Arrangement may
generally choose a tiered or breakpoint fee
schedule for the Advice Fee portion of the Program
Fee.
Baird generally offers two types of asset-based fee
arrangements: a tiered fee schedule and a
breakpoint fee schedule.
Tiered Advice Fee Schedule
The following fee schedule sets forth the maximum
tiered Advice Fee rates for the Programs.
Tiered Advice Fee Schedule
Value of Assets
Annual Fee Rate
First $1,000,000
2.00%
Next $1,000,000
1.50%
Next $3,000,000
1.35%
Next $5,000,000
1.25%
Under a tiered fee schedule, the asset-based fee
will vary for different segments of client assets,
gradually decreasing as the Account balance
increases. For example, a client with an Account
value of $1,000,000 may pay one rate on the first
$250,000 of assets in the Account, a lower rate on
the next $250,000 of assets in the Account and a
still lower rate on the remaining $500,000 of
assets. Use of a tiered fee schedule will result in a
blended asset-based fee rate.
Above $10,000,000
1.00%
Breakpoint Advice Fee Schedule
The following fee schedule sets forth the maximum
breakpoint Advice Fee rates for the Programs.
Breakpoint Advice Fee Schedule
Under a breakpoint fee schedule, the asset-based
fee is determined by reference to the market value
of the client’s Account assets, with the fee being
equal or lower for accounts with higher levels of
assets. The breakpoint fee, once determined, is
then applied to all of the assets in the client’s
Account.
Value of Assets
Annual Fee Rate
$0 to $1,000,000
2.00%
$1,000,000 to $1,999,999
1.75%
$2,000,000 and above
1.50%
Portfolio Fee Schedule
The typical asset-based fee varies depending upon
the Program and the fee option selected by the
client. Fee options and rates may also differ among
different Accounts held by the same client,
depending on the Program and services selected
for an Account.
All new client Accounts paying an asset-based fee
are generally subject to a unified advice fee
arrangement (“Unified Advice Fee Arrangement”),
which is described below.
The Portfolio Fee rate varies by Program,
investment vehicle, and the type of investment
strategy or style being pursued by the Account.
The following fee schedule sets forth the maximum
Portfolio Fee rates or range of rates for the
Programs.
Portfolio Fee Schedule
Unified Advice Fee Arrangement
Program
Annual Fee Rate
or Range of
Rates
0.00%
ALIGN Elements Portfolios
0.00%
ALIGN Strategic Portfolios
ALIGN UMA Select Portfolios1
Under a Unified Advice Fee Arrangement, the
asset-based Program Fee is comprised of an advice
fee (“Advice Fee”) and, for some Programs, an
additional portfolio fee (“Portfolio Fee”). The Advice
Fee covers certain investment advisory, brokerage
and custody services provided by Baird. The
Portfolio Fee covers portfolio management and
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Portfolio Fee Schedule
Portfolio Fee Schedule
Program
Annual Fee Rate
or Range of
Rates
Program
Annual Fee Rate
or Range of
Rates
0.25% - 0.52%
Equity SMA Strategies
0.00%
Private Investment
Management (PIM)
0.16% - 0.40%
Fixed Income SMA Strategies
0.00%
Russell Model Strategies
0.25% - 0.60%
Global and International SMA
Strategies
Unified Advisory Select (UAS)
Portfolios1
0.00%
Mutual Funds
0.25% - 0.52%
Equity SMA Strategies
0.00%
ETFs
0.25% - 0.52%
Balanced SMA Strategies
0.00%
0.16% - 0.40%
Fixed Income SMA Strategies
ALIGN Strategic Sleeve or
Portfolio
0.00%
0.25% - 0.60%
Baird Advisory Choice
Global and International SMA
Strategies
0.00%
BairdNext Portfolios
0.32% - 0.50%
Riverfront SMA Strategies
0.02% - 0.50%
Fund Strategist Portfolios
Baird Affiliated Managers
Portfolios
0.00%
PWM-Managed Portfolios
Mutual Funds
0.00%
0.00%
AQA Portfolios
ETFs
0.00%
0.00%
ALIGN Elements Portfolios
Baird Recommended
Portfolio
0.00%
0.00%
ALIGN Strategic Sleeve or
Portfolio
Baird Rising Dividend
Portfolio
0.00%
AQA Portfolios
Baird Equity Asset Management
0.00%
Baird Recommended Portfolio
0.35% - 0.50%
SAM Strategic Portfolios
0.00%
Baird Rising Dividend Portfolio
0.32% - 0.50%
Other Portfolios
0.32% -0.40%
0.32% - 0.50%
Riverfront Managed Portfolios
Baird Equity Asset
Management Portfolios
0.35% - 0.45%
0.35%
Baird Trust Strategies
Baird Trust Strategies
0.37%
0.35% - 0.37%
CCM Portfolios
CCM Portfolios
0.15% - 0.25%
0.02% - 0.37%
GAMMA Portfolios
Strategas Portfolios
0.02% - 0.37%
Strategas Portfolios
Baird Recommended Managers
0.18% - 0.75%
Equity SMA Strategies
0.20% - 0.32%
Fixed Income SMA Strategies
1 Reflects the range of fees charged by managers or
products that are not affiliated with Baird. The range of
fees charged by Baird or by managers or products
affiliated with Baird are shown elsewhere in the Portfolio
Fee Schedule.
0.32% - 0.47%
Global and International SMA
Strategies
0.35% - 0.60%
Other SMA Strategies
0.10%
ALIGN 55ip Tax Managed
Solutions
Baird SMA Network (BSN)
2 Fees charged by managers under the DC Program are
negotiated by each client pursuant to a separate
agreement that does not include Baird. Baird, therefore,
does not have the necessary information to provide a
definitive range of fees paid to managers under the DC
Program.
0.22% - 0.77%
Equity SMA Strategies
0.22% - 0.52%
Balanced SMA Strategies
0.10% - 0.27%
Fixed Income SMA Strategies
0.27% - 0.52%
Global and International SMA
Strategies
0.37% - 0.77%
Alternative SMA Strategies
0.02% - 0.50%
Fund Strategist Portfolios
The Portfolio Fee rates are current as of the date of
this Brochure. A client’s actual Portfolio Fees could
be higher or lower than the amounts shown above
if Baird adds new investment managers to the
Programs with higher or lower fees or if Baird and
a manager renegotiate the amount of the
subadvisory fee.
—2
Dual Contract (DC)
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
The Advice Fee and Portfolio Fee rates do not
reflect the internal fees and expenses of any Funds
or other investment products used in connection
with a strategy, the costs of which are borne by a
client in addition to the Program Fee. See “Other
Fees and Expenses” below.
class in the Account. In other words, the overall
Portfolio Fee rate for the UMA as a whole will be a
blended rate. The blended Portfolio Fee rate, and
the actual Portfolio Fee paid by a client, will vary
over time due to many factors, including market
appreciation or depreciation of the assets in the
Account and changes in allocations to different
investment vehicles or asset classes in the
Account.
Overlay Manager Tax and Value Overlay
Services
The Overlay Manager charges an additional fee for
tax and value overlay services, which will be
included in the Program Fee. The amount of the fee
will be disclosed to a client prior to enrolling an
Account in the service.
Baird provides operational and administrative
services to 55ip
in connection with 55ip’s
management of client Accounts using an ALIGN
55ip Tax Managed Solution. As compensation for
those services, Baird receives a portion of the
Portfolio Fee at an annual rate of up to 0.02% of
the value of the Account. Additional information is
contained in the document titled “Administrative
Servicing, Revenue Sharing, and Other Third Party
Payments” available on Baird’s website at
bairdwealth.com/retailinvestor.
Flat Fee Arrangement
The Portfolio Fee rates set forth above do not
include the overlay fees charged by the Overlay
Manager for tax overlay or values overlay services,
which are generally 0.10% of the value of the
Account annually.
Under a flat fee arrangement, the applicable fee
may be determined according to a fixed asset-
based fee rate or may be a fixed dollar amount.
Specific services may each have their own,
separately-stated, flat fee, or several services may
be grouped together under a single flat fee. Some
services may entail a flat fee per usage. Flat fees
are negotiable and vary by client. The details of flat
fee arrangements, including fee amounts, the
billing schedule, and the services covered, will be
included in the client’s advisory agreement.
Program Account Minimums
The minimum asset value to open an Account in a
Program is set forth in the table below.
Account Minimum
Program
Asset Level
ALIGN Elements Portfolios
$5,000
Certain managers offer lower Portfolio Fee rates for
SMA Strategies to clients through the DC Program
compared to the BAM, BRM or BSN Programs. If a
client has decided to participate in the DC Program,
upon the client’s request, the client’s Financial
Advisor may assist the client with the client’s
negotiation with the manager of the Portfolio Fee
rate for the applicable SMA Strategy. The Portfolio
Fee negotiated by the client could be higher or
lower than the Portfolio Fee that applies to the
same SMA Strategy that is available through other
Programs. The client is ultimately responsible for
understanding the differences between the SMA
Programs, deciding to participate in the DC
the SMA Strategy, and
Program, selecting
negotiating and agreeing to the Portfolio Fee rate.
ALIGN Strategic Portfolios
ALIGN UMA Select Portfolios
$25,000
$100,000(1)
Baird Advisory Choice
$10,000
investments
BairdNext Portfolios
$5,000
Baird Affiliated Managers
$250,000
Baird Equity Asset
Management Growth
Portfolios
$250,000(2)
Baird Equity Asset
Management SAM
Portfolios
Baird Trust
$60,000
Important Information about UMAs and Blended
Rates. UMAs offer
in different
investment vehicles (such as mutual funds, ETFs,
SMAs and PWM-Managed Portfolios) and asset
classes (such as equity securities and fixed income
securities). Each investment vehicle and asset
class may have a different Portfolio Fee rate, which
is shown in the table above. For purposes of
calculating the Portfolio Fee for a UMA, the Portfolio
Fee rate applicable to each investment vehicle or
asset class will be applied to the value of assets
invested in each such investment vehicle or asset
$100,000(3)
Riverfront Managed
Portfolios
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Account Minimum
to the increase in resources needed to administer
the Account.
Program
Asset Level
$50,000
Riverfront Managed ETF
Portfolios
CCM Portfolios
$100,000
GAMMA Portfolios
A client is encouraged to periodically review with
the client’s Financial Advisor the client’s Program
Fee and the services provided to determine if the
services and fees continue to meet the client’s
needs.
Strategas Portfolios
$250,000
$100,000(4)
$100,000(5)
Calculation and Payment of Program Fees
Baird Recommended
Managers
Baird SMA Network
Dual Contract
$100,000(5)
$100,000(5)
$50,000(6)
Private Investment
Management
Russell Model Strategies
$10,000
$5,000(7)
Unified Advisory Select
(UAS) Portfolios
(1) Account minimums for ALIGN UMA Select Portfolios
range from $100,000 to $400,000, depending upon
the particular Portfolio.
Baird will calculate a client’s Program Fee by
applying the applicable fee rate to the value of all
of the assets in the client’s Accounts, including
cash and its equivalent and including all Held-Away
Assets, unless otherwise agreed to in writing.
Liabilities held in a client's Accounts, including the
value of margin debit balances, open short sale
positions and open options positions with a
negative market value will be excluded from the
calculation of a client's Program Fee. The value of
cash balances held in a client’s Account will be
excluded from the calculation of a client's Program
Fees in an amount equal to the value of any open
short sale positions and options positions with a
negative market value held in the margin account.
(2) Baird Equity Asset Management’s SAM Strategic
Portfolios have a minimum account requirement of
$250,000 and its SAM Custom Portfolios have a
minimum account requirement of $1,000,000.
(3) Riverfront Managed Portfolios have an account
minimum ranging from $50,000 to $100,000.
(4) Strategas Managed Portfolios that use strategies that
primarily invest in mutual funds or ETFs may have
an account minimum as low as $25,000.
(5) BSN Fund Strategist Portfolios have a minimum
account requirement of $10,000. Other SMA
Strategies typically have an account minimum of
$100,000. However, each investment manager sets
its own minimum account size requirements, which
can range from $25,000 to more than $1,000,000.
As a result, some investment managers may not be
available to clients with smaller accounts.
If requested by a client and approved by Baird, a
client’s Program Fee may be determined by also
including the aggregate value of assets in certain
other Advisory accounts held by a client and certain
members of the client’s household or family (a
“household fee arrangement”). A client should note
that Retirement Accounts may not be included in a
household fee arrangement to the extent a
prohibited transaction under ERISA or the IRC may
result. The terms of any such household fee
arrangement will be set forth in the client’s
advisory agreement.
(6) PIM Accounts that use strategies that primarily
invest in mutual funds or ETFs may have an account
minimum of less than $50,000.
(7) Account minimums vary depending upon the
investments that are selected for UAS Program
Account and will be significantly higher if, for
example, an SMA Strategy is selected.
including but not
While Baird and Baird Financial Advisors may
perform an analysis as to whether any client
Accounts may be eligible for a household fee
arrangement, a client should note that it is client’s
sole responsibility to inform the client’s Financial
Advisor that client’s household or family has two or
more Advisory accounts that are eligible for a
household fee arrangement. Baird and its Financial
Advisors do not undertake any obligation to ensure
client Accounts are eligible for a household fee
arrangement. By agreeing to a household fee
arrangement, each client subject
to such
household fee arrangement consents to Baird
providing to each other client subject to such
in Baird’s sole
household
fee arrangement,
A client’s Account may also be subject to a
minimum quarterly Program Fee that will be set
forth in the client’s advisory agreement regardless
of the value of the assets in the client’s Account. In
addition, if a third party custodian has custody of
the client’s Account assets, Baird may impose
Account requirements different than those set forth
limited to higher
above,
minimums, and it may impose additional fees due
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
discretion, information about the aggregate level,
or range, of household assets used for fee
calculation purposes. As a result, each such client
should understand that the other clients included
in the household fee arrangement may be able to
ascertain the amount of the client’s assets at Baird.
As mentioned above, Baird will include cash and
cash equivalent balances in a client’s Account when
calculating a client’s asset-based Program Fee.
Baird has adopted internal policies that monitor the
percentage of an Account swept into cash under
the Cash Sweep Program. These internal policies
are designed to inform Baird Financial Advisors and
their clients who hold large cash sweep balances in
their Accounts for sustained periods that those
Accounts are holding large cash sweep balances
and that there may be other investment or account
options for their cash and that Baird receives direct
compensation in addition to the Program Fee from
client balances in the Cash Sweep Program.
If a client maintains a debit balance in the client’s
margin account with Baird, such balance has no
bearing on the asset-based Program Fees charged
on client’s Account. In other words, the margin
balance (i.e., the outstanding amounts of the
margin loan a client owes to Baird) in client’s
Account will not be applied to reduce the client’s
billable Account value in calculating the Program
Fee.
For purposes of calculating a client’s asset-based
Program Fee, the value of a client’s assets is
generally determined by Baird. Baird generally
relies upon third party sources, such as third party
pricing services when valuing Account assets. In
some instances, such as when Baird is unable to
obtain a price for an asset from a pricing service,
Baird may obtain a price from its trading desk or it
may elect to not price the asset. Obtaining a price
from its trading desk may present a conflict of
interest. In some cases, Baird obtains prices from
the issuers or sponsors of investment products in
the client’s Account when prices are not otherwise
readily available. This frequently occurs with
respect to the valuation of annuities, Complex
Investment Products, community bank stocks and
private funds. If the assets in the client’s Account
are held by a custodian other than Baird, Baird may
also use valuation information provided by the
client’s third party custodian in determining the
value of the assets in the client’s Account.
The Account value used for the Program Fee
calculation may differ from that shown on a client’s
Account statement or performance report due to a
variety of factors, including the client’s use of
margin, options,
sales, and other
short
considerations. If a client has assets held by a third
party custodian, the prices shown on a client’s
Account statements provided by the custodian
could be different from the prices shown on
statements and reports provided by Baird. See
“Services, Fees and Compensation—Additional
Program Information—Custody Services” above for
more information.
for
Complex
Investment
Baird does not conduct a review of valuation
third party pricing
information provided by
services, issuers, sponsors, or custodians, and it
does not verify or guarantee the accuracy of such
information. Baird does not accept responsibility
for valuations provided by third parties that are
inaccurate unless Baird has a reason to believe that
the source of such valuations is unreliable.
investments, particularly
Valuation data
annuities,
Products,
community bank stocks and private funds, may not
be provided to Baird in a timely manner, resulting
in valuations that are not current. The prices
obtained by Baird from third party pricing services,
issuers, sponsors and custodians may differ from
prices that could be obtained from other sources.
Values used for fee-calculation purposes may vary
from prices received in actual transactions and are
not firm bids, offers or guarantees of any type with
respect to the value of assets in an Account, and
the Program Fee for some securities may be
calculated based on values that are greater than
the amount a client would receive if the securities
were actually sold from the client’s Account.
A client’s Program Fees are payable in accordance
with the terms of the client’s advisory agreement.
Typically, Program Fees are payable on a calendar
quarterly basis, in advance. The initial billing period
begins when the client’s advisory agreement is
accepted by Baird and the Account is opened by
Baird (the “Opening Date”). The initial Program Fee
payment will be adjusted for the number of days
remaining in the then current quarter. The initial
Program Fee will be based on the value of assets
in the client’s Account on the Opening Date. The
period which such payment covers shall run from
the Opening Date through the last business day of
the then current calendar quarterly billing period.
Thereafter, the quarterly Program Fees shall be
calculated based upon the Account’s asset value on
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the last business day of the prior calendar quarter
and shall become payable on the first business day
of the then current calendar quarter.
made. However, Baird, in its sole discretion, may
make fee adjustments in response to asset
fluctuations in a client’s Account occurring during a
billing period that result from contributions to, or
withdrawals from, the client’s Account.
“Program
Fees—Program
Each Program may have a minimum asset value in
order to open an Account as further described
under
Account
Minimums” above. A client’s Account may be
subject to a minimum Program Fee. The minimum
Program Fee will be described in the client’s
the
advisory agreement. Baird may waive
minimum Program Fee at its discretion. The
minimum Program Fee is subject to change upon
notice to the client.
A client’s Program Fees and other charges will be
automatically deducted from the client’s Account,
unless the client requests, and Baird agrees, to an
alternate arrangement, such as having Baird issue
the client an invoice for the Program Fees (“direct
billing”). A client should understand that the
client’s Program Fees and other charges relating to
the client’s Account may be satisfied from free
credit balances and other assets in the client’s
Account. If free credit balances in a client’s Account
are insufficient to pay the Program Fees or other
charges when due, Baird and any investment
manager managing the client’s Account may sell
investments from the client’s Account to the extent
they deem necessary and appropriate, in their sole
discretion, to pay the client’s Program Fees and
other charges.
The Program Fee and minimum account value are
negotiable in certain instances and may vary based
upon a number of factors, including but not limited
to the size and nature of the assets in the client’s
Account, the client’s particular investment strategy
or objective, and any particular services requested
by the client. In some instances, clients may pay a
higher fee than indicated in the fee schedules
above. The fees paid by a client may differ from
the fees paid by other clients based on a number
of factors, including but not limited to the factors
identified above.
If a client’s Account is subject to direct billing, the
client is required to pay each bill within 30 days of
the date of the invoice. Baird may automatically
deduct a client’s Program Fees and other charges
from the client’s Account as described above in the
event that Baird does not receive payment from
the client within 30 days of the date of the invoice.
Baird may rescind a direct billing arrangement with
a client at any time. Direct billing may not be
available for Retirement Accounts.
To the extent permitted by applicable law, Baird
may modify a client’s existing fees and other
charges or add additional fees or charges by
providing the client with 30 days’ prior written
notice.
The fee schedules set forth above are the current
fee schedules for the Programs. Each Program has
had other fee schedules in effect, which may reflect
fees that are lower or higher, as the case may be,
than those shown above. As new fee schedules are
put into effect, they are made applicable only to
new clients, and fee schedules applicable to
existing clients may not be affected. Associates and
affiliates of Baird may be eligible for reduced fees.
Therefore, some clients may pay different fees
than those shown above.
Obtaining Program Services Separately:
Brokerage or Advisory? Factors to Consider
If either Baird or the client terminates the client’s
advisory agreement or the client’s participation in
a Program, a pro-rated refund from the date of
termination through the end of the applicable
billing period will generally be made to the client in
the client’s affected Accounts. Baird will not
implement a decrease in the client’s fee rate during
a billing period or otherwise reimburse or adjust
Program Fees during any such period for asset
value appreciation or depreciation in a client’s
Account during such period. For example, if a
client’s Account is subject to a tiered or breakpoint
fee schedule and the asset levels of the Account
move into a new tier or cross a breakpoint during
such period, no rebate or fee adjustment will be
Baird generally does not offer the Programs to
clients on an unbundled basis. In other words, the
Programs do not permit clients to pay for services,
such as investment advice, trade execution, and
separately. However, Baird offers
custody
brokerage accounts and other services to clients,
and certain services provided to a client in
connection with a particular Program may be
available to a client outside of the Program
separately. Thus, a client’s participation in a
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
internal ongoing operating fees and expenses
(e.g., Funds).
Program could cost the client more or less than if
the client purchased each service separately. A
number of factors bear upon the relative cost of
each Program. In comparing the Programs to
brokerage accounts or other services, a client
should consider a number of factors, including, but
not limited to:
Additional important information about brokerage
accounts and facts to consider when making
account type decisions is contained in the Client
Relationship Details document, which should have
been delivered to the client and is available on
Baird’s website at bairdwealth.com/retailinvestor.
• whether a client prefers to have ongoing
monitoring, investment advice or professional
management of the client’s investments, which
are provided to Program Accounts, or whether
the client does not want or need such services;
A client should review other account types and
programs with the client’s Financial Advisor to
determine whether they are more appropriate or
should be used in addition to a Program.
• whether the types of investment strategies,
products and solutions the client seeks are
available;
Program Fee Payments to Baird, Financial
Advisors and Investment Managers
Baird and its associates and Associated Managers
benefit from the Program Fees and charges that
clients pay for the services described in this
Brochure.
• whether there are limitations on the types of
securities and other investments available for
purchase and whether those limitations are
significant to the client;
• whether the nature and level of transaction
services, account performance reporting, or
other ancillary services the client wants are
available;
Baird retains the entire Program Fee paid by
clients, except as further described below. With
respect to SMA Strategies available under the SMA
and UMA Programs managed by Other Managers,
Baird pays Other Managers (including Associated
Managers and Implementation Managers, if any) a
Portfolio Fee or subadvisory fee as compensation
for the manager’s services as further described
below.
• whether the client prefers to pay an ongoing
Program Fee for continuous advice or pay
commissions and other fees on a transaction-by-
transaction basis;
• the relative costs and expenses of a Program
Account and a brokerage account, which will vary
depending upon:
fee or commission rate
the client
o the
negotiates;
o the size of the client’s account;
o the level of trading activity and size of trade
orders;
o applicable account fees and charges;
Client Accounts are generally subject to a Unified
Advice Fee Arrangement in which the Program Fee
consists of an Advice Fee and a separate Portfolio
Fee. Baird pays the manager out of the Portfolio
Fee paid by the client. The Portfolio Fee rates are
set forth under “Fee Options and Fee Schedules—
Unified Advice Fee Arrangement—Portfolio Fee”
above. However, Baird, in many instances, retains
a portion of the Portfolio Fee when a client’s
Account is managed by an Other Manager. The
maximum portion of the Portfolio Fee retained by
Baird in those instances is equal to an annual rate
of 0.10% of the value of a client’s Account. Such
amounts are retained by Baird for the services it
provides.
o the client’s use of third party managers who
charge their own fees for managing accounts
in addition to Baird’s Advice Fee; and
o the amount of the client’s account invested in
investment products that have additional
As the portion of the Program Fee or Portfolio Fee
paid to an Other Manager increases, the portion of
the Program Fee or Portfolio Fee that is retained by
Baird decreases. Thus, Baird (but not its Financial
Advisors) has an incentive to recommend or favor
investment managers that are paid less, because
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird will receive a higher portion of the Program
Fee or Portfolio Fee.
Advisor’s total production level. Thus, Baird
Financial Advisors have a general incentive to
generate financial and other plans and charge
higher fees for advisory accounts and recommend
larger investments in advisory accounts.
In addition, Baird has an incentive to favor
Associated SMA Strategies over other SMA
Strategies because the entire Program Fee is
retained by Baird and Associated Managers and
because Baird benefits from its receipt of Program
Fees and the overall success of Associated
Managers. For more information, see “Additional
Information—Other Financial Industry Activities
and Affiliations” below.
incentive
Given the nature of the Program Fee, Baird also
has an
to select or recommend
investment managers that trade less frequently
with or that trade away from Baird because Baird
will incur lower trading costs with respect to such
managers and such relationships will be more
profitable to Baird. With respect to UMAs, Baird
retains a portion of the Portfolio Fee paid to certain
managers as described above. Thus, Baird has an
incentive to favor SMA Strategies provided by
those managers over other SMA Strategies, mutual
funds, ETPs and PWM-Managed Portfolios because
it will be more profitable for Baird.
Interest
Given the structure of their compensation, they
also have an incentive to recommend that a client
transfer the client’s accounts to Baird, establish
new accounts with Baird (including IRA rollovers)
and add more money into the client’s accounts. In
addition, most Baird Financial Advisors are
shareholders of Baird Financial Group, Inc.
(“BFG”), Baird’s ultimate parent company, and
thus benefit financially from the overall success of
Baird and its Associated Parties. The number of
shares of BFG stock that a Financial Advisor may
purchase is based in part on the Financial Advisor’s
total production level. Baird Financial Advisors
generally receive compensation for referrals to
certain affiliated managers and products and for
referrals to a limited number of other firms. More
specific information is provided under the headings
“Additional Information—Other Financial Industry
Activities and Affiliations” and
“Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading—Participation or
in Client
Transactions” below. They also generally receive
non-cash compensation and other benefits from
Baird and from sponsors of investment products
with which Baird does business. Such non-cash
compensation and other benefits may include
invitations to attend conferences or educational
seminars, payment of related travel, lodging and
meal expenses, reimbursement for branch and
client events, and
receipt of gifts and
entertainment. Receipt of such compensation and
benefits provides Baird Financial Advisors an
incentive to favor investment products and their
sponsors that provide the greatest levels of
compensation and benefits.
eligible
for
professional
Baird Financial Advisors generally
receive
recruitment bonuses and/or special compensation
from Baird when they join Baird from another firm.
The amount of such special compensation is
typically based on the Baird Financial Advisor’s
production at the prior firm for the 1-year period
prior to joining Baird or on the level of the Financial
Advisor’s client assets at the prior firm. All or a
substantial portion of the special compensation is
paid in the form of an upfront bonus when the Baird
Financial Advisor joins Baird, and the remaining
portion, if any, is paid in the form of back end
A Baird Financial Advisor is primarily compensated
on a monthly basis based upon a percentage of the
Financial Advisor’s total production each month,
which primarily consists of the total advisory fees
and transaction-based fees paid to Baird by the
Financial Advisor’s clients and any other fees Baird
earns on advisory and brokerage accounts held by
those clients, including trail fees paid by third
parties. The percentage of the Financial Advisor’s
total production actually paid to the Financial
Advisor will increase as the total amount of the
Financial Advisor’s production increases, meaning
that, as the total amount of the Financial Advisor’s
production increases, the rate and amount of
compensation that Baird pays to the Financial
Advisor also increase. Baird Financial Advisors
generally also receive deferred compensation or
bonuses based on various criteria, including net
new assets they gather, performing certain wealth
management activities, such as financial planning,
and their total production levels. Baird Financial
Advisors who achieve certain production thresholds
are
development
conferences, business development coaching,
reimbursements, awards and recognition trips to
attractive destinations. Baird Financial Advisors are
also eligible for bonuses for achievement of
professional designations depending on a Financial
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
than
will have a financial incentive to trade less for Baird
Advisory Choice Accounts
traditional
brokerage accounts and to reduce trading or
increase a client’s Program Fees if trading for a
client’s Advisory Choice Account exceeds certain
levels established by Baird. From time to time,
Baird Financial Advisors outside of the PIM Program
may refer their clients to PIM Managers. In those
instances, the PIM Manager generally shares a
portion of his or her compensation with the
referring Baird Financial Advisor.
Baird addresses the conflicts described above
through disclosure in this Brochure and by
adopting internal policies and procedures for Baird
and its associates that require them to provide
investment advice that is suitable for advisory
clients (based upon the information provided by
such clients).
Other Fees and Expenses
Cost and Expense Information for Certain
Investment Products
include
fees, distribution (12b-1)
fees, accounting
under
the
heading
Interest
bonuses generally in equal installments on an
annual basis thereafter for a certain number of
years (generally from one to three years).
Installment payments are generally contingent
upon the Baird Financial Advisor achieving annual
production or client asset levels that exceed a
significant percentage of the Financial Advisor’s
annual production for the 1-year period prior to
joining Baird or the client assets that the Financial
Advisor had prior to joining Baird. The special
compensation is intended to compensate Baird
Financial Advisors for the significant effort involved
in transitioning their business from the prior firm.
This compensation provides Baird Financial
Advisors who have left another firm additional
incentive to recommend that clients of the prior
firm become Baird clients and to recommend
investment products and services that increase
their production, and thus presents a conflict of
interest. The special compensation is generally
structured in the form of a forgivable loan from
Baird to the Baird Financial Advisor. Under the
terms of the forgivable loan, Baird makes the
upfront or installment payment to the Baird
Financial Advisor in the form of a loan, and Baird
forgives a portion of the loan made to the Baird
Financial Advisor each month for so long as the
Baird Financial Advisor remains Baird’s employee.
Should the Baird Financial Advisor cease to be
Baird’s employee prior to the maturity date of the
loan, the Baird Financial Advisor is required to
repay Baird the amount of the loan outstanding
and not forgiven by Baird. In other words, upon
leaving Baird, the Baird Financial Advisor would be
required to repay to Baird a portion of the special
compensation that the Baird Financial Advisor had
received and that had not been forgiven. The
amount of such repayment declines over time in
proportion to the time the Baird Financial Advisor
remains Baird’s employee. Structuring this special
compensation in the form of forgivable loans
provides
the Baird Financial Advisor added
incentive to remain Baird’s employee and to
recommend that persons become and remain a
Baird client. Additional information about referral
and non-cash compensation and other financial
incentives provided to Baird Financial Advisors is
provided
“Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading—Participation or
in Client
Transactions” below.
A client should be aware that certain investment
products in which the client invests, such as mutual
funds and other Funds, annuities and other
products, have their own ongoing management
and other operating fees and expenses that are
deducted from the assets of the product (or income
or gains generated by the product on
its
investments) and thus reduce the value or return
of the client’s investment in the product. These
investment
fees and expenses may
management
fees,
shareholder servicing fees, transfer agency fees,
networking
fees, marketing
support payments, administration fees, custody
fees, expense reimbursements, and expenses
associated with executing securities transactions
for the investment product’s portfolio (“ongoing
operating expenses”). These ongoing operating
expenses are separate from, and in addition to, the
Program Fees. As a result of making investments
in these types of products, a client should be aware
that the client is paying multiple layers of fees and
expenses on the amount of the client’s assets so
invested—the ongoing operating expenses and the
Program Fee. Additional important information
about ongoing fees and expenses that apply to
those types of investments is provided in Baird’s
Client Relationship Details document and Baird’s
website at bairdwealth.com/retailinvestor. A client
can find the actual ongoing fees and expenses of
an investment product that the client will pay or
Due to the manner in which Baird compensates its
Financial Advisors, a Financial Advisor generally
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bear in the product’s prospectus or offering
document.
Additional Account Fees and Charges
• fees related to the establishment, administration
or
termination of Retirement Accounts,
retirement or profit sharing plans, trusts or any
other legal entity, including, without limitation,
the calculation and payment of unrelated
business income tax (“UBIT”);
website
If the client’s Account is custodied at Baird, the
client is also responsible for all applicable account
fees and service charges Baird may impose in
connection with the client’s agreements with Baird.
A schedule of fees and service charges is available
on
at
Baird’s
bairdwealth.com/retailinvestor.
• fees imposed by the SEC or securities markets,
including transaction fees imposed by electronic
trading platforms, which fees may be imbedded
in the price the client receives for the security;
and
imposed upon or
resulting
• taxes
Other Fees and Charges
from
transactions effected for a client’s Account, such
as income, transfer or transaction taxes, foreign
stamp duties, or any other costs or fees
mandated by law or regulation.
In addition to the Program Fee described above, a
client will incur other fees and expenses. A client is
responsible for bearing or paying, in addition to the
Program Fee, the costs of all:
to
all
set-up, maintenance
Clients who use a custodian other than, or in
addition to, Baird will pay the other custodian’s
fees and expenses in addition to the Program Fee.
In addition, if a third party custodian has custody
of the client’s Account assets, the Account is
subject
and
administrative fees, if any, established by Baird.
Baird may waive such fees in its discretion.
• markups, markdowns, and spreads charged by
Baird in a principal transaction with a client or
charged by other broker-dealers that buy
securities from, or sell securities to, the client’s
Account (such costs are inherently reflected in
the price the client pays or receives for such
securities);
• front-end or deferred sales charges, redemption
fees, or other commissions or charges associated
with securities transferred into or from an
Account;
• redemption fees, surrender charges or similar
fees that an investment product or its sponsor
may impose;
In addition to the Program Fee, a client will be
responsible for paying the fees charged by each DC
Manager selected by the client under the Dual
Contract Program. If a client directs Baird to pay
the client’s DC Manager’s fee out of the client’s
Account, and Baird agrees to do so, Baird will not
be responsible for verifying the calculation or
accuracy of such fee.
• underwriting discounts, dealer concessions or
similar fees related to the public offering of
investment products;
through another
• extra or special fees or expenses that may result
from the execution of odd lot trade orders (i.e.,
“odd-lot differential”);
A client may also be assessed other trading costs
in addition to the Program Fee if client trades are
executed
firm. Please see
“Services, Fee and Compensation—Additional
Program Information—Trading for Client Accounts”
above for more information.
• electronic fund fees, wire transfer fees, fees for
transferring an investment between firms, and
similar fees or expenses related to account
transfers (including any such fees imposed by
Baird);
• currency conversions and transactions;
conversions,
• securities
including, without
limitation, the conversion of ADRs to or from
foreign ordinary shares;
• interest, fees and other costs related to margin
accounts, short sales and options trades;
If a client holds an Unsupervised Asset in the
client’s Account, the client may be charged a
commission, markup or markdown in connection
with its purchase or sale. The cash proceeds from
the sale of an Unsupervised Asset that remain in a
client’s Account are
considered Permitted
Investments subject to the asset-based Program
Fee. If an asset becomes an Unsupervised Asset
during a quarterly billing period, that asset will be
excluded for purposes of determining the asset-
based Program Fee beginning at the start of the
next quarterly billing period, and no portion of the
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asset-based Program Fee paid by a client in
advance for the quarter will be refunded or rebated
to the client. Additionally, Unsupervised Assets in
an Account are subject to any applicable set-up,
maintenance and administrative fees established
by Baird. Baird may waive such fees in its
discretion.
Account Requirements and Types of
Clients
Opening an Account
A client that wishes to participate in a Program will
enter into an advisory agreement with Baird. The
client’s advisory agreement will contain the specific
terms applicable to the services selected by the
client, Program Fees payable by the client, and
other terms applicable to the client’s advisory
relationship with Baird.
Clients who have Accounts may also have other
accounts with Baird under programs or services not
described in this Brochure. Those accounts may be
subject to fees, commissions or other expenses
that are entirely separate from the payment of
Program Fees.
In addition to the investment advisory services that
Baird provides in connection with each Program,
Baird, in its capacity as broker-dealer, also
provides clients with trade execution, custody and
other standard brokerage services. For this reason,
a client will also enter into a client account
agreement with Baird if the client has not already
done so. The client account agreement is a
brokerage agreement that authorizes Baird to
execute trades for, and perform related brokerage
and custody services to, the client’s Account.
Baird generally requires that assets in a client’s
Account be held in a Baird account, for which Baird
acts as custodian. However, in certain limited
circumstances when requested by a client, Baird
may permit a client to include Held-Away Assets in
the client’s Account.
to
Compensation Received by Baird and Baird
Financial Advisors
The individual who recommends a Program to a
client, including a Baird Financial Advisor, receives
compensation from Baird that is based upon the
amount of the Program Fee paid by the client. The
amount of the compensation may be more than
what the individual would receive if the client
participated in other Baird investment advisory
programs or paid separately for investment advice,
brokerage, and other services. Accordingly, the
individual may have a financial incentive to
recommend a Program over other programs or
services offered by Baird. However, when providing
investment advisory services to clients, Baird and
its Financial Advisors are fiduciaries and are
required to act solely in the best interest of clients.
Baird addresses this conflict through disclosure in
this Brochure and by adopting internal policies and
procedures for Baird and its associates that require
them to provide investment advice that is suitable
for advisory clients (based upon the information
provided by such clients). For more specific
information about Baird’s compensation and other
benefit arrangements and how Baird addresses the
potential conflicts of interest, please see the
sections “Services, Fees and Compensation—
Additional Program Information” and “Services,
Fees and Compensation—Program Fees—Program
Fee Payments to Baird, Financial Advisors and
Investment Managers” above, and “Additional
Information—Other Financial Industry Activities
and Affiliations” and “Additional Information—Code
of Ethics, Participation or Interest in Client
Transactions and Personal Trading” below.
After a client has signed and delivered an advisory
agreement to Baird, the agreement is subject to
review and acceptance by the client’s Financial
Advisor, his or her Branch Office Manager or PWM
Supervision department supervisor (or his or her
respective designee), and Baird PWM’s Home
Office. The agreement and Baird’s advisory
relationship with a client will become effective
when the client’s paperwork is accepted by Baird
PWM’s Home Office and following such acceptance
Baird has delivered
the client written
confirmation of the Account’s enrollment in the
applicable Program. A client should understand
that the advisory agreement will not become
effective, and Baird will not provide any advisory
services to the client, until such time that Baird has
accepted the advisory agreement. Baird may delay
acceptance of the advisory agreement and the
provision of advisory services to the client for
various reasons, including deficiencies in the
client’s paperwork. Once it has become effective,
the agreement shall continue until it is terminated
in accordance with the terms described in the
advisory agreement.
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
The terms of a client’s agreements and this
Brochure apply to all Accounts that a client
establishes with Baird, including any Accounts that
a client may open with Baird in the future. Some of
the information in those documents may not apply
to a client now, but may apply in the future if a
client changes Programs or services or establishes
other Accounts with Baird. Baird will generally not
provide a client another copy of the agreements or
this Brochure when a client changes Programs or
services or establishes new Accounts unless the
client requests a copy from a Financial Advisor.
Therefore, a client should retain those documents
for future reference as they contain important
information if a client changes Programs or
services or establishes other Accounts with Baird.
Certain Account Requirements
Minimum Account Size
Accounts they manage. Additional information will
be provided to a client if the client enrolls in a DCA
service. A client should note that, if dollar cost
averaging is used to invest cash in the client’s
Account, the returns for the Account could,
depending upon market and other conditions, be
lower than the returns that could have been
obtained had all the cash in the Account been fully
invested upon contribution to the Account. In
addition, a client should note that, when dollar cost
averaging is used, the amount of cash in the
client’s Account will be included in the value of the
Account for fee calculation purposes. Whenever
assets are contributed to an Account, a client
should discuss with the client’s Baird Financial
Advisor the timing of when the assets will be
invested. If DCA will be used to invest the assets,
a client should ask for more specific information
about how the assets will be invested and the
associated timing for investing.
Each Program has a minimum account size and
may have a minimum Program Fee, which are
described in the section entitled “Services, Fees
and Compensation—Program Fees” above. Baird
may remove a client from a Program and
immediately terminate the advisory agreement
with respect to an Account upon written notice to
the client if the client fails to maintain the required
minimum asset levels in an Account or if the client
fails to otherwise abide by the terms of a Program
as determined by Baird in its sole discretion.
Account Contributions and Withdrawals
A client may fund an Account with cash and with
securities that Baird and the client’s investment
manager, if any, deem to be acceptable in their
sole discretion. Funds deposited or transferred to a
client’s SMAs or UMAs from another Baird account
and funds deposited or transferred to a client’s
SMAs or UMAs from outside of Baird will not be
available for investment by the client’s investment
manager until the next business day and therefore
the investment of such funds, at the discretion of
the manager, will occur no earlier than the next
business day.
Some Baird Financial Advisors will invest, or
recommend investing, cash contributions made to
an Account over a period of time. This method of
investment is sometimes referred to dollar cost
averaging (“DCA”). The goal of this method of
investment is to reduce the risk of making large
purchases of securities at an inopportune time or
price. The Overlay Manager and certain investment
managers also offer an optional DCA service for
When a client funds an Account with securities,
including when a client changes Programs for an
Account or changes investment managers for an
Account within the same Program, the client should
understand that Baird’s or the client’s investment
manager’s review of securities used to fund the
Account may delay investing. In addition, Baird or
the client’s investment manager, if any, may
determine that the securities contributed to the
Account may not be appropriate for the client’s
strategy, and Baird or the investment manager, if
any, may sell, or recommend the sale of, such
securities. Further, an investment manager may be
removed from the management of a client’s
Account and a replacement investment manager
may be appointed. In such event, Baird, at the
direction of the client’s replacement manager, or
the client’s replacement manager may sell all or a
portion of the securities or other investments in the
Account that were managed by the prior manager
and the replacement manager will reinvest the
cash proceeds of those sales. Any such sale could
result in adverse tax consequences for the client. A
client should note that securities transferred into
an Account may be subject to the Program Fee
immediately upon its transfer into the Account,
even if the client paid a commission or front-end
sales charge on the security prior to its transfer
into the Account. In addition, if the securities are
subject to deferred sales charges or redemption
fees, the client will be responsible for paying those
charges and fees. To the extent permitted by
applicable law, certain funding transactions may be
handled by Baird on a principal basis, and such
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
transactions are not considered
investment
advisory services of Baird or the client’s investment
manager.
disrupt a client’s investment strategy, and have an
adverse impact on the Account’s performance. A
client should review the client’s agreements for
more information.
All of the assets in a client’s Account must be free
and clear from any security interest, lien, charge
or other encumbrance (other than a security
interest, lien, charge or other encumbrance in
favor of Baird) and must remain so for the duration
of the client’s relationship with Baird, unless Baird
otherwise specifically agrees in writing.
If an asset transferred to an Account is an
Unpermitted Investment under the terms of the
applicable Program, Baird, the client’s Financial
Advisor or the client’s investment manager may
sell the asset or transfer it into a separate
brokerage account. Alternatively,
they may
designate such asset as an Unsupervised Asset as
further described under “Services, Fees and
Compensation—Additional Program Information—
Unsupervised Assets” above.
If a client wishes to obtain loans secured by assets
in the client’s Account (commonly referred to as
“securities-based lending”) and Baird agrees to the
arrangement, the client should understand that the
lender may exercise certain rights and powers over
the assets in the Account, including the disposition
and sale of any and all assets pledged as collateral
for the loan to meet a collateral call, which may
occur without prior notice to the client. A collateral
call could have adverse tax consequences, disrupt
a client’s investment strategy, and have an
adverse impact on the Account’s performance. A
client should be aware of these and other potential
adverse effects of securities-based lending and
collateralizing Accounts before deciding to do so.
A client is responsible for notifying the client’s
Financial Advisor and any investment manager
managing the client’s Account of any contributions
made into the Account and instructing the client’s
Financial Advisor and any investment manager to
liquidate positions in the event the client wishes to
withdraw assets from the Account. Baird and its
Financial Advisors have no responsibility to invest
cash deposits (other than complying with a client’s
cash sweep instructions) or liquidate positions with
respect to an Account managed by an Other
Manager, and they are not responsible for any
losses that may result from a client’s failure to
notify the client’s Financial Advisor and any
investment manager managing the client’s Account
regarding deposits or withdrawals.
A client is required to disclose the terms of the
client’s agreements with Baird to any lender
seeking to use Account assets as collateral. A client
must promptly notify Baird of any default or similar
event under the client’s collateral arrangements.
A client may also incur additional expenses and
liabilities, including tax-related liabilities, when
transferring assets out of an Account or Baird’s
custody. See “Termination of Accounts” below.
Liens and Use of Account Assets as Collateral
A client should understand that Baird and its
Financial Advisors will not provide advice on or
oversee a securities-based lending or collateral
arrangement and they will not act as investment
adviser or a fiduciary to the client with respect to
the liquidation of securities held in the client’s
Account to meet a collateral call. Any such
liquidation will be executed in Baird’s capacity as
broker-dealer and may, as permitted by law, result
in executions on a principal basis.
In some instances, Baird and its Financial Advisors
may refer a client to a third party lender under its
Securities-Based Lending Program that pays Baird
and its Financial Advisors certain compensation.
See “Services, Fees and Compensation—Additional
Program Information—Securities-Based Lending
Program” above for more information.
As security for the full and complete payment when
due of any debts and other obligations that a client
owes to Baird, and to the extent permitted by
applicable law or regulation, all assets in a client’s
Account held at Baird will be subject to a first
priority security interest, lien and right of setoff in
favor of Baird. Baird may sell assets in an Account
to satisfy the lien. As a secured party, Baird may
have interests that are adverse to a client. Neither
Baird nor its Financial Advisors will act as
investment adviser to a client with respect to such
sale of assets held in an Account. Any such sale of
assets will be executed in Baird’s capacity as
broker-dealer and creditor and may, as permitted
by law, result in executions on a principal basis.
Such sales could have adverse tax consequences,
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
review
Investment Products” above
Securities purchased on margin are used as Baird’s
collateral for the margin loan. Clients that have a
margin account should
the section
“Services, Fees and Compensation—Additional
Program Information—Complex Strategies and
Complex
for
additional information.
instructions,
investment manager managing such
other
Account, shall be under no obligation
to
recommend any action with regard to, or to
liquidate the securities or other investments in,
such Account. After an Account is removed from a
Program, it is the client’s exclusive responsibility to
issue
in writing, regarding the
management of any assets in such Account.
Electronic Delivery of Documents
By signing an advisory agreement, a client
consents to the electronic delivery of documents
that Baird may deliver to the client. The term of
the consent to electronic delivery is indefinite but
a client may revoke the consent at any time by
notifying the client’s Baird Financial Advisor.
website
If a client directs Baird to liquidate assets in
connection with a closure of an Account, the client
should understand that Baird acts as broker-
investment adviser, when
dealer, and not
processing such a liquidation request and that the
client will generally be charged commissions, sales
charges, sales “loads”, or other applicable
transaction-based fees in accordance with the
applicable Baird fee schedule or other third-party
transaction-based fee schedule for the particular
investment then in effect. Additional information
about the compensation that a client pays to Baird
for effecting brokerage transactions is contained in
Baird’s Client Relationship Details document,
available
at
Baird’s
on
bairdwealth.com/retailinvestor.
A client may incur significant expenses and
liabilities, including tax-related liabilities for which
the client will be solely liable, if the client closes an
Account, terminates an advisory agreement, or
transfers assets out of Baird’s custody. Baird will
not be liable to a client in any way with respect to
the termination, closure, transfer or liquidation of
the client’s Accounts.
Termination of Accounts
The client’s advisory agreement will survive any
event that causes the client’s Financial Advisor to
be unable to provide services to the client (either
on a temporary or permanent basis), including if
the client’s Financial Advisor ceases to be
employed by Baird. In any such event, Baird will
endeavor to continue to provide services to the
client and will as promptly as practicable assign
another Financial Advisor to the client’s Accounts
(either on a temporary or permanent basis) and
the client will be notified of any such change.
Similarly, if a client’s PIM Manager or UAS Manager
ceases to participate in the PIM of UAS Program or
be employed by Baird, Baird may assign the client’s
PIM or UAS Account to another PIM Manager, UAS
Manager or Financial Advisor, as applicable, or, if
Baird determines that it is unable to continue to
provide advisory services to the client, Baird may
remove the applicable Account from the PIM or
UAS Program and convert the Account to a
brokerage account upon notice to the client.
Baird may remove an Account from a Program and
immediately close an Account upon written notice
to a client if the client fails to abide by the terms of
the Program. Baird may also remove an Account
from a Program at any time upon written notice to
a client if the client fails to maintain the required
minimum asset levels in such Account.
Some of the investments offered in connection with
the Programs contain restrictions that limit their
use, and such investments may be unavailable for
purchase or holding outside of an Account. For
example, certain mutual funds, ETFs or other
Funds held in an Account may only be available to
a client through a Baird Program or may not be
held at another firm. If such restrictions apply and
the client terminates a Program or closes an
Account, the Client will be required to sell or
redeem such Funds or exchange them for other
Funds that may be more costly to the client or have
poorer performance. A client should consider
restrictions applicable to investments carefully
before participating in a Program. A client should
contact the client’s Financial Advisor for specific
information as to how Account closure, termination
of an agreement, or asset transfers might impact
the assets in the client’s Accounts.
Upon the termination of an Account’s enrollment in
a Program, Baird and, if relevant, any other
investment manager managing such Account, shall
have no obligation to act as investment adviser to
such Account. If such Account is custodied at Baird,
the Account shall be converted to and designated
as a brokerage account. Baird, and, if relevant, any
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
stated
objectives,
causes for removal may include significant drift
from
sustained
underperformance in relation to peers, or other
adverse changes affecting the manager.
Baird Trust, GAMMA, Reinhart, Riverfront
and Strategas
Types of Clients
Baird offers the Programs to all types of current or
prospective clients, including, but not limited to:
individuals; trusts; estates; Retirement Accounts;
pension and profit sharing plans; charitable
organizations; and corporations or other business
entities.
Portfolio Manager Selection and
Evaluation
The persons providing portfolio management
services to clients vary by Program. Information
about how Baird may select and evaluate portfolio
managers is further described below.
the
firm,
Selection and Evaluation
Baird Affiliated Managers Program
Baird conducts a very limited review of Baird Trust,
GAMMA, Reinhart, Riverfront and Strategas
consisting solely of an annual compliance
questionnaire that asks the manager to confirm
certain matters or provide certain information
about the manager’s compliance policies and
procedures, material legal and regulatory matters,
management of
the manager’s
presentation of performance information, and
delivery of the manager’s Form ADV Part 2
brochure documents to clients.
Baird Recommended Managers Program
When selecting and removing BRM Strategies for
the Baird Recommended Managers Program, Baird
uses the process described under the heading
“Methods of Analysis, Investment Strategies and
Risk of Loss—Methods of Analysis—Certain
Recommended
Lists—Baird’s
Recommended
Managers List” below.
The process and standards that Baird uses for
determining whether to make PWM-Managed
Portfolios and SMA Strategies available under the
Baird Affiliated Managers Program are significantly
less rigorous than those used in connection with
other SMA Programs offered by Baird. Baird
generally makes available all SMA Strategies
offered by Baird Equity Asset Management, Baird
Trust, GAMMA, Reinhart, Riverfront and Strategas
under the Program, and Baird generally does not
remove any of those SMA Strategies from the
Program unless Baird Equity Asset Management,
Baird Trust, GAMMA, Reinhart, Riverfront or
Strategas ceases to offer the SMA Strategy or
otherwise requests that Baird remove the SMA
Strategy from the Program.
Using the BRM Strategies made available for the
Baird Recommended Managers Program, Baird
Financial Advisors will select or replace, or
recommend the selection or replacement of, a
particular BRM Strategy based upon the client’s
particular goals and circumstances.
PWM-Managed Portfolios and Baird Equity
Asset Management
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, a client should note that Baird does not
monitor or ascertain whether a third party
Implementation Manager is fully and faithfully
implementing the Model Portfolio on a continuous
basis.
responsibility
for
In order for Baird PWM and Baird Equity Asset
Management to provide portfolio management
services under the Program, Baird requires that
Baird PWM and Baird Equity Asset Management
associates meet all applicable requirements set
forth by self-regulatory organizations. Baird Equity
Asset Management also requires Baird Equity Asset
Management portfolio managers to have an
undergraduate degree. Furthermore, Baird Equity
Asset Management strongly encourages all Baird
Equity Asset Management portfolio managers to
pursue and work towards the attainment of the
CFA designation or a relevant graduate level
degree. Baird may remove a PWM or Baird Equity
Asset Management portfolio manager
from
providing services under the Program if Baird
deems circumstances warrant removal. Potential
A client assumes ultimate responsibility for client’s
selection of an Other Manager under the Baird
Recommended Managers Program (including any
third party Implementation Manager). Baird
assumes no
the client’s
termination of an Other Manager (including any
third party Implementation Manager), the Other
Manager’s investment decisions, performance,
compliance with applicable laws or regulations, or
for any other matters involving or affecting the
Other Manager.
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird SMA Network and Dual Contract
Programs
Risk of Loss—Principal Risks—Available Investment
Product Risks” below for more information.
A client should only participate in the BSN or DC
Programs if the client wishes to take more
responsibility for monitoring the client’s Account,
the Baird Recommended Managers Program does
not contain an SMA Strategy that meets the client’s
particular needs, and the client understands the
risks of doing so.
Clients participating in the BSN Program or the DC
Program should note that the level of initial and
ongoing review performed by Baird on the
managers and their SMA Strategies made available
under those Programs, including any Associated
SMA Strategies, is significantly less than that
performed by Baird with respect to managers and
their strategies eligible for the Baird Recommended
Managers Program.
A client should note that the client’s appointment
and continued retention of an investment manager
to manage the client’s Account in connection with
the BSN or DC Programs are based ultimately upon
the client’s independent review of the investment
manager and the investment manager’s services.
Once retained by the client, an investment
manager will only be removed from managing the
client’s Account upon the investment manager’s
withdrawal, removal from the Program, or the
client’s direction to do so.
BSN and DC Managers are subject to an initial
review by Baird that considers the manager’s
assets under management,
regulatory and
compliance history, and certain other limited
factors deemed
qualitative and quantitative
relevant by Baird. The ongoing review is generally
performed on an annual basis and is generally
limited to significant changes in the managers’
assets under management in the SMA Strategy and
a review of the SMA strategy in comparison to a
relevant peer group or benchmark.
(including
any
third
A client assumes ultimate responsibility for client’s
selection of a manager under the BSN or DC
party
Programs
Implementation Manager). Baird assumes no
responsibility for the client’s termination of a
manager under the BSN or DC Programs (including
any third party Implementation Manager). Baird
also assumes no responsibility for any Other
Manager’s investment decisions, performance,
compliance with applicable laws or regulations, or
for any other matters involving or affecting the
Other Manager.
The BSN and DC Programs are designed to
accommodate a client who wishes to independently
select an investment manager not available in the
Baird Recommended Managers Program
to
manage the assets in the client’s Account. A client
should note that Baird does not make any
recommendation to clients regarding any BSN
Strategy or DC Strategy or any representations
regarding a BSN Manager’s or DC Manager’s
qualifications as an investment adviser or abilities
to manage client assets.
The Overlay Manager may provide review and
ongoing evaluations of certain BSN Managers that
it makes available through the BSN Program.
Clients should review Overlay Manager’s Form ADV
Part 2A Brochure for more information, which is
available upon request, or contact their Financial
Advisor for more information.
and
regulations
of
is
fully
and
Portfolio management services under the DC
Program may be provided by an investment
management department of Baird if the client
selects such an SMA Strategy. In order to provide
portfolio management services under the DC
Program, Baird requires that Baird associates meet
all applicable requirements set forth by applicable
law
self-regulatory
organizations, such as the Financial Industry
Regulatory Authority,
Inc., exchanges, and
governmental agencies.
Baird does not monitor or ascertain whether the
Overlay Manager
faithfully
implementing Model Portfolios under the BSN
Program on a continuous basis.
ALIGN, BairdNext Portfolios, PIM and Russell
Programs
SMA Strategies offered under the BSN and DC
Programs are subject to certain risks. See
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Portfolio management services under the ALIGN,
BairdNext Portfolios, PIM and Russell Programs are
provided by Baird PWM, Baird PWM’s home office
investment professionals, and Baird Financial
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Advisors. In order to provide portfolio management
services under the Programs, Baird requires that
Baird associates meet all applicable requirements
set forth by applicable law and regulations of self-
regulatory organizations, such as the Financial
Industry Regulatory Authority, Inc., exchanges,
and governmental agencies.
her Branch Office Manager; completion of a
portfolio management course acceptable to Baird,
which may include a CFA, Certified Financial
PlannerTM (CFP), Certified Private Wealth Advisor®
(CPWA®), or CIMA® designation or acceptance in
the PIM Program as a PIM Manager; and
completion of an application to the UAS Program,
which typically requires the UAS Manager to
complete one or more investment strategy or
experience statements acceptable to Baird. Certain
UAS Managers may have been admitted to the UAS
Program using different qualifications than those
currently in place. In some instances, Baird may
waive certain eligibility requirements when it
deems it appropriate to do so, such as when a UAS
Manager acted as a portfolio manager (or in a
similar capacity) at another investment firm prior
to joining Baird.
requirements when
it deems
Potential causes for removing a UAS Manager from
the UAS Program include operating outside of the
policies of the Program, a change in investment
philosophy or style, significant drift from stated
objectives, significant and sustained performance
issues over lengthy periods of time, or other
adverse changes affecting the UAS Manager that in
Baird’s opinion warrants removal.
Typically, PIM Managers must also meet the
following additional criteria: endorsement by his or
her Branch Office Manager; completion of a
portfolio management course acceptable to Baird,
include an Accredited Portfolio
which may
Management Advisor (APMA), Chartered Financial
Analyst (CFA), Certified Investment Management
Analyst® (CIMA®) or Certified Portfolio Manager
(CPM) designation; and completion of an
application to the PIM Program, which typically
requires the PIM Manager to complete one or more
investment strategy or experience statements
acceptable to Baird. Certain PIM Managers may
have been admitted to the PIM Program using
different qualifications than those currently in
place. In some instances, Baird may waive certain
eligibility
it
appropriate to do so, such as when a PIM Manager
acted as a portfolio manager (or in a similar
capacity) at another investment firm prior to
joining Baird.
Under the UMA Programs, portfolio management
services are also provided by managers of mutual
funds and ETPs, if those investments are part of a
UMA Portfolio, and by Other Managers and the
Overlay Manager, if an SMA Strategy is part of the
UMA Portfolio.
Potential causes for removing a PIM Manager from
the PIM Program include operating outside of the
policies of the Program, a change in investment
philosophy or style, significant drift from stated
objectives, significant and sustained performance
issues over lengthy periods of time, or other
adverse changes affecting the PIM Manager that in
Baird’s opinion warrants removal.
UMA Programs
Portfolio management services under the UMA
Programs are provided by Baird PWM, Baird PWM’s
home office investment professionals, investment
management departments of Baird and Baird
Financial Advisors. In order to provide portfolio
management services under the Programs, Baird
requires that Baird associates meet all applicable
requirements set forth by applicable law and
regulations of self-regulatory organizations, such
as the Financial Industry Regulatory Authority,
Inc., exchanges, and governmental agencies.
The UMA Programs make available UMA
Recommended Funds and UMA Recommended
SMA Strategies. The process Baird uses for
selecting and removing UMA Recommended Funds
for the UMA Programs is substantially similar to the
process Baird uses to select and remove mutual
funds and ETPs in connection with the ALIGN
Strategic Portfolios Program described under
“ALIGN Programs—ALIGN Strategic Portfolios”
below. The process Baird uses for selecting and
removing UMA Recommended SMA Strategies for
the UMA Programs is the same process used for
selecting and removing BRM Strategies, which is
described under the heading “Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis—Certain Recommended Lists—Baird’s
Recommended Managers List” below.
Typically, UAS Managers must also meet the
following additional criteria: endorsement by his or
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and
Evaluation—Baird
removing PWM-Managed Portfolios from the BAM
Program, which is described under the heading
“Portfolio Manager Selection and Evaluation—
Affiliated
Selection
Managers Program” above.
In addition to the UMA Recommended Funds and
the UMA Recommended SMA Strategies, the UAS
Program also makes available UAS Available Funds
and UAS Available SMA Strategies. Clients
participating in the UAS Program should note that
the level of initial and ongoing review performed by
Baird on UAS Available Funds and UAS Available
SMA Strategies, including Associated Funds and
Associated SMA Strategies, is significantly less
than that performed by Baird with respect to UMA
Recommended Funds and UMA Recommended
SMA Strategies.
qualifications
as
If a client has not selected the discretionary
management option of the UAS Program, the client
should note that: (1) the UAS Available Funds and
UAS Available SMA Strategies are made available
to accommodate a client who wishes
to
independently select investments that are not on a
Baird recommended list for the client’s Account;
(2) Baird does not make any recommendation to
clients regarding any UAS Available Fund or UAS
Available SMA Strategy and Baird does not select
any investments for the client’s UAS Program
Account; and (3) Baird does not make any
representation to clients regarding any UAS
Available Manager’s
an
investment adviser or abilities to manage client
assets.
The Overlay Manager may provide review and
ongoing evaluations of certain UAS Available
Managers that it makes available through the UAS
Program. Clients should review Overlay Manager’s
Form ADV Part 2A Brochure for more information,
which is available upon request, or contact their
Financial Advisor for more information.
UAS Available Funds, other than Associated Funds,
are subject to an initial review by Baird that
considers the fund’s assets under management,
regulatory and compliance history, and certain
other limited qualitative and quantitative factors
deemed relevant by Baird. The ongoing review is
generally performed on an annual basis and is
generally limited to significant changes in the
managers’ assets under management and a review
of the fund strategy in comparison to a relevant
peer group or benchmark. The process Baird uses
for selecting and removing UAS Available SMA
Strategies, other than Associated SMA Strategies,
from the UAS Program is the same process used
for selecting and removing BSN Strategies from the
BSN Program, which is described under the
heading
“Portfolio Manager Selection and
Evaluation—Selection and Evaluation—Baird SMA
Network and Dual Contract Programs” above.
is
fully
and
Baird does not monitor or ascertain whether the
Overlay Manager
faithfully
implementing Model Portfolios under the UMA
Programs on a continuous basis.
UAS Available Funds and UAS Available SMA
Strategies are subject to certain risks. See
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks—Available Investment
Product Risks” below for more information.
To be included the UAS Available Funds lineup or
the UAS Available SMA Strategies
lineup,
Associated Funds and Associated SMA Strategies,
respectively, are subject to less rigorous standards
than the standards imposed upon funds and SMAs
that are not associated with Baird. The standards
used by Baird are substantially similar to those it
uses when including Associated SMA Strategies in
the BAM Program. For more information see the
information contain under the heading “Portfolio
Manager Selection and Evaluation—Selection and
Evaluation—Baird Affiliated Managers Program”
above.
the
A client retaining discretion over the client’s UAS
Program Account should only select UAS Available
Funds or UAS Available SMA Strategies if the client
wishes to take more responsibility for managing
and monitoring the client’s UAS Program Account,
the UMA Recommended Funds and UMA
Recommended SMA Strategies do not meet the
client’s particular needs, and
client
understands the risks of doing so.
Likewise, the PWM-Managed Portfolios made
available under the UAS Program are not subject
to the same processes and standards used by Baird
in determining whether to make non-affiliated
investment options available under other
Programs. The process Baird uses for selecting and
removing PWM-Managed Portfolios from the UAS
Program is the same process used for selecting and
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oversees the Baird Equity Asset Management
portfolio managers.
providing
information
If a client has not selected the discretionary
management option of the UAS Program, it is
important to note that: the UAS Available Funds
and UAS Available SMA Strategies are made
available to accommodate a client who wishes to
independently select investments that are not on a
Baird recommended list for the client’s Account;
the client assumes ultimate responsibility for
monitoring each UAS Available Fund and UAS
Available SMA Strategy and the manager’s
performance; the client’s selection and continued
holding of a UAS Available Fund or a UAS Available
SMA Strategy are based ultimately upon the
client’s independent review of such investment;
and once an investment is made by the client, the
investment will only be removed from the client’s
Account upon the manager’s withdrawal, removal
of the investment from the Program, or the client’s
direction to do so.
The IAOC delegates its day-to-day oversight
responsibilities to certain subcommittees of the
IAOC, Baird’s PWM Supervision, Investment
Solutions and Compliance Departments to monitor
the Programs and the performance of Baird
associates
portfolio management
services under the ALIGN, BairdNext, PIM, Russell
and ALIGN UMA Select Programs, and the
discretionary management of UAS Program
Accounts by UAS Managers. Baird’s Investment
Solutions Department, along with the Compliance
Department and other designees, provide periodic
review of the performance of Baird associates
providing portfolio management services under
is
those Programs. Performance
provided to the IAOC or a subcommittee thereof.
calculates
Performance Calculation
As part of Baird’s selection and evaluation of
portfolio managers, Baird
the
investment performance of:
Manager’s
investment
• Baird associates acting as portfolio managers
under the ALIGN, BairdNext, PIM, BAM, ALIGN
UMA Select Programs and PWM-Managed
Portfolios; and
A client assumes ultimate responsibility for client’s
selection of an Other Manager under the UAS
Program (including any third party Implementation
Manager). Baird assumes no responsibility for the
client’s termination of an Other Manager (including
any third party Implementation Manager), the
decisions,
Other
performance, compliance with applicable laws or
regulations, or for any other matters involving or
affecting the Other Manager.
• Other Managers participating in the BAM, BRM,
BSN and DC Programs that directly manage
client accounts under a Manager-Traded
Strategy.
the Financial
Portfolio management services under the UMA
Programs may be provided by Baird PWM’s home
office investment professionals or an investment
management department of Baird if the client
selects a model portfolio or an SMA Strategy
offered by them. In order to provide portfolio
management services under the UMA Programs,
Baird requires that Baird associates meet all
applicable requirements set forth by applicable law
and regulations of self-regulatory organizations,
such as
Industry Regulatory
Authority, Inc., exchanges, and governmental
agencies.
Oversight of the Programs
Fixed
Asset Management,
PWM
When Baird calculates a manager’s investment
performance, Baird generally uses composites of
the manager’s client accounts to calculate the
manager’s performance. A composite
is an
aggregation of client accounts managed by the
manager that are representative of a particular
investment strategy, style, or objective. Examples
of composites include large cap growth, all cap
value, balanced (which includes equity and fixed
income securities), and fixed income. Composites
may be further broken down to separate taxable
and non-taxable portfolios.
income
composites may be categorized by portfolio
duration.
Investment
The Investment Advisory Oversight Committee
(“IAOC”) of Baird, which includes members of
Sales
Baird’s
Management,
Investment Solutions, Asset
Manager Research, Compliance, Legal, and Risk
Management Departments, oversees the standards
and implementation of the Programs. In addition,
Baird Equity Asset Management’s Director also
When calculating composite performance, Baird
seeks to utilize calculation methods that adhere to
Performance Standards
Global
calculates
(GIPS®)
recommendations. Baird
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the
composite performance generally using
following principles:
• A total return calculation is used in reporting.
• Current market value including accrued income
or external sources is accurate. In addition, a client
should note that such investment performance
information may not be calculated on a uniform or
consistent basis or reviewed by any independent
third party. A client should ask the client’s Financial
Advisor for more information.
is used.
• Trade date accounting is used in deriving
valuations.
• Monthly returns are calculated using the Modified
Dietz calculation.
• Returns for periods greater than a month are
calculated by geometrically linking the monthly
returns. Returns for periods greater than one
year are annualized.
receive
higher
instead of
Portfolio Management by Baird and
Associated Managers
Portfolio management services under the ALIGN,
BairdNext Portfolios, PIM, Russell, BAM, Baird
Recommended Managers, DC and UMA Programs
may be provided by Baird and Associated
Managers. Such arrangements create a potential
conflict of interest because Baird and Associated
Managers may
aggregate
compensation if clients retain Baird and Associated
Managers
retaining unassociated
managers.
• Reporting is net of fees at the total portfolio, but
gross of fees for individual investment categories
(e.g., equity or fixed income).
departments,
No independent third party reviews the composite
performance information calculated by Baird to
verify its accuracy or compliance with presentation
standards.
is described under
The following Programs exclusively offer portfolio
management by Baird, its Financial Advisors, its
PWM home office investment professionals, its
investment management
or
investment managers that are affiliated with Baird:
ALIGN, BairdNext Portfolios, PIM, Russell and Baird
Affiliated Managers Programs (“Affiliates-Only
Programs”). The processes, if any, used by Baird
those portfolio
for selecting and reviewing
managers
the headings
“Portfolio Manager Selection and Evaluation—
Selection and Evaluation” above and “Portfolio
Manager Selection and Evaluation—Methods of
Analysis, Investment Strategies and Risk of Loss—
Program Portfolio Strategies” below.
from
To the extent Baird selects or reviews other
portfolio managers participating in the Programs,
Baird does not calculate investment performance
information for such managers. Baird obtains
investment performance information for those
managers directly from the managers (including
the Overlay Manager) or from other external
sources that Baird believes to be reliable. A client
should understand that: Baird does not recalculate
the performance provided by such managers or
external
sources; neither Baird nor any
independent third party reviews the performance
information provided by such managers to verify
its accuracy or compliance with presentation
standards unless otherwise stated in writing; those
managers may not calculate performance on a
uniform or consistent basis; and Baird does not
guarantee the accuracy of information provided by
such managers or any external source.
A client should note that the processes and
standards used by Baird in determining whether to
make affiliated investment options available under
those
Affiliates-Only Programs differ
processes and standards used by Baird
in
determining whether
to make non-affiliated
investment options available under other
Programs. Baird approves, and continues to make
available, affiliated investment options under
Affiliates-Only Programs
that would not be
approved for, or would have been removed from,
such other Programs. For the Affiliates-Only
Programs, this practice presents a conflict of
interest because Baird has a financial incentive to
maximize the number of affiliated investment
options it makes available under Affiliates-Only
Programs due to the fact that, by increasing
investment options, Baird will likely attract more
A client should note that Baird does not generally
present its investment performance calculations to
clients. The information that Baird provides to
clients about portfolio managers from time to time
may not be calculated by Baird but may be
calculated by the managers themselves or derived
from external sources. Baird does not audit or
verify that investment performance information
presented to clients that is calculated by managers
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thereby
and periodically discuss
is described under
client assets and
increase Baird’s
revenues. A client participating in an Affiliates-Only
Program should monitor the client’s Account
the
performance
performance of such Account with the client’s
Financial Advisor.
by Baird
in determining whether to make
unassociated investment options available under
other Programs. The processes, if any, used by
Baird for selecting and reviewing those portfolio
managers
the headings
“Portfolio Manager Selection and Evaluation—
Selection and Evaluation” above and “Portfolio
Manager Selection and Evaluation—Methods of
Analysis, Investment Strategies and Risk of Loss—
Program Portfolio Strategies” below.
professionals,
an
through disclosure
in
Portfolio management services under the Baird
Recommended Managers Program or DC Program
could be provided by Baird PWM home office
investment
investment
management department of Baird or an Associated
Manager should a client select an Associated SMA
Strategy. When Baird selects SMA Strategies, or
otherwise determines manager availability or
eligibility, for the Baird Recommended Managers
Program or the DC Program, Associated SMA
Strategies and Associated Managers are subject to
the same selection and review processes, if any,
that Baird applies to unassociated SMA Strategies
and investment managers participating in each
respective Program. The processes, if any, used by
Baird for selecting and reviewing SMA Strategies
and Associated SMA Strategies for those Programs
are further described under the heading “Portfolio
Manager Selection and Evaluation—Selection and
Evaluation” above.
When providing investment advisory services to
clients, Baird and its Financial Advisors are
fiduciaries and are required to act solely in the best
interest of clients. Baird addresses the conflicts
described above
this
Brochure and by adopting internal policies and
procedures for Baird and its associates that require
them to provide investment advice that is suitable
for advisory clients (based upon the information
provided by such clients). For more specific
information about these potential conflicts and how
Baird addresses them, please see the sections
“Additional Information—Other Financial Industry
Activities and Affiliations” and
“Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
Advisory Business
Baird is privately-held, employee-owned global
investment and wealth management firm formed
in the State of Wisconsin in 1919.
or
for
Baird is owned indirectly by its associates through
several holding companies. Baird is owned directly
by Baird Financial Corporation (“BFC”). BFC is, in
turn, owned by Baird Financial Group, Inc. (“BFG”),
which is the ultimate parent company of Baird.
Associates of Baird own substantially all of the
outstanding stock of BFG.
and
recommendations
consulting;
financial
Baird offers various investment advisory services
to clients, including services not described in this
Brochure. The investment advisory services Baird
offers include: portfolio management and analysis;
analysis and recommendations regarding asset
allocation and investment strategies; research,
regarding
analysis
investment managers and individual securities;
investment
planning;
investment policy development; and account
performance monitoring. Baird also offers clients
and
execution
of
brokerage
transactions
Portfolio management services under the UMA
Programs could be provided by Baird PWM home
office investment professionals, an investment
management department of Baird or an Associated
Manager. The PWM-Managed Portfolios made
available under the UAS Program exclusively offer
portfolio management by Baird. If a client selects
the discretionary management option of the UAS
Program, portfolio management is also provided by
the client’s UAS Manager. When Baird selects SMA
Strategies, or otherwise determines manager
the UMA
eligibility,
availability
Recommended SMA Strategies lineup for the UMA
Programs, Associated SMA Strategies and
Associated Managers are subject to the same
selection and review processes that Baird applies
to unassociated SMA Strategies and managers.
However, when Baird selects SMA Strategies, or
otherwise determines manager availability or
eligibility, for the UAS Available SMA Strategies
lineup for the UAS Program, Associated SMA
Strategies and Associated Managers are subject to
a less rigorous selection and review processes than
Baird applies to unassociated SMA Strategies and
managers. Likewise, the PWM-Managed Portfolios
made available under the UAS Program are not
subject to the same processes and standards used
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administrative services,
including maintaining
custody of account assets. Clients may also
negotiate other services with Baird. Baird offers its
services separately or in combination with other
services. Baird tailors its advisory services to the
individual needs of clients. For more information
about the services offered by Baird, please see
“Services, Fees and Compensation” above.
see
conflicts of interest posed by performance-based
fee arrangements by periodically monitoring the
holdings and performance of performance-based
fee accounts and comparing them to accounts not
subject to a performance fee that are also
managed using a similar strategy in an attempt to
detect any possible inequitable treatment. Baird
also attempts to minimize potential conflicts of
fee
interest posed by performance-based
arrangements through internal trade allocation
procedures that are designed to make securities
allocations to discretionary client accounts in a
manner such that all such clients receive fair and
equitable treatment over time.
above
Subject to the agreement of Baird, a client may
impose reasonable restrictions on the securities or
types of securities to be held in the client’s
“Services, Fees and
Account. Please
Compensation—Additional Program Information—
Investment Discretion”
for more
information.
Methods of Analysis, Investment
Strategies and Risk of Loss
Investment Strategies
Baird participates in wrap fee programs not
described in this Brochure and it provides portfolio
management services in connection with those
programs. Baird receives a portion of the wrap fee
paid by clients for providing portfolio management
services under those wrap fee programs.
The investment styles, philosophies, strategies,
techniques and methods of analysis that Baird
PWM home office investment professionals, its
Financial Advisors and Other Managers use in
formulating investment advice for clients vary
widely by Program and the person providing the
advice. A brief description of commonly used
strategies is provided below.
Equity Strategies
As of December 31, 2025, Baird had approximately
$394.0688 billion in regulatory assets under
management, approximately $289.4898 billion of
which was managed on a discretionary basis and
approximately $104.5790 billion of which was
managed on a non-discretionary basis.
performance-based
fee
focused,
Act.
Performance-based
Equity strategies generally have an objective to
provide growth of capital and primarily invest in
equity securities, such as common stocks.
However, these strategies may also invest in other
types of investments, such as fixed income
securities and cash. Equity strategies may invest in
companies of all market capitalization ranges or
may
focus on any combination of specific
capitalization ranges, such as large cap, mid cap or
small cap companies. Equity strategies may be
combined with other strategies described below,
such as growth, value, income, economic industry
or sector
international, global, or
geographic region or country focused strategies.
Fixed Income or Bond Strategies
fee
arrangements
because
Performance-Based Fees and Side-By-Side
Management
Baird advises client accounts not participating in
services described in this Brochure that are subject
to
arrangements.
Performance-based fee arrangements involve the
payment of fees based upon the capital gains or
capital appreciation of a client’s account. Any such
fee arrangements are made in compliance with
applicable provisions of Rule 205-3 under the
Advisers
fee
arrangements present a potential conflict of
interest for Baird with respect to other client
accounts that are not subject to performance-
based
such
arrangements give Baird an incentive to favor
client accounts subject to performance-based fees
over client accounts that are not subject to
performance-based fees.
Fixed income or bond strategies generally have one
or more of the following objectives: (1) provide
current income; or (2) preservation of capital.
These strategies primarily invest in fixed income
securities, such as corporate bonds, municipal
securities, mortgage-backed or asset-backed
securities, or government or agency debt
obligations. However, these strategies may also
invest in other types of investments, such as equity
In addition to complying with its fiduciary duties by
disclosing this conflict of interest to clients through
this Brochure, Baird generally addresses potential
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bonds. This type of strategy may also invest in
yield- or
income-producing, Non-Traditional
Assets.
Economic Industry or Sector Focused Strategies
technology,
securities or cash. Fixed income strategies may
invest in debt obligations having any credit rating,
maturity or duration, or they may focus on specific
credit ratings, maturities or durations, such as
investment grade, non-rated, or high yield (“junk”)
bonds, or bonds having short-term, intermediate-
term or
income
long-term maturities. Fixed
strategies may be combined with other strategies
described below, such as economic industry or
sector focused, international, global, or geographic
region or country focused strategies.
Balanced Strategies
Economic industry or sector focused strategies
primarily invest in companies in one or more
economic industries or sectors, such as the
telecommunications,
industrial,
materials, or financial sectors. These strategies
alone generally are not intended to satisfy a client’s
entire portfolio diversification needs. These
strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
International Strategies
ranges,
Generally, international strategies primarily invest
in securities issued by foreign companies, which
may include companies in developed and emerging
markets. International strategies may invest in
companies of all market capitalization ranges and
in investments having any credit rating, maturity
or duration, or they may focus on specific
capitalization
industries or sectors,
geographic regions, credit ratings, maturities or
durations.
Balanced strategies generally have one or more of
the following objectives: (1) provide current
income; (2) growth of capital/principal or income;
or (3) preservation of capital. These strategies
primarily invest in a mix of equity, fixed income
securities and cash. Balanced strategies may
invest in companies of all market capitalization
ranges and in investments having any credit rating,
maturity or duration, or they may focus on specific
capitalization ranges, credit ratings, maturities or
durations as described above. Balanced strategies
may be combined with other strategies described
below, such as economic industry or sector
focused, international, global, or geographic region
or market focused strategies.
Global Strategies
Value Strategies
A value strategy typically invests primarily in
equity securities of value companies, which are
those that the investment manager believes are
out of favor with investors, appear underpriced by
the market relative to their earnings or intrinsic
value, or have high dividend yields. This strategy
is subject to investment style risks.
ranges,
Growth Strategies
Generally, global strategies invest in a mix of
securities issued by U.S. and foreign companies,
which may include companies in developed and
emerging markets. Global strategies may invest in
companies of all market capitalization ranges and
in investments having any credit rating, maturity
or duration, or they may focus on specific
capitalization
industries or sectors,
geographic regions, credit ratings, maturities or
durations.
Geographic Region or Country Focused Strategies
A growth strategy typically invests primarily in
equity securities of growth companies, which are
those that the investment manager believes
exhibit signs of above-average growth relative to
peers or the market, even if the share price is high
relative to earnings or intrinsic value. This strategy
is subject to investment style risks.
Income Strategies
fixed
invest
Geographic region or country focused strategies
primarily invest in companies located a particular
part of the world, such as Latin America, Europe or
Asia, in a group of similarly-situated countries,
such as developed or emerging markets, or one or
more specific countries. These strategies alone
generally are not intended to satisfy a client’s
entire portfolio diversification needs. These
strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
An income strategy typically invests primarily in
income-producing securities, such as dividend-
income
paying equity securities and
securities. This strategy may
in a
combination of investment grade and high yield
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Tactical and Rotation Strategies
than other strategies. The
to
Opportunity strategies often experience higher
fluctuations in annual returns and overall market
value
types of
implement opportunity
investments used
strategies vary widely by manager and could
include equity securities, fixed income securities,
Non-Traditional Assets, Alternative Investment
Products and cash.
Tax Management Strategies
and
overweighting
Tax management strategies involve buying and
selling investments in a manner intended to reduce
the negative impact of U.S. federal income taxes.
They often involve buying or selling investments to
limit taxable investment gains or to offset taxable
investment gains with investment losses or selling
investments to avoid recognition of taxable
investment gains.
tax management strategy
is
Tactical strategies typically tactically and actively
adjust account allocations to different categories of
investments, such as asset classes, geographic
locations or market sectors, based upon the
manager’s perception of how those investments
will perform in the short-term. Similarly, rotation
typically actively adjust account
strategies
allocations to different market sectors based upon
the manager’s perception of how those market
sectors will perform in the short-term. Tactical and
rotation strategies are often driven by technical
analysis or methodologies and typically involve
underweighting
account
allocations to certain asset classes, geographic
locations or market sectors relative to an applicable
long-term strategic asset allocation, benchmark
index or the market generally. These strategies
often will be focused or concentrated in one or
more asset classes, geographic locations or market
sectors from time to time, and it is likely that they
will have limited or no exposure to one or more
asset classes, geographic locations or market
sectors. For that reason, tactical and rotation
strategies are often subject to concentration risk.
Because the decision-making for tactical and
rotation strategies is based upon the manager’s
short-term market outlook, accounts pursuing
these strategies often experience higher levels of
trading and portfolio turnover relative to other
strategies.
A
typically a
secondary strategy used to achieve a secondary
tax management objective and it is typically
implemented
together with other primary
investment strategies designed to achieve primary
investment objectives or goals. However,
managers in certain situations may use a tax
management strategy as the primary investment
strategy or tax management may be their primary
consideration when managing client Accounts,
such as when the manager is transitioning an
Account from one investment strategy to another.
Opportunity or Opportunistic Strategies
investment
Accounts pursuing a tax management strategy in
some instances will be subject to additional or
different risks of loss, which may be material. The
holdings of Accounts pursuing tax management
strategies will often differ from the holdings of
similarly-managed accounts that do not utilize
such a strategy, particularly if the tax management
strategy utilizes replacement securities. Therefore,
the performance of Accounts utilizing a tax
management strategy will vary from similarly-
managed accounts that do not utilize such a
strategy, possibly in a materially negative manner,
and such Accounts may not be successful in
pursuing any other
strategies,
objectives or goals.
adversely
investment strategies, there
Opportunity strategies will generally be invested in
a manner that seeks to provide long term growth
through capital appreciation and/or income by
utilizing an active management style that shifts the
amount of investment made in different asset
classes and market sectors to take advantage of
the manager’s perception of market pricing
anomalies, those market or industry sectors
deemed favorable for investment by the manager,
the current interest rate environment and/or other
macro-economic trends identified by the manager.
Opportunity strategies often involve the use of
other strategies, particularly tactical or rotation
strategies, and will have the risks associated with
those strategies. Opportunity Strategies may also
involve investment in a more-limited number of
companies compared to other strategies. As a
result, a decline in value of one or a few
investments will more
impact
performance than if assets were more evenly
invested in a larger number of companies.
Tax management strategies are not intended to,
and likely will not, eliminate a client’s tax
obligations relating to investments in an Account.
Like all
is no
guarantee that the implementation of a tax
management strategy will be successful. A client’s
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use of a tax management strategy may not actually
lower a client’s tax obligations or otherwise achieve
a client’s tax goals.
or another firm do not violate appliable tax rules
and bears the risk of such violations. A client is
strongly urged to consult the client’s tax advisor
prior to pursuing a tax management strategy.
Direct Indexing Strategies
involve
above
The effectiveness of tax management strategies
will be reduced if a client’s ability to recognize
losses for tax purposes is disallowed, limited or
deferred under applicable tax rules, such as the
IRS wash sales rules, which disallow losses if
substantially identical securities are purchased by
a client (whether through Baird or another firm)
within 30 days before or after a sale, and IRS
straddle rules, which limit and defer a client’s
ability to claim tax deductions related to the loss
on a sale of an investment in an Account if the
client holds an offsetting position in any account
held at Baird or another
firm. Some tax
the sale of
management strategies
securities at a loss and the reinvestment of the
proceeds into a replacement security that the
manager believes to not be “substantially identical”
for purposes of the IRS wash sales rule. A
manager’s belief may be incorrect, resulting in a
disallowance of the loss and reducing the intended
benefits of the tax management strategy.
Direct indexing strategies involve investing in a
basket of individual securities, such as stocks, that
seeks to track a selected benchmark index. Direct
indexing strategies may be more costly than other
investment options that track benchmark indices,
such as mutual funds and ETFs. Direct indexing
strategies also generally include the use of tax
management strategies in an attempt to enhance
Account performance. The use of tax management
strategies will cause an Account to deviate from the
benchmark index, which will cause the Account’s
returns to vary from that of the benchmark index.
The use of tax management strategies may not be
successful and the performance of Accounts
pursuing a direct index strategy could be materially
lower than the benchmark index. See “Tax
Management Strategies”
for more
information about the risks and limitations of tax
management strategies.
Alternative Strategies and Complex Strategies
invest
Alternative Strategies and other Complex
Strategies may
in a wide range of
investments, which may include equity securities,
fixed income securities, Non-Traditional Assets,
Alternative
Investment Products and cash.
Alternative Strategies and other Complex
Strategies generally involve the use of margin,
leverage, short sales and derivative instruments.
Many Alternative Strategies and other Complex
Strategies have no substantive restrictions on the
types of investments that may be used. Examples
of Alternative Strategies and other Complex
Strategies include the following.
Trading activity in a client’s accounts (whether at
Baird or another firm) may also inadvertently
violate the wash sales rules, resulting in disallowed
losses. The risk of inadvertent violations increases
as the number of client accounts and managers
involved increases because there is a higher
chance of uncoordinated or conflicting trading
activity in those accounts. Automatic purchases in
client accounts, such as dividend reinvestment
programs, may also inadvertently violate wash
sales rules. A client’s investments held in other
accounts at Baird or another firm may be deemed
to be offsetting positions for purposes of the IRS
straddle rules, which will also negatively impact the
client’s ability to deduct losses and will reduce the
intended benefit of the tax management strategy.
similar
or
• Relative Value Strategies. Relative value
strategies generally involve the purchase of
traditional assets, such as stocks and bonds, and
Non-Traditional Assets and the use of short sales
and derivative instruments in an attempt to
exploit price differences among securities that
share
financial
economic
characteristics.
Managers do not consider the holdings or
transactions in other client accounts (whether held
at Baird or another firm) when implementing tax
management
strategies. Managers do not
undertake any responsibility to monitor or verify a
client’s compliance with applicable tax rules, and
they are not responsible for any tax‑related effects
or obligations resulting from the investments or
transactions in a client’s Account. A client is
responsible for ensuring that the holdings and
transactions in the client’s other accounts at Baird
• Long/Short Strategies. Long/short strategies
generally involve the purchase of securities
believed to be undervalued and selling short
securities believed to be overvalued. They may
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also involve the use of Non-Traditional Assets,
leverage and derivative instruments.
and Non-Traditional Assets in an attempt to
generate performance that has low correlation to
the major equity markets over a complete
market cycle. They may also involve the use of
derivative instruments.
• Market Neutral Strategies. Market neutral
strategies generally involve the purchase of
securities and selling securities short in similar
dollar amounts in an attempt to produce returns
independent of general market
that are
performance. They may also involve the use of
Non-Traditional Assets, leverage and derivative
instruments.
as mergers,
restructurings,
• Event-Driven Strategies. Event-driven strategies
generally involve the use of Non-Traditional
Assets, short sales and derivative instruments in
an attempt to seek arbitrage opportunities,
particularly those triggered by corporate events
(such
and
liquidations). These strategies typically involve
the assessment of if, how and when an
announced transaction will be completed.
• Statistical Arbitrage Strategies. Statistical
Arbitrage is based on the theory that stocks have
a tendency to return to a short-term trend line.
This type of strategy typically involves the
“systematic” or automated trading of securities
based upon where a security is relative to its
trend line.
reorganizations
and
• Merger Arbitrage/Special Situations Strategies.
Merger arbitrage strategies involve the purchase
and sale of securities of companies involved in
corporate
business
combinations, such as mergers, exchange offers,
cash tender offers, spin-offs, leveraged buy-
outs, restructurings and liquidations. These
strategies often involve short selling, options
trading, and the use of other derivative
instruments.
• Convertible Arbitrage Strategies. Convertible
arbitrage involves the purchase and short sale of
multiple securities of the same company. The
strategy is implemented by purchasing securities
believed to be undervalued and selling short
securities believed to be overvalued. Often, the
strategy involves the purchase of a convertible
bond issued by a company and selling short that
company’s common stock. This strategy may
involve the use of a wide range of derivative
instruments.
• Distressed Strategies. Distressed strategies
generally involve the purchase of securities in
companies that are in financial distress, or
companies that are entering into or are already
in bankruptcy. They may also involve the use of
short sales and derivative instruments.
interest
rate
• Fixed Income Arbitrage Strategies. Fixed income
arbitrage strategies generally seek to profit from
interest rate, credit spread and other arbitrage
opportunities by investing in fixed income
securities,
instruments and
derivative instruments.
• Macro Strategies. Macro strategies generally
involve the purchase of traditional assets, such
as stocks and bonds, and Non-Traditional Assets
and the use of short sales and derivative
instruments in an attempt to profit from
in securities markets,
anticipated changes
commodities markets, currency values, and/or
interest rates.
trading
• Capital Structure Arbitrage Strategies. Capital
structure arbitrage generally involves investing
in multiple levels of a single company’s capital
structure, often taking long and short positions
in a company’s debt or equity in order to
capitalize on perceived mispricings resulting
from market inefficiencies or different pricing
assumptions. This type of strategy typically
involves the use of derivatives and structured
products.
• Discretionary and Systematic Trading Strategies.
strategies generally
Discretionary
attempt to identify and capitalize on patterns or
trends in the markets. Systematic trading
strategies generally rely on computerized trading
systems or models to identify and capitalize on
those patterns or trends. These strategies often
involve the use of Non-Traditional Assets, short
sales, derivative instruments and significant
leverage.
• Absolute Return, Total Return and Real Return
Strategies. Absolute return, total return and real
return strategies generally involve the purchase
of traditional assets, such as stocks and bonds,
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• Private Investment Strategies.
or environmental hazards. Leverage is often
used in private real estate investments, which
can
increase potential returns but also
amplifies potential losses.
typically made
o Private
invest
and
transportation.
typically made
in
private
o Private Equity Strategies. Private equity
strategies generally involve equity investments
in companies in private transactions. These
investments are
through
participation in private equity funds or funds of
private equity funds. Private equity strategies
may invest in companies of all market
capitalization ranges or may focus on any
combination of specific capitalization ranges.
They may also focus on companies in one or
industries or sectors or
more economic
geographic regions. Some private equity
strategies focus on companies that are newly
formed, in financial distress or already in
bankruptcy. The securities purchased are
typically unregistered and illiquid. Private
equity strategies may also involve the use of
leverage.
Infrastructure Strategies. Private
infrastructure
in
strategies
infrastructure projects and assets and may
involve exposure to a range of economic or
market sectors, geographic locations and asset
types. Examples of infrastructure investments
include, among others, telecommunication,
These
utilities,
investments are
through
participation in private infrastructure funds.
Investments
infrastructure
strategies are often illiquid. They may focus on
certain sectors, industries, geographic regions,
size ranges or stages of development or
operations, or on certain types and sizes of
investments and may, therefore, also lack
diversification.
• Leveraged Strategies. Leveraged strategies
generally involve the use of Non-Traditional
Assets, leverage, short sales and derivative
instruments in an attempt to amplify returns or
produce returns that are a multiple of a
benchmark index.
• Inverse Strategies. Inverse strategies generally
involve the use of Non-Traditional Assets,
leverage, short sales and derivative instruments
in an attempt to produce returns that are the
opposite of a benchmark index.
involve
investment
in
distressed
or
o Private Debt or Private Credit Strategies.
Private debt (also known as private credit)
strategies invest in loans or debt instruments
issued by companies in private transactions.
These investments are typically made through
participation in private debt funds or funds of
private debt funds. The investments involved
are typically unrated or rated below investment
grade and are illiquid. Oftentimes, the interest
rate paid by the companies is determined by a
reference interest rate, such as the federal
funds rate, which is periodically reset. These
types of investments are sometimes referred
to as floating rate corporate debt, floating rate
loans or floating rate bank loans. Private debt
strategies often involve the use of leverage and
smaller
may
capitalization,
bankrupt
companies.
industrial
typically made
Alternative Strategies and other Complex
Strategies are not appropriate for some clients
because they are subject to special risks. See
“Services, Fees and Compensation—Additional
Program Information—Complex Strategies and
Complex
Investment Products” above and
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks—Non-Traditional
Assets and Complex Strategies Risks” below for
more information.
Asset Allocation Strategies
Certain Programs, including the ALIGN, BairdNext
Portfolios, PIM, Russell, Baird Affiliated Managers,
and UMA Programs, make available asset allocation
strategies. Asset allocation strategies involve
o Private Real Estate Strategies. Private real
estate strategies invest in physical properties,
such as office buildings, apartments, retail
facilities. These
centers, and
investments are
through
participation in private REITs. Private real
focus on specific
estate strategies may
types, or
regions, property
geographic
economic sectors. Investments in private real
estate can be illiquid, meaning they may take
time to sell or refinance. Property values can
fluctuate due to market conditions, supply and
demand, and other factors. There are also risks
related to tenant vacancies, property damage,
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investing in one or more of the following categories
of assets:
strategies, sometimes referred to as dynamic
strategies.
Asset allocation strategies may be implemented
using a variety of investment types, such as
individual securities, mutual funds and ETPs. The
amount allocated to an asset class or investment
type varies by strategy, and some strategies may
have little or no allocation to one or more asset
classes or types of investments described above.
• the equity securities asset category, which is
comprised of certain asset classes, such as,
equity securities issued by: U.S. large cap growth
companies; U.S. large cap value companies; U.S.
large cap core companies; U.S. mid cap growth
companies; U.S. mid cap value companies; U.S.
mid cap core companies; U.S. small cap growth
companies; U.S. small cap value companies;
U.S. small cap core companies;
foreign
companies located in developed markets; foreign
companies located in emerging markets; U.S.
REITs; and foreign REITs;
that are based upon
• the fixed income securities asset category, which
is comprised of certain asset classes, such as:
short-term taxable bonds; intermediate term
taxable bonds; long-term taxable bonds; short-
term tax-exempt bonds; intermediate term tax-
exempt bonds; long-term tax-exempt bonds;
high yield fixed income securities; foreign fixed
income securities; and broad fixed income
securities;
Baird uses its Capital Market Assumptions in
developing its proprietary model asset allocation
strategies, including those used in the ALIGN,
BairdNext Portfolios and UMA Programs, and those
used by some PIM Managers. In determining its
Capital Market Assumptions, Baird conducts an
analysis of different asset classes and the different
levels of risk associated with those investments.
That analysis involves the consideration of past
performance and the use of forward-looking
certain
projections
assumptions made by Baird about how markets will
perform in the future. There is no assurance that
asset classes or markets will perform in accordance
with Baird’s projections or assumptions. For more
about Baird’s Capital Market
information
Assumptions, a client should contact the client’s
Financial Advisor.
• the Non-Traditional Assets category, which is
comprised of certain asset classes, such as:
commodities and commodity-linked instruments;
and currencies and currency-linked instruments,
and Digital Assets;
Baird’s most common asset allocation strategies
are described below. A client should note that the
specific investments in an Account following a
particular asset allocation strategy could vary from
the description below for a number of reasons,
including market conditions.
• the Alternative Investment Products category
which is comprised of certain asset classes, such
as: hedge funds, private equity funds and
managed futures; and
• cash.
allocation
strategies
have
All Growth Portfolio. An All Growth Portfolio
typically seeks to provide growth of capital.
Typically, an All Growth Portfolio will experience
high fluctuations in annual returns and overall
market value. Under normal market conditions,
this strategy generally invests nearly all of its
assets in equity securities. This strategy may also
invest in other asset classes, such as fixed income
securities, Non-Traditional Assets and cash. This
strategy may also invest in Alternative Investment
Products or may involve the use of leverage, short
sales and derivative instruments.
Capital Growth Portfolio. A Capital Growth Portfolio
typically seeks to provide growth of capital.
Typically, a Capital Growth Portfolio will experience
moderately high fluctuations in annual returns and
varying
Asset
investment objectives, ranging from growth of
capital to preservation of capital. Asset allocation
strategies also have varying investment strategies.
Some asset allocation strategies use strategic
investment strategies, which involve investing
accounts in accordance with a predetermined
target allocation to different asset classes. Some
asset allocation strategies use tactical investing,
which typically involves tactically and actively
adjusting account allocations to different asset
classes based upon the manager’s perception of
how those asset classes will perform in the short-
term. Some asset allocation strategies involve the
use of both strategic and tactical investment
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Generally, under normal market conditions, this
strategy will primarily invest in a mix of fixed
income securities, cash and equity securities, with
a significantly higher allocation to fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets.
Generally, under normal market conditions, this
strategy will have a significantly higher allocation
to fixed income securities and cash than equity
securities.
Preservation
A
Portfolio.
overall market value. Generally, under normal
market conditions, this strategy will primarily
invest in a mix of equity securities and fixed income
securities, with a significantly higher allocation to
equity securities. This strategy may also invest in
other asset classes, such as Non-Traditional Assets
and cash. This strategy may also invest in
Alternative Investment Products or may involve
the use of leverage, short sales and derivative
instruments. Generally, under normal market
conditions, this strategy will have a significantly
higher allocation to equity securities than fixed
income securities.
typically seeks
Capital
Capital
Preservation Portfolio typically seeks to preserve
capital while generating current income. Typically,
a Capital Preservation Portfolio will experience
relatively small fluctuations in annual returns and
overall market value. Under normal market
conditions, this strategy generally invests nearly all
of its assets in a mix of fixed income securities and
cash. This strategy may also invest in other asset
classes, such as equity securities and Non-
Traditional Assets.
Growth with Income Portfolio. A Growth with
Income Portfolio
to provide
moderate growth of capital and some current
income. Typically, a Growth with Income Portfolio
will experience moderate fluctuations in annual
returns and overall market value. Generally, under
normal market conditions, this strategy will
primarily invest in a mix of equity securities and
fixed income securities, with a bias towards equity
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
equity securities than fixed income securities.
fixed
Some ALIGN Programs, UMA Programs, Baird
Financial Advisors and investment managers use
asset allocation strategies that include target asset
allocation percentages for equity and/or fixed
income investments in the names or descriptions
of the strategies (e.g., 80-20, 60-40, 40-60, 20-
80, etc.). A client should note that those
percentages are intended to be asset allocation
targets only. There is no guarantee that Accounts
following asset allocation strategies will be
invested strictly in accordance with target asset
allocations. It is likely that the actual investments
in Accounts following those strategies will vary,
sometimes significantly, from the target asset
allocations and may include other asset classes due
to market conditions and Baird’s, the Financial
Advisor’s or investment manager’s assessment of
how to best invest a client’s Accounts. See
“Important Information about Implementation of
Investment Objectives and Investment Strategies”
below for more information.
Income with Growth Portfolio. An Income with
Growth Portfolio typically seeks to provide current
income and some growth of capital. Typically, an
Income with Growth Portfolio will experience
moderate fluctuations in annual returns and overall
market value. Generally, under normal market
conditions, this strategy will primarily invest in a
income securities and equity
mix of
securities, with a bias towards fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
fixed income securities than equity securities.
For information about the risks associated with the
asset allocation strategies described above, see the
section of the Brochure entitled “Principal Risks—
Investment
Risks Associated with Certain
Objectives and Asset Allocation Strategies” below.
Conservative Income Portfolio. A Conservative
Income Portfolio typically seeks to provide current
income. Typically, a Conservative Income Portfolio
will experience relatively small fluctuations in
returns and overall market value.
annual
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Important Information about Implementation of
Investment Objectives and Investment Strategies
managed or advised and whether any such
conditions exist.
Methods of Analysis
its PWM home office
Baird,
investment
professionals, and its Financial Advisors may use
various forms of investment analyses, including
the following:
A client should note that, to implement an
investment strategy, a client’s Financial Advisor or
investment manager may use or recommend
mutual funds, ETPs or other Funds that primarily
invest in particular types of securities instead of
direct investment in those types of securities. A
client should also note that the client’s Financial
Advisor or investment manager may use a strategy
not described above or they may use a strategy
with the same or similar name that is implemented
differently. A client should ask the client’s Financial
Advisor or investment manager for more specific
information about the strategy being used for the
client’s Account.
• Fundamental Analysis. Fundamental analysis
involves an approach to investing through a
detailed analysis of specific companies, such as
their financial statements and financial ratios,
management, competitive advantages and
markets, in an attempt to determine the value of
an
investment. Fundamental analysis may
include qualitative and quantitative analyses.
A client’s Account is subject to the risks associated
with the Account’s particular strategies and
investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
• Qualitative Analysis. Qualitative analysis involves
the use of subjective judgment to analyze factors
that may be difficult to quantify or measure
objectively. As it pertains to managers and
investment products, qualitative analysis may
include review of the background and experience
of a manager or a mutual fund company.
in an attempt
• Quantitative Analysis. Quantitative analysis is a
method of evaluating securities by analyzing a
large amount of data through the use of
algorithms or models
to
understand behavior, predict market events,
market prices, etc., and generate an investment
decision. As it pertains to managers and
investment products, quantitative analysis may
review of manager performance,
include
investment style, style consistency, risk, and
risk-adjusted performance.
• Technical Analysis. Technical analysis is a
method of analyzing past price and volume
patterns and trends in the trading markets to
attempt to predict the direction of both the
overall market and specific investments.
• Top-Down Analysis. Top-down analysis involves
a consideration of certain macroeconomic trends,
such as general economic conditions, geographic
or market sector performance,
fiscal and
monetary policy, taxes, or interest rates, to
make investment decisions.
From time to time, the client’s Financial Advisor or
invest the client’s
investment manager will
Account, or recommend that the client invest the
Account, in a manner that is inconsistent with the
investment strategy or
investment objective
selected by the client for the Account when the
client’s Financial Advisor or investment manager
determines that it is appropriate to do so, such as
using defensive strategies in response to adverse
market or other conditions or engaging in tax
management. Similarly, a client’s Account may be
invested in a manner inconsistent with the
investment strategy or
investment objective
selected by the client for the Account in certain
other circumstances, such as when the client’s
Account is transitioning to a new Program,
investment objective or investment strategy, or
due to other factors, such as market appreciation
or depreciation of the assets in the client’s Account,
deposits and withdrawals made by the client, and
investment restrictions, if any, imposed by the
client. A client’s Account may not be able to
achieve its investment objectives during any such
period of time and the Account may be subject to
different or enhanced risks than would be the case
had the Account been invested in a manner wholly
consistent with the
investment objective or
investment strategy selected by the client. Clients
are encouraged to discuss with their Financial
Advisor on a regular basis how the Account is being
• Bottom-Up Analysis. Bottom-up analysis involves
consideration of factors particular to a particular
investment, such as business financials (e.g.,
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in
(e.g., price-to-earnings
Tool-assisted outputs used
formulating
investment advice are subject to human review
before such outputs inform recommendations or
investment decisions.
balance sheet strength and cash flows), financial
ratios
ratio), and
business fundamentals (e.g., management and
product or services performance) to make
investment decisions.
When providing investment advice to clients, Baird
Financial Advisors utilize research reports and
other research material created by Baird PWM
Research Groups, such as PWM Equity Research,
PWM Fixed Income Research, and Asset Manager
Research. Baird Financial Advisors may also utilize
research reports created by Baird’s Institutional
Equities & Research Department. It should be
noted that Baird Financial Advisors are not
obligated to act in a manner consistent with those
research reports and they may act in a manner that
is contrary to those reports if they deem it to be in
the client’s best interest.
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations,
deceptive behaviors and other flaws due to the
construction of their underlying models and the
composition of their training data, which can result
in outputs that seem plausible but are in fact
inaccurate, incomplete, or misleading. The use of
AI Tools creates a risk that erroneous information
could negatively influence the investment-advice
process. Baird has established policies and
procedures designed to address the risks posed by
AI Tools, which include requirements that AI Tools
pass a firm-level due diligence process and that
Baird associates obtain training and independently
verify AI Tool outputs. However, such measures
cannot eliminate the risks posed by AI Tools.
Baird PWM Research Groups and Baird Financial
Advisors use various third party information and
tools when formulating investment advice. The
sources of information and tools may include,
among others, information provided or created by
issuers and their sponsors (which may include
information that is reported publicly, provided
directly to Baird, or reported through third party
platforms) and information and tools provided by
third party research firms, which may include firms
affiliated with Baird. Although Baird has deemed
the information and tools provided by third party
research firms to be generally reliable, Baird does
not independently verify or guarantee the accuracy
of the information or tools used.
When providing investment advice to clients, Baird
Financial Advisors may also use the model
portfolios or recommended or eligible product lists
(described below) made available by Baird’s PWM
Research Groups, or they may use investment
products that Baird has generally deemed to be
“available” for use in its advisory programs
(“Available Investment Products”). The level of
initial and ongoing evaluation, monitoring and
review that Baird and its Financial Advisors perform
on managers and on investment products varies.
Available Investment Products generally do not
receive the same level of initial or ongoing
evaluation, monitoring or review by Baird as those
managers or products that are included in a model
portfolio or on a recommended or eligible product
list. As a result, Available Investment Products are
subject to certain risks. See “Portfolio Manager
Selection and Evaluation—Methods of Analysis,
Investment Strategies and Risk of Loss—Principal
Risks—Available Investment Product Risks” below
for more information.
summarization,
analysis
for
the client’s Account,
Baird PWM home office investment professionals
and Baird Financial Advisors may use artificial
intelligence (“AI”) tools, such as machine learning,
predictive analytics and probabilistic modeling
tools, data processing and automation tools,
generative AI tools, visual, speech and audio tools,
specialized domain tools, and other similar
technologies and tools (collectively, “AI Tools”), in
formulating investment advice. Generally, the use
of AI Tools is limited to certain aspects of Baird’s
investment-advice process, such as assisting with
drafting of materials, automation of workflow
processes, and the compilation, reproduction,
organization,
and
interpretation of information. The use of AI Tools is
only supportive of Baird’s
investment-advice
process and does not replace the professional
judgment of Baird PWM home office investment
professionals or Baird Financial Advisors. All AI
More specific information about Baird PWM model
portfolios, recommended lists and eligible product
lists is provided below. A client should note that
investment products recommended to the client or
selected
including
investment managers or products included on a
Baird PWM recommended or eligible product list,
are those which, in Baird’s professional judgment,
may be appropriate to help the client pursue the
client’s financial goals. Baird and its Financial
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Advisors do not represent or guarantee that such
investment managers or products are or will be the
best investment managers or products available.
Under certain circumstances when requested by a
client, Baird may allow a client to transfer from
another firm or select an investment product that
is not on a Baird recommended or eligible product
list or that does not qualify as an Available
Investment Product. A client should note that Baird
does not provide any initial or ongoing evaluation,
monitoring or review of any such investment
product and that the client’s decision to transfer or
select such investment product is based solely
upon the client’s review of the investment product.
Certain PWM-Managed Portfolios
Baird Recommended Portfolio
portfolio yield above that of the S&P 500 Index.
The team’s top–down investment approach begins
with macroeconomic and market outlooks from
Baird’s Investment Strategy team. The 30–50
stocks in the portfolio are primarily large cap
stocks—as defined by a market capitalization of
$10 billion or greater at the time of investment—
and all are above $5 billion at the time of
investment. The team looks for quality companies
with strong
fundamental characteristics and
management, attractive dividend yields, and the
ability to increase their dividends. Companies are
screened for dividend history and consistency,
earnings growth expectations, and balance sheet
quality. Each stock selected is assigned a weighting
as a percentage of the portfolio. No single company
stock will comprise more than the greater of 5% of
the portfolio or 1.5 times the stock’s market weight
in the S&P 500 index; provided that a stock will not
be removed due to capital appreciation. A position
can be reduced or removed due to changes in
valuation, company fundamentals or the perceived
ability to continue to raise its dividend in the
future—among a variety of other potential reasons
for portfolio changes including a change in industry
sector weighting. The Portfolio is intended as a
long-term investment strategy.
AQA Portfolios
investment
approach
The Baird Recommended Portfolio, which
is
managed by Baird’s PWM Equity Research team,
seeks to outperform the S&P 500 Index by
investing in a diversified core portfolio of 35–50
stocks. The portfolio invests primarily in stocks
with market capitalization greater than or equal to
$10 billion (large cap). The portfolio may also
contain stocks with market caps below $10 billion
but these stocks generally will not represent more
than 35% of the total portfolio. The team’s top–
down
begins with
macroeconomic and market outlooks from Baird’s
Investment Strategy team. This information is
used to underweight or overweight particular
industry sectors compared to the S&P 500 Index.
Individual stocks are selected with an emphasis on
higher quality companies that the team believes
have strong
fundamental characteristics and
management teams, attractive growth prospects,
and reasonable price-appreciation expectations.
Each stock selected is assigned a weighting as a
percentage of the portfolio. No single company
stock will comprise more than the greater of 5% of
the portfolio or 1.5 times the stock’s market weight
in the S&P 500 index; provided that a stock will not
be removed due to capital appreciation. Stocks can
be sold or positions reduced for a variety of reasons
such as valuation, a change in company or industry
fundamentals, or a change in industry sector
weighting. The Portfolio is intended as a long-term
investment strategy.
Baird Rising Dividend Portfolio
Baird makes available to clients certain Automated
Quantitative Analysis (“AQA”) Portfolios, which are
managed by Baird’s PWM Equity Research team.
AQA is an analytical tool that seeks to identify
stocks of companies that are undervalued by
calculating the intrinsic values for the stocks and
comparing the calculated values to current market
prices. Focusing on a company’s past financial
performance, AQA analyzes fundamental ratios
and trends of the most recent eight-year history of
a company and each company in its peer group,
excluding estimates of future balance sheet and
income statement performance. The analysis is
quantitative and
ignores certain qualitative
information such as company-specific material
news and events. Stocks are ranked from the most
undervalued to the most overvalued based on the
difference between the values calculated by AQA
and current market prices. The stocks identified by
AQA as being the most undervalued are then
selected for investment. Baird offers the following
four (4) AQA Portfolio strategies, each of which
invest in undervalued stocks identified using AQA,
excluding securities issued by banks, REITS and
insurance companies: (1) the AQA All Cap
The Baird Rising Dividend Portfolio, which is
managed by Baird’s PWM Equity Research team,
seeks to provide a core equity strategy with a
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Baird’s Asset Manager Research Department may
also employ the use of computers and third party
software to more readily display information and
assist with the evaluation and analysis.
Strategy, which primarily invests in stocks across
market capitalizations, generally those included in
the S&P 500®, S&P MidCap 400® or S&P SmallCap
600® Indices; (2) the AQA Large Cap Strategy,
which primarily invests in large cap stocks,
generally those included in the S&P 500® Index;
(3) the AQA Mid Cap Strategy, which primarily
invests in mid cap stocks, generally those included
in the S&P MidCap 400® Index; and (4) the AQA
Small Cap Strategy, which primarily invests in
small cap stocks, generally those included in the
S&P SmallCap 600® Index.
Certain Recommended Lists
Baird’s Recommended Managers List
Baird’s initial screening process begins with a
proprietary, multi-factor model that evaluates
managers on different factors including risk-
adjusted performance, consistency of returns and
downside protection. These factors are scored over
various time periods and relative to a specific peer
group universe, narrowing the pool of managers
for further evaluation. Baird’s Asset Manager
Research Department then performs a more in-
depth evaluation of managers that are identified
through the initial screening process, which
generally includes a review of the following factors:
stability of the firm/team, the robustness and
repeatability of the investment process, the
portfolio’s past returns pattern and tax-efficiency,
and how the manager adds value. The final
determination of Baird’s Recommended Managers
List is subject to the approval of Baird’s Investment
Committee.
to see
for
removal
When selecting managers and BRM Strategies for
Baird’s Recommended Managers List, Baird often
seeks registered investment advisory firms having
portfolio managers with academic credentials such
as a master’s degree or participation or completion
of
the Chartered Financial Analyst (“CFA”)
program. Baird also typically looks for a portfolio
manager with greater than three (3) years of
investment experience focusing on the particular
investment style that is offered by the portfolio
manager. Baird generally looks for portfolio
managers that have demonstrated success, that
have performance histories showing sufficient
ability to achieve returns in excess of their
respective benchmarks, and that have investment
processes, infrastructure, personnel and other
resources satisfactory
to Baird. Baird also
considers other qualitative and quantitative
factors.
Baird’s Asset Manager Research Department is
primarily responsible for selecting and evaluating
included on Baird’s
investment managers
Recommended Managers List.
selecting
In
investment managers, Baird’s Asset Manager
Research Department utilizes quantitative and
qualitative measures to evaluate managers based
on the:
Ongoing manager evaluation generally includes
quarterly conference calls, performance attribution
and periodic onsite visits. Material adverse changes
affecting a manager may result in the manager
being placed on “watch” status. Managers on
if
“watch” status are scrutinized
improvement or degradation is taking place.
Potential causes
from Baird’s
Recommended Managers List include fundamental
changes in the operations of the manager,
turnover in key personnel, substantial changes in
management or ownership, a change in investment
philosophy or style, significant drift from stated
objectives, major legal, regulatory or compliance
difficulties, impairment of financial condition,
sustained underperformance in relation to its
peers, or other adverse changes affecting the
manager that in Baird’s opinion warrants the
manager’s removal.
• quality and stability of their organization
• soundness and clarity of their investment
philosophy
that
• reliability and consistency of their investment
process
• competitiveness of their investment
performance
If a Model-Traded BRM Strategy is selected for a
client’s Account, it is important to note that Baird’s
selection and ongoing evaluation of a BRM Strategy
the
is based upon an assumption
Recommended Manager’s Model Portfolio will be
fully and faithfully implemented by the Overlay
Manager or Implementation Manager on a
continuous basis. A client should understand that
the Overlay Manager or Implementation Manager
has discretion over the client’s Account and may
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invest the client’s Account in a manner that differs
from the Model Portfolio. Baird does not monitor
the Account’s performance nor does it ascertain
whether the Overlay Manager or Implementation
Manager is implementing the Model Portfolio as
provided by the Recommended Manager. If the
Overlay Manager or Implementation Manager, in
the exercise of its discretion, decides to implement
the Model Portfolio differently, the performance of
a client’s Account could be negatively impacted.
Baird is not monitoring, evaluating or reviewing the
Overlay Manager or Implementation Manager or
the performance of a client’s Account under those
circumstances.
Recommended Managers List” above. Baird’s
Investment Committee is ultimately responsible for
selecting funds included on the List. The Baird Ultra
Short Bond Fund, Baird Short-Term Bond Fund,
Baird Aggregate Bond Fund, Baird Quality
Intermediate Municipal Bond Fund, Baird Core
Intermediate Municipal Bond Fund, and Baird Mid
Cap Growth Fund, mutual funds affiliated with
Baird, have been selected by Baird for inclusion in
Baird’s Recommended Mutual Fund List. This
presents a conflict of interest. However, the criteria
used by Baird in deciding to select Associated
Funds for Baird’s Recommended Mutual Fund List
are the same as those used for unassociated funds.
Baird’s Recommended Funds of Hedge Fund List
SMA
Strategies
for
Certain SMA Strategies offered by Baird Equity
Asset Management have been selected by Baird for
inclusion on Baird’s Recommended Managers List.
This presents a conflict of interest. However, the
criteria used by Baird in deciding to select
Associated
Baird’s
Recommended Managers List are the same as
those used for unassociated SMA Strategies.
Baird’s Recommended Mutual Fund List
Baird’s Recommended Funds of Hedge Fund List
may contain several types of funds of hedge funds
(“FOHFs”)
that pursue various Alternative
Strategies or other Complex Strategies. Some
FOHFs primarily use credit-oriented investment
strategies, which Baird classifies as fixed income
diversifiers. Some FOHFs primarily use equity-
oriented investment strategies and are classified as
equity diversifiers. Other FOHFs use a combination
of credit- and equity-oriented strategies, which
Baird views as balanced diversifiers. In certain
circumstances, FOHFs may be an appropriate
substitute for part of a client’s allocation to
traditional high yield fixed income or equity
investments.
the
To be added to Baird’s Recommended FOHF List, a
FOHF must generally meet
following
requirements: the investment advisor to the FOHF
is registered as an Investment Adviser under the
Advisers Act; the fund has stable to growing assets
under management as determined by Baird,
principals of the fund have an appropriate level of
fund management experience and a
hedge
sufficient network of contacts in the industry as
determined by to Baird; in Baird’s opinion, the fund
has adequate diversification by number of hedge
funds and type of hedge fund strategy; effective
risk management programs have been established
for the fund; and the service providers to the fund
(e.g., auditor, administrator, and legal counsel) are
deemed to be reputable in the judgment of Baird.
Baird also seeks FOHFs that it believes possess one
or more unique attributes that may lead to
favorable performance relative to their peers going
forward.
Baird’s Recommended Mutual Fund List is designed
to include mutual funds and ETFs across numerous
asset classes. When selecting funds for inclusion on
the List, Baird generally seeks funds that have
investment managers with tenure of at least three
(3) years and have underlying investments that
adhere to the fund’s market capitalization policy
and are consistent with the manager’s stated
investment process and philosophy. Baird
generally looks for funds that are among the top-
performing funds in a style category in terms of
risk-adjusted returns or that are managed by
individuals or firms that have demonstrated
success in other, related asset classes; that have
performance histories showing sufficient ability to
achieve returns in excess of their respective style
index; and that have investment processes,
infrastructure, personnel and other resources
satisfactory to Baird. Baird’s Asset Manager
Research Department is primarily responsible for
assisting with selecting and evaluating funds
included on the List. In selecting funds, Baird’s
Asset Manager Research Department utilizes a
quantitative and qualitative evaluation process of
the investment managers of such funds. The
process Baird uses for selecting and removing
funds for the Baird Recommended Fund List is
similar to the process Baird uses to select and
remove BRM Strategies described under “Baird’s
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Baird’s opinion, the problem has been or is in
process of being adequately addressed. However,
Baird will terminate a FOHF from the List if it
believes the issue is likely to be long-term and
adversely affect the FOHF’s future performance.
legal documents
Baird’s Recommended Private Funds Lists
offering memorandum,
Baird maintains lists of recommended private
Funds (“Recommended Private Funds”), including
a Recommended Funds of Private Equity Funds
List, a Recommended Private Debt Fund List, and
a Recommended Private Real Assets Fund List.
Before adding a prospective FOHF to the List,
Baird’s Asset Manager Research Department
conducts an in-depth due diligence process. The
process begins with a review of the FOHF’s
responses to a due diligence questionnaire and of
marketing and
(such as,
subscription documentation, investor agreements,
and
organizational
documents, and the investment advisor’s Form
ADV Part 2A Brochures). This is followed by an
onsite review, where Baird meets with one or more
principals and analysts to assess how the FOHF
terminates
identifies, hires, monitors, and
individual hedge funds. Baird also evaluates how
the FOHF constructs its hedge fund portfolio and
manages risk. At the conclusion of the onsite
review, an investment thesis is presented to and
discussed with a Baird Investment Committee. The
Committee votes on whether to add the FOHF to
Baird’s Recommended Funds of Hedge Fund List.
In making that determination, the Committee
considers the information presented, taking into
account the merits of the individual FOHF, how that
FOHF compares to other FOHFs that Baird offers,
and the level of expected demand for the particular
FOHF.
Baird’s Recommended Funds of Private Equity
Funds List contains funds of private equity funds
that pursue certain Alternative Strategies or other
Complex Strategies. These strategies can include
buyout, growth equity, venture capital, special
situations or distressed
investments. The
investments are typically structured in the form of
primary funds, secondary funds or co-investments.
Most will be to “middle market” companies, many
of which have above average to high levels of
leverage, or debt relative to equity. In certain
circumstances, funds of private equity funds may
be an appropriate substitute for part of a client’s
allocation to traditional equity investments.
and
onsite
changes
After a FOHF is added to Baird’s Recommended
Funds of Hedge Fund List, it is monitored each
quarter,
reviews
subsequent
periodically take place. As part of its quarterly
monitoring, Baird evaluates a FOHF’s assets under
(subscriptions and
management and
flows
redemptions), organizational
(e.g.,
personnel changes or new offerings), recent
changes made to the FOHF portfolio (e.g., hedge
funds added or removed), and reasons for
performance differences between the FOHF and its
benchmark. Subsequent onsite reviews are similar
in nature and scope to the initial on-site review.
Baird’s Recommended Private Debt Fund List
contains private debt funds (also known as private
credit funds) that pursue certain Alternative
Strategies or other Complex Strategies. The
private debt funds on Baird’s Private Debt Funds
List generally make first lien, second lien and
unsecured loans, primarily to middle market
companies sponsored by private equity firms. In
certain circumstances, private debt funds may be
an appropriate substitute for part of a client’s
allocation to traditional high yield fixed income or
equity investments.
Baird’s Recommended Private Real Assets Fund
List contains private real estate and private
infrastructure funds that pursue certain Alternative
Strategies or other Complex Strategies. These
strategies invest in different real assets and may
involve exposure to a range of economic or market
sectors, geographic locations and asset types.
Examples of investments may include, among
others, real estate, telecommunication, utilities,
and transportation. The investments may be
structured in the form of asset ownership or leasing
or include direct investment in or joint ventures
with companies that control infrastructure assets.
Baird may place a FOHF on “watch” status if it has
experienced a material event that, in Baird’s
opinion, may negatively affect
the FOHF’s
performance going forward or possibly lead to the
departure of an important member(s) of the FOHF.
Examples include a large decline in assets under
management, high rate of redemptions, notable
change in the investment or compliance teams,
weakening performance, or regulatory problems.
Any firm that is placed on “watch” status is
evaluated more closely to determine if the problem
is likely to be temporary or long-term, and whether
it can be remedied. Baird will remove a FOHF from
“watch” status and return it to active status if, in
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In certain circumstances, private real assets funds
may be an appropriate substitute for part of a
client’s allocation to traditional fixed income or
equity investments.
(subscriptions and redemptions), organizational
changes
(e.g., personnel changes or new
offerings), recent changes made to the portfolio,
and reasons for performance differences between
the fund and its benchmark. Subsequent onsite
reviews are similar in nature and scope to the initial
on-site review.
To be added to a Baird Recommended Private Fund
List, a fund must generally meet the following
requirements: the investment advisor to the fund
is registered under the Advisers Act ; the fund has
stable to growing assets under management as
determined by Baird; principals of the fund have
an appropriate level of applicable experience and a
sufficient network of contacts in the industry as
determined by Baird; effective risk management
programs have been established for the fund; and
the service providers to the fund (e.g., auditor,
administrator, and legal counsel) are deemed to be
reputable in the judgment of Baird. Baird also
seeks funds that it believes possess one or more
unique attributes that may lead to favorable
performance relative to their peers going forward.
fund
Baird may place a Recommended Private Fund on
“watch” status if it has experienced a material
event that, in Baird’s opinion, may negatively
affect the fund’s performance going forward or
possibly lead to the departure of an important
member(s) of the
investment team.
fund’s
Examples include a large decline in assets under
management, high rate of redemptions, notable
change in the investment or compliance teams,
weakening performance, or regulatory problems.
Any fund that is placed on “watch” status is
evaluated more closely to determine if the problem
is likely to be temporary or long-term, and whether
it can be remedied. Baird will remove a fund from
“watch” status and return it to active status if, in
Baird’s opinion, the problem has been or is in
process of being adequately addressed. However,
Baird will remove a fund from a Recommended
Private Fund List if it believes the issue is likely to
be long-term and adversely affect the fund’s future
performance.
Certain Eligible Product Lists
Annuities
third-party service providers. At
When determining whether to make an annuity
product available to Baird clients, Baird reviews the
offering documents for the product and considers:
the size of the insurer and the insurer’s credit
rating, the insurer’s distribution and support
model, and product specifications and features of
the product. Baird favors highly-rated insurers and
evaluates them by using credit rating agencies
financial strength ratings and independent third-
party research.
Baird’s ETF Focus List
the
Before adding a prospective
to a
Recommended Private Fund List, Baird’s Asset
Manager Research Department conducts an in-
depth due diligence process. The process begins
with a review of the fund’s responses to a due
diligence questionnaire (known as a DDQ or RFI)
and of marketing and legal documents (such as,
subscription documentation, investor agreements,
offering memorandum, organizational documents,
and the investment advisor’s Form ADV Part 2A
Brochures). This is followed by an onsite review,
where Baird meets with one or more principals and
analysts to assess how the fund makes investment
decisions. Baird also evaluates how the fund
constructs its portfolio and manages risk. In
addition, Baird may undertake a brief review of the
fund’s
the
conclusion of the onsite review, an investment
thesis is presented to and discussed with a Baird
Investment Committee. The Committee votes on
whether to add the fund to a Baird Recommended
Private Fund List. In making that determination,
information
considers
the Committee
presented, taking into account the merits of the
individual fund, how that fund compares to other
similar funds that Baird offers, and the level of
expected demand for that particular fund.
Baird’s ETF Focus List is designed to encompass
numerous asset classes and varied investment
objectives. Baird generally seeks to include ETPs,
primarily ETFs, with transparent, experienced
sponsors that have stable or growing assets under
management and have demonstrated consistent
strategy performance over time. Baird tends to
favor ETPs that have well-known, diversified
benchmark indices, lower fees and tracking errors,
and higher trading liquidity relative to other ETPs.
After a fund is added to a Baird Recommended
Private Fund List, it is monitored each quarter, and
subsequent onsite reviews periodically take place.
As part of its quarterly monitoring, Baird evaluates
a fund’s assets under management and fund flows
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Investment Solutions Department
is not meant
Inclusion on or exclusion from the Baird ETF Focus
List
to be a buy or sell
recommendation. Rather, the List is a collection of
ETPs that may be appropriate to meet particular
client investment goals.
PWM Stock Opportunities List
Baird’s
is
primarily responsible for selecting and evaluating
structured products made available to clients under
the Programs. Baird’s Alternative Investment
Committee, which includes members of Baird’s
Investment Solutions, Asset Manager Research,
Compliance, Legal, and Risk Management
Departments, ultimately determines whether to
make a structured product available to Baird
clients.
Available Hedge Funds
yield,
The PWM Stock Opportunities List is comprised of
stocks that Baird’s PWM Equity Research team
believes offer timely investment opportunities
based on market, sector, and
fundamental
analysis. Stocks on the list must be covered by
Baird, Evercore ISI, or Morningstar and are
screened to curb near-term fundamental risk. The
List focuses on large cap and mid/small cap
companies,
and
investments with
speculative investment opportunities.
Managed Futures
Effective March 1, 2018, Baird ceased maintaining
an official list of managed futures funds that are
structured as limited partnerships. Therefore, Baird
does not, and will not in the future, provide any
evaluation, monitoring or review of those funds or
their sponsors. A client’s decision to invest in, or to
maintain an investment in, a managed futures fund
is based solely upon the client’s own review and
evaluation of the fund.
Baird makes hedge funds available to clients in
certain Programs sponsored by, affiliated with or
offered by Capital Integration Systems LLC or CAIS
Capital LLC (“CAIS”). An independent third-party
research firm provides research and due diligence
materials to Baird on the hedge funds available on
the CAIS platform (“Available Hedge Funds”).
Clients interested in an Available Hedge Fund or
invested in an Available Hedge Fund may obtain
additional information from Baird upon request.
Clients should note that Baird solely relies upon the
independent third-party research firm to provide
an independent analysis of each Available Hedge
Fund, Baird does not conduct its own research or
due diligence on any Available Hedge Fund, and
Baird does not verify the accuracy of the
information contained in the research and due
diligence materials.
Structured Products
Available Private Funds
When determining whether to make a structured
product available to Baird clients, Baird reviews the
offering documents for the structured product and
considers: the size of the issuer and issuer’s credit
rating, the maturity of the product, how interest is
calculated, the underlying asset category (e.g., a
basket of securities or currencies or a market
index), applicable caps, barriers, and participation
rate, and whether the structured product has
principal protection.
third-party
research
firm
that are more
In addition to Recommended Private Funds, Baird
makes available to clients in certain Programs
other private funds sponsored by, affiliated with, or
offered by CAIS (“Available Private Funds”),
including Available Private Equity Funds, Available
Private Debt Funds, Available Private REITs and
Available Private Infrastructure Funds. When
determining whether to make a fund an Available
Private Fund, Baird utilizes the services of an
independent
that
provides research and due diligence materials to
Baird on the private funds available on the CAIS
platform. Clients interested in an Available Private
Fund or invested in an Available Private Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely relies
upon the independent third-party research firm to
provide an independent analysis of each Available
Private Fund, Baird does not conduct its own
research or due diligence on any Available Private
Fund, and Baird does not verify the accuracy of the
Baird tends to favor larger-sized issuers of
structured products over smaller-sized issuers and
also tends to favor structured products that have
shorter maturities, less complex payout structures,
underlying assets
liquid or
transparent, and offer full or partial principal
protection. If a product does not offer full principal
protection, Baird also considers how much principal
is exposed to loss, whether, in Baird’s judgment,
there is reasonable risk/reward trade-off for that
exposure, as well as the events that could trigger
loss of principal and Baird’s belief as to the
likelihood of the occurrence of such events.
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information contained in the research and due
diligence materials.
income securities. This strategy has a target
allocation of 70% of its assets to equity securities
and 30% of its assets to fixed income securities.
Affiliated Private Equity Funds
(4)
The Baird Trust Core + Satellite 50/50
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation portion of the
portfolio while providing exposure to satellite asset
classes (such as mid cap and small cap companies)
and fixed income securities through the use of ETFs
that principally invest in equity securities and fixed
income securities. This strategy has a target
allocation of 50% of its assets to equity securities
and 50% of its assets to fixed income securities.
“Additional
(5)
The Baird Trust Equity Income strategy
primarily invests in dividend paying companies that
Baird Trust believes have the ability to consistently
grow their dividend at attractive rates over the
long‑term.
In addition to Recommended Funds of Private
Equity Funds and Available Private Equity Funds,
Baird makes available to clients private equity
funds that are affiliated with Baird (“Affiliated
Private Equity Funds”). Baird does not subject
Affiliated Private Equity Funds to the criteria
imposed upon Recommended Funds of Private
Equity Funds or Available Private Equity Funds
described above when making them available to
clients, and Baird does not perform any evaluation,
monitoring or review of Affiliated Private Equity
Funds. This presents a potential conflict of interest.
Information—Other Financial
See
Industry Activities
and Affiliations—Certain
Relationships and Arrangements—Baird and
Associated Parties” below.
Baird Trust Strategies
More specific information about the particular
investment strategies and methods of analysis that
Baird uses in connection with each Program is
further described below.
Program Portfolio Strategies
ALIGN Strategic Portfolios Program
Under the BAM and UAS Programs, Baird makes
available to clients five (5) portfolio strategies
developed and maintained by Baird Trust (“Baird
Trust Strategies”) described below. The Baird Trust
Strategies invest in a mix of equity securities and
ETFs.
The ALIGN Strategic Portfolios Program offers
model asset allocation portfolios that have varying
investment objectives and strategies. Each ALIGN
Portfolio provides for specific levels of investment
(or allocation) across the asset classes described
under the heading “Investment Strategies—Asset
Allocation Strategies” above.
(1)
The Baird Trust Large Cap Equity strategy
invests in a fairly concentrated portfolio of large
cap equity securities. This strategy is intended for
clients seeking investment in large cap companies
as one part of their overall asset allocation. This
strategy is generally not intended to be a complete
investment program.
(2)
The Baird Trust Core + Satellite 100
strategy is a diversified portfolio with a 100%
target equity allocation. The strategy uses the
Baird Trust Large Cap Equity strategy as the core
allocation of the portfolio while providing exposure
to satellite asset classes (such as mid cap and
small cap companies) through the use of ETFs that
principally invest in equity securities. This model
does not include fixed income.
(3)
The Baird Trust Core + Satellite 70/30
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation of the portfolio while
providing exposure to satellite asset classes (such
as mid cap and small cap companies) and fixed
income securities through the use of ETFs that
principally invest in equity securities and fixed
Each ALIGN Portfolio generally uses mutual funds
and ETPs, primarily ETFs and ETNs, in order to
implement the model asset allocation strategy.
Depending on the ALIGN Portfolio chosen, the
ALIGN Portfolio may consist of mutual funds and
ETFs that have various investment objectives and
strategies, including but not limited to, the
following: large cap, mid cap and small cap
strategies (which may include value, growth or
core strategies); short-term, intermediate-term
and long-term fixed income strategies (which may
include high yield corporate bond strategies);
international and global
balanced strategies;
equity and fixed income strategies; market sector
focused strategies, geographic area
focused
strategies; real estate strategies; commodities
strategies; currency strategies; managed futures
strategies; and other Alternative Strategies. For
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review
additional information regarding the characteristics
of the mutual funds and ETPs used in an ALIGN
their Baird
Portfolio, clients should contact
the applicable
Financial Advisor or
prospectus.
The amount allocated to each asset class and type
of investment varies by Portfolio. However, some
Portfolios may have little or no allocation to one or
more asset classes or types of investments
described above.
More specific information about how Baird develops
its asset allocation strategies is contained under
the heading
“Investment Strategies—Asset
Allocation Strategies” above.
The ALIGN Strategic Portfolios Program offers
“environmental, social and governance” (“ESG”)
portfolios, which focus investments in mutual funds
and ETFs with investment managers that evaluate
portfolio companies’ performance on various
environmental, social and corporate governance
criteria as part of the managers’ investment
process. The particular environmental, social and
governance criteria used by mutual funds and ETFs
vary by mutual fund and ETF and are determined
by the manager for the applicable mutual fund or
ETF and not Baird. How each company performs
with respect to those criteria is a matter of
subjective judgement. It is possible managers
could come to different conclusions about how a
particular company performs with respect to the
same environmental, social and governance
criteria.
The ALIGN Strategic Portfolios Program offers
model portfolios that have different investment
objectives and use different strategic investment
strategies. The ALIGN Strategic Portfolios Program
generally accommodates both taxable and tax-
exempt accounts of clients with differing
investment objectives and risk tolerances.
Product
allocations
intended
to
Generally, under normal market conditions, the
equity security allocation of each ALIGN Strategic
Portfolio is designed to be global in nature and
attempts to be diversified across countries,
industry sectors and company capitalization sizes,
with an objective to participate in the total return
potential of the global stock markets. The fixed
income allocation is also normally global in nature
and diversified across credit quality and maturity.
The Non-Traditional Asset and Alternative
provide
Investment
reduce
diversification and are
correlation to U.S. stock and bond markets.
The ALIGN Strategic Portfolios include active and
hybrid options. Active ALIGN Strategic Portfolios
primarily consist of actively managed mutual funds
and hybrid ALIGN Strategic Portfolios primarily
consist of both actively managed mutual funds and
passive ETFs. Multiple funds may be used for a
particular asset class (referred to as a “sleeve”).
The ALIGN Strategic Portfolios are described
below.
Some ALIGN Strategic Portfolios invest a material
portion of assets in mutual funds and ETFs that
pursue Alternative Strategies designed to provide
absolute return. Those strategies generally involve
the purchase of traditional assets, such as stocks
and bonds, and Non-Traditional Assets and the use
of derivative instruments in an attempt to generate
performance that has low correlation to the major
equity markets over a complete market cycle.
ALIGN Strategic All Growth Portfolio. The ALIGN
Strategic All Growth Portfolio seeks to provide
aggressive growth of capital. Under normal market
conditions, this Portfolio generally invests nearly all
of its assets in mutual funds that in turn principally
invest in equity securities. This Portfolio may also
invest in other asset classes described above,
including fixed income securities, Non-Traditional
Assets, Alternative Investment Products and cash.
This Portfolio has the same risk profile as an All
Growth Portfolio.
Some ALIGN Strategic Portfolio Strategies invest a
material portion of assets in mutual funds and ETFs
that that focus on investments that provide
diversified yield or sources of income, such as
dividend-paying stocks, preferred stocks, high
yield bonds, foreign (including emerging markets)
fixed income securities, Non-Traditional Assets,
Alternative Investment Products and derivative
instruments.
ALIGN Strategic All Growth Hybrid Portfolio. The
ALIGN Strategic All Growth Hybrid Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the ALIGN Strategic
All Growth Portfolio described above, except that
this Portfolio also includes investments in passively
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managed ETFs in addition to actively managed
mutual funds.
ALIGN Strategic Capital Growth (Tax Exempt)
Portfolio. The ALIGN Strategic Capital Growth (Tax
Exempt) Portfolio has
the same objective,
underlying investments, target allocations and risk
profile as the ALIGN Strategic Capital Growth
Portfolio described above, except that this Portfolio
primarily invests its fixed income allocation in
actively managed mutual funds that in turn
principally invest in municipal securities.
ALIGN Strategic All Growth (Absolute Return)
Portfolio. The ALIGN Strategic All Growth (Absolute
Return) Portfolio seeks to provide aggressive
growth of capital. Under normal market conditions,
this Portfolio primarily invests its assets in mutual
funds that in turn principally invest in equity
securities. A material portion of this Portfolio will
normally seek to provide absolute return by
investing in Alternative Investment Products,
primarily mutual funds, that pursue that strategy.
This may involve material exposure to Non-
Traditional Assets, leverage, short sales, and
derivative instruments. This Portfolio may also
invest in other asset classes described above,
including fixed income securities, Non-Traditional
Assets, other Alternative Investment Products and
cash. This Portfolio has the same risk profile as an
All Growth Portfolio.
ALIGN Strategic Capital Growth Hybrid (Tax
Exempt) Portfolio. The ALIGN Strategic Capital
Growth Hybrid (Tax Exempt) Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the ALIGN Strategic
Capital Growth Portfolio described above, except
that this Portfolio: (1) includes investments in
passively managed ETFs in addition to actively
managed mutual funds; and (2) primarily invests
its fixed income allocation in actively managed
mutual funds and ETFs that in turn principally
invest in municipal securities.
underlying
investments,
ALIGN Strategic All Growth Hybrid (Absolute
Return) Portfolio. The ALIGN Strategic All Growth
Hybrid (Absolute Return) Portfolio has the same
objective,
target
allocations and risk profile as the ALIGN Strategic
All Growth (Absolute Return) Portfolio described
above, except that this Portfolio also includes
investments in passively managed ETFs in addition
to actively managed mutual funds.
ALIGN Strategic Capital Growth (Absolute Return)
Portfolio. The ALIGN Strategic Capital Growth
(Absolute Return) Portfolio seeks to provide growth
of capital. Under normal market conditions, this
Portfolio primarily invests its assets in mutual
funds that in turn principally invest in equity
securities or fixed income securities. This Portfolio
normally will have a significantly higher underlying
asset allocation to equity securities than fixed
income securities. A material portion of this
Portfolio will normally seek to provide absolute
return by investing in Alternative Investment
Products, primarily mutual funds, that pursue that
strategy. This may involve material exposure to
Non-Traditional Assets, leverage, short sales, and
derivative instruments. This Portfolio may also
invest in other asset classes described above,
including Non-Traditional Assets, other Alternative
Investment Products and cash. This Portfolio has
the same risk profile as a Capital Growth Portfolio.
ALIGN Strategic Capital Growth Portfolio. The
ALIGN Strategic Capital Growth Portfolio seeks to
provide growth of capital. Under normal market
conditions, this Portfolio primarily invests its assets
in mutual funds that in turn principally invest in
equity securities or fixed income securities. This
Portfolio normally will have a significantly higher
underlying asset allocation to equity securities than
fixed income securities. This Portfolio may also
invest in other asset classes described above,
including Non-Traditional Assets, Alternative
Investment Products and cash. This Portfolio has
the same risk profile as a Capital Growth Portfolio.
ALIGN Strategic Capital Growth Hybrid (Absolute
Return) Portfolio. The ALIGN Strategic Capital
Growth Hybrid (Absolute Return) Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the ALIGN Strategic
Capital Growth
(Absolute Return) Portfolio
described above, except that this Portfolio also
includes investments in passively managed ETFs in
addition to actively managed mutual funds.
ALIGN Strategic Capital Growth Hybrid Portfolio.
The ALIGN Strategic Capital Growth Hybrid
Portfolio has the same objective, underlying
investments, target allocations and risk profile as
the ALIGN Strategic Capital Growth Portfolio
described above, except that this Portfolio also
includes investments in passively managed ETFs in
addition to actively managed mutual funds.
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Portfolio has the same risk profile as a Growth with
Income Portfolio.
ALIGN Strategic Capital Growth (Tax Exempt with
Absolute Return) Portfolio. The ALIGN Strategic
Capital Growth (Tax Exempt with Absolute Return)
Portfolio Has the same description as the ALIGN
Strategic Capital Growth
(Absolute Return)
Portfolio described above, except that this Portfolio
primarily invests its fixed income allocation in
actively managed mutual funds that in turn
principally invest in municipal securities.
ALIGN Strategic Growth with Income Hybrid
Portfolio. The ALIGN Strategic Growth with Income
Hybrid Portfolio has the same objective, underlying
investments, target allocations and risk profile as
the ALIGN Strategic Growth with Income Portfolio
described above, except that this Portfolio also
includes investments in passively managed ETFs in
addition to actively managed mutual funds.
ALIGN Strategic Growth with Income (Tax Exempt)
Portfolio. The ALIGN Strategic Growth with Income
(Tax Exempt) Portfolio has the same objective,
underlying investments, target allocations and risk
profile as the ALIGN Strategic Growth with Income
Portfolio described above, except that this Portfolio
primarily invests its fixed income allocation in
actively managed mutual funds that in turn
principally invest in municipal securities.
ALIGN Strategic Capital Growth Hybrid (Tax
Exempt with Absolute Return) Portfolio. The ALIGN
Strategic Capital Growth Hybrid (Tax Exempt with
Absolute Return) Portfolio has the same objective,
underlying investments, target allocations and risk
profile as the ALIGN Strategic Capital Growth
(Absolute Return) Portfolio described above,
except that this Portfolio: (1) includes investments
in passively managed ETFs in addition to actively
managed mutual funds; and (2) primarily invests
its fixed income allocation in actively managed
mutual funds and ETFs that in turn principally
invest in municipal securities.
ALIGN Strategic Growth with Income Hybrid (Tax
Exempt) Portfolio. The ALIGN Strategic Growth
with Income Hybrid (Tax Exempt) Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the ALIGN Strategic
Growth with Income Portfolio described above,
except that this Portfolio: (1) includes investments
in passively managed ETFs in addition to actively
managed mutual funds; and (2) primarily invests
its fixed income allocation in actively managed
mutual funds and ETFs that in turn principally
invest in municipal securities.
ALIGN Strategic Capital Growth (Diversified Yield)
Portfolio. The ALIGN Strategic Capital Growth
(Diversified Yield) Portfolio seeks to provide growth
of capital. Under normal market conditions, this
Portfolio primarily invests its assets in mutual
funds that in turn principally invest in equity
securities or fixed income securities. This Portfolio
normally will have a significantly higher underlying
asset allocation to equity securities than fixed
income securities. A material portion of this
Portfolio will normally seek to provide diversified
yield by investing in mutual funds that pursue that
strategy. This may involve material exposure to
high yield bonds, foreign (including emerging
markets) fixed income securities, Non-Traditional
Assets, REITs, MLPs, and derivative instruments.
This Portfolio may also invest in other asset classes
described above, including Alternative Investment
Products and cash. This Portfolio has the same risk
profile as a Capital Growth Portfolio.
ALIGN Strategic Growth with Income (Absolute
Return) Portfolio. The ALIGN Strategic Growth with
Income (Absolute Return) Portfolio seeks to
provide moderate growth of capital and some
current income. Under normal market conditions,
this Portfolio primarily invests its assets in mutual
funds that in turn principally invest in equity
securities or fixed income securities. A material
portion of this Portfolio will normally seek to
provide absolute return by investing in Alternative
Investment Products, primarily mutual funds, that
pursue that strategy. This may involve material
exposure to Non-Traditional Assets, leverage,
short sales, and derivative instruments. This
Portfolio may also invest in other asset classes
described above, including Non-Traditional Assets,
other Alternative Investment Products and cash.
This Portfolio has the same risk profile as a Growth
with Income Portfolio.
ALIGN Strategic Growth with Income Portfolio. The
ALIGN Strategic Growth with Income Portfolio
seeks to provide moderate growth of capital and
some current income. Under normal market
conditions, this Portfolio primarily invests its assets
in mutual funds that in turn principally invest in
equity securities or fixed income securities. This
Portfolio may also invest in other asset classes
described above, including Non-Traditional Assets,
Alternative Investment Products and cash. This
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ALIGN Strategic Growth with Income Hybrid
(Absolute Return) Portfolio. The ALIGN Strategic
Growth with Income Hybrid (Absolute Return)
Portfolio has the same objective, underlying
investments, target allocations and risk profile as
the ALIGN Strategic Growth with Income (Absolute
Return) Portfolio described above, except that this
Portfolio also includes investments in passively
managed ETFs in addition to actively managed
mutual funds.
Assets,
Alternative
ALIGN Strategic Income with Growth Portfolio. The
ALIGN Strategic Income with Growth Portfolio
seeks to provide high current income and some
growth of capital. Under normal market conditions,
this Portfolio primarily invests its assets in mutual
funds that in turn principally invest in fixed income
securities or equity securities. This Portfolio
normally will have a higher underlying asset
allocation to fixed income securities than equity
securities. This Portfolio may also invest in other
asset classes described above, including Non-
Traditional
Investment
Products and cash. This Portfolio has the same risk
profile as an Income with Growth Portfolio.
ALIGN Strategic Growth with Income (Tax Exempt
with Absolute Return) Portfolio. The ALIGN
Strategic Growth with Income (Tax Exempt with
Absolute Return) Portfolio Has
the same
description as the ALIGN Strategic Growth with
Income (Absolute Return) Portfolio described
above, except that this Portfolio primarily invests
its fixed income allocation in actively managed
mutual funds that in turn principally invest in
municipal securities.
ALIGN Strategic Income with Growth Hybrid
Portfolio. The ALIGN Strategic Income with Growth
Hybrid Portfolio has the same objective, underlying
investments, target allocations and risk profile as
the ALIGN Strategic Income with Growth Portfolio
described above, except that this Portfolio also
includes investments in passively managed ETFs in
addition to actively managed mutual funds.
underlying
investments,
ALIGN Strategic Income with Growth (Tax Exempt)
Portfolio. The ALIGN Strategic Income with Growth
(Tax Exempt) Portfolio has the same objective,
underlying investments, target allocations and risk
profile as the ALIGN Strategic Income with Growth
Portfolio described above, except that this Portfolio
primarily invests its fixed income allocation in
actively managed mutual funds that in turn
principally invest in municipal securities.
ALIGN Strategic Growth with Income Hybrid (Tax
Exempt with Absolute Return) Portfolio. The ALIGN
Strategic Growth with Income Hybrid (Tax Exempt
with Absolute Return) Portfolio has the same
target
objective,
allocations and risk profile as the ALIGN Strategic
Growth with Income (Absolute Return) Portfolio
described above, except that this Portfolio: (1)
includes investments in passively managed ETFs in
addition to actively managed mutual funds; and
(2) primarily invests its fixed income allocation in
actively managed mutual funds and ETFs that in
turn principally invest in municipal securities.
ALIGN Strategic Income with Growth Hybrid (Tax
Exempt) Portfolio. The ALIGN Strategic Income
with Growth Hybrid (Tax Exempt) Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the ALIGN Strategic
Income with Growth Portfolio described above,
except that this Portfolio: (1) includes investments
in passively managed ETFs in addition to actively
managed mutual funds; and (2) primarily invests
its fixed income allocation in actively managed
mutual funds and ETFs that in turn principally
invest in municipal securities.
fixed
ALIGN Strategic Income with Growth (Diversified
Yield) Portfolio. The ALIGN Strategic Income with
Growth (Diversified Yield) Portfolio seeks to
provide high current income and some growth of
capital. Under normal market conditions, this
Portfolio primarily invests its assets in mutual
funds that in turn principally invest in fixed income
ALIGN Strategic Growth with Income (Diversified
Yield) Portfolio. The ALIGN Strategic Growth with
Income (Diversified Yield) Portfolio seeks to
provide moderate growth of capital and some
current income. Under normal market conditions,
this Portfolio primarily invests its assets in mutual
funds that in turn principally invest in equity
securities or fixed income securities. A material
portion of this Portfolio will normally seek to
provide diversified yield by investing in mutual
funds that pursue that strategy. This may involve
material exposure to high yield bonds, foreign
income
(including emerging markets)
securities, Non-Traditional Assets, REITs, MLPs,
and derivative instruments. This Portfolio may also
invest in other asset classes described above,
including Alternative Investment Products and
cash. This Portfolio has the same risk profile as a
Growth with Income Portfolio.
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the ALIGN Strategic Conservative Income Portfolio
described above, except that this Portfolio: (1)
includes investments in passively managed ETFs in
addition to actively managed mutual funds; and
(2) primarily invests its fixed income allocation in
actively managed mutual funds and ETFs that in
turn principally invest in municipal securities.
clients
preferring
passive
securities or equity securities. This Portfolio
normally will have a higher underlying asset
allocation to fixed income securities than equity
securities. A material portion of this Portfolio will
normally seek to provide diversified yield by
investing in mutual funds that pursue that
strategy. This may involve material exposure to
high yield bonds, foreign (including emerging
markets) fixed income securities, Non-Traditional
Assets, REITs, MLPs, and derivative instruments.
This Portfolio may also invest in other asset classes
described above, including Alternative Investment
Products and cash. This Portfolio has the same risk
profile as an Income with Growth Portfolio.
The ALIGN Strategic Portfolios also include certain
ALIGN Elements Portfolios that are designed for
certain specific client investment preferences, such
as
investment
management or tax efficiency, and clients with
smaller accounts. ALIGN Elements Portfolios do not
invest in as many mutual funds or ETFs compared
to other ALIGN Strategic Portfolios and are
therefore comparatively less diversified.
The ALIGN Elements Portfolios are described
below.
ALIGN Strategic Conservative Income Portfolio.
The ALIGN Strategic Conservative Income Portfolio
seeks to provide high current income. Under
normal market conditions, this Portfolio primarily
invests its assets in mutual funds that in turn
principally invest in fixed income securities and
equity securities. This Portfolio normally will have
a significantly higher underlying asset allocation to
fixed income securities than equity securities. This
Portfolio may also invest in other asset classes
described above, including Non-Traditional Assets
and cash. This Portfolio has the same risk profile as
a Conservative Income Portfolio.
ALIGN Elements All Growth Portfolio. The ALIGN
Elements All Growth Portfolio seeks to provide
aggressive growth of capital. Under normal market
conditions, this Portfolio generally invests nearly all
of its assets in mutual funds that in turn principally
invest in equity securities. This Portfolio may also
invest in other asset classes described above,
including fixed income securities, Non-Traditional
Assets, Alternative Investment Products and cash.
This Portfolio has the same risk profile as an All
Growth Portfolio.
ALIGN Strategic Conservative Income Hybrid
Portfolio. The ALIGN Strategic Conservative
Income Hybrid Portfolio has the same objective,
underlying investments, target allocations and risk
profile as the ALIGN Strategic Conservative Income
Portfolio described above, except that this Portfolio
also includes investments in passively managed
ETFs in addition to actively managed mutual funds.
Income
The
ALIGN
ALIGN Elements All Growth ETF Portfolio. The
ALIGN Elements All Growth ETF Portfolio has the
same objective, types of underlying investments,
target allocations and risk profile as the ALIGN
Elements All Growth Portfolio described above,
except that this Portfolio primarily invests in
instead of actively
passively managed ETFs
managed mutual funds.
(Tax
ALIGN Strategic Conservative
Strategic
Portfolio.
Exempt)
Conservative Income (Tax Exempt) Portfolio has
the same objective, underlying investments, target
allocations and risk profile as the ALIGN Strategic
Conservative Income Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in actively managed mutual
funds that in turn principally invest in municipal
securities.
ALIGN Elements ETF All Growth ESG Portfolio. The
ALIGN Elements All Growth ESG Portfolio has the
same objective, types of underlying investments,
target allocations and risk profile as the ALIGN
Elements All Growth Portfolio described above,
except that this Portfolio primarily invests in ETFs
that incorporate ESG criteria into their investment
process.
Portfolio.
The
ALIGN
Income Hybrid
ALIGN Strategic Conservative Income Hybrid (Tax
Exempt)
Strategic
Conservative
(Tax Exempt)
Portfolio has the same objective, underlying
investments, target allocations and risk profile as
ALIGN Elements Capital Growth Portfolio. The
ALIGN Elements Capital Growth Portfolio seeks to
provide growth of capital. Under normal market
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in mutual funds that in turn principally invest in
equity securities or fixed income securities. This
Portfolio may also invest in other asset classes
described above, including Non-Traditional Assets,
Alternative Investment Products and cash. This
Portfolio has the same risk profile as a Growth with
Income Portfolio.
conditions, this Portfolio primarily invests its assets
in mutual funds that in turn principally invest in
equity securities or fixed income securities. This
Portfolio normally will have a significantly higher
underlying asset allocation to equity securities than
fixed income securities. This Portfolio may also
invest in other asset classes described above,
including Non-Traditional Assets, Alternative
Investment Products and cash. This Portfolio has
the same risk profile as a Capital Growth Portfolio.
ALIGN Elements Growth with Income (Tax Exempt)
Portfolio. The ALIGN Elements Growth with Income
(Tax Exempt) Portfolio has the same objective,
underlying investments, target allocations and risk
profile as the ALIGN Strategic Growth with Income
Portfolio described above, except that this Portfolio
primarily invests its fixed income allocation in
actively managed mutual funds that in turn
principally invest in municipal securities.
ALIGN Elements Capital Growth (Tax Exempt)
Portfolio. The ALIGN Elements Capital Growth (Tax
Exempt) Portfolio has
the same objective,
underlying investments, target allocations and risk
profile as the ALIGN Strategic Capital Growth
Portfolio described above, except that this Portfolio
primarily invests its fixed income allocation in
actively managed mutual funds that in turn
principally invest in municipal securities.
same objective,
ALIGN Elements Growth with Income ETF Portfolio.
The ALIGN Elements Growth with Income ETF
Portfolio has the same objective, types of
underlying investments, target allocations and risk
profile as the ALIGN Elements Growth with Income
Portfolio described above, except that this Portfolio
primarily invests in passively managed ETFs
instead of actively managed mutual funds.
that
ALIGN Elements Capital Growth ETF Portfolio. The
ALIGN Elements Capital Growth ETF Portfolio has
the
types of underlying
investments, target allocations and risk profile as
the ALIGN Elements Capital Growth Portfolio
this Portfolio
described above, except
primarily invests in passively managed ETFs
instead of actively man
underlying
investments,
ALIGN Elements Growth with Income ETF (Tax
Exempt) Portfolio. The ALIGN Elements Growth
with Income (Tax Exempt) Portfolio has the same
target
objective,
allocations and risk profile as the ALIGN Strategic
Growth with Income Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in passively managed ETFs that
in turn principally invest in municipal securities.
ALIGN Elements Capital Growth ETF (Tax Exempt)
Portfolio. The ALIGN Elements Capital Growth (Tax
Exempt) Portfolio has
the same objective,
underlying investments, target allocations and risk
profile as the ALIGN Strategic Capital Growth
Portfolio described above, except that this Portfolio
primarily invests its fixed income allocation in
passively managed ETFs that in turn principally
invest in municipal securities. aged mutual funds.
ALIGN Elements ETF Growth with Income ESG
Portfolio. The ALIGN Elements Growth with Income
ESG Portfolio has the same objective, types of
underlying investments, target allocations and risk
profile as the ALIGN Elements Growth with Income
Portfolio described above, except that this Portfolio
primarily invests in ETFs that incorporate ESG
criteria into their investment process.
that
ALIGN Elements ETF Capital Growth ESG Portfolio.
The ALIGN Elements Capital Growth ESG Portfolio
has the same objective, types of underlying
investments, target allocations and risk profile as
the ALIGN Elements Capital Growth Portfolio
described above, except
this Portfolio
primarily invests in ETFs that incorporate ESG
criteria into their investment process.
ALIGN Elements Growth with Income Portfolio. The
ALIGN Elements Growth with Income Portfolio
seeks to provide moderate growth of capital and
some current income. Under normal market
conditions, this Portfolio primarily invests its assets
ALIGN Elements Income with Growth Portfolio. The
ALIGN Elements Income with Growth Portfolio
seeks to provide high current income and some
growth of capital. Under normal market conditions,
this Portfolio primarily invests its assets in mutual
funds that in turn principally invest in fixed income
securities or equity securities. This Portfolio
normally will have a higher underlying asset
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Assets,
Alternative
allocation to fixed income securities than equity
securities. This Portfolio may also invest in other
asset classes described above, including Non-
Investment
Traditional
Products and cash. This Portfolio has the same risk
profile as an Income with Growth Portfolio.
allocations and risk profile as the ALIGN Strategic
Conservative Income Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in actively managed mutual
funds that in turn principally invest in municipal
securities.
Income ETF
ALIGN Elements Conservative
Portfolio. The ALIGN Elements Conservative
Income ETF Portfolio has the same objective, types
of underlying investments, target allocations and
risk profile as the ALIGN Elements Conservative
Income Portfolio described above, except that this
Portfolio primarily invests in passively managed
ETFs instead of actively managed mutual funds.
ALIGN Elements Income with Growth (Tax Exempt)
Portfolio. The ALIGN Elements Income with Growth
(Tax Exempt) Portfolio has the same objective,
underlying investments, target allocations and risk
profile as the ALIGN Strategic Income with Growth
Portfolio described above, except that this Portfolio
primarily invests its fixed income allocation in
actively managed mutual funds that in turn
principally invest in municipal securities.
Portfolio.
ALIGN
ALIGN Elements Income with Growth ETF Portfolio.
The ALIGN Elements Income with Growth ETF
Portfolio has the same objective, types of
underlying investments, target allocations and risk
profile as the ALIGN Elements Income with Growth
Portfolio described above, except that this Portfolio
primarily invests in passively managed ETFs
instead of actively managed mutual funds.
ALIGN Elements Conservative Income ETF (Tax
Exempt)
Elements
The
Conservative Income (Tax Exempt) Portfolio has
the same objective, underlying investments, target
allocations and risk profile as the ALIGN Strategic
Conservative Income Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in passively managed ETFs that
in turn principally invest in municipal securities.
underlying
investments,
The descriptions of the ALIGN Strategic Portfolios
are current as of the date of this Brochure.
However, Baird may change
the objective,
investments, target allocations or risk profile for
any Portfolio at any time. Baird may also offer
other model portfolios under the Program from
time to time.
ALIGN Elements Income with Growth ETF (Tax
Exempt) Portfolio. The ALIGN Elements Income
with Growth (Tax Exempt) Portfolio has the same
objective,
target
allocations and risk profile as the ALIGN Strategic
Income with Growth Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in passively managed ETFs that
in turn principally invest in municipal securities.
An ALIGN Strategic Portfolio is subject to the risks
associated with the Portfolio’s particular strategies
and investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
The construction of the ALIGN Strategic Portfolios,
including allocation and strategic decisions, and the
selection of the mutual funds and ETFs for each
Strategic Portfolio, are made by Baird’s ALIGN
Oversight Committee.
ALIGN Elements Conservative Income Portfolio.
The ALIGN Elements Conservative Income Portfolio
seeks to provide high current income. Under
normal market conditions, this Portfolio primarily
invests its assets in mutual funds that in turn
principally invest in fixed income securities and
equity securities. This Portfolio normally will have
a significantly higher underlying asset allocation to
fixed income securities than equity securities. This
Portfolio may also invest in other asset classes
described above, including Non-Traditional Assets
and cash. This Portfolio has the same risk profile as
a Conservative Income Portfolio.
Income
ALIGN
(Tax
ALIGN Elements Conservative
Exempt)
Elements
The
Portfolio.
Conservative Income (Tax Exempt) Portfolio has
the same objective, underlying investments, target
Baird’s Asset Manager Research Department is
primarily responsible for assisting with selecting
and evaluating mutual funds and ETFs available in
the ALIGN Strategic Portfolios Program. The
process Baird uses for selecting and removing
funds for the ALIGN Strategic Portfolios Program is
substantially similar to the process Baird uses to
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and
remove
funds
invest
Recommended
more asset classes or types of investments
described above. While the BairdNext Portfolios
may
in Non-Traditional Assets and
Alternative Investment Products, those Portfolios
tend to have little or no allocation to those asset
classes.
select
from Baird’s
Recommended Mutual Fund List described under
the heading “Portfolio Manager Selection and
Investment
Evaluation—Methods of Analysis,
Strategies and Risk of Loss—Methods of Analysis—
Certain
Lists—Baird’s
Recommended Mutual Fund List” above. The ALIGN
Strategic Portfolios Program may include funds
included on Baird’s Recommended Mutual Fund List
and funds associated with Baird.
More specific information about how Baird develops
its asset allocation strategies is contained under
the heading
“Investment Strategies—Asset
Allocation Strategies” above.
The Portfolio asset allocations and the funds
included in the Program are evaluated on an
ongoing basis, generally at
least quarterly.
Portfolios may be modified or rebalanced and funds
may be removed or added as Baird determines is
appropriate.
The BairdNext Portfolios include mutual fund and
ETF portfolio options. BairdNext mutual fund
portfolios primarily consist of actively managed
mutual
funds; and BairdNext ETF portfolios
primarily consist of passively managed ETFs.
BairdNext Portfolios Program
Program
The BairdNext Portfolios Program offers model
asset allocation portfolios that have different
investment objectives and use different strategic
investment strategies. Each BairdNext Portfolio
provides for specific levels of investment (or
allocation) across the asset classes described
under the heading “Investment Strategies—Asset
Allocation Strategies” above.
The BairdNext
offers
Portfolios
“environmental, social and governance” (“ESG”)
portfolios, which focus investments in mutual funds
and ETFs with investment managers that evaluate
portfolio companies’ performance on various
environmental, social and corporate governance
criteria as part of the managers’ investment
process. The particular environmental, social and
governance criteria used by mutual funds and ETFs
vary by mutual fund and ETF and are determined
by the manager for the applicable mutual fund or
ETF and not Baird. How each company performs
with respect to those criteria is a matter of
subjective judgement. It is possible managers
could come to different conclusions about how a
particular company performs with respect to the
same environmental, social and governance
criteria.
Product
allocations
intended
to
review
Generally, under normal market conditions, the
equity security allocation of each BairdNext
Portfolio is designed to be global in nature and
attempts to be diversified across countries,
industry sectors and company capitalization sizes,
with an objective to participate in the total return
potential of the global stock markets. The fixed
income allocation is also normally global in nature
and diversified across credit quality and maturity.
The Non-Traditional Asset and Alternative
provide
Investment
reduce
diversification and are
correlation to U.S. stock and bond markets.
Each BairdNext Portfolio generally uses mutual
funds or ETPs, primarily ETFs, in order to
implement the model asset allocation. Depending
on the BairdNext Portfolio chosen, the BairdNext
Portfolio may consist of mutual funds and ETFs that
have various investment objectives and strategies,
including but not limited to, the following: large
cap, mid cap and small cap strategies (which may
include value, growth or core strategies); short-
term, intermediate-term and long-term fixed
income strategies (which may include high yield
corporate bond strategies); balanced strategies;
international and global equity and fixed income
strategies; market sector
focused strategies,
geographic area focused strategies; real estate
strategies; commodities strategies; currency
strategies; and Alternative Strategies. For
additional information regarding the characteristics
of the mutual funds and ETFs used in a BairdNext
their Baird
Portfolio, clients should contact
the applicable
Financial Advisor or
prospectus.
The BairdNext Portfolios Program is designed for
clients with smaller accounts and as such does not
invest in as many mutual funds or ETFs compared
The amount allocated to each asset class and type
of investment varies by Portfolio. However, some
Portfolios may have little or no allocation to one or
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underlying
investments,
to other Programs. Clients that are able to satisfy
applicable account minimums for other Programs
are encouraged to discuss with their Financial
Advisor whether another Program may be a more
appropriate choice for them.
The BairdNext Portfolios are described below.
BairdNext ETF All Growth Portfolio ESG. The
BairdNext ESG Growth Portfolio has the same
objective,
target
allocations and risk profile as the BairdNext Growth
Portfolio described above, except that this Portfolio
invests in passively managed ETFs that incorporate
ESG criteria into their investment process instead
of actively managed mutual funds.
BairdNext ETF Capital Growth Portfolio. The
BairdNext ETF Capital Growth Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the BairdNext Capital
Growth Portfolio described above, except that this
Portfolio invests in passively managed ETFs instead
of actively managed mutual funds.
BairdNext All Growth Portfolio. The BairdNext
Growth Portfolio seeks to provide aggressive
growth of capital. Under normal market conditions,
this Portfolio generally invests nearly all of its
assets in mutual funds that in turn principally
invest in equity securities. This Portfolio may also
invest in other asset classes described above,
including fixed income securities, Non-Traditional
Assets, Alternative Investment Products and cash.
This Portfolio has the same risk profile as an All
Growth Portfolio.
BairdNext ETF Capital Growth Portfolio ESG. The
BairdNext ETF Capital Growth Portfolio ESG has the
same objective, underlying investments, target
allocations and risk profile as the BairdNext Capital
Growth Portfolio described above, except that this
Portfolio invests in passively managed ETFs that
incorporate ESG criteria into their investment
process instead of actively managed mutual funds.
BairdNext Capital Growth Portfolio. The BairdNext
Capital Growth Portfolio seeks to provide growth of
capital. Under normal market conditions, this
Portfolio primarily invests its assets in mutual
funds that in turn principally invest in equity
securities or fixed income securities. This Portfolio
normally will have a significantly higher underlying
asset allocation to equity securities than fixed
income securities. This Portfolio may also invest in
other asset classes described above, including
Non-Traditional Assets, Alternative Investment
Products and cash. This Portfolio has the same risk
profile as a Capital Growth Portfolio.
BairdNext ETF Growth with Income Portfolio. The
BairdNext ETF Growth with Income Portfolio has
the same objective, underlying investments, target
allocations and risk profile as the BairdNext Growth
with Income Portfolio described above, except that
this Portfolio invests in passively managed ETFs
instead of actively managed mutual funds.
including
Non-Traditional
BairdNext ETF Growth with Income Portfolio ESG.
The BairdNext ETF Growth with Income ESG
Portfolio has the same objective, underlying
investments, target allocations and risk profile as
the BairdNext Growth with Income Portfolio
described above, except that this Portfolio invests
in passively managed ETFs that incorporate ESG
criteria into their investment process instead of
actively managed mutual funds.
BairdNext Growth with Income Portfolio. The
BairdNext Growth with Income Portfolio seeks to
provide moderate growth of capital and some
current income. Under normal market conditions,
this Portfolio primarily invests its assets in mutual
funds that in turn principally invest in equity
securities or fixed income securities. This Portfolio
may also invest in other asset classes described
above,
Assets,
Alternative Investment Products and cash. This
Portfolio has the same risk profile as a Growth with
Income Portfolio.
The descriptions of the BairdNext Portfolios are
current as of the date of this Brochure. However,
Baird may change the objective, investments,
target allocations or risk profile for any Portfolio at
any time. Baird may also offer other model
portfolios under the Program from time to time.
BairdNext ETF All Growth Portfolio. The BairdNext
ETF Growth Portfolio has the same objective,
underlying investments, target allocations and risk
profile as the BairdNext Growth Portfolio described
above, except that this Portfolio invests in
passively managed ETFs
instead of actively
managed mutual funds.
A BairdNext Portfolio is subject to the risks
associated with the Portfolio’s particular strategies
and investments. A client should review the risks
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associated with those strategies and investments
described under the heading “Principal Risks”
below.
deemed to be “available” for use in its advisory
programs. For more information about Baird model
portfolios, recommended lists and eligible product
lists, see “Methods of Analysis, Investment
Strategies and Risk of Loss—Methods of Analysis”
above.
The process Baird uses for selecting and removing
funds and ETFs for the BairdNext Portfolios
Program is substantially similar to the process
Baird uses to select and remove mutual funds and
ETFs in connection with the ALIGN Strategic
Portfolio Program described under
“ALIGN
Programs—ALIGN Strategic Portfolios” above. A
BairdNext Portfolio may include funds included on
Baird’s Recommended Mutual Fund List and funds
and ETFs offered by Associated Managers.
included
PIM Managers may use a wide variety of
investment products to implement the client’s
investment strategy, which
investments are
further described under “Services, Fees and
Compensation—Additional Program Information—
Permitted Investments” above. PIM Managers may
also engage in certain strategies and use certain
investments that
involve special, sometimes
significant,
risks. See “Services, Fees and
Compensation—Discretionary Programs—Private
Investment Management Program” above for more
information.
The Portfolio asset allocations and the investment
in the BairdNext Portfolios
options
Program are evaluated on an ongoing basis,
generally at least quarterly.
Baird Advisory Choice Program
A client should ask the client’s PIM Manager for
additional information about the investment styles,
philosophies, strategies, analyses, techniques and
investments the PIM Manager will use in order to
meet the client’s objectives.
Russell Model Strategies Program
Strategies—Asset
The Russell Program offers model asset allocation
portfolios that have different investment objectives
and use different strategic and tactical investment
strategies. Each Russell Strategy provides for
specific levels of investment (or allocation) across
the asset classes described under the heading
“Investment
Allocation
Strategies” above.
When recommending investment products to
clients under the Baird Advisory Choice Program,
Baird Financial Advisors may use the investment
strategies described in the section “Methods of
Analysis, Investment Strategies and Risk of Loss—
Investment Strategies” above. They may also use
the model portfolios or recommended or eligible
product lists made available by Baird’s PWM
Research Groups, or they may use lists of
investment products that Baird has generally
deemed to be “available” for use in its advisory
programs. For more information about Baird model
portfolios, recommended lists and eligible product
lists, see “Methods of Analysis, Investment
Strategies and Risk of Loss—Methods of Analysis”
above.
Private Investment Management Program
Under the PIM Program, a PIM Manager may use
various investment strategies. A client’s particular
investment strategy is typically determined by the
client’s PIM Manager in consultation with the client.
Each Russell Strategy generally uses mutual funds
and ETFs in order to implement the model asset
allocation. Depending on the Russell Strategy
chosen, the Russell Strategy may consist of mutual
funds and ETFs that have various investment
objectives and strategies, including but not limited
to, the following: large cap, mid cap and small cap
strategies (which may include value, growth or
core strategies); short-term, intermediate-term
and long-term fixed income strategies (which may
include high yield corporate bond strategies);
balanced strategies;
international and global
equity and fixed income strategies; market sector
focused strategies, geographic area
focused
strategies; real estate strategies; commodities
strategies; currency strategies; and Alternative
Strategies. Each Russell Strategy will typically
invest exclusively or significantly in mutual funds
PIM Managers, as a group, utilize a wide variety of
investment styles, philosophies, strategies and
techniques, including the investment strategies
described in the section “Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment Strategies” above. They may also use
the model portfolios or recommended or eligible
product lists made available by Baird’s PWM
Research Groups, or they may use lists of
investment products that Baird has generally
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offered by Russell Funds. For additional
information regarding the characteristics of the
mutual funds and ETFs used in a Russell Strategy,
clients should contact their Baird Financial Advisor
or review the applicable prospectus.
Model Strategies primarily consist of actively
managed mutual funds; and Russell Hybrid Model
and Income Model Strategies primarily consist of
both actively managed mutual funds and passive
ETFs.
Russell Core Model Strategies
The amount allocated to each asset class and type
of investment varies by Strategy. However, some
Strategies may have little or no allocation to one
or more asset classes or types of investments
described above.
The Russell Core Model Strategies offer model
portfolios that have different investment objectives
and use different strategic investment strategies.
Generally, under normal market conditions, the
Russell Core Model Strategies are designed to be
globally diversified and offer exposure to mix of
asset classes and investment styles. The Russell
Core Model Strategies are described below.
Russell
generally
reviews
Assets,
Alternative
Russell Equity Growth Strategy. The Russell Equity
Growth Strategy seeks to provide high long-term
capital appreciation. Under normal market
conditions, this Strategy generally invests nearly
all of its assets in mutual funds that in turn
principally invest in equity securities. This Portfolio
will also invest in other asset classes described
above, including fixed income securities, Non-
Traditional
Investment
Products and cash.
organization,
information management,
Russell performs a quantitative and qualitative
assessment in the selection of money managers for
the mutual funds and ETFs included in the Russell
Strategies. The quantitative review generally
includes a performance and investment profile
analysis.
the
performance patterns of the money managers
relative to historic market trends, comparing the
manager’s performance to benchmarks and peer
group performance statistics. Russell also may
review the money manager’s performance in
volatile markets for adherence to the money
manager’s stated investment philosophy and
relative performance
in such markets. The
qualitative review may include a review of the
money manager’s
ownership,
leadership, experience, research and development
efforts,
investment
process, stability of personnel, adherence to
philosophy and risk management. Based on
Russell’s quantitative and qualitative assessment,
Russell establishes an overall opinion of the money
manager.
Russell Growth Strategy. The Russell Growth
Strategy seeks to provide high long-term capital
appreciation and low current income. Under normal
market conditions, this Strategy generally invests
nearly all of its assets in mutual funds that in turn
principally invest in equity securities, fixed income
securities. This Strategy normally will have a
significantly higher underlying asset allocation to
equity securities than fixed income securities. This
Portfolio will also invest in other asset classes
described above, including Non-Traditional Assets,
Alternative Investment Products and cash.
Each Russell Strategy allocates a portion of the
client’s Account to a short term component,
typically a money market mutual fund. This
allocation is typically for the payment of fees and
other charges. Russell determines the percent
allocated to this short term component; however,
Baird determines which short term investment
product is used. This short term investment
allocation may include investments in money
market mutual funds associated with Baird.
Russell Balanced Strategy. The Russell Balanced
Strategy seeks to provide above average capital
appreciation and moderate current income. Under
normal market conditions, this Strategy generally
invests nearly all of its assets in mutual funds that
in turn principally invest in equity securities, fixed
income securities. This Portfolio will also invest in
other asset classes described above, including
Non-Traditional Assets, Alternative Investment
Products and cash.
The Russell Program offers a number of investment
strategies through four primary asset allocation
models: core models (“Russell Core Models”), tax-
managed models (“Russell Tax-Managed Models”),
hybrid Models (“Russell Hybrid Models”), and
income models (“Russell Income Models”). Russell
Core Model Strategies and Russell Tax-Managed
Russell Moderate Strategy. The Russell Moderate
Strategy seeks to provide moderate long-term
capital appreciation and high current income.
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on certain investment characteristics (also known
as factors), such as value, quality, momentum or
low volatility, and passively managed ETFs. The
Russell Hybrid Model Strategies will likely engage
in short- and intermediate-term tactical trading
that will cause the Strategy’s actual asset
allocation to differ from the Strategy’s long-term
strategic target asset allocation from time to time.
Assets,
Alternative
Under normal market conditions, this Strategy
generally invests nearly all of its assets in mutual
funds that in turn principally invest in fixed income
securities, equity securities. This Strategy normally
will have a significantly higher underlying asset
allocation to fixed income securities than equity
securities. This Portfolio will also invest in other
asset classes described above, including Non-
Investment
Traditional
Products and cash.
Russell Conservative Strategy. The Russell
Conservative Strategy seeks to provide low long-
term capital appreciation and high current income.
Under normal market conditions, this Strategy
generally invests nearly all of its assets in mutual
funds that in turn principally invest in fixed income
securities. This Portfolio will also invest in other
asset classes described above, including equity
securities, Non-Traditional Assets, Alternative
Investment Products and cash.
The Russell Hybrid Model Strategies generally
include: (1) a Hybrid Equity Growth Strategy; (2)
a Hybrid Growth Strategy; (3) a Hybrid Balanced
Strategy; (4) a Hybrid Moderate Strategy; and (5)
a Hybrid Conservative Strategy. Each Russell
Hybrid Model Strategy generally has the same
objective and target asset allocations as its
counterpart Russell Core Model Strategy discussed
above, except that Hybrid Model Strategies will
seek to achieve their objectives by investing in a
mix of actively managed mutual funds, multi-factor
mutual funds and passively managed ETFs as
described above.
Russell Tax-Managed Model Strategies
Russell Income Model Strategies
The Russell Income Models have a dynamic, yield-
oriented income approach to investing. The Income
Model Strategies invest in a mix of actively
managed mutual funds and passively managed
ETFs.
The Russell Tax-Managed Models also seek to
improve after-tax returns by investing in actively
managed funds that place a higher priority on
managing tax liability, such as funds that consider
shareholder tax consequences when buying and
selling portfolio securities or that invest in tax-
exempt securities.
Russell Conservative Income Strategy. The Russell
Conservative Income Strategy is designed to seek
current income over a long-term time horizon. It is
intended to be a core part of an income-seeking
portfolio.
intended to be a complete
Russell Balanced Income Strategy. The Russell
Balanced Income Strategy is designed to meet
more aggressive current income needs and has a
higher potential for capital depreciation compared
to the Russell Conservative Income Strategy. It is
not
investment
program, but rather it is intended to be a
compliment to other income sources.
The Russell Tax-Managed Model Strategies
generally include: (1) a Tax-Managed Equity
Growth Strategy; (2) a Tax-Managed Growth
Strategy; (3) a Tax-Managed Balanced Strategy;
(4) a Tax-Managed Moderate Strategy; and (5) a
Tax-Managed Conservative Strategy. Each Russell
Tax-Managed Model Strategy generally has the
same objective and target asset allocations as its
counterpart Russell Core Model Strategy discussed
above, except that Russell Tax-Managed Models
will seek to achieve their objectives by investing in
actively managed mutual funds that place a higher
priority on managing tax liability as described
above.
Russell Hybrid Model Strategies
Under normal market conditions, the Russell
Income Models will invest in mutual funds and ETFs
that invest in a mix of equity securities, fixed
Assets,
securities, Non-Traditional
income
Alternative Investment Products and cash.
Implementation by Baird
typically
implement
The Russell Hybrid Model Strategies are designed
to balance an investor’s preference for active
management and the investor’s aversion to the risk
of relative underperformance associated with
active management. The Russell Hybrid Model
Strategies invest in a mix of actively managed
mutual funds, multi-factor mutual funds that focus
the Russell
Baird will
Strategies as they are proposed by Russell.
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• ALIGN Large Cap Value Sleeve, which seeks to
provide consistent exposure to larger companies
that are trading at below-market valuations, on
average;
However, since Baird has discretionary authority,
Baird may implement a Russell Strategy differently
than proposed by Russell or may sell the client’s
investments if Baird determines such action to be
necessary and in the client’s best interest.
• ALIGN Mid Cap Sleeve, which seeks to provide
to medium-sized
exposure
regarding
consistent
companies;
Clients should contact their Baird Financial Advisor
the Russell
with any questions
Strategies.
UMA Programs
• ALIGN Small Cap Sleeve, which seeks to provide
consistent exposure to smaller-sized companies;
• ALIGN International Equity Sleeve, which seeks
to provide consistent exposure to non-U.S.
companies;
Strategies—Asset
The UMA Programs offer model asset allocation
portfolios that have varying investment objectives
and strategies. Each UMA Portfolio provides for
specific levels of investment (or allocation) across
the asset classes described under the heading
Allocation
“Investment
Strategies” above.
• ALIGN Absolute Return Sleeve, which seeks to
provide diversification to a traditional stock and
bond allocation by investing in Alternative
Strategies;
• ALIGN Diversified Yield Sleeve, which seeks to
provide exposure to a wide range of income-
producing securities, including various equity
investments such as dividend-paying stocks,
MLPs, and REITs, as well as various fixed income
instruments;
• ALIGN Short-Term Taxable Fixed Income Sleeve,
which seeks to provide consistent exposure to
income securities that have shorter
fixed
maturities, typically less than five years;
• ALIGN Short-Term Tax Exempt Fixed Income
Sleeve, which seeks to provide consistent
exposure to municipal or other tax exempt fixed
income securities that have shorter maturities,
typically less than five years;
Each UMA Portfolio may use mutual funds, ETPs,
primarily ETFs, and SMA Strategies, and with
respect to the UAS Program, PWM-Managed
Portfolios, in order to implement the model asset
allocation. Depending on the UMA Portfolio chosen,
the UMA Portfolio may consist of mutual funds,
ETFs, SMAs and PWM-Managed Portfolios that have
various investment objectives and strategies,
including but not limited to, the following: large
cap, mid cap and small cap strategies (which may
include value, growth or core strategies); ultra-
short term, short-term, intermediate-term and
long-term fixed income strategies (which may
include high yield corporate bond strategies);
balanced strategies;
international and global
equity and fixed income strategies; market sector
focused strategies, geographic area
focused
strategies; real estate strategies; commodities
strategies; currency strategies; and Alternative
Strategies. For additional information regarding
the characteristics of the mutual funds and ETPs
used in a UMA Portfolio, clients should contact their
Baird Financial Advisor or review the applicable
prospectus.
• ALIGN Intermediate Taxable Fixed Income
Sleeve, which seeks to provide consistent
exposure to a broad range of fixed income
securities that under normal market conditions
on average will have intermediate term durations
and maturities; and
The UMA Programs may offer investment in the
following sleeves of mutual funds used in the
ALIGN Strategic Portfolios Program (the “ALIGN
Strategic Sleeves”):
• ALIGN Large Cap Growth Sleeve, which seeks to
provide consistent exposure to larger companies
that have above-market growth rates;
• ALIGN Intermediate Tax Exempt Fixed Income
Sleeve, which seeks to provide consistent
exposure to a broad range of municipal or other
tax exempt fixed income securities that under
normal market conditions on average will have
intermediate term durations and maturities.
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The amount allocated to each asset class and type
of investment varies by Portfolio. However, some
Portfolios may have little or no allocation to one or
more asset classes or types of investments
described above.
vary by mutual fund and ETF and are determined
by the manager for the applicable mutual fund or
ETF and not by Baird. How each company performs
with respect to those criteria is a matter of
subjective judgement. It is possible managers
could come to different conclusions about how a
particular company performs with respect to the
same environmental, social and governance
criteria.
More specific information about how Baird develops
its asset allocation strategies is contained under
the heading
“Investment Strategies—Asset
Allocation Strategies” above.
The ALIGN UMA Select Portfolios are described
below.
Some UMA Portfolios have a risk profile designation
of (1) All Growth Portfolio, (2) Capital Growth
Portfolio, (3) Growth with Income Portfolio, (4)
Income with Growth Portfolio, (5) Conservative
Income Portfolio, or (6) Capital Preservation
Portfolio, which are described under “Principal
Risks—Risk Information for ALIGN, PIM, and UMA
Program Accounts and Other Accounts Following
Asset Allocation Strategies” below.
ALIGN UMA Select Portfolios
ALIGN UMA Select All Growth Portfolio. The ALIGN
UMA Select All Growth Portfolio seeks to provide
aggressive growth of capital. Under normal market
conditions, this Portfolio generally invests nearly all
of its assets in mutual funds, ETFs and SMAs that
in turn principally invest in equity securities. This
Portfolio may also invest in other asset classes
described above, including fixed income securities,
Non-Traditional Assets, Alternative Investment
Products and cash. This Portfolio has the same risk
profile as an All Growth Portfolio.
The ALIGN UMA Select Portfolios Program offers
model portfolios that have different investment
objectives and use different investment strategies.
The ALIGN UMA Select Portfolios Program generally
accommodates both taxable and tax-exempt
accounts of clients with differing investment
objectives and risk tolerances.
in
companies
across
Product
allocations
intended
to
Generally, under normal market conditions, the
equity security allocation of each ALIGN UMA
Select Portfolio is designed to be global in nature
and attempts to be diversified across countries,
industry sectors and company capitalization sizes,
with an objective to participate in the total return
potential of the global stock markets. The fixed
income allocation is also normally global in nature
and diversified across credit quality and maturity.
The Non-Traditional Asset and Alternative
provide
Investment
diversification and are
reduce
correlation to U.S. stock and bond markets.
ALIGN UMA Select ESG Equity. The ALIGN UMA
Select ESG Equity Portfolio seeks to provide growth
of capital, with some consideration for volatility.
Under normal market conditions, this Portfolio
generally invests nearly all of its assets in mutual
funds, ETFs and SMAs that in turn principally invest
in equity securities and that have investment
managers that that incorporate ESG criteria into
their investment process. While this Portfolio may
invest
all market
capitalizations, the equity securities portion of this
Portfolio tends to emphasize mid cap and large cap
companies. This Portfolio may also invest in other
asset classes described above, including fixed
Assets,
securities, Non-Traditional
income
Alternative
Investment Products and cash.
However, it tends to have little or no allocation to
those asset classes, except for cash. This Portfolio
has the same risk profile as an All Growth Portfolio.
performance
on
ALIGN UMA Select Opportunistic Equity Portfolio.
The ALIGN UMA Select Opportunistic Equity
Portfolio seeks to provide growth of capital, with
limited consideration for volatility. Under normal
market conditions, this Portfolio generally invests
nearly all of its assets in mutual funds, ETFs and
SMAs that in turn principally invest in equity
securities. This Portfolio may also invest in other
asset classes described above, including fixed
Certain strategies offered under the ALIGN UMA
Select Portfolios Program are “environmental,
social and governance” (“ESG”) portfolios, which
focus investments in mutual funds, ETFs and SMAs
with investment managers that evaluate portfolio
companies’
various
environmental, social and corporate governance
criteria as part of the managers’ investment
process. The particular environmental, social and
governance criteria used by mutual funds and ETFs
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securities, Non-Traditional
Assets,
income
Alternative
Investment Products and cash.
However, it tends to have little or no allocation to
those asset classes, except for cash. This Portfolio
has the same risk profile as an All Growth Portfolio.
Portfolio may also invest in other asset classes
described above, including Non-Traditional Assets,
Alternative Investment Products and cash. This
Portfolio has the same risk profile as a Capital
Growth Portfolio.
in turn principally
invest
ALIGN UMA Select Capital Growth (Municipal)
Portfolio. The ALIGN UMA Select Capital Growth
(Municipal) Portfolio has the same objective,
underlying investments, target allocations and risk
profile as the ALIGN UMA Select Capital Growth
Portfolio described above, except that this Portfolio
primarily invests its fixed income allocation in
actively managed mutual funds, ETPs and SMAs
that
in municipal
securities.
ALIGN UMA Select Traditional Equity Portfolio. The
ALIGN UMA Select Traditional Equity Portfolio
seeks to provide growth of capital, with some
consideration for volatility. Under normal market
conditions, this Portfolio generally invests nearly all
of its assets in mutual funds, ETFs and SMAs that
in turn principally invest in equity securities. While
this Portfolio may invest in companies across all
market capitalizations, the equity securities portion
of this Portfolio tends to emphasize mid cap and
large cap companies. This Portfolio may also invest
in other asset classes described above, including
fixed income securities, Non-Traditional Assets,
Alternative
Investment Products and cash.
However, it tends to have little or no allocation to
those asset classes, except for cash. This Portfolio
has the same risk profile as an All Growth Portfolio.
ALIGN UMA Select Growth with Income Portfolio.
The ALIGN UMA Select Growth with Income
Portfolio seeks to provide moderate growth of
capital and some current income. Under normal
market conditions, this Portfolio primarily invests
its assets in mutual funds, ETFs and SMAs that in
turn principally invest in equity securities or fixed
income securities. This Portfolio may also invest in
other asset classes described above, including
Non-Traditional Assets, Alternative Investment
Products and cash. This Portfolio has the same risk
profile as a Growth with Income Portfolio.
investments,
ALIGN UMA Select Growth with Income (Municipal)
Portfolio. The ALIGN UMA Select Growth with
the same
Income (Municipal) Portfolio has
objective,
target
underlying
allocations and risk profile as the ALIGN UMA
Select Growth with Income Portfolio described
above, except that this Portfolio primarily invests
its fixed income allocation in actively managed
mutual funds that in turn principally invest in
municipal securities.
ALIGN UMA Select Conservative Equity Portfolio.
The ALIGN UMA Select Conservative Equity
Portfolio seeks to provide growth of capital, with
great consideration for volatility. Under normal
market conditions, this Portfolio generally invests
nearly all of its assets in mutual funds, ETFs and
SMAs that in turn principally invest in equity
securities. While this Portfolio may invest in
companies across all market capitalizations and
geographic locations, the equity securities portion
of this Portfolio tends to emphasize mid cap and
large cap companies and the foreign equity
securities portion of this Portfolio tends to
emphasize developed market companies. This
Portfolio may also invest in other asset classes
described above, including fixed income securities,
Non-Traditional Assets, Alternative Investment
Products and cash. However, it tends to have little
or no allocation to those asset classes, except for
cash. This Portfolio has the same risk profile as an
All Growth Portfolio.
ALIGN UMA Select Income with Growth Portfolio.
The ALIGN UMA Select Income with Growth
Portfolio seeks to provide current income and some
growth. Under normal market conditions, this
Portfolio primarily invests its assets in mutual
funds, ETFs and SMAs that in turn principally invest
in fixed income securities or equity securities. This
Portfolio normally will have a higher underlying
asset allocation to fixed income securities than
equity securities. This Portfolio may also invest in
other asset classes described above, including
Non-Traditional Assets, Alternative Investment
ALIGN UMA Select Capital Growth Portfolio. The
ALIGN UMA Select Capital Growth Portfolio seeks
to provide growth of capital. Under normal market
conditions, this Portfolio primarily invests its assets
in mutual funds, ETFs and SMAs that in turn
principally invest in equity securities or fixed
income securities. This Portfolio normally will have
a significantly higher underlying asset allocation to
equity securities than fixed income securities. This
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Products and cash. This Portfolio has the same risk
profile as an Income with Growth Portfolio.
Mutual Fund List for exposure to non-US dividend
stocks and high yield fixed income. This Portfolio
has the same risk profile as an All Growth Portfolio.
investments,
ALIGN UMA Select Income with Growth (Municipal)
Portfolio. The ALIGN UMA Select Income with
the same
Growth (Municipal) Portfolio has
objective,
target
underlying
allocations and risk profile as the ALIGN UMA
Select Income with Growth Portfolio described
above, except that this Portfolio primarily invests
its fixed income allocation in actively managed
mutual funds that in turn principally invest in
municipal securities.
included
Baird Research Capital Growth (Taxable) Portfolio.
The Baird Research Capital Growth (Taxable)
Portfolio seeks to provide growth of capital. Under
normal market conditions, the Baird Research
Capital Growth (Taxable) Portfolio provides a
globally-diversified asset allocation with a target
allocation of 80% to equity securities and 20% to
fixed income securities. The Portfolio invests in
in the Baird Recommended
stocks
Portfolio, which is then complimented by investing
in sleeves of mutual funds used in the ALIGN Mid
Cap Sleeve, ALIGN Small Cap Sleeve, the ALIGN
International Equity Sleeve, ALIGN Short-Term
Income Sleeve, and ALIGN
Taxable Fixed
Intermediate Taxable Fixed Income Sleeve. The
Portfolio may also include other investments
deemed appropriate by Baird, such as funds
included on the Recommended Mutual Fund List.
This Portfolio has the same risk profile as a Capital
Growth Portfolio.
such as
included on
Baird Research Equity Portfolio. The Baird
Research Equity Portfolio seeks
to provide
aggressive growth of capital. The Baird Research
Equity portfolio provides a globally-diversified
allocation to equity securities by investing in stocks
included in the Baird Recommended Portfolio,
which is then complimented by investing in sleeves
of mutual funds used in the ALIGN Mid Cap Sleeve,
ALIGN Small Cap Sleeve and
the ALIGN
International Equity Sleeve. The Portfolio may also
include other investments deemed appropriate by
Baird,
the
funds
Recommended Mutual Fund List. This Portfolio has
the same risk profile as an All Growth Portfolio.
in
stocks
included
in
Baird Research Capital Growth ETF (Taxable)
Portfolio. The Baird Research Capital Growth ETF
(Taxable) Portfolio seeks to provide growth of
capital. Under normal market conditions, the Baird
Research Capital Growth (Taxable) Portfolio
provides a globally-diversified asset allocation with
a target allocation of 80% to equity securities and
20% to fixed income securities. The Portfolio
invests
the Baird
Recommended Portfolio, which is complimented by
investing in ETPs, primarily ETFs, for diversified
equity and fixed income exposure. The Portfolio
may also include other investments deemed
appropriate by Baird, such as ETPs included on the
Recommended Mutual Fund List, or ETF Focus List.
This Portfolio has the same risk profile as a Capital
Growth Portfolio.
Baird Research Equity ETF Portfolio. The Baird
Research Equity ETF Portfolio seeks to provide
aggressive growth of capital. The Baird Research
Equity portfolio provides a globally-diversified
allocation to equity securities by investing in stocks
included in the Baird Recommended Portfolio,
which is complimented by investing in ETPs,
primarily ETFs, for diversified equity exposure. The
Portfolio may also include other investments
deemed appropriate by Baird, such as ETPs
included on the Recommended Mutual Fund List, or
ETF Focus List. This Portfolio has the same risk
profile as an All Growth Portfolio.
included
Baird Research Income Portfolio. The Baird
Research Income Portfolio seeks to provide income
while outperforming the MSCI ACWI index on a
risk-adjusted basis over full market cycles. The
Baird Research Income Portfolio provides a
solution for certain income-oriented investors
seeking to benefit from broader diversification. The
Portfolio invests in stocks included in Baird’s Rising
Dividend Portfolio, which is then complimented by
investing in the ALIGN Diversified Yield Sleeve and
mutual funds included on the Baird Recommended
Baird Research Growth with Income ETF (Taxable)
Portfolio. The Baird Research Growth with Income
ETF (Taxable) Portfolio seeks to provide moderate
growth of capital and some current income. Under
normal market conditions, the Baird Research
Growth with Income (Taxable) Portfolio provides a
globally-diversified asset allocation with a target
allocation of 60% to equity securities and 40% to
fixed income securities. The Portfolio invests in
stocks
in the Baird Recommended
Portfolio, which is complimented by investing in
ETPs, primarily ETFs, for diversified equity and
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
included
fixed income exposure. The Portfolio may also
include other investments deemed appropriate by
Baird, such as ETPs included on the Recommended
Mutual Fund List, or ETF Focus List. This Portfolio
has the same risk profile as a Growth with Income
Portfolio.
fixed income securities. The Portfolio invests in
stocks
in the Baird Recommended
Portfolio, which is then complimented by investing
in sleeves of mutual funds used in the ALIGN Mid
Cap Sleeve, ALIGN Small Cap Sleeve, the ALIGN
International Equity Sleeve, ALIGN Short-Term
Taxable Fixed
Income Sleeve, and ALIGN
Intermediate Taxable Fixed Income Sleeve. The
Portfolio may also include other investments
deemed appropriate by Baird, such as funds
included on the Recommended Mutual Fund List.
This Portfolio has the same risk profile as a Growth
with Income Portfolio.
included
in
stocks
Baird Research Income with Growth ETF (Taxable)
Portfolio. The Baird Research Income with Growth
ETF (Taxable) Portfolio seeks to provide high
current income and some growth of capital. Under
normal market conditions, the Baird Research
Income with Growth (Taxable) Portfolio provides a
globally-diversified asset allocation with a target
allocation of 40% to equity securities and 60% to
fixed income securities. The Portfolio invests in
stocks
in the Baird Recommended
Portfolio, which is complimented by investing in
ETPs, primarily ETFs, for diversified equity and
fixed income exposure. The Portfolio may also
include other investments deemed appropriate by
Baird, such as ETPs included on the Recommended
Mutual Fund List, or ETF Focus List. This Portfolio
has the same risk profile as an Income with Growth
Portfolio.
included
in
Portfolio, which
is
funds
included on
in
stocks
Baird Research Growth with Income (Tax-Exempt)
Portfolio. The Baird Research Growth with Income
(Tax-Exempt) Portfolio seeks to provide moderate
growth of capital and some current income. Under
normal market conditions, the Baird Research
Growth with
Income (Tax-Exempt) Portfolio
provides a globally-diversified asset allocation with
a target allocation of 60% to equity securities and
40% to fixed income securities. The Portfolio
the Baird
invests
Recommended
then
complimented by investing in sleeves of mutual
funds used in the ALIGN Mid Cap Sleeve, ALIGN
Small Cap Sleeve, the ALIGN International Equity
Sleeve, ALIGN Short-Term Tax-Exempt Fixed
Income Sleeve, and ALIGN Intermediate Tax-
Exempt Fixed Income Sleeve. The Portfolio may
also include other investments deemed appropriate
by Baird, such as
the
Recommended Mutual Fund List. This Portfolio has
the same risk profile as a Growth with Income
Portfolio.
included
in
Portfolio, which
is
funds
included on
Baird Research Capital Growth (Tax-Exempt)
Portfolio. The Baird Research Capital Growth (Tax-
Exempt) Portfolio seeks to provide growth of
capital. Under normal market conditions, the Baird
Research Capital Growth (Tax-Exempt) Portfolio
provides a globally-diversified asset allocation with
a target allocation of 80% to equity securities and
20% to fixed income securities. The Portfolio
invests
the Baird
then
Recommended
complimented by investing in sleeves of mutual
funds used in the ALIGN Mid Cap Sleeve, ALIGN
Small Cap Sleeve, the ALIGN International Equity
Sleeve, ALIGN Short-Term Tax-Exempt Fixed
Income Sleeve, and ALIGN Intermediate Tax-
Exempt Fixed Income Sleeve. The Portfolio may
also include other investments deemed appropriate
by Baird, such as
the
Recommended Mutual Fund List. This Portfolio has
the same risk profile as a Capital Growth Portfolio.
Baird Research Income with Growth (Taxable)
Portfolio. The Baird Research Income with Growth
(Taxable) Portfolio seeks to provide high current
income and some growth of capital. Under normal
market conditions, the Baird Research Income with
Growth (Taxable) Portfolio provides a globally-
diversified asset allocation with a target allocation
of 40% to equity securities and 60% to fixed
income securities. The Portfolio invests in stocks
included in the Baird Recommended Portfolio,
which is then complimented by investing in sleeves
of mutual funds used in the ALIGN Mid Cap Sleeve,
ALIGN Small Cap Sleeve, the ALIGN International
Equity Sleeve, ALIGN Short-Term Taxable Fixed
Income Sleeve, and ALIGN Intermediate Taxable
Fixed Income Sleeve. The Portfolio may also
include other investments deemed appropriate by
the
funds
Baird,
such as
included on
Baird Research Growth with Income (Taxable)
Portfolio. The Baird Research Growth with Income
(Taxable) Portfolio seeks to provide moderate
growth of capital and some current income. Under
normal market conditions, the Baird Research
Growth with Income (Taxable) Portfolio provides a
globally-diversified asset allocation with a target
allocation of 60% to equity securities and 40% to
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and products and SMA Strategies offered by Baird
and Associated Managers.
Recommended Mutual Fund List. This Portfolio has
the same risk profile as an Income with Growth
Portfolio.
The Portfolio asset allocations and the investment
options included in the ALIGN UMA Select Program
are evaluated on an ongoing basis, generally at
least quarterly.
Unified Advisory Select Portfolios
in
stocks
included
in
Portfolio, which
is
UAS Portfolios involve the use of various different
investment strategies because they are customized
for each client. A client’s particular investment
strategy is typically determined by the client in
consultation with the client’s Financial Advisor.
Certain mutual funds, ETPs, SMA Strategies and
PWM-Managed Portfolios are available to clients to
pursue an investment objective or implement a
customized asset allocation strategy.
funds
included on
Baird Research Income with Growth (Tax-Exempt)
Portfolio. The Baird Research Income with Growth
(Tax-Exempt) Portfolio seeks to provide high
current income and some growth of capital. Under
normal market conditions, the Baird Research
Income with Growth (Tax-Exempt) Portfolio
provides a globally-diversified asset allocation with
a target allocation of 40% to equity securities and
60% to fixed income securities. The Portfolio
the Baird
invests
Recommended
then
complimented by investing in sleeves of mutual
funds used in the ALIGN Mid Cap Sleeve, ALIGN
Small Cap Sleeve, the ALIGN International Equity
Sleeve, ALIGN Short-Term Tax-Exempt Fixed
Income Sleeve, and ALIGN Intermediate Tax-
Exempt Fixed Income Sleeve. The Portfolio may
also include other investments deemed appropriate
by Baird, such as
the
Recommended Mutual Fund List. This Portfolio has
the same risk profile as an Income with Growth
Portfolio.
and
Mutual Funds and ETPs. The UAS Portfolios
Program makes available two categories of mutual
funds and ETPs: (1) UMA Recommended Funds and
(2) UAS Available Funds. The process Baird uses
for selecting and removing mutual funds and ETPs
under the UAS Portfolios Program is described
under the heading “Portfolio Manager Selection and
Evaluation—Selection
Evaluation—UMA
Programs” above.
The descriptions of the ALIGN UMA Select Portfolios
are current as of the date of this Brochure.
However, Baird may change
the objective,
investments, target allocations or risk profile for
any Portfolio at any time. Baird may also offer
other model portfolios under the Program from
time to time.
and
SMA Strategies. The UAS Portfolios Program makes
available two categories of SMA Strategies: (1)
UMA Recommended SMA Strategies; and (2) UAS
Available SMA Strategies. The process Baird uses
for selecting and removing SMA Strategies under
the UAS Portfolios Program is described under the
“Portfolio Manager Selection and
heading
Evaluation—Selection
Evaluation—UMA
Programs” above.
An ALIGN UMA Select Portfolio is subject to the
risks associated with the Portfolio’s particular
strategies and investments. A client should review
the risks associated with those strategies and
investments described under the heading “Principal
Risks” below.
PWM-Managed Portfolios. The PWM-Managed
Portfolios made available under the UAS Portfolios
Program include the following:
• The ALIGN Strategic Sleeves;
The ALIGN UMA Select Portfolios Program makes
available certain UMA Recommended Funds and
certain UMA Recommended SMA Strategies. The
process Baird uses for selecting and removing UMA
Recommended Funds and UMA Recommended
SMA Strategies under the ALIGN UMA Select
Portfolio Program is described under the heading
“Portfolio Manager Selection and Evaluation—
Selection and Evaluation—UMA Programs” above.
• the Baird Recommended Portfolio, Baird Rising
Dividend Portfolio, and AQA Portfolios described
under
the heading “Methods of Analysis,
Investment Strategies and Risk of Loss—
Methods of Analysis—Certain PWM-Managed
Portfolios” above; and
An ALIGN UMA Select Portfolio may include funds
included on Baird’s Recommended Mutual Fund List
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• certain ALIGN Elements Portfolios and ALIGN
Strategic Portfolios described under the heading
“ALIGN Programs” above.
value may
fluctuate,
The descriptions of the PWM-Managed Portfolios
are current as of the date of this Brochure.
However, Baird may change
the objective,
investments or target allocations for any PWM-
Managed Portfolio at any time. Baird may also offer
other PWM-Managed Portfolios under the Program
from time to time.
a client could lose all or a portion of the amount
invested. The management of client accounts and
recommendations made to clients are based in part
upon the use of forward-looking projections, which
in turn are based upon certain assumptions about
how markets will perform in the future. There can
be no guarantee that markets will perform in the
manner assumed and the actual performance of
markets and a client’s Account could differ
materially from those assumptions. Also, a client’s
Account
sometimes
dramatically, depending upon the nature of the
client’s investments, market conditions and other
factors. By participating in a Program, a client may
be subject to certain risks, including, but not
limited to the risks described below. The risks
discussed below vary by Program, investment style
or strategy, and the investments in the client’s
Account, and each risk may or may not apply to a
client. Clients should not pursue a strategy or
invest in an investment product unless they are
prepared to accept the associated risks. Clients are
encouraged to discuss with their Financial Advisor
the risks that apply to them. A client should also
review
the prospectus or other disclosure
document for any security or other investment
product in which the client invests, as it will contain
important information about the risks associated
with investing in such security or other investment
product.
Investment Risk Information
Strategies—Asset
The investment risks of the Programs generally
include the following:
Discretionary Management by UAS Managers. If a
client has selected the discretionary management
option of the UAS Program, the Financial Advisor,
acting as UAS Manager, will manage the client’s
Account in accordance with the UAS Portfolio
strategy selected by client. UAS Managers, as a
group, utilize a wide variety of investment styles,
philosophies, strategies and techniques, including
the investment strategies described in the section
“Methods of Analysis, Investment Strategies and
Risk of Loss—Investment Strategies” above. To
implement a client’s UAS Portfolio strategy, UAS
Managers may use any of the mutual funds, ETPs,
SMA Strategies and PWM-Managed Portfolios made
available by Baird for use in the Program. UAS
Portfolio strategies will have one of the following
investment objectives: (1) All Growth Portfolio, (2)
Capital Growth Portfolio, (3) Growth with Income
Portfolio, (4) Income with Growth Portfolio, (5)
Conservative Income Portfolio, or (6) Capital
Preservation Portfolio, which are described under
“Investment
Allocation
Strategies” above.
A client should ask the client’s Financial Advisor for
additional information about the investment styles,
philosophies, strategies, analyses and techniques
the Financial Advisor will use in order to meet the
client’s objectives.
Market Risks. A client’s Account may change in
value due to overall market fluctuations. General
economic conditions, political developments,
international events and other factors may cause
the overall market to decline, which in turn may
reduce the value of the client’s Account regardless
of the relative strength of the securities held in the
Account. Securities prices often vary for reasons
unrelated to matters directly affecting the issuers
of the securities.
A UAS Portfolio is subject to the risks associated
with the Portfolio’s particular strategies and
investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
Principal Risks
Management and Securities Selection Risks. A
client’s Account may fluctuate in value differently
than, or in the opposite direction as, the overall
market or applicable benchmark because of the
selection of individual securities for the Account.
The judgments made by the persons managing
client accounts about the attractiveness, value and
potential appreciation of particular securities may
Risk is inherent in any investment product and
Baird does not guarantee any level of return on a
client’s investments. There is no assurance that a
client’s investment objectives will be achieved, and
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factors directly related to a specific company, such
as decisions made by its management.
prove to be incorrect. For example, while the stock
markets may experience increases in value, the
client’s Account may experience a decline in value
due to the underperformance of the stocks selected
for investment in the client’s Account.
Common Stock Risks. Common stocks are
susceptible to general stock market fluctuations
and to volatile increases and decreases in value as
market confidence in and perceptions of their
issuers change. These investor perceptions are
based on various and unpredictable
factors
including: expectations regarding government,
economic, monetary and fiscal policies; inflation
and
interest rates; economic expansion or
contraction; and global or regional political,
economic and banking crises. Holders of common
stocks are generally subject to greater risk than
holders of preferred stocks and debt obligations of
the same issuer because common stockholders
generally have inferior rights to receive payments
from issuers in comparison with the rights of
preferred stockholders, bondholders and other
creditors.
Investment Objective and Asset Allocation
Risks. A client’s investment objective and asset
allocation strategies involve the risk that certain
asset classes selected for the client’s Account may
not perform as well as other asset classes during
varying periods. In addition, clients who pursue
more aggressive investment objectives and asset
allocation strategies, while hoping to achieve high
returns, may face greater risk of loss than clients
with more conservative objectives and strategies.
In developing investment objectives and asset
allocation strategies, clients should carefully
consider their financial situation and needs,
investment goals, investment time horizon and risk
tolerance. A client should inform the client’s
Financial Advisor of these considerations so the
Financial Advisor can assist in determining the
client’s investment objectives and asset allocation
strategies.
Fixed Income Security Risks. Fixed income
securities are subject to certain risks, including
interest rate risk, credit risk and liquidity risk. In
addition, they are subject to maturity risk.
Generally, the longer a bond’s maturity, the
greater the interest rate risk and the higher its
yield. Conversely, the shorter a bond’s maturity,
the lower the interest rate risk and the lower its
yield. Non-rated, split-rated, below investment
grade, and asset-backed securities, including
mortgage-backed securities and CMOs, have
additional, special risks.
Conflicts of Interest Risks. Issuers, advisors or
other sponsors of investment products or their
affiliates may engage in business practices that
conflict with the interests of investors. Among
other things, these business practices can have a
negative impact on the market price of the
investment product. Clients are encouraged to
review
the prospectus or other disclosure
document for the investment product and also
discuss with their Financial Advisor the conflicts of
interest risks that may apply to them.
Stock Market Risks. Equity security prices vary
and may fall, thus reducing the value of a client’s
investments. Certain stocks selected for a client’s
Account may decline in value more than the overall
stock market.
Interest Rate Risk. The value of some
investment products, particularly fixed income
securities, is affected significantly by changes in
interest rates. Generally, when interest rates rise,
the product’s market value declines and when
interest rates decline, its market value rises. In
addition, a rise in interest rates may have a
negative impact on the issuer, which, in turn, could
have a negative impact on the market value of the
investment product.
Equity Securities Risks. Equity securities may
experience sudden, unpredictable drops in value or
long periods of decline in value. This may occur
because of factors that affect the securities
markets in general, such as adverse changes in
economic conditions, the general outlook for
corporate earnings, interest rates or investor
sentiment. Equity securities may also lose value
because of factors affecting an entire industry or
sector, such as increases in production costs, or
Credit Risk. The value of some investment
products, particularly fixed income securities, is
affected by changes in the product’s credit quality
rating or the issuer’s financial condition. If the
credit quality rating or the issuer’s financial
condition declines, so may the value of the
investment product. Issuers may experience
unanticipated financial problems and may be
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financial
there
confiscatory
currencies. For instance, foreign governments may
limit or prevent investors from transferring their
capital out of a country. This may affect the value
of a client’s investment in the country that adopts
such currency controls. Exchange rate fluctuations
also may impair an issuer’s ability to repay U.S.
dollar denominated debt, thereby increasing the
credit risk of such debt. In addition, there may be
less publicly available information about a foreign
company than about a domestic company. Foreign
companies generally are not subject to uniform
accounting, auditing and
reporting
standards comparable to those applicable to
domestic companies. With respect to certain
is a possibility of
foreign countries,
expropriation or
taxation, or
diplomatic developments, which could affect
investment in those countries.
Investments
unable to meet its payment obligations. Municipal
obligations in particular may be adversely affected
by political and economic conditions and
developments (for example, legislation reducing
state aid to local governments.) Bonds receiving
the lowest investment grade rating or a non-
investment grade rating may have speculative
characteristics and, compared to higher grade debt
obligations, may have a weakened capacity to
make principal and interest payments due to
changes in economic conditions or other adverse
circumstances. Ratings agencies such as Moody’s,
Fitch and S&P provide ratings on bonds based on
their analyses of information they deem relevant.
Ratings are essentially opinions or judgments of
the credit quality of an issuer and may prove to be
inaccurate. In addition, there may be a delay
between events or circumstances adversely
affecting the ability of an issuer to pay interest
and/or repay principal and an agency’s decision to
downgrade a security.
less
liquid
Emerging Markets Risks.
in
emerging markets can involve risks in addition to
and greater than those generally associated with
investing in more developed foreign markets. The
extent of economic development, political stability,
market depth, infrastructure, capitalization, and
regulatory oversight can be less than in more
developed markets. Emerging market economies
can be subject to greater social, economic,
regulatory, and political uncertainties. All of these
factors can make emerging market securities more
volatile and potentially less liquid than securities
issued in more developed markets.
financial
Capitalization Size Risks. A client may be
invested in small and mid cap stocks, which are
often more volatile and
than
investments in larger companies. The frequency
and volume of trading in securities of such
companies may be substantially less than is typical
of larger companies. Therefore, the securities of
such companies may be subject to greater and
more abrupt price fluctuations. In addition, small-
and mid-size companies may lack the management
experience,
resources and product
diversification of larger companies, making them
more susceptible to market pressures and business
failure.
the
foreign
that
could
compromise
technology
Such
incidents may
Foreign Issuer and Investment Risks.
Securities of
issuers, ADRs, Global
Depositary Receipts (“GDRs”) and European
Depositary Receipts (“EDRs”), and investments in
foreign markets generally, are subject to certain
inherent risks, such as political or economic
instability of the country of issue, the difficulty of
predicting international trade patterns and the
possibility of imposition of exchange controls. Such
securities may also be subject
to greater
fluctuations in price than securities of domestic
corporations. Investors in foreign markets may
face delayed settlements, currency controls and
adverse economic developments as well as higher
overall transaction costs. In addition, fluctuations
in the U.S. dollar’s value versus other currencies
may enhance, erode, reverse gains or widen losses
foreign
from
investments denominated
in
Information Security, Cybersecurity and
Technology-Related Risks. As issuers and their
service providers increasingly rely on digital
technologies, such as
Internet, cloud
computing, and AI‑enabled systems, they face
heightened information security, cybersecurity,
including
and other technology‑related risks,
incidents
the
confidentiality, integrity, or availability of their
systems, data, or
infrastructure.
Technology-related incidents may result from
deliberate adversarial actions (such as cyber
attacks) or unintentional events (such as systems
or human error) and could have a materially
adverse impact on the issuer’s performance and
involve
operations.
unauthorized access, disclosure, use, corruption,
degradation, or destruction of systems or data
(such as
through hacking, malware, social
engineering or theft of digital devices); or the
disruption of systems access to authorized users
(such as through denial of service attacks). Such
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limit visibility
or
penalties,
reputational
involve
cybersecurity,
and
Similar
or
legal and
security
controls,
and
events can impede critical functions, compromise
sensitive business and protected customer
information, and may result in financial losses,
business interruptions, impediments to the ability
to process transactions, breaches of applicable
privacy, data protection, or other laws, regulatory
fines
harm,
reimbursement or other remediation costs, and
increased compliance or operational expenses.
Substantial costs may be incurred to prevent,
detect, investigate, or remediate future technology
related incidents. Issuers’ increasing use of AI
systems introduces additional risks discussed in
the section titled “Artificial Intelligence Risks”
below. Issuers may also rely on third party or cloud
based platforms that present their own information
security,
other
adverse
risks.
technology‑related
consequences may arise from technology related
incidents affecting governmental authorities,
financial market systems,
regulatory bodies,
insurance
exchanges, brokers-dealers, banks,
companies,
other market
custodians,
participants. Although issuers and their service
providers may adopt business continuity plans,
information
risk
management programs designed to prevent or
mitigate such incidents, these measures are
subject to inherent limitations, including the
possibility that certain risks may not be identified
or fully addressed. As a result, client Accounts and
investments may be negatively affected.
to high‑quality, compliant data, and any disruption
in data availability can impair or disable AI Tool
functionality. Issuers often rely on third-party AI
systems, infrastructure, and data, which can create
vendor dependency,
into and
validation of AI model performance, and increase
the risk of disruption in data availability. The
regulatory environment for AI is rapidly evolving
and may
inconsistent or conflicting
requirements across jurisdictions. Compliance may
require significant investment, changes to AI
systems, or
the discontinuation of certain
AI‑enabled features. Non‑compliance may lead to
fines, enforcement actions, or operational
constraints. AI systems are vulnerable
to
cyberattacks or other adversarial actions that can
impair system performance and integrity and
compromise sensitive business and protected
customer information. The impairment of AI
systems or the unauthorized disclosure of sensitive
business or protected information can result in
material disruption and damage to business
operations, significant
regulatory
liabilities, substantial remediation expenses, and
reputational harm. AI systems may inadvertently
use protected information, potentially giving rise to
infringement claims and
intellectual property
substantial damages. Public concerns regarding
fairness, transparency, and responsible use of AI
may reduce demand for an issuer’s products or
services. Failure to use AI responsibly may harm
an issuer’s reputation and competitive position.
Intelligence Risks.
supported only by
issuers to
Government Obligation Risks. Client assets
may be invested in securities issued, sponsored or
guaranteed by the U.S. Government, its agencies
and instrumentalities. However, no assurance can
be given that the U.S. Government will provide
financial support to U.S. Government-sponsored
agencies or instrumentalities where it is not
obligated to do so by law. For instance, securities
issued by the Government National Mortgage
Association (“Ginnie Mae”) are supported by the
full faith and credit of the United States. Securities
the Federal National Mortgage
issued by
Association (“Fannie Mae”) and the Federal Home
Loan Mortgage Corporation (“Freddie Mac”) have
historically been
the
discretionary authority of the U.S. Government.
While the U.S. Government provides financial
support to various U.S. Government-sponsored
agencies and instrumentalities, such as those listed
above, no assurance can be given that it will always
do so.
Artificial
Issuers of
investments increasingly use AI systems in various
aspects of their business operations, creating
competitive market pressures to increase the
development and use of AI systems. Failure to
effectively develop or use AI systems may place an
issuer at a competitive disadvantage. At the same
time, AI systems present significant risks that
could materially affect an issuer’s business and
financial performance. AI Tools rely on complex
models, large datasets, and evolving algorithms.
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations,
deceptive behaviors and other flaws due to the
construction of their underlying models and the
composition of their training data, which can result
in outputs that seem plausible but are in fact
inaccurate, incomplete, or misleading. The use of
erroneous outputs can undermine customer trust
and expose
litigation, regulatory
remediation costs, and
scrutiny, substantial
reputational harm. AI tools require timely access
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fund value per share
fall.
falling. Since
interest
to
the
government agency. Although some money market
funds seek to preserve the value of an investment
at $1.00 per share, there can be no assurance that
will occur, and it is possible to lose money should
the
In some
circumstances, money market funds may be forced
to cease operations when the value of a fund drops.
In that event, the fund's holdings may be
fund's
liquidated and distributed
shareholders. This liquidation process could take
time to complete. During that time, the amounts a
client has invested in the money market fund
for purchases or
would not be available
withdrawals. In addition, retail and institutional
money market funds are required to impose
redemption fees (also known as liquidity fees) and
suspend redemptions (also known as redemption
gates) in certain circumstances. Government
money market funds may also impose redemption
fees and suspend redemptions in those same
circumstances. More specific information about
how a money market fund calculates its NAV and
the circumstances under which it will impose a
redemption fee or suspend redemptions is set forth
in the prospectus for that money market fund.
Municipal Securities Risks. Repayment of
municipal securities depends on the ability of the
issuer or project backing such securities to
generate taxes or revenues. Municipal securities
may also decrease in value during times when tax
rates are
income on
municipal securities is normally not subject to
regular federal income taxation, the attractiveness
in relation to other
of municipal securities
investment alternatives is affected by changes in
federal income tax rates applicable to, or the
continuing federal tax-exempt status of, such
interest income. Any proposed or actual changes in
such rates or exempt status, therefore, can
significantly affect the liquidity, marketability and
supply and demand for municipal securities, which
would in turn affect Baird’s ability to acquire and
dispose of municipal securities at desirable yield
and price levels. Investment in tax-exempt debt
obligations poses additional risks. In many cases,
the IRS has not ruled on whether the interest
received on a tax-exempt obligation is tax-exempt,
and accordingly, purchases of these municipal
securities are based on the opinion of bond counsel
to the issuers at the time of issuance. Thus, there
is a risk that interest may be taxable on a municipal
security that is otherwise expected to produce tax-
exempt interest.
effect on
and/or
repurchase
Money Market Fund Risks. A money market fund
is a type of mutual fund that generally invests in
short-term debt instruments. Many investors use
money market funds to store cash. There are three
primary types of money market funds: (1)
government money market funds (funds that
invest nearly all assets in cash, government
securities,
agreements
collateralized by cash or government securities);
(2) retail money market funds (funds that have
policies and procedures reasonably designed to
limit beneficial ownership to natural persons); and
(3) institutional money market funds (funds that
permit beneficial ownership by institutions and
natural persons). The rules governing money
market funds vary based on the type of money
market fund. Government and retail money market
funds generally try to keep their net asset value
(NAV) at a stable $1.00 per share using special
pricing and valuation conventions. Institutional
money market funds are required to calculate their
NAV in a manner such that the NAV will vary based
upon the market value of assets and liabilities of
the fund (also known as a “floating NAV”). An
investment in a money market fund is not insured
or guaranteed by the FDIC or any other
Illiquid Securities and Liquidity Risks. Liquidity
risk is the risk that certain investments may be
difficult or impossible to sell at the time and price
that a client would like to sell. Clients may have to
lower the price, sell other investments or forego an
investment opportunity, any of which may have a
negative
the management or
performance of client accounts. The liquidity of a
particular investment depends on the strength of
demand for the investment, which is generally
related to the willingness of broker-dealers to
make a market for the investment as well as the
interest of other investors to buy the investment.
During periods of economic uncertainty, significant
economic and market downturns and periods in
which financial services firms are unable to commit
capital to make a market in, or otherwise buy,
certain investments, a client may experience
challenges in selling such investments at optimal
prices. In addition, recent regulatory changes
applicable to financial intermediaries that make
markets in debt securities have restricted or made
it less desirable for those financial intermediaries
to hold large inventories of debt securities.
Because market makers provide stability to a
market through their intermediary services, a
reduction in dealer inventories may lead to
decreased liquidity and increased volatility in the
fixed income markets. In the event the client
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directs Baird to liquidate an illiquid investment, the
client should understand that Baird may have
difficulty finding a buyer in the market for such
investment and such investment may be held in
the Account for a period of time while Baird
attempts to satisfy the client’s liquidation request.
paid to the issuer or guarantor of the securities.
Asset-backed securities are issued in multiple
classes (or tranches) and their relative payment
rights may be structured in many ways. Asset-
backed securities may be subject to greater risk of
default during periods of economic downturn than
other instruments. Asset-backed securities also
can be more sensitive to interest rate risk than
other types of fixed income securities. Modest
movements in interest rates (both increases and
decreases) may quickly and significantly reduce
the value of certain types of these securities.
Asset-backed securities are subject to a number of
other risks, including, but not limited to, market
and valuation risks, liquidity risk, and prepayment
risk.
Split-Rated,
and
Concentration Risks. A client’s Account may
consist of a portfolio of securities that
is
concentrated in an issuer or group of issuers, an
industry or economic sector or group of related
industries or sectors, or concentrated in limited
asset classes. Client accounts with concentrated
positions are susceptible to greater volatility and
increased risk of loss than an Account that is
diversified across several issuers and industries or
sectors and asset classes. A client should not
engage in strategies using concentration unless the
client is prepared to experience significant losses
in the value of the client’s Account.
rate. Higher
Below
Non-Rated,
Investment Grade Securities (High Yield or
“Junk” Bonds) Risks. Investing in securities or
other investment products that are not rated, split-
rated or are below investment grade (also known
as high yield or “junk” bonds) involve significant,
special risks. As a result, they may not be suitable
for some clients. The risks associated with these
investments include, but not limited to, price
volatility risk, credit risk, default risk, and liquidity
risk. Clients investing in securities or other
investment products that are not rated, split-rated
or are below investment grade should have a high
tolerance for risk, including the willingness and
ability to accept significant price volatility, potential
lack of liquidity and potential loss of their
investment.
equity,
Frequent Trading and Portfolio Turnover
Risks. Some of the investment strategies offered
to clients in this Brochure may involve frequent or
active trading for client accounts, which could
result in high portfolio turnover. Strategies that
involve frequent or active trading increase the
management and securities selection risks because
the persons managing the accounts are making
more trading decisions, which may prove to be
incorrect. A portfolio with a high turnover rate will
also incur more transaction costs than one with a
lower
transaction costs may
negatively impact the return of the portfolio. High
portfolio turnover may also cause a client to
experience adverse tax consequences due to the
fact that the client may have increased instances
of realized gains and losses and such gains and
losses may commonly be characterized as short
term gains and losses under applicable tax law.
Mutual Fund Risks. Mutual funds can have many
different investment objectives and strategies,
including
income, balanced,
fixed
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. Mutual funds have risks, which
may
include market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, and emerging market
risk. Certain mutual
funds pursue Complex
Strategies, which are subject to special risks. The
degree of these and other risks will vary depending
on the type of mutual fund selected. Also,
return and principal value will
investment
Asset-Backed Securities Risks. Asset-backed
securities are securities secured or backed by
mortgage loans, student loans, automobile loans,
installment sale contracts, credit card receivables
or other assets and are issued by entities such as
commercial banks, trusts, financial companies,
finance subsidiaries of
industrial companies,
savings and loan associations, mortgage banks and
investment banks. These securities represent
interests in pools of assets in which periodic
payments of interest or principal on the securities
are made, thus, in effect passing through periodic
payments made by the individual borrowers on the
assets that underlie the securities, net of any fees
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fluctuate, and shares, when redeemed, may be
worth more or less than their original cost.
investments
securities
selection
cannot require closed-end funds to buy back their
shares, although closed-end fund shares are listed
and traded on an exchange. For many reasons,
closed-end fund shares often trade at a discount to
their net asset value and the market prices of
closed end fund shares often fall below their public
offering prices. Clients are therefore cautioned
about buying shares of a closed-end fund in its
initial public offering. Closed-end funds often
engage in leverage to raise additional capital for
purposes of making
through
borrowings and issuances of senior securities (such
as preferred stock). Such leverage may present the
opportunity to enhance potential returns but also
involve the risk of exacerbating losses and
depreciation in the value of the underlying
securities. Closed-end funds have other risks,
which may include market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, and emerging market
risk. Certain closed-end funds pursue Complex
Strategies, which are subject to special risks. Some
closed-end funds are organized as interval funds,
which differ from traditional closed-end funds in
that their shares do not trade on the secondary
market, but instead their shares are subject to
repurchase offers from the fund. Closed-end funds
structured as an interval fund will, therefore be
relatively less liquid. Interval funds also often
impose a redemption fee when shares are sold
back to the fund. The degree of these and other
risks will vary depending on the type of close-end
fund selected.
Exchange Traded Fund Risks. An ETF is different
from a mutual fund in that an ETF does not sell its
shares directly to public investors and does not
redeem shares from public investors. Rather,
shares of an ETF are commonly purchased or sold
in the secondary market on a securities exchange,
like common stocks. An ETF maintains a net asset
value but, based on demand and other factors, the
market price of shares of an ETF may vary from its
net asset value. ETFs invest in and hold securities
and other assets, such as stocks, bonds,
commodities and currencies, and have stated
investment objectives and principal strategies.
ETFs can have many different
investment
objectives and strategies, including equity, fixed
income, balanced,
international, and global
strategies, and strategies that focus on a particular
market capitalization, investment style, economic
industry or sector, or geographic region. Many
ETFs seek to track the performance of an index or
other underlying benchmark. Passively managed
ETFs will not be able to replicate exactly the
performance of the indices the ETFs track because
the total return generated by the securities will be
reduced by management fees, transaction costs
and other expenses incurred by the ETF. ETFs have
other risks, which may include market risk,
risk,
management and
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate risk, credit risk, capitalization risk, investment
style risk, foreign issuer and investment risk, and
emerging market risk. Certain ETFs pursue
Complex Strategies, which are subject to special
risks. The degree of these and other risks will vary
depending on the type of ETF selected.
including equity,
fixed
including equity,
fixed
Unit Investment Trust Risks. A UIT is a pooled
investment vehicle in which a portfolio of securities
is selected by the sponsor and deposited into the
trust for a specified period of time. The portfolio of
a UIT is designed to follow an investment objective
over a specified time period, although there is no
guarantee that the objective will be met. UITs can
have many different investment objectives and
strategies,
income,
balanced, international, and global strategies, and
strategies that focus on a particular market
capitalization, investment style, economic industry
or sector, or geographic region. UITs are passively
managed and follow a “buy and hold” strategy,
meaning that UITs buy a fixed portfolio of
securities and hold on to that portfolio until their
termination date at which time the portfolio is
Closed-End Fund Risks. Unlike mutual funds
which continuously offer and redeem their shares
on a daily basis at net asset value, closed-end
funds typically raise money by selling a fixed
number of shares of common stock in a single,
one-time offering, much the way a company issues
stock in an initial public offering. Closed-end funds
can have many different investment objectives and
strategies,
income,
balanced, international, and global strategies, and
strategies that focus on a particular market
capitalization, investment style, economic industry
or sector, or geographic region. Closed-end fund
shares are not redeemable, meaning that investors
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those
conditions affecting
local economies.
Community bank stocks are also subject to
capitalization risk and
illiquid securities and
liquidity risks described above.
Risks Associated with Certain Investment
Strategies
liquidated with the net proceeds paid to investors.
UITs, thus, generally have a relatively higher risk
of loss than other funds in the event of adverse
changes in market or economic conditions. UITs
have other risks, which may include management
and securities selection risk, investment objective
and asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, and emerging market
risk. Certain UITs pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of UIT selected. Also, investment return and
principal value will fluctuate, and units, if and when
redeemed, may be worth more or less than their
original cost.
Growth and Value Investment Style Risks.
Investment styles or strategies that focus on
growth stocks may perform better or worse than
styles or strategies that focus on value stocks or
that are broader or more diversified. Similarly,
investment styles or strategies that focus on value
stocks may perform better or worse than styles or
strategies that focus on growth stocks or that are
broader or more diversified. A particular style of
investing may go out of favor at times and for
extended periods. Growth stocks are often
characterized by high price-to-earnings ratios and
may be more volatile than stocks with lower price-
to-earnings ratios. Value stocks are subject to the
risk that the broader market may not agree with
the manager’s assessment of, or recognize, the
investments’ intrinsic value.
large purchases or
ESG Considerations Risk. Consideration of ESG
factors in the investment process may cause an
advisor or manager to forgo opportunities to
recommend or invest in certain companies or to
gain exposure to certain industries or regions.
Therefore, there is a risk that, under certain
market conditions, an Account pursuing strategies
that consider ESG factors may underperform
accounts that do not consider such factors. There
are not universally accepted ESG factors and
advisors and managers typically consider them in
their discretion.
Risks Common to All Funds; Purchase and
Redemption Risks. Funds are generally subject
to the same risks as the securities or other assets
in which they invest. In addition, from time to time
Baird, a PIM Manager, or an investment manager
may decide to add or remove a Fund to or from an
investment strategy or Program. In addition, they
may decide to increase or decrease their clients’
account allocations to a Fund. In general, they will
place transactions for all affected Accounts at one
time, which may cause the Fund to experience
redemptions.
relatively
redemptions may
Significant purchases and
adversely affect the Fund
in question and
consequently, a client’s investment. A Fund
receiving large purchase orders may have difficulty
investing the cash, which may have a negative
impact on the Fund’s performance. A Fund
experiencing large redemption orders may have to
sell portfolio securities, which may negatively
impact performance and which may have negative
tax consequences. Large redemptions could also
reduce liquidity as the Fund may suspend or delay
redemptions. These risks are more pronounced
with respect to newer Funds and those with smaller
asset sizes.
an
investment
in which
they are
Quantitative Strategy Risks. Some investment
managers may employ quantitative investment
methodologies or processes to make investment
decisions. The success of
the quantitative
investment methodologies and processes used by
investment managers depends on the analyses and
assessments that were used in developing such
methodologies and processes, as well as on the
accuracy and reliability of models and data
provided by third parties. Incorrect analyses and
assessments or inaccurate or incomplete models
and data would adversely affect performance.
Additionally,
manager’s
methodologies and processes are predictive in
nature, based on historical outcomes and trends.
Certain low-probability events or factors that are
Community Bank Stock Risks. Stocks issued by
community banks, small banks and their holding
companies are subject to unique risks. Unlike
national or larger regional banks, community
banks are less geographically diversified and their
businesses and revenues tend to be closely tied to
the economies
located.
Investments in community bank stocks could
therefore be negatively impacted by adverse
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generally more difficult to value, less liquid, and
subject to greater volatility compared to stocks and
bonds.
by
the
that were not predicted by
can be no assurance
that
assigned little weight may occur or prove to be
more likely or may have more relevance than
expected, for short or extended periods of time,
the portfolios
which may adversely affect
generated
investment manager’s
quantitative methodologies and processes. It is
also possible that prices of securities may move in
directions
the
investment manager’s quantitative methodologies
and processes or may fail to move as much as
predicted, for reasons that were not expected.
There
these
methodologies will enable a client to achieve the
client’s objective.
Commodities Risks. Investments in commodities
markets or a particular sector of the commodities
markets, and investments in securities or other
instruments denominated in or indexed or linked to
commodities, are subject to certain risks. Those
investments generally will subject a client Account
to greater volatility than investments in traditional
securities. The commodities markets are impacted
by a variety of factors, including changes in overall
market movements, domestic and foreign political
and economic conditions, interest rates, inflation
rates and investment and trading activities in
commodities. Prices of commodities may also be
affected by factors such as drought, floods,
weather, livestock disease, embargoes, tariffs and
other regulatory developments. The prices of
commodities can also fluctuate widely due to
supply and demand disruptions in major producing
or consuming regions. Certain commodities may be
produced in a limited number of countries and may
be controlled by a small number of producers or
groups of producers. As a result, political,
economic and supply related events in such
countries could have a disproportionate impact on
the prices of such commodities. No active trading
market may exist
for certain commodities
investments, which may impair the value of the
investments.
Technical Strategy Risks. Some investment
managers and Financial Advisors may employ
technical analysis or investment methodologies to
make investment decisions or recommendations.
The primary risk of using technical analysis is that
past price and volume patterns and trends in the
trading markets cannot predict future prices,
volume patterns or trends. There is no guarantee
that technical investment methods used are
designed properly, are updated with new data as it
becomes available, or can accurately predict future
market or investment performance. In order for
technical investment methods to work, there must
be sufficient data about the markets available so
that trends can be identified and predictions can be
made. A technical method may fail to identify
trends or be able to accurately predict future prices
if a market does not have sufficient data or trends
or if the market behaves erratically.
of
Other Strategy Risks. The risks associated with
other types of investment strategies are described
under the heading “Portfolio Manager Selection and
Investment
Evaluation—Methods of Analysis,
Loss—Investment
and Risk
Strategies
Strategies” above.
adversely
the
Non-Traditional Assets and Complex
Strategies Risks
Currency Risks. Investments in currencies, and
investments in securities or other instruments
denominated in or indexed or linked to currencies,
are subject to certain risks. Those investments are
subject to all of the risks associated with foreign
investing generally. In addition, currency markets
generally are not as regulated as securities
markets. Also, changes in currency exchange rates
could
investment.
impact
Devaluation of a currency by a country will also
have a significant negative impact on the value of
any investment denominated in that currency.
Currency investments may also be positively or
negatively affected by a country’s strategies
intended to make its currency stronger or weaker
relative to other currencies.
Non-Traditional Assets Risks. Non-Traditional
Assets, such as commodities, currencies, securities
indices, interest rates, credit spreads, private
companies, and Digital Assets, are subject to risks
that are different from, and in some instances,
greater than, other assets like stocks and bonds.
Some Non-Traditional Assets are less transparent
and more sensitive to domestic and foreign political
and economic conditions than more traditional
investments. Non-Traditional Assets are also
Leverage and Margin Risks. Leveraging
strategies may amplify the impact of any decrease
in the value of underlying securities in the client’s
Account, thereby increasing a client’s risk of loss.
The use of leverage may also increase an Account’s
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put option faces the risk of significant loss if the
prevailing market price of the underlying security
or index decreased below the strike price.
volatility. Strategies involving margin can cause a
client to lose more money than deposited in the
client’s margin account. A client should not engage
in strategies involving leverage or margin unless
the client is prepared to experience significant
losses in the value of the client’s Account.
Hedging Risks. When a derivative instrument is
used as a hedge against an opposite position, any
loss on the derivative instrument should be
substantially offset by gains on the hedged
investment, and vice versa. Although hedging can
be an effective way to reduce the investment risk,
it may not always perfectly offset one position with
another. As a result, there is no assurance that
hedging transactions will be effective.
Short Sales Risks. Short selling runs the risk of
loss if the price of the securities sold short does not
decline below the price at which they were
originally sold. This risk of loss is theoretically
unlimited, as there is no cap on the amount that
the price of a security may appreciate. In addition,
a lender may request, or market conditions may
dictate, that securities sold short be returned to the
lender on short notice, which may result having to
buy the securities sold short at an unfavorable
price. A client should not engage in short sales
unless the client is prepared to experience
significant losses in the client’s Account.
in
the marketplace and
commodity,
currency,
or
limited number of
instruments
Derivative Instrument Risks. The values of
options, convertible securities, futures, swaps,
forward contracts and other derivative instruments
is derived from an underlying asset, such as a
security,
index.
Derivative instruments often have risks similar to
the underlying asset, however, in certain cases,
those risks are greater than the risks presented by
the underlying asset. Derivative instruments may
experience dramatic price changes and imperfect
correlations between the price of the derivative and
the underlying asset, which may increase volatility.
Derivatives generally create leverage, and as a
result, a small movement in the underlying asset's
value can result in large change in the value of the
derivative instrument. Derivatives are also subject
to liquidity risk, interest rate risk, market risk,
credit risk, management risk and counterparty
is not
risk. The use of these
appropriate for some clients because they involve
special risks. A client should not invest in these
instruments unless the client is prepared to
experience volatility and significant losses in the
client’s Account.
Digital Assets Risks. Digital Assets are not
appropriate for some clients because they involve
substantial risk of loss including special risks not
present in traditional financial markets. Digital
Assets derive value primarily from the demand for
such assets
their
association with decentralized networks and other
technology. Digital Assets may lack an intrinsic
value and markets
for Digital Assets are
susceptible
to extreme and sudden price
movements and fragmented liquidity. Markets for
Digital Assets continue to evolve, but lack certainty
regarding the status of regulation and investor
protections. The use and custody of Digital Assets
involve technological and cybersecurity risks,
including the potential for system outages, protocol
flaws, operational disruptions, hacking incidents,
or failures of third-party platforms and service
providers that support trading, settlement, and
storage infrastructure. Many Digital Assets depend
on external validators, miners, or protocol
developers whose actions or inaction can impact
network stability or asset functionality and affect
value. Market structure risks—such as reliance on
a
trading venues or
counterparties—may impair the ability to transact
or liquidate positions during periods of market
stress. A client should not invest in these
instruments unless the client is prepared to
experience extreme volatility and significant losses
in the client’s Account.
Complex Investment Product Risks
Hedge Funds and Funds of Hedge Fund Risks.
Hedge funds typically engage in one or more
Complex Strategies, including the use of Non-
Traditional Assets, short sales, leverage and other
derivative instruments. Funds of hedge funds
typically invest substantially all of their assets in
other hedge funds. Hedge funds and funds of
Options Risks. In purchasing a put or call option,
the purchaser faces the risk of loss of the premium
paid for the option if the market price moves in a
direction opposite to what the purchaser had
expected. In selling or writing an option, the seller
faces significantly more risk. A seller of a call option
faces the risk of significant loss if the prevailing
market price of the underlying security or index
increases above the strike price, and a seller of a
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for those
investments
short
sales,
leverage,
risk,
foreign
hedge funds have unique tax characteristics. A
client should consult with a tax advisor before
investing in those funds. Some hedge funds and
funds of hedge funds are subject to limited
regulation and offer
limited disclosure and
transparency. Also, the costs of hedge funds and
funds of hedge funds are typically higher than
other types of funds. Investment advisers or
funds often receive a
managers
management fee plus an incentive or performance-
based
fee. Because of the existence of a
performance-based fee, fund managers may be
motivated to make riskier investments that have
the potential for significant growth in value. Hedge
funds and funds of hedge funds are also subject to
a higher risk of incorrect valuations. Many hedge
funds hold
for which market
quotations are not readily available, which
necessitates the use of “fair value” pricing. Fair
value pricing is an inherently subjective process
and may not accurately reflect the prices that can
actually be obtained upon sale of the assets for
which fair values are used. Investments in hedge
funds and funds of hedge funds also have reduced
liquidity compared to other investments and are
generally subject to a higher risk of volatility.
Investing in hedge funds and funds of hedge funds
involves other special risks, including, but not
limited to, risks associated with Non-Traditional
Assets,
derivative
instruments, and Complex Strategies. Other risks
may include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, and emerging market
risk. Hedge funds and funds of hedge funds are
complex investments that have significant, special
risks. As a result, they may not be suitable for
some clients. Clients investing in hedge funds or
funds of hedge funds should have a high tolerance
for risk, including the willingness and ability to
accept significant price volatility, potential lack of
liquidity and potential loss of their investment.
objective or strategy that may focus on companies
in certain sectors, industries, geographic regions,
size
ranges or stages of development or
operations, or on certain types and sizes of
investments. Funds of private equity
funds
typically invest substantially all of their assets in
other private equity funds. Private equity funds and
funds of private equity funds have unique tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
equity funds and funds of private equity funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private equity funds and funds of private equity
funds are typically higher than other types of
funds. Investment advisers or managers for those
funds often receive a management fee plus an
incentive fee or carried interest. Private equity
funds and funds of private equity fund are also
generally subject to administrative service fees and
portfolio company transaction fees. Because of the
existence of a carried interest, fund managers may
be motivated to make riskier investments that
have the potential for significant growth in value.
Investments in private equity funds and funds of
private equity funds also have reduced liquidity
compared to other investments. Investors should
not expect to receive distributions from a fund for
a number of years. Private equity investing is very
in portfolio
risky. Many
investments made
In addition,
companies are not profitable.
investments made by private equity funds and
funds of private equity funds may be concentrated
in one or more economic industries or sectors,
geographic regions, stages of development or
operation, or sizes of companies. Investing in
private equity funds and funds of private equity
funds involves other special risks, including, but
not limited to, dependence upon key personnel and
conflicts of interest risks. Other risks may include:
market risk, management and securities selection
risk, investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, and emerging market risk. Private
equity funds and funds of private equity funds are
complex investments that have significant, special
risks. As a result, they may not be suitable for
some clients. Clients investing in private equity
funds and funds of private equity funds should
have a high tolerance for risk, including the
willingness and ability to accept lack of liquidity and
potential loss of their investment.
Private Equity Funds and Funds of Private
Equity Funds Risks. Private equity funds are
pools of actively managed capital that invest
primarily in private companies with the intent of
creating value in the companies in which they
invest by improving operations, reducing costs,
selling non-core assets and maximizing cash flow.
Private equity funds usually have an investment
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or sectors, geographic
regions, stages of
development or operation, or sizes. Investing in
private debt funds and funds of private debt funds
involves special risks, including, but not limited to,
dependence upon key personnel, conflicts of
interest risks, market risk, management and
securities selection risk, investment objective and
asset allocation risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, emerging market risk,
illiquid securities and liquidity risks, concentration
risks, investment fund risks, currency risks and
leveraging risks. Private debt funds and funds of
private debt funds are complex investments that
have significant, special risks. As a result, they
may not be suitable for some clients. Clients
investing in private debt funds and funds of private
debt funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
receive a management
transaction
Private Debt Funds (or Private Credit Funds)
and Funds of Private Debt Funds Risks. Private
debt funds (also known as private credit funds) are
pools of actively managed capital that invest
primarily in loans or debt instruments issued by
companies in private transactions. Sometimes,
repayment of the loan is secured by assets of the
companies obtaining the loans. However, the
companies often have low or no credit ratings.
Thus, investments held by private debt funds
generally are subject the same risks as below
investment grade or “junk” bonds. Trading
markets for the investments held by those funds
are also limited and their investments may be
illiquid. Oftentimes, the interest rate paid by the
companies is determined by a reference interest
rate, such as the federal funds rate, which is
periodically reset. These types of investments are
sometimes referred to as floating rate corporate
debt, floating rate loans or floating rate bank loans.
Private debt funds usually have an investment
objective or strategy that may focus on companies
in certain sectors, industries, geographic regions,
size
ranges or stages of development or
operations, or on certain types and sizes, including
focusing investments on smaller capitalization,
distressed or bankrupt companies. Private debt
funds commonly use borrowings or leverage to
make investments. Funds of private debt funds
typically invest substantially all of their assets in
other private debt funds. Private debt funds and
funds of private debt funds have unique tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
debt funds and funds of private debt funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private debt funds and funds of private debt funds
are typically higher than other types of funds.
Investment advisers or managers for those funds
often
fee plus a
performance fee. Private debt funds and funds of
private debt fund are also generally subject to
operational expenses and
fees.
Because of the existence of a performance fee,
fund managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Investments in private debt funds
and funds of private debt funds also have reduced
liquidity compared to other investments. Investors
should not expect to receive distributions from a
fund for a number of years. Private debt investing
is very risky. Investments made by private debt
funds and funds of private debt funds may be
concentrated in one or more economic industries
Real Estate Investment Trusts (“REITs”) and
Private REIT Risks. A REIT is a corporation, trust
or association that owns and typically operates
income-producing real estate or real estate-related
assets. The income-producing real estate assets
owned by a REIT may include office buildings,
shopping malls, multi-family housing, student
housing, hotels, resorts, hospitals and health care
facilities, self-storage
facilities, data centers,
warehouses, telecommunications facilities, and
mortgages or loans. Many REITs are registered
with the SEC and their common stock and
preferred stock are publicly traded on a stock
exchange. These are known as publicly-traded
REITs. Others may be registered with the SEC but
are not publicly traded. These are known as private
REITs (also known as non-traded or non-exchange
traded REITs). There is no public trading market
for private REITs and the sole method for disposing
of the shares may be limited to a periodic offer to
redeem the shares by the issuer, if the issuer offers
a redemption program. Private REITs are generally
subject to limited regulation and offer limited
disclosure and transparency. The shareholders of a
REIT are responsible for paying taxes on the
dividends that they receive and on any capital
gains associated with their investment in the REIT.
Dividends paid by REITs generally are treated as
ordinary income and are not entitled to the reduced
tax rates on other types of corporate dividends.
Prices of REIT securities and trading volumes may
be more volatile that other investments. Many
REITs focus on a particular sector of the real estate
market, such as apartments, student housing,
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fee,
geographic
regions,
stages
hotels and hospitality, health care, office buildings,
shopping malls, warehouses, self-storage facilities
and the like. Those REITs are subject to risks
associated with sectors in which they are focused.
Additionally, many REITs may own properties that
are concentrated in a particular geographic region
or regions, which subject them to the risk of
deteriorating economic conditions in those areas.
Investing in REITs involves other special risks,
including, but not limited to, real estate portfolio
risk
(including development, environmental,
competition, occupancy and maintenance risk),
liquidity risk, leverage risk, distribution risk, capital
markets access risk, growth risk, counterparty risk,
conflicts of interest risk, dependence upon key
personnel risk, and regulatory risk. Other risks may
include: market risk, management and securities
selection risk, investment objective and asset
allocation risk, stock market risk, equity securities
risk, interest rate risk, credit risk, foreign issuer
and investment risk, and emerging market risk.
REITs involve significant, special risks and may not
be suitable for some clients. Clients investing in
REITs should have a high tolerance for risk,
including the willingness and ability to accept
significant price volatility and volatility of regular
distribution amounts, potential lack of liquidity and
potential loss of their investment.
of
interest
securities
risks, market
selection
risk,
foreign
fund
risks, currency
redevelopment,
tax advisor before investing in those funds. Private
real estate funds and funds of private real estate
funds are subject to limited regulation and offer
limited disclosure and transparency. Also, the costs
of private real estate funds and funds of private
real estate funds are typically higher than other
types of funds. Investment advisers or managers
for those funds often receive a management fee
plus a performance fee. Private real estate funds
and funds of private real estate fund are also
generally subject to operational expenses and
transaction fees. Because of the existence of a
fund managers may be
performance
motivated to make riskier investments that have
the potential for significant growth in value.
Investments in private real estate funds and funds
of private real estate funds also have reduced
liquidity compared to other investments. Investors
should not expect to receive distributions from a
fund for a number of years. Private real estate
investing is very risky. Investments made by
private real estate funds and funds of private real
estate funds may be concentrated in properties
involved in one or more economic industries or
sectors,
of
development or operation, or sizes. Investing in
private real estate funds and funds of private real
estate funds involves special risks, including, but
not limited to, dependence upon key personnel,
risk,
conflicts
risk,
management and
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
investment
risks and
leveraging risks. Private real estate funds and
funds of private real estate funds are complex
investments that have significant, special risks. As
a result, they may not be suitable for some clients.
Clients investing in private real estate funds and
funds of private real estate funds should have a
high tolerance for risk, including the willingness
and ability to accept lack of liquidity and potential
loss of their investment.
Private Real Estate Funds and Private Real
Estate Fund of Funds. Private real estate funds
are pools of actively managed capital that directly
invest primarily in investments in real estate and
real estate-related investments. Private real estate
funds may invest in any number of types of real
estate, such as office, apartment, retail, lodging,
industrial and other real estate and real estate-
related investments. Some may focus investment
in properties involved in certain sectors or
industries, located in certain geographic regions or
that have certain sizes of operations or investment
requirements. Some may focus investment on
properties the manager or sponsor believes are
undervalued or undercapitalized or that require
improved
repositioning,
management or additional capital to reach their full
value. Private real estate funds commonly use
borrowings or leverage to make investments.
Trading markets for investments held by those
funds are limited and their investments may be
illiquid. Funds of private real estate funds typically
invest substantially all of their assets in other
private real estate funds. Private real estate funds
and funds of private real estate funds have unique
tax characteristics. A client should consult with a
Private Infrastructure Funds Risks. Private
infrastructure funds are pools of actively managed
capital that invest primarily in infrastructure
projects and assets and may involve exposure to a
range of economic or market sectors, geographic
locations and asset
types. Examples of
infrastructure investments may include, among
and
others,
telecommunication,
utilities,
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Robert W. Baird & Co. Incorporated
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
reduced
liquidity compared
risk,
foreign
Non-Traditional Asset investments or other assets,
or an index or other benchmark linked to stocks,
market volatility, bonds, interest rates, Treasury
yields, yield curves and spreads, derivative
instruments, strategies, commodities, currencies
or other assets. ETNs trade on exchanges
throughout the day at prices determined by the
market. Unlike ETFs, issuers of ETNs do not buy or
hold assets to replicate or approximate the
performance of the underlying benchmark. Also in
contrast to ETFs, ETNs also do not calculate their
net asset value, are generally not redeemable on a
daily basis, and are not registered under the
Investment Company Act of 1940. Issuers may
also have the right and option to redeem ETNs.
Redemptions are made at the ETN’s “indicative
value” or “closing indicative value”. An ETN's
closing indicative value is computed by the issuer
and is distinct from an ETN's market price, which is
the price at which an ETN trades in the secondary
market. Issuers of ETNs may also issue and
redeem notes as a means to keep the ETN’s market
price in line with its indicative value, which have
caused significant fluctuations in ETN prices.
Investing in ETNs involves special risks, including,
but not limited to, risks associated with Non-
Traditional Assets and derivative instruments and
the risk that the actual market price for an ETN
may vary significantly from the indicative value
computed by the issuer. Other risks may include:
market risk, management and securities selection
risk, investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate risk, credit risk, capitalization risk, investment
style risk, foreign issuer and investment risk, and
emerging market
risk. ETNs are complex
investments and involve significant, special risks.
As a result, ETNs may not be suitable for some
clients.
pools
(typically
structured
transportation. Private infrastructure funds usually
have an investment objective or strategy that may
focus on certain sectors, industries, geographic
regions, size ranges or stages of development or
operations, or on certain types and sizes of
investments. Private infrastructure funds have
unique tax characteristics. A client should consult
with a tax advisor before investing in those funds.
Private infrastructure funds are subject to limited
limited disclosure and
regulation and offer
transparency. Also,
costs of private
the
infrastructure funds are typically higher than other
types of funds. Investment advisers or managers
for those funds often receive a management fee
plus an incentive fee. Private infrastructure funds
are also generally subject to administrative service
fees and investment transaction fees. Because of
the existence of incentive fees, fund managers may
be motivated to make riskier investments that
have the potential for significant growth in value.
Investments in private infrastructure funds also
to other
have
investments. Investors should not expect to
receive distributions from a fund for a number of
years. Private infrastructure investing is very risky.
Many investments are not profitable. In addition,
investments made by private infrastructure funds
may be concentrated in one or more economic
industries or sectors, geographic regions, stages of
development or operation, or sizes of companies.
Investing in private infrastructure funds involves
other special risks, including, but not limited to,
dependence upon key personnel and conflicts of
interest risks. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, and emerging market risk. Private
infrastructure funds are complex investments that
have significant, special risks. As a result, they
may not be suitable for some clients. Clients
investing in private infrastructure funds should
have a high tolerance for risk, including the
willingness and ability to accept lack of liquidity and
potential loss of their investment.
Exchange Traded Notes Risks. An ETN is a type
of debt security that trades on an exchange and
provides a return linked to the performance of an
underlying benchmark. The underlying benchmark
can be a particular security, bond, commodity,
currency, or other Non-Traditional Asset type, a
group or basket of companies, securities,
commodities, currencies, derivative instruments,
Managed Futures Risks. Managed futures are
commodity
as
investment partnerships) managed by a futures
trading adviser that trade speculatively in various
derivative instruments and other investments.
There are significantly higher fees and expenses
associated with investments in managed futures
than other types of funds. Sponsors or managers
for these pools often receive a management fee
plus incentive or performance-based fee. Because
of the existence of a performance-based fee,
managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Managed futures may seek
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in managed
risks and
currencies,
Assets,
leverage,
involves special risks, including, but not limited to,
risks associated with Non-Traditional Assets, short
sales, leverage, and derivative instruments. Other
risks may include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk, foreign
issuer and investment risk, and emerging market
risk. Leveraged funds and inverse funds are
complex investments that have an increased risk
of loss compared to other funds and they involve
significant, special risks. As a result, they may not
be suitable for some clients. A client should not
invest in these securities unless the client is
prepared to experience significant losses in the
value of the client’s Account.
Investing
exposure to different asset classes, such as equity
securities, fixed income securities, commodities
(such as metals, agricultural products, and energy
products), currencies, interest rates, and indices.
Managed futures often obtain this exposure
through derivative instruments, which may be
traded on U.S. or foreign exchanges or markets.
Managed futures often employ computerized,
systematic and often proprietary trading models
and systems. Investing
futures
involves special risks, including, but not limited to,
risks associated with
liquidity
and other Non-
commodities,
Traditional
derivative
instruments and Complex Strategies. Other risks
may include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk, foreign
issuer and investment risk, and emerging market
futures can be speculative
risk. Managed
investments because of the types of investments
they make and they involve significant, special
risks. As a result, they may not be suitable for
some clients. Clients investing in these funds
should have a high tolerance for risk, including the
willingness and ability to accept significant price
volatility, potential lack of liquidity and potential
loss of their investment.
Structured Products Risks. Structured products
are a hybrid between two asset classes (typically
issued in the form of a CD or note) but instead of
having a pre-determined rate of interest, the
return is linked to the performance of an
underlying asset class, such as single security or
basket or index of securities; a commodity or
basket or index of commodities, including futures;
and a foreign currency or basket of foreign
currencies.
in structured products
involves special risks, including, but not limited to,
risks associated with derivative instruments. Other
risks may include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk, foreign
issuer and investment risk, emerging market risk,
commodities risk and currency risk. Structured
products are complex investments and involve
special risks. As a result, they may not be suitable
for some clients.
funds
Leveraged Fund and Inverse Fund Risks.
Leveraged funds and inverse funds may be
structured as ETNs, ETFs or open-end mutual
funds. Leveraged funds seek to deliver multiples of
the performance of the index or benchmark they
track. Inverse funds seek to deliver the opposite of
the performance of the index or benchmark they
track. Leveraged inverse funds seek to achieve a
return that is a multiple of the inverse performance
of the underlying index. Most leveraged and
inverse funds “reset” daily, meaning that they are
designed to achieve their stated objectives on a
daily basis. Because of the effects of compounding,
volatility and the fund expenses, the returns of a
leveraged or inverse fund over longer periods of
time can differ significantly from the performance
(or inverse of the performance) of their underlying
index or benchmark during the same period of
time. To achieve their objectives, leveraged and
inverse
typically employ aggressive
investment techniques, such as the use of
leverage, short sales, swap contracts, futures,
instruments.
options and other derivative
Investing in leveraged funds and inverse funds
Business Development Company Risks. A BDC
is typically a domestic, closed-end investment
company that is operated for the purpose of
making equity and debt investments in small and
developing businesses, as well as financially
troubled businesses. As a result, investments
made by BDCs tend to be risky and speculative.
Investment advisers or managers for BDCs often
receive a management fee plus incentive or
performance-based fee. Because of the existence
of a performance-based fee, managers may be
motivated to make riskier investments that have
the potential for significant growth in value. BDCs
commonly use borrowings or leverage to make
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
including, but not
industry. Those MLPs are subject
to risks
associated with sectors or industries in which they
are focused. The value of an investment in an MLP
and the amount of distributions it makes may
depend on the prices of the underlying commodity,
such as oil or natural gas. Many MLPs are sensitive
to changes in the prevailing level of commodity
prices. MLPs have also shown sensitivity to interest
rate movements. Investing in MLPs involves other
special risks,
limited to,
macroeconomic risk, interest rate risk, liquidity
risk, operating risk, capital markets access risk,
growth risk, distribution risk, conflicts of interest
risk, and regulatory risk. MLPs are complex
investments that have significant, special risks. As
a result, MLPs may not be suitable for some clients.
Clients investing in MLPs should have a high
tolerance for risk, including the willingness and
ability to accept potential lack of liquidity and
potential loss of their investment.
on
website
and
Additional information about certain Complex
Investment Products and other investments
pursuing Complex Strategies, including the
risks associated with those investments, is
at
available
Baird’s
on
bairdwealth.com/retailinvestor
FINRA’s website
at www.finra.org/
Investors. A client is encouraged to read the
disclosure documents
included on those
websites carefully before investing.
Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies
investments
in portfolio companies. Adverse
interest rate movements can negatively impact a
BDC’s ability to make investments. Investments
made by BDCs are typically illiquid, and valuing
such investments is challenging. It is possible that
valuations on investments used are materially
different from the values that BDCs will ultimately
receive upon disposition of those investments.
Changing market and economic conditions
affecting a BDC’s
investments may cause
significant volatility in the BDC’s net asset value
and stock price. Due to the nature of BDCs’
investments, securities issued by BDCs are subject
to greater liquidity risk than other investments. A
debt security or preferred stock issued by a BDC,
in many cases, is non-rated or is rated below
investment grade, which can carry its own risks.
Investing in BDCs involves other special risks,
including, but not limited to, portfolio company
credit and investment risk, leverage risk, capital
markets access risk, dependence upon key
personnel risk, and regulatory risk. Other risks may
include: market risk, management and securities
selection risk, investment objective and asset
allocation risk, stock market risk, equity securities
risk, common stock risk, fixed income securities
risk, and interest rate risk. BDCs can be speculative
investments because of the types of investments
they make and involve significant, special risks. As
a result, BDC investments may not be suitable for
some clients. Clients investing in BDCs should have
a high tolerance for risk, including the willingness
and ability to accept significant price volatility,
potential lack of liquidity and potential loss of their
investment.
partnership. MLPs
have
unique
Each Account is subject to the risks associated with
the investments in the Account. Generally, an
Account will be subject to the risks associated with
the portfolio listed below that corresponds to the
investment objective of the Account or the asset
allocation strategy pursued by the Account.
All Growth Portfolio. An All Growth Portfolio will
generally be invested in a manner that seeks to
provide growth of capital. All Growth Portfolios
have historically experienced high fluctuations in
annual returns and overall market value, typically
as a result of changes to market and economic
conditions. The Portfolio’s investments are subject
to a high risk of price declines, especially during
periods when stock markets in general are
declining. An All Growth Portfolio’s primary risks
generally include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
Master Limited Partnership Risks. An MLP is a
form of publicly-traded partnership that is taxed as
a
tax
characteristics. A client should consult with a tax
advisor before investing in MLPs. An MLP must
generally earn at least 90% of its income from
certain qualifying sources, which includes income
and gains from certain activities involving natural
resources such as oil, natural gas, natural gas
liquids, refined petroleum products, coal, carbon
dioxide and biofuels. An MLP is generally structured
as a limited partnership or limited liability company
and managed and operated by a general partner or
manager. Owners of an MLP are called “limited
partners” or “unit holders”. Unit holders own
interests or units in the MLP (“units”) that are
traded on a stock exchange. MLPs make
distributions to unit holders of their available cash
flows. Many MLPs focus on a particular sector or
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
risk,
common
stock
upon
Portfolio’s
to other primary
risks,
risks,
foreign
foreign
issuer and
investment
and
securities
risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, emerging market risks, fixed
income security risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
rate risk, credit risk, and capitalization risks.
Depending
specific
the
investments, the Portfolio may also be subject to
other primary risks, including investment style
risks,
risks,
emerging market risks, asset-backed securities
risks, below investment grade (high yield or “junk”
bonds) securities risks, and the risks described
under the headings “Non-Traditional Assets and
Complex Strategies Risks”
“Complex
Investment Product Risks” above.
securities
selection
securities
selection
to other primary
risks,
risks,
foreign
Capital Growth Portfolio. A Capital Growth
Portfolio will generally be invested in a manner that
seeks to provide growth of capital. Capital Growth
Portfolios have historically experienced moderately
high fluctuations in annual returns and overall
market value, typically as a result of changes to
market and economic conditions. The Portfolio’s
investments are subject to a risk of price declines,
especially during periods when stock markets in
general are declining. A Capital Growth Portfolio’s
primary risks generally include: market risk,
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, and capitalization risks. Depending upon
the Portfolio’s specific investments, the Portfolio
may also be subject to other primary risks,
including investment style risks, foreign issuer and
investment risks, emerging market risks, fixed
income securities risk, interest rate risk, credit risk,
asset-backed securities risks, below investment
grade (high yield or “junk” bonds) securities risks,
and the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
Income with Growth Portfolio. An Income with
Growth Portfolio will generally be invested in a
manner that seeks to provide current income and
some growth of capital. Income with Growth
Portfolios have historically experienced moderate
fluctuations in annual returns and overall market
value, typically as a result of changes to interest
rates and market and economic conditions. The
Portfolio’s investments are subject to a risk of price
declines, especially during periods when interest
rates are rising or when stock markets in general
are declining. An Income with Growth Portfolio’s
primary risks generally include: market risk,
management and
risk,
investment objective and asset allocation risk,
fixed income securities risk, interest rate risk,
credit risk, money market fund risk, stock market
risk, equity securities risk, common stock risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
to
economic
The
Growth with Income Portfolio. A Growth with
Income Portfolio will generally be invested in a
manner that seeks to provide moderate growth of
capital and some current income. Growth with
Income Portfolios have historically experienced
moderate fluctuations in annual returns and overall
market value, typically as a result of changes to
market and economic conditions and interest rates.
The Portfolio’s investments are subject to a risk of
price declines, especially during periods when
stock markets in general are declining or when
interest rates are rising. A Growth with Income
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
Conservative Income Portfolio. A Conservative
Income Portfolio will generally be invested in a
manner that seeks to provide current income.
the portfolios described above,
Relative
Conservative Income Portfolios have historically
experienced smaller fluctuations in annual returns
and overall market value as a result of changes in
stock market conditions, but have experienced
fluctuations in relation to changes in interest rates
and
Portfolio’s
conditions.
investments are subject to risk of price declines,
especially during periods when interest rates are
rising. A Conservative Income Portfolio’s primary
risks generally include: market risk, management
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the
and securities selection risk, investment objective
and asset allocation risk, fixed income securities
risk, interest rate risk, credit risk, money market
fund risk, equity securities risk, and common stock
risks. Depending upon the Portfolio’s specific
investments, the Portfolio may also be subject to
other primary risks, including investment style
risks, foreign issuer and investment risks, asset-
backed securities risks, and below investment
grade (high yield or “junk” bonds) securities risks.
upon
Portfolio’s
foreign
issuer and
investment
income. Relative
to
and
conditions. Depending upon
investment
strategy used and the investments made, the
Portfolio’s investments may be subject to a high
risk of price declines, especially during periods
when stock markets in general are declining. An
Opportunistic Portfolio’s primary risks generally
include: market risk, management and securities
selection risk, investment objective and asset
allocation risk, stock market risk, equity securities
risk, common stock risk, and capitalization risks.
Depending
specific
the
investments, the Portfolio may also be subject to
other primary risks, including investment style
risks,
risks,
emerging market risks, fixed income security risks,
below investment grade (high yield or “junk”
bonds) securities risks, and the risks described
under the headings “Non-Traditional Assets and
Complex Strategies Risks”
“Complex
Investment Product Risks” above.
interest
rates are
under
certain
upon
Portfolio’s
Capital Preservation Portfolio. A Capital
Preservation Portfolio will generally be invested in
a manner that seeks to preserve capital while
generating current
the
portfolios described above, Capital Preservation
Portfolios have historically experienced smaller
fluctuations in annual returns and overall market
value as a result of changes in stock market
conditions, but have experienced fluctuations in
relation to changes in interest rates and economic
conditions. The Portfolio’s investments are subject
to risk of price declines, especially during periods
when
rising. A Capital
Preservation Portfolio’s primary risks generally
include: market risk, management and securities
selection risk, investment objective and asset
allocation risk, fixed income securities risk, interest
rate risk, credit risk, and money market fund risk.
Depending
specific
the
investments, the Portfolio may also be subject to
other primary risks, including foreign issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
Additional Considerations. A client should note
that an Account pursuing a particular investment
objective or asset allocation strategy will from time
to time be subject to actual risks that are higher or
lower than, or different from, the risks described
circumstances. See
above
“Investment Strategies—Important Information
about Implementation of Investment Objectives
and Investment Strategies” above for more
information. In addition to the specific risks
described above, a client’s Account may be subject
to additional risks, depending upon the particular
investments in the client’s Account. A client should
discuss the risks of particular investments with the
client’s Financial Advisor. A client should also note
that there is no guarantee as to how an Account
will perform in the future. It is possible that an
Account could experience more dramatic return or
market value fluctuations than occurred in the
past.
Available Investment Product Risks
that Baird
establishes
for
The use of Available Investment Products,
including SMA Strategies made available under the
BSN and DC Programs, and including UAS Available
SMA Strategies and UAS Available Funds made
available under the UAS Program, are subject to
additional risks compared to the use of Baird
recommended
investment products. Available
Investment Products are investment products that
generally do not meet the qualifications and
standards
its
recommended product lists. As a result, there is a
Opportunistic Portfolio. An Opportunistic
Portfolio will generally be invested in a manner that
seeks to provide long term growth through capital
appreciation and/or income by utilizing an active
management style that shifts the amount of
investment made in different asset classes and
market sectors to take advantage of the manager’s
perception of market pricing anomalies, those
market or industry sectors deemed favorable for
investment by the manager, the current interest
rate environment and/or other macro-economic
trends identified by the manager to achieve growth
while accounting for a client’s specific short,
intermediate and long term investment and/or
cash flow needs. Depending upon the investment
strategy used, some Opportunistic Portfolios have
historically experienced high fluctuations in annual
returns and overall market value, typically as a
result of changes to market and economic
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
less
if an Available
Internationally, geopolitical risks have increased as
the U.S. and Israel are engaged in a military
conflict with Iran. The conflict has disrupted global
trade and caused an increase in the price of oil. The
continuation or escalation of military strikes could
lead to a lengthy period of military conflict, and
Iran’s military attacks and other hostile actions
against other countries present a risk of widening
the conflict. In addition, the war between Ukraine
and Russia is now passing its fourth anniversary,
instability in parts of the Middle East persist, and
relations between the U.S. and other countries are
strained.
Rapid advancements in artificial intelligence (AI)
and automation are increasingly influencing global
economic trends, corporate decision making, and
financial market dynamics. Expanding investment
in these technologies is contributing to shifts in
how industries operate, compete, and allocate
resources. The fast pace of technological change,
potential disruptions to existing business models,
and evolving regulatory responses
introduce
additional uncertainty and may contribute to
market volatility.
higher likelihood that some Available Investment
Products will have poor performance and will
significantly underperform compared
to an
index or peer group.
applicable benchmark
Available Investment Products are also subject to
significantly
review by Baird
rigorous
compared to recommended investment products.
Thus,
Investment Product
experiences significant performance problems or if
the manager or sponsor of an Available Investment
Product experiences significant management,
organizational, operational, compliance,
legal,
regulatory or other problems, there is a higher risk
that the Available Investment Product will be made
available (and will continue to be made available)
to clients by Baird. An investment by a client in an
Available Investment Product that experiences the
occurrence of any such event could negatively
impact the client’s Account. Available Investment
Products should only be used by a client if the client
wishes to take more responsibility for monitoring
and managing the assets in the client’s Account,
the list of recommended products does not contain
an investment product that meets the client’s
particular needs, and the client understands the
risks of doing so.
Recent Events
Taken together, these developments may have a
significant negative impact upon global economic
conditions and contribute to a heightened risk
environment. As a result, fluctuations in asset
prices may increase, and such volatility could
adversely affect the value of a client’s Account.
priorities,
changes
in
Global
financial markets have continued to
experience periods of elevated volatility, driven by
a combination of economic, political, and broader
macroeconomic developments. Conditions across
major economies have been influenced by shifting
policy
geopolitical
relationships, and evolving investor expectations.
Voting Client Securities
Baird Advisory Choice Program and Other
Non-Discretionary Accounts
Under the Baird Advisory Choice Program and with
respect to any other Accounts over which the client
retains discretionary investment authority, a client
retains the right to vote proxies with respect to the
securities held in such Accounts. Accordingly, the
client is responsible for voting proxies and
otherwise addressing all matters submitted for
consideration by security holders, and Baird is
under no obligation to take any action or render
any advice regarding such matters. The client’s
Baird Financial Advisor may, upon the client’s
request, provide advice on proxy voting or what
other action the client could take.
UMA Programs
Within the United States, the current U.S.
administration has demonstrated
intent on
implementing policy changes through executive
orders and legislation, contributing to a less certain
policy environment. Potential adjustments to
federal programs, regulatory
initiatives, and
legislative priorities create additional factors for
markets to assess, which may cause meaningful
inflation reduction
market uncertainty. While
remains a central focus for policymakers, achieving
the U.S. Federal Reserve Board’s long term
inflation
to prove
target of 2% continues
challenging. Although annual price increases have
generally moderated, the price of many goods and
services remains elevated compared to levels from
a few years ago. Leadership changes at the Federal
Reserve and political divisions and discord add
further uncertainty to the economic outlook.
Under the ALIGN UMA Select Portfolios and UAS
Portfolios Programs, a client may retain the right
to vote proxies with respect to the securities held
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in the client’s Account, or the client may delegate
such right to the Overlay Manager. A client may
select either option by making the appropriate
election in the client’s advisory agreement. For
information about the Overlay Manager’s voting
policies and procedures, clients should review the
Overlay Manager’s Form ADV Part 2A Brochure.
Separately Managed Accounts
clients. Those procedures address material
conflicts of interest that may arise between Baird’s
interests and those of its clients. Although a
description of Baird’s proxy voting policies and
procedures is provided below, Baird will furnish a
copy of its proxy voting policies and procedures to
clients upon their request. Additionally, clients may
obtain information on how Baird actually voted
proxies with respect to the securities held in their
accounts by contacting their Baird Financial Advisor
or by calling (414) 765-3500.
currently
and make
independent
review
Under the Baird Affiliated Managers Program, Baird
Recommended Managers Program, Baird SMA
Network Program, and Dual Contract Program, a
client may retain the right to vote proxies with
respect to the securities held in the client’s
Account, or, in most instances, the client may
delegate such right to the investment manager
selected to manage the client’s Account (which
may include Baird, the Overlay Manager or an
Implementation Manager). A client may select
either option by making the appropriate election in
the client’s advisory agreement (and in the case of
a dual contract arrangement under the Dual
Contract Program, by providing proper instructions
to the manager directly). Some managers do not
offer proxy voting services in connection with
certain strategies, such as option strategies.
Clients pursuing those strategies will automatically
retain the right to vote proxies in those instances.
For information about a manager’s voting policies
and procedures, clients should
the
manager’s Form ADV Part 2A Brochure.
manager
believes
the
Discretionary Programs
Under the ALIGN Strategic Portfolios, BairdNext
Portfolios, PIM, and Russell Programs, a client may
retain the right to vote proxies with respect to the
securities held in the client’s Account, or a client
may delegate such right to Baird.
If a client retains proxy voting authority, Baird will
forward proxy materials that Baird actually
receives to the client. The client will then be solely
responsible for analyzing the materials and casting
the vote.
If a client delegates voting authority to Baird, Baird
will vote proxies solicited by, or with respect to,
securities held in the client’s Account for the
exclusive benefit of the client and in accordance
with policies and procedures adopted by Baird.
In situations in which a client has delegated to
Baird voting authority with respect to securities in
the client’s Account, Baird will vote proxies in a
manner that Baird believes is consistent with the
client’s best interests. Baird utilizes an independent
provider of proxy voting and corporate governance
services,
Institutional Shareholder
Services (“ISS”), to analyze proxy materials and
votes
voting
recommendations. ISS provides proxy voting
guidelines regarding its position on various matters
presented by companies to their shareholders for
consideration. Baird will typically vote shares in
accordance with the recommendations made by
ISS. However, ISS’s guidelines are not exhaustive,
do not address all potential voting issues, and do
not necessarily correspond with the opinions of
Baird Financial Advisors or other Baird portfolio
managers managing a client’s Account. In the
event the client’s Financial Advisor or Baird
portfolio
ISS
recommendation is not in the best interest of the
client, the Financial Advisor or Baird portfolio
manager, as applicable, will bring the issue to
Baird’s Proxy Voting Sub-Committee through a
proxy challenge process. The Sub-Committee will
then be responsible for determining how the vote
will be cast. The decision made by the Proxy Voting
Sub-Committee on the proxy challenge applies to
all advisory accounts managed by the Financial
Advisor or Baird portfolio manager (or team of
Financial Advisors or Baird portfolio managers),
unless the client has directed Baird to utilize
specific voting guidelines (e.g., Taft-Hartley
guidelines). For those matters for which the
independent proxy voting service does not provide
a specific voting recommendation, each Financial
Advisor or Baird portfolio manager will cast the
vote in a manner he or she believes is in the best
interest of clients. The votes cast for a client’s
Account may differ from those votes cast for other
Baird clients based on differing views of Baird
Baird has adopted written policies and procedures
that are reasonably designed to ensure that it
votes client securities in the best interests of
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Financial Advisors and other Baird portfolio
managers.
While Baird uses its best efforts to vote proxies,
there are instances when voting is not practical or
is not, in Baird’s or Baird Financial Advisors’ view,
in the best interest of clients. For example, casting
a vote on a foreign security may involve additional
costs or may prevent, for a period of time, sales of
shares that have been voted. Also, when a client
has entered into a securities lending program,
Baird generally will not seek to recall the securities
on loan for the purpose of voting the securities;
however, Baird reserves the right to recall the
shares on loan on a best efforts basis if the client’s
Financial Advisor becomes aware of a proxy
proposal where the proxy vote is materially
important to the client’s Account.
In addition to the services described above, Baird
has engaged ISS for vote execution and record-
keeping services.
Baird uses ISS’s electronic vote management
system to cast votes on behalf of clients. In
connection with Baird’s use of that system, ISS
pre-populates how client votes should be cast
based upon ISS’s voting recommendations. The
system allows Baird to change the pre-populated
vote (to the extent permitted by Baird’s proxy
voting policies) up until a certain time prior to the
applicable meeting (the “voting cut-off time”).
Baird’s proxy voting policies are designed to
address situations when additional information
becomes available after the votes are pre-
populated in the system and before the voting cut-
off time. However, there is no guarantee that all
information that could affect Baird’s proxy voting
decision will be received or considered by Baird
prior to a vote being cast.
Other Proxy Voting Information
(or
Clients wishing to direct particular votes once they
have granted Baird discretionary voting authority
may do so by contacting their Baird Financial
Advisor. However, if Baird has been granted
discretionary voting authority, neither Baird nor
the client’s Financial Advisor will provide a client
with notice that Baird has received a proxy
solicitation, nor will they consult with the client
before casting a vote, unless the client otherwise
directs them to do so.
Except to the extent a client has delegated proxy
voting authority to Baird, Baird has no authority,
direct or implicit, and accepts no responsibility for
taking any action or rendering any advice with
respect to the voting of proxies related to securities
held in a client’s Accounts.
Providing Baird Voting Instructions
in
The proxy voting policies and procedures also
address instances in which Baird’s interests may
appear to conflict with client interests, such as
when Baird or an affiliate of Baird is managing or
administering
to manage or
seeking
administer) a corporate retirement, pension or
employee benefit plan or providing (or seeking to
provide) advisory or other services to a company
whose management is soliciting proxies. In such
instances, there may be a concern that Baird would
be inclined to vote in favor of management
because of Baird’s relationship or pursuit of a
relationship with the company. In situations where
there is a potential conflict of interest, Baird’s
Proxy Voting Sub-Committee will determine the
nature and materiality of the conflict. If the conflict
is determined to not be material, the Sub-
Committee will vote the proxy in a manner the
Sub-Committee believes is in the best interests of
the client and without consideration of any benefit
to Baird or its affiliates. If the potential conflict is
determined to be material, Baird’s Proxy Voting
Sub-Committee will take one of the following steps
to address the potential conflict: (1) cast the vote
in accordance with the recommendations of ISS or
other independent third party; (2) refer the proxy
to the client or to a fiduciary of the client for voting
purposes; (3) suggest that the client engage
another party to determine how the proxy should
be voted; (4) if the matter is not addressed by ISS,
vote
accordance with management’s
recommendation; or (5) abstain from voting.
As mentioned above, Baird may be the holder of
record for certain securities in a client’s Account. If
the client retains voting authority over such
securities (or delegates such authority to party
other than Baird), and a proxy is solicited with
respect to any such securities, the client (or other
authorized party) will need to provide voting
instructions to Baird. To the extent the client (or
other authorized party) does not provide timely
voting instructions, Baird will vote such securities
to the extent permitted by law and in compliance
with the rules of the New York Stock Exchange and
the SEC relating to such matters.
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Legal Proceedings and Corporate Actions
Generally, neither Baird nor any Other Manager
responsible for managing all or a portion of the
assets in a client’s Account will render advice or
take action on a client’s behalf with respect to
securities that are or were held in the client’s
Account, or the issuers thereof, which go into
default or become the subject of legal proceedings,
such as class action claims, defaults or
bankruptcies. Also, they may or may not vote or
advise clients on other corporate actions, like
tender offers, that are not solicited by a proxy
statement. At a client’s request, Baird will forward
information that Baird actually receives to the
client.
found
Additional Information
Disciplinary Information
In April 2016, Baird, without admitting or denying
the findings, consented to the sanctions and
findings of the Financial Industry Regulatory
Authority, Inc. (“FINRA”) that it violated NASD
Conduct Rule 3010, FINRA Rule 3110, and FINRA
Rule 2010, by failing to establish and maintain a
supervisory system and procedures reasonably
designed to ensure that customers who purchased
mutual fund shares received the benefit of
applicable sales charge waivers. In May 2015,
Baird began a review to determine whether Baird
had provided available sales charge waivers to
eligible customers. Based on this review, in May
2015, Baird self-reported to FINRA that various
eligible customers had not received available sales
charge waivers. Baird was
to have
retirement plan and
disadvantaged certain
charitable organization customers
that were
eligible to purchase Class A shares in certain
mutual funds without a front-end sales charge. The
findings also stated that these customers were
instead sold Class A shares with a front-end sales
charge or Class B or C shares with higher ongoing
fees and the potential application of a contingent
deferred sales charge. Baird was censured and
required to pay restitution to affected customers
estimated to be approximately $2.1 million
including interest.
Client Information Provided to
Portfolio Managers
Under the Baird Affiliated Managers Program, Baird
Recommended Managers Program, Baird SMA
Network Program, and Dual Contract Program, and
UMA Programs, Baird provides certain information
about the client to the investment managers
managing the client’s Account (which may include
the Overlay Manager or an Implementation
Manager) when the client establishes the advisory
relationship with such managers. Such information
includes the client’s investment objectives and risk
tolerance and tax lot information for the applicable
Account assets. Under the Baird Recommended
Managers Program and Baird SMA Network
Program, Baird also provides to the investment
manager a client’s age, investment timeframe, and
liquidity requirements.
Unless specifically requested to do so by a client,
Baird does not generally provide such information
about the client on an ongoing basis to the
investment manager managing
the client’s
Account.
Baird also generally provides the following to the
client’s manager unless otherwise instructed by a
client: trade confirmations, account statements,
and access to client’s Account on Baird’s system.
Client Contact with Portfolio Managers
Baird does not place any restrictions upon clients
who wish to contact or consult with Other
Managers managing
their accounts. Baird
encourages clients to discuss their accounts with
their Baird Financial Advisor.
In July 2016, Baird, without admitting or denying
the findings, consented to the sanctions and to the
entry of findings of FINRA that the firm and a firm
supervisor within its Private Wealth Management
business did not reasonably supervise a former
Financial Advisor who misused a customer’s funds.
The findings stated that the supervisor did not
reasonably follow-up on red flags associated with a
trade correction request submitted by the Financial
Advisor that should have alerted him to the
Financial Advisor's misuse of a customer’s funds.
The supervisor also did not follow certain of Baird’s
written supervisory procedures (“WSPs”) relating
to trade corrections. After the supervisor realized
that the Financial Advisor misused the customer’s
funds, Baird reimbursed the customer for the loss.
The findings also included that Baird 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. Baird was censured and fined $200,000.
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the
fees and/or
the conflict of
fees
for
Disclosure
website
bought for or recommended to their investment
advisory 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 advisory clients, and the investment advisory
firms did not adequately disclose their receipt of
12b-1
interest
associated with those 12b-1 paying share classes.
Baird and many other firms self-reported under the
program and entered into substantially identical
orders. By self-reporting and consenting to the
order, Baird agreed to a censure and to cease and
desist from committing or causing any violations
and future violations of Sections 206(2) and 207 of
the Advisers Act. Baird also agreed to establish a
distribution fund and to deposit into that fund the
improperly disclosed 12b-1 fees received by Baird
plus prejudgment interest, which will be paid to
affected advisory clients. More information about
the order is contained in Baird’s Form ADV, which
is available on the SEC’s Investment Advisory
Public
at
https://www.adviserinfo.sec.gov/IAPD/Default.as
px or in the SEC’s press release about the SCSD
Initiative at https://www.sec.gov/news/press-
release/2019-28.
In September 2016, the SEC announced that Baird,
without admitting or denying
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
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. Baird also was ordered to cease
and desist committing or causing any violations
and any future violations of Section 206(4) of the
Advisers Act and Rule 206(4)-7 thereunder and
pay a civil money penalty in the amount of
$250,000.
In June 2019, Baird, without admitting or denying
the findings, consented to the sanctions and to the
entry of findings of FINRA that between late April
2013 and early July 2013 it published 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 and that the failure to disclose the
research analyst’s employment discussions with
the issuer in the research reports made those
reports misleading. Baird was censured and fined
$150,000.
the program,
it
charged
reasonably designed
In March 2019, Baird, without admitting or denying
the findings, consented to an order of the SEC,
which found that it violated Sections 206(2) and
207 of the Advisers Act for making inadequate
disclosures to advisory clients about mutual fund
share classes. The order was part of a voluntary
self-reporting program initiated by the SEC called
the “Share Class Selection Disclosure (or SCSD)
Initiative.” Under
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 settlement terms imposed by the SEC, including
returning money to affected investment advisory
clients. The central issue identified by the SEC was
that, in many cases, investment advisory firms
In August 2022, Baird, without admitting or
denying the findings, consented to the entry of
findings of FINRA, which found that it charged
certain brokerage customers an unfair commission
when
its published minimum
commission amount of $100 on 7,277 retail equity
trades and failed to establish and maintain a
supervisory system
to
prevent charging a customer a commission that is
unreasonable or unfair in violation of FINRA Rules
3110, 2121, and 2010. Baird also consented to a
censure, a fine in the amount of $150,000, and the
payment of restitution of $266,481 plus interest.
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findings
related
to
FINRA’s
to
review of Baird’s policies and procedures, training,
surveillance program, technology solutions and
similar matters
off-channel
related
communications.
The
routine
examination of Baird in 2020. Following that
examination, Baird modified
its minimum
commission schedule and supervisory procedures.
Baird also took steps to make payments to the
affected customers, which on average amounted 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.
its
In March 2026, Baird entered into an Offer of
Settlement with the Massachusetts Securities
Division to settle a regulatory matter relating to the
timing of state investment adviser representative
registration approvals for two of Baird’s Financial
Advisors located in Massachusetts. The Division
alleged that, for a limited period in early 2025, the
two individuals provided investment advisory
services before their Massachusetts registrations
were completed as a form was missing from their
application materials. 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.
Additional information about Baird’s disciplinary
history is available on the SEC’s website at
www.adviserinfo.sec.gov.
other
Other Financial Industry Activities and
Affiliations
Baird’s Broker-Dealer Activities
including
including
implementing
a
Baird PWM offers brokerage accounts and related
services to its clients. Baird is also engaged in a
broad range of broker-dealer activities through
other business units,
its Global
Investment Banking, Fixed Income Capital Markets
(including Baird Public Finance) and Institutional
Equities and Research Departments. Certain Baird
associates and certain management persons of
Baird are registered, or have an application
pending to register, as registered representatives
and associated persons of Baird to the extent
necessary or appropriate to perform their job
responsibilities.
Certain Relationships and Arrangements
Baird and Associated Parties
including
including
Baird PWM has relationships or arrangements with
other Baird businesses units and the Associated
referral
Parties described below,
programs that pay special compensation to Baird
Financial Advisors for eligible referrals. Additional
information about
referral programs,
those
including the amount of the referral compensation,
at
is
disclosed
on
Baird’s
website
In September 2023, Baird entered into an Offer of
Settlement with the SEC, 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
business-related
associates’
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
off-channel
and
instant messages
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. While
Baird had policies and procedures in place
prohibiting such off-channel communications, 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, and the findings were reported to the
SEC. Baird took steps prior to and after the SEC’s
review,
new
communication tool designed for Baird associates’
training, and
personal devices, conducting
to
periodically requiring requisite associates
provide an attestation relating to their business-
related communications. 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
retaining an
certain undertakings,
independent compliance consultant to conduct a
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
engaging
Trust
for
indirectly wholly owned by BFG. Baird and Baird
Financial Advisors receive compensation from
Baird Trust for referring clients and providing
ongoing relationship management services to
clients
trust
Baird
administration services as described under the
heading “Services, Fees and Compensation—
Additional Program Information—Trust Services
Arrangements” above.
Baird Capital
bairdwealth.com/retailinvestor.
These
relationships or arrangements present a conflict of
interest because they provide a financial incentive
to Baird and Baird Financial Advisors to use, select
or recommend the investment products and
services of Baird and Associated Parties over those
of unassociated parties and those that pay the
greatest level of compensation. Baird addresses
this potential conflict through disclosure in this
Brochure. Further, when acting as fiduciaries, Baird
and Baird Financial Advisors are required to select
or recommend investment products only when
they determine it to be in the client’s best interest
to do so.
Baird is engaged in a global private equity business
through Baird Capital (“Baird Capital”). Baird and
Baird Financial Advisors may refer clients to Baird
Capital. Baird Financial Advisors who assist in
obtaining a client’s investment in a private equity
fund offered through Baird Capital are eligible for
referral compensation.
website
located
Baird has a financial incentive to the extent it would
recommend that a client invest in a portfolio
company owned by a Baird Capital private equity
fund. A list of the portfolio companies held by Baird
Capital private equity funds is located on Baird
Capital’s
at
https://www.bairdcapital.com/portfolio/baird-
capital-portfolio.aspx.
Baird Asset Management
Baird’s Asset Management business, Baird
Advisors, Baird Equity Asset Management, and
Chautauqua Capital Management (“CCM”), part of
Baird Equity Asset Management,
provide
investment management services to institutional
clients and Funds. Baird Financial Advisors who
refer clients to Baird Asset Management are eligible
for referral compensation to be paid by Baird. Baird
Financial Advisors, therefore, have a financial
incentive to favor the services provided by Baird
Asset Management over those provided by other
managers.
Baird Funds
Baird Global Investment Banking
Baird Institutional Equities and Research
Baird Public Finance
its Global
municipal
advisory,
Through
Investment Banking,
Institutional Equities and Research, and Public
Finance Businesses, Baird provides investment
securities
banking,
underwriting, stock buyback and related services
to various corporate, municipal, and other issuers
of securities. Baird receives compensation from
such issuers in connection with the services it
provides, and the success of its services generally
depends upon Baird’s ability to sell the securities
of such issuers. Baird may, therefore, have an
incentive to favor the securities of issuers for which
Baird provides such services over the securities of
issuers for which Baird does not provide such
services.
Baird is the investment adviser and principal
underwriter for Baird Funds, Inc. (the “Baird
Funds”). Baird Advisors provides
investment
management, administrative, and other services to
certain Baird Funds investing primarily in fixed
income securities (the “Baird Bond Funds”). Baird
Equity Asset Management and CCM provide
investment management and other services to
certain Baird Funds investing primarily in equity
securities (the “Baird Equity Funds”), and
Greenhouse Funds LLLP, a party related to Baird,
is the investment subadvisor to one of those Funds,
the Baird Equity Opportunity Fund. In certain
instances, Baird Financial Advisors who refer
clients to the Baird Funds are eligible for referral
compensation to be paid by Baird. Due to the
amount of referral compensation, Baird Financial
Advisors have a financial incentive to favor the
Baird Equity Funds over the Baird Bond Funds.
Investment Banking
Baird Trust
Baird is affiliated, and may be deemed to be under
common control, with Baird Trust, a Kentucky-
chartered trust company, because both entities are
A Baird Financial Advisor who refers a client to
for a possible
Baird
transaction in which Baird Investment Banking
earns a financial advisory or underwriting fee
receives a portion of such fee. A Baird Financial
Advisor who refers a client to Baird Public Finance
for a municipal advisory or underwriting
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opportunity receives a portion of the compensation
earned by Baird Public Finance on that opportunity.
Baird and Baird Financial Advisors thus have an
incentive to recommend the securities issued in
those offerings. A Baird Financial Advisor who
refers a corporation to Baird’s Institutional Equities
business for a stock buy-back program receives a
portion of the commissions earned by Baird’s
Institutional Equities business. Baird and its
Financial Advisors may, therefore, have an
incentive to buy, and to recommend that clients
sell, the securities of issuers that are part of Baird’s
buyback services.
Sagard
Party).
Baird
considers
Certain Associated Parties are associated with
Baird because BFC, Baird’s parent corporation,
owns some or all of the Associated Parties’ voting
securities. BFC’s parent corporation (and Baird’s
ultimate parent corporation), BFG, may be deemed
to indirectly own or control such voting securities.
Baird is deemed to be under common control and
“affiliated” with an Associated Party when BFG
indirectly owns or controls 25% or more of such
Associated Party’s voting securities (or of an entity
deemed to control such Associated Party). Baird
considers itself “related” to an Associated Party
when BFG indirectly owns or controls at least 10%
but less than 25% of such Associated Party’s voting
securities (or of an entity deemed to control such
Associated
itself
“associated” with an Associated Party when certain
other relationships or other arrangements exist
between Baird and such Associated Party that
might present a conflict of interest with clients.
Baird’s direct parent corporation, BFC, has a
minority ownership interest (about 5%) in Sagard
Holdings Management, Inc. (“Sagard”) and the
right to appoint a member to Sagard’s board of
directors, which is currently a management person
of Baird. Baird has agreed to use best efforts, to
the extent consistent with its fiduciary duties, best
interest obligations, and other
regulatory
responsibilities, to offer to clients investment
products managed by affiliates of Sagard. Baird
has an incentive to do so because not reaching
minimum thresholds would give Sagard a right to
redeem BFC’s ownership interest in Sagard and
reaching significant thresholds would give BFC the
right to increase its ownership interest. Baird
Financial Advisors do not receive any additional
compensation for recommending Sagard-affiliated
investment products. Additional
information
identifying Sagard-affiliated investment products
will be provided to clients prior to investment.
An Associated Party receives fees or other
compensation for investment advisory or other
services that it provides to an Associated Fund. The
amount of fees and other compensation paid by an
Associated Fund to an Associated Party is disclosed
in the Associated Fund’s prospectus or other
offering document. An Associated Party also
receives fees from a client for services that it
provides related to the client’s Associated SMA
Strategy. Information about the amount of fees
paid to an Associated Party with respect to an SMA
Strategy is contained in the applicable Baird Form
ADV Part 2A Brochure, the applicable Program
Account Schedule, or in some instances, the
client’s contract with the Associated Party.
55ip
55I, LLC (d/b/a 55ip, “55ip”) uses research and
other services from Riverfront, an affiliate of Baird,
in the development of its portfolios under the BSN
Program, and Riverfront receives compensation
from 55ip with respect to those portfolios. Due to
its affiliation with Riverfront, Baird has a financial
favor 55ip portfolios that use
incentive to
Riverfront services.
Associated Investment Products and
Services
interest over
Baird and Baird Financial Advisors may select or
recommend Associated Investment Products and
Services, including the Associated Funds and
Associated SMA Strategies, listed in Appendix A to
this Brochure.
Baird and Baird Financial Advisors have a financial
incentive to use, select or recommend Associated
Investment Products and Services because Baird
and BFG benefit financially if a client utilizes those
investment products and services rather than
unassociated investment products and services,
and Baird Financial Advisors benefit financially
from the overall success of Baird and BFG.
Similarly, Baird and Baird Financial Advisors also
generally have a financial incentive to favor the
investment products and services of Baird over
Associated Parties and to favor those of Associated
Parties in which BFG has a materially greater
indirect ownership
those of
Associated Parties in which BFG has a materially
lesser indirect ownership interest. Baird addresses
this potential conflict through disclosure in this
Brochure. Further, when acting as fiduciaries, Baird
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clients and the interests of Baird and its affiliates
and associates.
and its Financial Advisors are required to select or
recommend investment products only when they
determine it to be in the client’s best interest to do
so. The criteria used by them in deciding to select
or recommend Associated Investment Products are
generally the same as those used for unassociated
investment products. However, a client should note
that certain Programs and certain categories of
investment
investment products only offer
products and services of Associated Parties. In
those cases, Baird and Baird Financial Advisors do
not impose the same criteria or level of review.
Relationships and Arrangements with
Investment Managers
managers,
including
in which Baird clients
appropriate
deemed
or
by
Baird’s
advisory
selecting
To address the potential for conflicts of interest,
Baird has adopted a Code of Ethics (the “Code”)
that applies to
its associates that provide
investment advisory services to clients, including
Baird Financial Advisors, their supervisors, and
certain associates who have access to non-public
information relating to advisory client accounts
(“Access Persons”). The Code prohibits Access
Persons from using knowledge about advisory
client account transactions to profit personally,
directly, or indirectly, by trading in his or her
personal accounts. The Code also generally
prohibits Access Persons from executing a security
transaction for their personal accounts during a
blackout period one business day before or after
the date that a client transaction in that same
security is executed. The Code provides for certain
by Baird
exceptions
Compliance
management
Department. In addition, orders for the accounts of
Access Persons and other Baird associates that are
under discretionary management by Baird may be
aggregated with orders for other Baird client
accounts, so long as the order is executed as part
of a block transaction with client orders. A copy of
the Code is available to clients or prospective
clients upon request.
investment manager or
Investment
those
participating in the Programs, may select Baird, in
its capacity as a broker-dealer, to execute portfolio
trades for their clients, including for Funds they
advise and
invest.
Investment managers may also select Baird to
provide custody, research or other services. Baird
receives compensation for those services. This may
create an incentive for Baird to favor the
investment products and services of such
is a
investment managers. However, Baird
fiduciary that is required to act in the best interest
of
or
clients when
recommending investment managers or their
investment products and services to such clients.
Baird addresses this potential conflict through
disclosure in this Brochure. Baird does not consider
the extent to which an investment manager directs
or is expected to direct trading, custody or
research services to Baird when considering the
its
eligibility of an
investment products or services for the Programs.
Baird has also implemented certain policies and
procedures relating to Baird’s and its associates’
trading activities that are designed to prevent them
from improperly benefiting from the trading
activities of Baird’s advisory clients. In addition,
Baird’s Compliance Department monitors the
personal trading activities of all of Baird’s
associates providing advisory-related services to
clients.
Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
Code of Ethics
Participation or Interest in Client
Transactions
Investment Advisory Accounts
Subject to the restrictions described below, Baird
and its affiliates and associates may engage in
securities transactions for their own accounts,
including the same or related securities that are
recommended to or owned by Baird clients. These
transactions may include trading in securities in a
manner that differs from, or is inconsistent with,
the advice given to Baird clients, and the
transactions may occur at or about the same time
that such securities are recommended to or are
purchased or sold for client accounts. This creates
a potential for a conflict between the interest of
Asset-based Program Fee arrangements create an
incentive for Baird and Baird Financial Advisors to
set the applicable fee rate at a high level and to
encourage clients to add more money into their
accounts. Baird and Baird Financial Advisors also
have an incentive to recommend an investment
advisory account to a client rather than a
brokerage account if the client has, or is expected
to have, lower levels of trading activity in the
client’s account. Select clients may pay a fixed
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Financial Advisors an incentive to recommend or
refer clients to those Associated Parties and to
recommend that a client participate in the
Securities-Based Lending Program. For more
information about referral compensation paid to
Baird Financial Advisors and related conflicts of
interest, please see “Baird Referral Programs” on
Baird’s website at bairdwealth.com/retailinvestor.
dollar fee, which presents a conflict in that such fee
does not give the Baird Financial Advisor an
incentive to make recommendations that could
benefit the client’s account, or a performance or
incentive fee, which presents a conflict because it
gives the Baird Financial Advisor an incentive to
recommend riskier investments in order to achieve
the level of performance in the account that would
result in payment of the fee.
Ongoing Product Fees
receives ongoing
fees
Baird also periodically provides special incentives
to Baird Financial Advisors to recommend advisory
products and services to clients and to recommend
that clients put more assets into their Accounts.
Accounts and Investments Provide Different
Levels of Compensation
Baird
from certain
investment products that are purchased and held
in client Accounts. Those fees, such as distribution
(12b-1) and/or service fees (“12b-1 fees”) from
mutual funds, are based on the value of client
assets invested in those products. A Baird Financial
Advisor’s compensation increases as those fees
increase. Thus, Baird and Baird Financial Advisors
have an incentive to use, select or recommend
such products and to recommend such products
that pay the greatest ongoing fees.
The types of accounts and investment products
offered to clients provide Baird and Baird Financial
Advisors different levels of compensation. Baird
and Baird Financial Advisors have an incentive to
from client accounts by
generate revenues
selecting and recommending account types and
investment products that will provide them the
greatest level of compensation.
Certain mutual funds charge 12b-1 fees, which are
paid to Baird. Baird receives 12b-1 fees on an
ongoing basis as compensation for the services
Baird provides to the applicable mutual fund. The
12b-1 fees paid by a mutual fund are disclosed in
the mutual fund’s prospectus.
Recommendations of Associated Investment
Products and Services
Arrangements—Associated
Baird and Baird Financial Advisors have an
incentive to use, select or recommend the
investment products and services of Associated
Parties because they will benefit financially. See
“Additional Information—Other Financial Industry
Activities and Affiliations—Certain Relationships
Investment
and
Products and Services” above and “Certain Parties
Associated with Baird” on Baird’s website at
bairdwealth.com/retailinvestor.
Referral Compensation Paid to Baird Financial
Advisors
Parties
described
Baird generally does not allow mutual funds with
12b-1 fees to be purchased for Program Accounts.
If Baird receives 12b-1 fees from a fund with
respect to a client’s mutual fund investment in the
client’s Account and the client’s Account is subject
to an asset-based fee arrangement, Baird either:
(1) rebates such 12b-1 fees to the client’s Account
if the client is paying an asset-based Program Fee
on such investment; or (2) excludes such fund
shares from the calculation of the client’s asset-
based Program Fee (sometimes referred to as
“unbillable assets”) for such period of time that
Baird collects and retains the 12b-1 fee. 12b-1 fees
rebated to a client’s Account are estimated based
on the average daily balance of the mutual fund
shares in the Account and the annual rate of the
12b-1 fee paid by the applicable fund. If any
rebated fees remain in a client’s Account at the
time of billing, those rebated amounts will be
included in the Account assets subject to the
Program Fee.
If Baird receives 12b-1 fees with respect to mutual
fund shares that are designated as unbillable
assets in a client’s Account, Baird will retain such
Baird Financial Advisors
receive additional
compensation for referring clients to certain
above. See
Associated
“Additional Information—Other Financial Industry
Activities and Affiliations—Certain Relationships
and Arrangements—Baird and Associated Parties”
above. Baird Financial Advisors also receive
additional compensation for referring clients to
unaffiliated banks that make loans to clients under
Baird’s Securities-Based Lending Program. See
“Services, Fees and Compensation—Additional
Program Information—Securities-Based Lending
Program” above. Such compensation gives Baird
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
for
does not share these payments with Baird Financial
Advisors. Please see “Revenue Sharing/Marketing
Support and Other Third Party Payments” at
more
bairdwealth.com/retailinvestor
information.
internal policies
that
limit
Schwab Clearing Arrangement
under which mutual
12b-1 fees. This presents a conflict of interest
because it provides Baird and its Financial Advisors
an incentive to use, select or recommend mutual
fund shares that pay greater 12b-1 fees. Baird
addresses this conflict by adopting a Mutual Fund
Share Class Policy described above and by
the
adopting
circumstances
fund
investments in client accounts can be designated
as unbillable assets and 12b-1 fees can be
retained.
Marketing Support and Revenue Sharing from
Mutual Fund and UIT Sponsors
Baird has a clearing arrangement with Charles
Schwab & Co., Inc. (“Schwab”) whereby Schwab
maintains an omnibus account with certain mutual
fund families for Baird on behalf of Baird clients.
Under the clearing arrangement, Schwab provides
clearing services for most “no load” funds and
“load” funds held by Baird clients. Although Baird
pays Schwab a fee for its clearing and omnibus
services, Schwab generally passes through to Baird
fees that Schwab
the shareholder servicing
receives from the funds. Shareholder servicing fees
are not paid by Schwab on mutual fund assets held
in Retirement Accounts to the extent prohibited by
applicable law. The amount of the shareholder
servicing fees paid to Baird is based on the value
of the client assets invested in those funds.
However, the shareholder servicing fee rate varies
based on the type of fund (load or no load), the
value of client assets in those funds, and the
relationship that Schwab has with those funds
(whether or not Schwab receives payments from
those funds or their sponsors, and the rates of such
payments). As a result, Baird has an incentive to
use, select or recommend mutual funds from which
Baird would receive higher payments from Schwab.
However, Baird generally does not compensate
Baird Financial Advisors based upon the amounts
Baird receives from Schwab except with respect to
amounts attributable to sales loads and 12b-1 fees
that Baird would otherwise receive directly from a
fund if it were not for the existence of the clearing
arrangement with Schwab. If Baird receives 12b-1
fees from Schwab with respect to a mutual fund
investment in a client’s Account, Baird rebates or
retains such fees as further described under the
heading “Ongoing Product Fees” above.
Baird Conference Sponsorships
Trust
Portfolios
and
Baird receives marketing support or revenue
sharing payments (“marketing support”) from the
sponsors and investment advisers of certain
mutual funds. These payments, which are based on
sales of, or client assets invested in, such funds,
are intended to compensate Baird for providing
marketing, distribution and other services for the
mutual funds. Marketing support is not paid by
sponsors or investment advisers of mutual funds
on mutual fund assets held in investment advisory
Retirement Accounts to the extent prohibited by
applicable law. Baird received marketing support
payments over the past two calendar years from
the sponsors or investment advisers of Alliance
Bernstein Funds, American Funds, Franklin
Templeton Funds, Goldman Sachs Funds, Hartford
Funds, Invesco Funds, John Hancock Funds,
JPMorgan Funds, Lord Abbett Funds, MFS Funds,
PIMCO Funds and Principal Funds. Baird also
generally receives marketing support related to the
sale of units of UITs. Sponsors of UITs typically
make marketing or concession payments to the
firms that sell their UITs, including Baird. These
payments are typically calculated as a percentage
of the total volume of sales of the sponsor’s UITs
made by the firm during a particular period. That
percentage typically increases as higher sales
volume levels are achieved. Descriptions of these
additional payments are provided in a UIT’s
prospectus. UIT sponsors that have paid volume
concessions to Baird over the past two calendar
years include Advisors Asset Management (AAM),
First
Guggenheim
Investments. Receipt of marketing support
payments from sponsors and investment advisers
of mutual funds and UITs provides Baird an
incentive to use, select and recommend such
mutual funds and UITs and to favor mutual funds
and UITs with sponsors or investment advisers that
make the greatest levels of such payments. Baird
Baird hosts a number of seminars and conferences
for Baird Financial Advisors in any given year,
including Baird’s PWM Symposium, which gives
sponsors of investment products, such as mutual
funds, the opportunity to make presentations at,
and contribute money toward the cost of, such
seminars and conferences. This presents a conflict
of interest in that it gives Baird an incentive to
promote or market the sponsors’ investment
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Third
Payments”
for
products in order to persuade them to continue
supporting Baird seminars and conferences. Please
see “Revenue Sharing/Marketing Support and
at
Party
Other
bairdwealth.com/retailinvestor
more
information.
arrangements that involve Baird and the Baird
Financial Advisor providing investment advisory
services to the client and Baird Trust only providing
trust administration services because it is more
profitable for them. Please see “Services, Fees and
Compensation—Additional Program Information—
Trust Services Arrangements” above for more
detailed information.
Baird Financial Advisors Receive Benefits from
Product Providers
Margin Loans
Baird has an incentive to recommend that a client
use margin because Baird receives interest on
client margin loans, and Baird and Baird Financial
Advisors also have an incentive to recommend that
a client use margin, because a margin loan allows
the client to make larger and more securities
purchases. It also increases the value of a client’s
Account and thus the Program Fee associated with
that Account because the margin loan is not
deducted for purposes of calculating the fee. Please
see “Services, Fees and Compensation—Additional
Program Information—Margin Loans” above for
more detailed information.
Securities-Based Lending Program
Third
Compensation—Additional
Payments”
for
Baird Financial Advisors generally receive non-cash
compensation and other benefits from Baird and
from sponsors of investment products with which
Baird does business. Such non-cash compensation
and other benefits may include invitations to
attend conferences or educational seminars,
payment of related travel, lodging and meal
expenses, and receipt of gifts and entertainment.
For example, Baird Financial Advisors are invited to
educational conferences hosted by sponsors of
mutual funds, annuities and other investment
products, with the costs associated with such
conference (including travel and lodging) paid by
the sponsors. In addition, Baird Financial Advisors
hold client events with some or all of the costs of
such events paid by sponsors of investment
products. Product sponsors may also provide gifts
and entertainment in connection with those or
other events. These benefits present a conflict of
interest in that they give Baird Financial Advisors
an
incentive to use, select or recommend
investment products and their sponsors that
provide the greatest levels of such benefits. Please
see “Revenue Sharing/Marketing Support and
at
Other
Party
bairdwealth.com/retailinvestor
more
information.
Baird and Baird Financial Advisors have an
incentive to recommend that a client participate in
Baird’s Securities-Based Lending Program because
Baird and Baird Financial Advisors receive referral
compensation and such loans allow a client to keep
more assets in the client’s Accounts, which result
in more advisory fees for us and paid to the client’s
Baird Financial Advisor. Please see “Services, Fees
and
Program
Information—Securities-Based Lending Program”
above for more detailed information.
Cash Sweep Program
Investment Advisory and Brokerage Account and
Service Recommendations
revenue
the
revenues Baird earns, and
Baird has an incentive to have clients participate
and maintain significant balances in Baird’s Cash
Sweep Program because Baird receives substantial
compensation on client cash balances that are
automatically swept into bank deposit accounts
and invested in money market mutual funds under
the program. Please see “Services, Fees and
Compensation—Additional Program Information—
Cash Sweep Program” above for more detailed
information.
Trust Services Arrangements
Advisor
receive
Baird and Baird Financial Advisors have an
incentive to recommend that a client retain Baird
Trust for the client’s trust services needs rather
than an unassociated firm and to recommend
Baird and Baird Financial Advisors generally have a
financial incentive to recommend investment
advisory Accounts to clients rather than brokerage
accounts because Program Fee
is
recurring, more predictable and typically greater
than
the
compensation Baird Financial Advisors receive,
from brokerage accounts. In addition, because
Program Fees are paid by a client regardless of the
trade activity in the client’s advisory Account, Baird
will receive greater revenue, and the client’s Baird
Financial
greater
will
compensation, from a low trade-activity advisory
Account than from a low trade-activity brokerage
account. Baird and Baird Financial Advisors thus
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a
financial
incentive
financial
with
Baird,
even
if
have an incentive to recommend an investment
advisory Account to a client rather than a
brokerage account if the client has, or is expected
to have, lower levels of trading activity in the
client’s account. However, because Baird’s
revenues and the compensation paid to Baird
Financial Advisors
from brokerage accounts
increase as the level of trading increases, Baird and
Baird Financial Advisors have an incentive to
recommend a brokerage account to a client rather
than an investment advisory Account if the client
has, or is expected to have, significant trading
activity in the client’s account. Baird Financial
Advisors also have a
incentive to
recommend certain wealth management services,
such as financial planning. Please see “Services,
Fees and Compensation—Program Fees—Program
Fee Payments to Baird, Financial Advisors and
Investment Managers” above for more detailed
information.
Account Transfers and New Accounts
Baird Financial Advisor thus has an incentive to
make recommendations that increase the Financial
Advisor’s total production on the client’s accounts
with Baird. Moreover, revenues from Baird’s PWM
department, in which Baird Financial Advisors
operate, contribute substantially to BFG’s overall
revenues and profitability, and the performance of
BFG’s stock price is largely due to the profitability
of Baird’s PWM department. As a result, a client’s
Baird Financial Advisor’s ownership of BFG stock
creates
to make
recommendations to the client that increase the
amount of revenues generated from the client’s
accounts
those
recommendations will not increase the Baird
Financial Advisor’s production, so as to increase
the revenues and profitability of Baird’s PWM
department and thus of BFG, which will serve to
grow the value of the BFG stock. For example,
ownership of BFG stock, the performance of which
is impacted by the success of Associated Parties,
provides a client’s Baird Financial Advisor an
incentive to use, select or recommend Associated
Investment Products and Services to a client even
though such recommendation does not increase
the client’s Baird Financial Advisor’s production.
Other Client Relationships
Baird and a client’s Baird Financial Advisor have an
incentive to recommend that the client transfer the
client’s accounts to Baird and establish new
accounts with Baird (including IRA rollovers)
because doing so will result in increased revenues
to Baird and compensation for the Baird Financial
Advisor.
Recommendations to Open Different Types of
Accounts
Certain client accounts overseen by Baird and Baird
Financial Advisors may have similar investment
objectives and strategies but may be subject to
different fee schedules or commission rates. Thus,
Baird and its Financial Advisors have an incentive
to favor client accounts that generate a higher level
of compensation.
Relationships with Issuers of Securities
in companies or
Baird and Baird Financial Advisors have an
incentive to recommend that a client open different
types of accounts with Baird, such as individual
accounts, IRA rollovers, joint accounts, 529 plan
accounts and UGMA/UTMA accounts, because if a
client has different types of accounts with Baird,
the client brings more of the client’s investable
assets to Baird, on which fees can be generated,
thereby increasing Baird’s revenues and the
client’s Baird Financial Advisor’s compensation.
Also, if a client has more account types with Baird,
the client is statistically more likely to maintain the
client’s relationship with Baird and the client’s
Baird Financial Advisor for longer periods of time.
Baird Stock Ownership
From time to time, Baird may have proprietary
investments
issuers whose
securities are offered and sold to clients, a Baird
Financial Advisor or another Baird associate may
have significant investments in companies or
issuers whose securities are offered and sold to
clients, or a Baird Financial Advisor or another
other Baird associate (or their spouses, partners or
family members) may have a position as an officer
or director of a company or issuer whose securities
are offered and sold to clients. In such cases, Baird
and/or a client’s Baird Financial Advisor will have
an incentive to recommend that the client invest in
those companies.
Most Baird Financial Advisors own common stock
of BFG, Baird’s ultimate parent, and when offered
the opportunity to buy BFG stock they usually do
so. The amount of BFG stock that a Financial
Advisor may purchase is based in part on the
Financial Advisor’s total production level. A client’s
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Baird Financial Advisors Transferring to Baird
for their past business or to generate future
business.
Trade Error Correction
A Baird Financial Advisor joining Baird from
another firm has an incentive to recommend that a
client to transfer the client’s accounts from such
firm to Baird because doing so will increase the
Baird Financial Advisor’s compensation. Please see
“Services, Fees and Compensation—Program
Fees—Program Fee Payments to Baird, Financial
Advisors and Investment Managers” above for
more detailed information.
Principal Trading
It is Baird’s policy that a client’s account will be
fully compensated for any losses incurred as a
result of a trade error for which Baird is
responsible. If the trade error results in a gain, the
gain may be retained by Baird. For more
information, please see “Services, Fees and
Compensation—Additional Program Information—
Trading
for Client Accounts—Baird’s Trading
Practices—Trade Error Correction” above.
Baird’s Other Broker-Dealer and Related Activities
the compensation
they
The investment advice provided to a client may be
based on the research opinions of Baird’s research
departments. Baird does, and seeks to do,
business with companies covered by
those
research departments and as a result, Baird may
have a conflict of interest that could affect the
content of its research reports.
Baird and Baird Financial Advisors have an
incentive to execute a trade for a client on a
principal basis. The compensation that Baird and
Baird Financial Advisors receive on principal trades,
such as a markup or markdown, is often higher
than
receive when
executing trades as agent, such as commissions.
The compensation received by Baird and Baird
Financial Advisors is in addition to the asset-based
Program Fee a client pays on the client’s advisory
Accounts. Thus, Baird and Baird Financial Advisors
have an incentive to trade as principal rather than
as agent. Principal trades also allow Baird to sell
securities from Baird’s account that Baird deems
undesirable and to buy securities for Baird’s
account that Baird deems desirable. For more
information, please see “Services, Fees and
Compensation—Additional Program Information—
Trading for Client Accounts—Trade Execution
Services Performed by Baird—Principal Trades”
above.
Baird Underwritten Offerings
Information—Trading
for
Baird and its Associated Parties and associates may
buy or sell investments that are recommended to
or owned by a client for their own accounts, or they
may act as broker or agent for other clients buying
or selling those investments. Those transactions
may include buying or selling investments in a
manner that differs from, or is inconsistent with,
the advice given to a client, and those transactions
may occur at or about the same time that such
investments are recommended to or are purchased
or sold for a client’s account. Baird may also
engage in agency cross transactions and principal
transactions with clients as further described under
“Services, Fees and Compensation—Additional
Program
Client
Accounts—Trade Execution Services Performed by
Baird” above.
Institutional
Equities
and
Baird and Baird Financial Advisors have an
incentive to recommend that clients purchase
securities in offerings underwritten by Baird
because the underwriting compensation that Baird
and Baird Financial Advisors will earn on those
offerings tends to be higher than the compensation
they would normally receive if clients were to buy
them in the secondary market, and because the
profitability of underwritten offerings to Baird
depends upon Baird’s ability to sell the securities
allocated to Baird in the offering.
to
Allocations of IPOs and Other Public Offerings
Baird and Baird Financial Advisors have an
incentive to favor the securities of issuers for which
Baird’s Global Investment Banking, Fixed Income
Capital Markets (including Baird Public Finance)
Research
and
Departments provide services due
the
compensation received by Baird and Baird Financial
Information—Other
Advisors. See “Additional
Financial Industry Activities and Affiliations—
Certain Relationships and Arrangements—Baird
and Associated Parties” above.
Baird Financial Advisors have the incentive to favor
some clients over other clients when allocating
shares issued in public offerings, particularly those
clients with larger accounts or accounts that
generate high fees and compensation, as a reward
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Account. Baird’s other activities thus present a
potential conflict of interest because such activities
may limit Baird’s ability to advise or manage client
Accounts.
Other Conflicts of Interest
As a registered broker-dealer, Baird effects
transactions in securities on a national exchange
and may receive and retain compensation for such
services, subject to the limitations and restrictions
made applicable to such transactions by Section
11(a) of the Exchange Act and Rule 11a2-2(T)
thereunder.
A client may choose to hold cash balances in the
client’s eligible accounts as broker-dealer “free
credits.” To the extent a client elects to hold cash
balances as free credits, a client understands that
Baird does not pay interest on such balances and
Baird may benefit from the possession or use in the
ordinary course of its business of any free credit
balances in the client’s accounts, subject to
restrictions imposed by Rule 15c3-3 under the
Exchange Act.
Baird offers to clients other investment products
and services not described in this Brochure. These
investment products and services provide different
levels of compensation to Baird and its Financial
Advisors. Baird and its Financial Advisors have an
incentive to favor those investment products and
level of
that generate a higher
services
compensation than those that generate a lower
level of compensation. For more information about
the other investment products and services offered
by Baird, clients should contact Baird or a Baird
Financial Advisor.
the size of
the order,
automated
Referrals
and
Other sections of this Brochure also describe
instances when Baird and its Financial Advisors
may recommend to clients, and may buy and sell
for client’s Account, securities in which Baird and
its Associated Parties and associates have a
material financial interest or practices that present
a conflict of interest. For more information, please
see “Services, Fees and Compensation—Program
Fees—Program Fee Payments to Baird, Baird
Financial Advisors and Investment Managers” and
“Additional Information—Other Financial Industry
Activities and Affiliations” above, and “Additional
Information—Client
Other
Compensation” below.
Addressing Conflicts
Baird selects securities trade execution venues
based on
trading
characteristics of the security, speed of execution,
likelihood of price improvement, availability of
efficient
transaction processing,
guaranteed automatic execution levels and other
qualitative factors. Baird receives payment or
liquidity rebates on certain options or equity
securities orders
to some venues
routed
(commonly known as “payment for order flow”).
The existence and amount of payments are
dependent upon the size and type of the routed
order. The
source and amount of any
compensation received by Baird in connection with
payment for order flow will be disclosed to the non-
institutional participants in the transaction upon
request. This compensation gives Baird an
incentive to route client orders for securities
transactions to those venues that provide Baird the
greatest levels of compensation, but Baird’s
routing decision is always based upon obtaining
favorable executions for clients rather than the
availability of payment for order flow. Information
about Baird’s order routing practices are available
at:
http://www.rwbaird.com/help/account-
disclosures/routing-equity-orders.aspx.
The foregoing activities could create a conflict of
interest with clients. In addition to the measures
described above, Baird addresses conflicts posed
by those activities through disclosure in this
Brochure, the client’s agreements with Baird, the
Client Relationship Booklet and prospectuses,
offering documents or other disclosure documents
provided or made available to clients. Baird has
also adopted a Code of Ethics and other internal
policies and procedures for Baird and its associates
that:
from
time
• require them to provide investment advice that
is suitable for advisory clients (based upon the
information provided by such clients);
• are designed to ensure that securities allocations
made to discretionary client accounts are made
Baird and its associates, by reason of Baird’s
investment banking or other
broker-dealer,
time acquire
to
activities, may
information deemed confidential, material and
non-public, about corporations or other entities
and their securities. Baird and its associates are
prohibited by applicable law or agreements from
disclosing such information to clients or acting
upon such information with respect to any client
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in a manner such that all such clients receive fair
and equitable treatment over time;
composites of client accounts are generally being
managed in accordance with the manager’s
investment philosophy statement and attempting
to ascertain whether client accounts within each
composite are being treated equitably.
• address Baird’s and its associates’ trading
activities and are designed to prevent them from
improperly benefiting from the trading activities
of Baird’s advisory clients; and
is most suitable
• address and limit cash and non-cash benefits
provided to Baird Financial Advisors by third
parties in an attempt to avoid any question of
propriety or any conduct inconsistent with Baird’s
high standards of ethics.
Duration Compensation Will Be Received
The performance of a client’s PIM Account may be
compared to one or more benchmark indices that
the PIM Manager, in conjunction with a PIM Product
Manager, determines
for
comparison with the portfolio’s investment style or
the Account may be monitored using a risk score
assigned to the Account by Baird based upon
information provided by the client. Baird may at
times change a client’s PIM Account benchmark
index without prior notice to the client.
Account Statements and Performance
Reports
If a client holds any of the investment products
described above, Baird, its Associated Parties and
associates will receive the fees and payments
described above for the duration of the client’s
advisory
In some
relationship with Baird.
circumstances, the receipt of such compensation
may extend beyond a client’s advisory relationship
with Baird if the client continues to hold those
assets at Baird.
If Baird provides transaction execution services to
a client, Baird will generally provide the client with
a monthly brokerage account statement when
activity occurs during that month. Otherwise, Baird
will provide the client with a quarterly statement if
there has not been any intervening monthly
transaction activity.
form at
If Baird, or an Associated Party or associate of
Baird, receives any compensation or benefit
described in this Brochure from or related to a
client’s investment, they will generally retain the
compensation or benefit. Except as otherwise
described above, Baird generally does not rebate
these amounts to a client’s Account or credit the
amount against the Program Fees payable by a
client unless such compensation may not be
retained under applicable law or regulation.
A client’s Baird Financial Advisor will provide the
client with a written report on the client’s Account’s
performance as often as the client and the Financial
Advisor may from time to time mutually agree. PIM
clients generally receive a performance report in
paper or electronic
least annually.
Performance reporting may not be available for
Account assets that are not custodied at Baird.
Baird may change or discontinue performance
reporting to a client at any time for any reason
upon notice.
Review of Accounts
Client Account Review
Advisor
generally
reviews
Client performance reports usually contain a
portfolio valuation and typically show the asset
allocation of the client’s portfolio, changes in a
client’s portfolio, and account performance
compared to a benchmark market index or indices
(such as the S&P 500® Index or the Bloomberg
U.S.
Intermediate Government/Credit Bond
Index). The benchmark may be a blended
benchmark that combines the returns for two or
more indices.
A client should note that past performance does
not indicate or guarantee future results. None of
Baird, its associates or investment managers
the client’s Account promise or
managing
Client accounts are monitored on a periodic basis
by the client’s Financial Advisor and are subject to
review by the Baird Branch Office Manager or PWM
Supervision department supervisor (or his or her
respective designee) responsible for supervising
the client’s Financial Advisor. A client’s Baird
Financial
the
performance of the client’s Account at least
annually. However, the client’s Financial Advisor
may not review the performance of a client’s SMAs
managed by Other Managers under the Baird SMA
Network Program or Dual Contract Program. Baird
has designated individuals who are responsible for
monitoring a client’s PIM Manager or UAS Manager
with respect to the client account’s trading activity,
verifying that the PIM Manager’s or UAS Manager’s
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
guarantee any level of investment returns or that
the client’s investment objective will be achieved.
Account
performance
to
above
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after they
have implemented the Model Portfolio updates for
client accounts managed by them or after they
have otherwise completed trading for those
accounts. As a result, the performance of a Model
Portfolio, as reported by the Model Provider, will
differ, perhaps in a materially negative manner,
from the actual performance realized by Baird
client Accounts pursuing the Model Portfolio
strategy. See “Additional Program Information—
Trading for Client Accounts—Trading Practices of
Investment Managers”
for more
information.
Benchmarks shown in performance reports are for
informational purposes only. Baird’s selection and
use of benchmarks is not a promise or guarantee
that the performance of a client’s Account will meet
or exceed the stated benchmark. When the client
compares
the
performance of a market index, the client should
recognize that a market index merely reflects the
performance of a list of unmanaged securities
included in the index and the index performance
does not take into account management fees,
execution costs, and other expenses related to
investing for a client’s Account. The securities
included in a client’s Account generally do not
exactly mirror the securities included in the index.
The benchmarks used by Baird with respect to a
client’s SMA may differ from the benchmarks used
by the manager of the client’s SMA. As a result, the
performance comparisons in Baird’s performance
reports may differ from reports provided to clients
directly by the investment manager for the client’s
SMA.
When preparing a client’s Account statements and
performance reports, Baird generally relies upon
third party sources, such as third party pricing
services. In some instances, such as when Baird is
unable to obtain a price for an asset from a pricing
service, Baird may obtain a price from its trading
desk or it may elect to not price the asset.
Obtaining a price from its trading desk may present
a conflict of interest. In some cases, Baird obtains
prices from the issuers or sponsors of investment
products in the client’s Account when prices are not
otherwise readily available. This frequently occurs
with respect to the valuation of annuities, Complex
Investment Products, community bank stocks and
private limited partnerships. If the assets in the
client’s Account are held by a custodian other than
Baird, Baird may also use valuation information
provided by the client’s third party custodian.
calculation,
calculation of
for
Complex
Investment
The performance of investment managers may,
under certain circumstances, be presented to
clients on a “gross” or “gross of fees” basis, which
means the performance results being presented
does not reflect the deduction of Program Fees and
other costs that clients have incurred and will incur
when retaining the manager. Had applicable
Program Fees and other costs been included in the
the manager’s
performance
performance results would have been lower than
the performance results presented. Documents
presenting a manager’s performance results on a
fees basis should contain certain
gross of
disclosures about the performance results being
presented. Clients are urged to review carefully
those disclosures because they contain important
information about
the
the
performance results. If a client is presented
performance information for a manager’s strategy
on a gross of fees basis and the client has an
Account managed by that manager pursuant to
the client should obtain a
that strategy,
performance report for the Account and review that
performance information carefully because the
performance report for the Account will reflect the
deduction of applicable Program Fees and other
costs.
Baird does not conduct a review of valuation
information provided by
third party pricing
services, issuers, sponsors, or custodians, and it
does not verify or guarantee the accuracy of such
information. Baird does not accept responsibility
for valuations provided by third parties that are
inaccurate unless Baird has a reason to believe that
the source of such valuations is unreliable.
Valuation data
investments, particularly
Products,
annuities,
community bank stocks and private funds, may not
be provided to Baird in a timely manner, resulting
in valuations that are not current. The prices
obtained by Baird from the third party pricing
services, issuers, sponsors and custodians may
differ from prices that could be obtained from other
sources. Values used in account statements and
performance reports may vary from prices received
in actual transactions and are not firm bids, offers
or guarantees of any type with respect to the value
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
of assets in an Account, and the values may be
greater than the amount a client would receive if
the securities were actually sold from the client’s
Account.
If a client has assets held by a third party
custodian, the prices shown on a client’s Account
statements provided by the custodian could be
different from the prices shown on statements and
reports provided by Baird. See “Services, Fees and
Compensation—Additional Program Information—
Custody Services” above for more information.
including,
of
Labor
without
(“DOL”)
Special Considerations for Retirement
Accounts
Each Retirement Account Fiduciary of a client
should understand that Baird may invest for the
client, recommend that the client invest in, or
make available for investment to plan participants,
Associated Investment Products, that Baird and its
Associated Parties will receive fees or other
compensation related to such investments, and
that they will retain such compensation to the
extent permitted by applicable law, rule or
regulation,
limitation,
Prohibited
Department
Transaction Exemption (“PTE”) 77-4, DOL PTE
2020-02 or other advisory opinions issued by the
DOL.
relationship and
Client Referrals and Other Compensation
Baird may provide compensation to individuals who
refer clients in some instances. When applicable,
the compensation paid is a percentage of the
client’s fee payments or the value of the client’s
Account. The amount of compensation will vary,
with the specific level determined based upon
consideration of various factors including, but not
limited to, the individual’s role in developing the
client
the assets under
management. Baird may pay these fees to
registered representatives of Baird and
its
Associated Parties as well as to unassociated
solicitors that have entered
into a written
agreement with Baird.
Baird and its associates and Associated Parties may
receive certain economic benefits in connection
with providing advisory services to clients, which
are described in the sections entitled “Services,
Fees and Compensation”, “Account Requirements
and Types of Clients”, “Additional Information—
Other Financial Industry Activities and Affiliations”
and “Additional Information—Code of Ethics,
Participation or Interest in Client Transactions and
Personal Trading” above.
the
Financial Information
Baird does not require or solicit prepayment of
more than $1,200 in fees per client six months or
more in advance and, thus, has not included a
balance sheet of its most recent fiscal year. Baird
is not aware of any financial condition that is
reasonably likely to impair its ability to meet its
contractual commitments to clients, nor has it been
the subject of a bankruptcy petition at any time
during the past ten years.
To the extent Baird and its Associated Parties rely
upon PTE 77-4, each Retirement Account Fiduciary
should understand that when Baird invests the
assets of a Retirement Account in an Associated
Investment Product that pays investment advisory
fees to Baird or any of its Associated Parties, Baird
and its Associated Parties will receive such
investment advisory fees in accordance with DOL
PTE 77-4, and, as required thereby, Baird will
waive its asset-based Program Fees on that portion
of the assets invested in the Associated Investment
Product for such period of time so invested or Baird
will offset the investment advisory fees received by
Baird or any of its Associated Parties from the
Associated Investment Product against the asset-
based Program Fee that Baird charges to the client.
For the purpose of complying with the terms of DOL
PTE 77-4, the client and each Retirement Account
Fiduciary of the client acknowledge in the client’s
advisory agreement that: (i) the investment in
Associated Investment Products for the client’s
Account is appropriate because of, among other
things,
investment goals, redeemability,
liquidity, and diversification of those products; (ii)
subject to the terms of the applicable Program, all
assets of the client’s Account may be invested in
one or more of the Associated Investment
Products; (iii) the client and such Retirement
Account Fiduciary received prospectuses or other
offering or disclosure documents for the Associated
Investment Products that may be used
in
connection with the Account, each of which include
a summary of all fees that may be paid by the
Associated Investment Products to Baird or its
Associated Parties; and (iv) the client received
information concerning the nature and extent of
the rate of such
any differential between
Associated Investment Product fees and the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
than
the
client
the applicable
Program Fees payable by the client. The differential
between the fees to be charged by Baird for the
investment advisory services it provides to the
client and, if applicable, the investment advisory
and other similar fees paid by the Associated
Investment Product to Baird or its Associated
Parties with respect to the services Baird or any of
its Associated Parties provides to the Associated
Investment Product is the difference between the
Program Fee disclosed in the client’s advisory
agreement and
investment
management, investment advisory and other
similar fees detailed in the applicable prospectus or
other offering or disclosure documents for the
Associated Investment Product.
see
“Additional
that
directed
in making such selection: (a) Baird and its
Associated Parties may receive higher aggregate
compensation
selected
if
investment managers, funds or other products not
associated with Baird and thus Baird may have an
incentive to offer Associated Investment Products
and Services; (b) Baird makes available to the
client investment managers, funds and products
not associated with Baird and the client may obtain
additional information about such unassociated
investment managers, funds or products at any
time by contacting the client’s Baird Financial
Advisor; and (c) the client is free to choose another
investment option or participate in another Baird
advisory program that does not use investment
managers, funds or products associated with Baird
at any time by contacting the client’s Baird
Financial Advisor. For more information about
Associated Investment Products and Services,
please
Information—Other
Financial Industry Activities and Affiliations” above.
the
fiduciary
Fiduciary
Fiduciaries are
If the client’s Account is a Retirement Account and
if Baird is directed to implement a directed
brokerage arrangement for the Account, each
Retirement Account Fiduciary of the client should
understand:
brokerage
the
arrangement must be for the exclusive benefit of
participants and beneficiaries of the Retirement
Account; and
responsibilities
discussed in ERISA Technical Bulletin 86-1. Each
Retirement Account
should also
understand that such Fiduciary is solely responsible
for complying with all fiduciary responsibilities
discussed
in ERISA Technical Bulletin 86-1,
including, without limitation, the duty to make an
initial determination that the directed broker-
dealer is capable of providing best execution for
the client’s brokerage transactions, the duty to
monitor the services provided by the directed
broker-dealer so as to assure that the client has
received best execution of the client’s brokerage
transactions, and the duty to determine that the
commissions paid by the client and any other fees
or costs incurred by the client are reasonable in
relation to the value of the brokerage and other
services received by the client. The client and each
Retirement Account Fiduciary of the client should
also understand that the client and the client’s
Retirement Account
solely
responsible for engaging a directed broker-dealer,
monitoring its performance and terminating a
directed brokerage arrangement, and that Baird is
not responsible for determining whether a directed
broker-dealer
is capable of providing best
execution.
If a client’s Account is a Retirement Account and if
the client is selecting Associated Investment
Products and Services, each Retirement Account
Fiduciary of the client understands and agrees that
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Appendix A
Associated Investment Products and Services
Entity Type
Name
Relationship
Baird Advisors1
Baird Department
Baird Equity Asset Management1
Baird Department
Chautauqua Capital Management1
Baird Department
55I, LLC (d/b/a 55ip, “55ip”)
Associated
Investment Advisor
GAMMA Investing, LLC
Affiliated
Greenhouse Fund GP LLC
Related
Greenhouse Funds LLLP
Related
LoCorr Fund Management, LLC
Related
Reinhart Partners, LLC
Affiliated
Riverfront Investment Group, LLC
Affiliated
Dual Registrant2
Strategas Securities, LLC
Affiliated
Trust Company
Baird Trust Company1
Affiliated
Baird Funds, Inc.1
Affiliated
Bridge Builder Trust (Baird series)
Affiliated
Mutual Fund
Financial Investors Trust (Riverfront series)
Affiliated
LoCorr Investment Trust
Related
Managed Portfolio Series Trust (Reinhart series)
Affiliated
Pace® Select Advisors Trust (Baird Series)
Affiliated
Advisors’ Inner Circle Fund III (Strategas series)
Affiliated
ETF
ALPS ETF Trust (Riverfront Series)
Affiliated
First Trust Exchange-Traded Fund III (Riverfront series)
Affiliated
Automated Quantitative Analysis (AQA®) Portfolio Series
Affiliated
UIT
Dividend Income Trust (DIT) Series
Affiliated
Strategas Trust, Series 1-1
Affiliated
CIT
Reliance Trust Institutional Retirement Trust (Baird/Chautauqua series)
Affiliated
Greenhouse Master Fund LP
Related
Hedge Fund
Greenhouse Onshore Fund LP
Related
Greenhouse Overseas Fund Ltd.
Related
Chautauqua Global Growth Equity QP Fund, LP
Affiliated
Private Fund
Chautauqua International Growth Equity QP Fund, LP
Affiliated
Chautauqua Series Fund, LLC
Affiliated
Appendix A - 1
Baird PWM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Venture Partners Management Company III, LLC
Baird Venture Partners III Limited Partnership
Affiliated
BVP III Affiliates Fund Limited Partnership
BVP III Special Affiliates Limited Partnership
Baird Venture Partners Management Company IV, LLC
Baird Venture Partners IV Limited Partnership
Affiliated
BVP IV Affiliates Fund Limited Partnership
BVP IV Special Affiliates Limited Partnership
Baird Venture Partners Management Company V, LLC
Baird Venture Partners V Limited Partnership
Affiliated
BVP V Affiliates Fund Limited Partnership
BVP V Special Affiliates Fund Limited Partnership
Baird Capital Partners Management Company V, LLC
Baird Capital1,3
Baird Capital Partners V Limited Partnership
Affiliated
Investment Advisor
BCP V Affiliates Fund Limited Partnership
Private Equity Fund
BCP V Special Affiliates Limited Partnership
Baird Capital Management Company, LLC
Baird Venture Partners GP VI, LLC
Baird Venture Partners VI LP
Affiliated
BVP VI Affiliates Fund LP
BVP VI Special Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management I LP
Baird Capital Global Fund I LP
Affiliated
Baird Capital Global Fund I-DE LP
BCGF I Special Affiliates LP
BCGF I Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management II LLC
Baird Capital Global Fund II Limited Partnership
Affiliated
BCGF II Affiliates Fund Limited Partnership
BCGF II Special Affiliates Limited Partnership
Appendix A - 2
Baird PWM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Capital Management Company, LLC
Baird Capital Global GP III LLC
Baird Capital Global Fund III LP
Affiliated
Baird Capital1,3
BCGF III Affiliates Fund LP
Investment Advisor
BCGF III Special Affiliates LP
Private Equity Fund
Baird Capital Partners Europe Limited4
Baird Capital Partners Europe II LP
Affiliated
Baird Capital Partners Europe II Special Affiliates LP
The Growth Fund
Baird Principal Group Management Company I, LLC
Baird Principal Group5
Baird Principal Group Partners Fund I Limited Partnership
Investment Advisor
Baird Principal Group Management Company II, LLC
Affiliated
Private Equity Fund
Baird Principal Group Partners Fund II Limited Partnership
Baird Principal Group Management Company, LLC
Baird Principal Group Partners Fund III, LP
Holding Company
Sagard Holdings Management, Inc.6
Associated
1. Participates in a Baird PWM Referral Program that pays compensation to Baird Financial Advisors for eligible referrals.
2. Registered with the SEC as a broker-dealer and investment advisor.
3. Baird Capital, Baird’s private equity business.
4. Baird Capital Partners Europe Limited, an English limited company, is regulated and authorized by the Financial Conduct
Authority.
5. Baird Principal Group, a group within Baird that has private equity funds only available to Baird employees.
6. Baird has a contractual relationship with and a small minority investment in Sagard Holdings Management, Inc., a
holding company for various financial services businesses whose investment products are made available to clients under
the Programs. See “Additional Information—Other Financial Industry Activities and Affiliations—Certain Relationships and
Arrangements—Baird and Associated Parties” above for more information.
Appendix A - 3
Baird PWM Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Additional Brochure: THE DDK GROUP (2026-03-27)
View Document Text
The DDK Group
Brochure
March 27, 2026
The DDK Group
777 East Wisconsin Avenue
Milwaukee, Wisconsin 53202
Toll Free: 800-792-2473
www.rwbaird.com
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue
Milwaukee, WI 53202
1-800-792-2473
rwbaird.com
Member FINRA & SIPC
SEC File No. 801-7571
This brochure (“Brochure”) provides information about the qualifications and business practices of
Robert W. Baird & Co. Incorporated (“Baird”) and the DDK Group (“DDK”), a team within Baird’s
Private Wealth Management department. Clients should carefully consider this information before
becoming a client of DDK. If you have any questions about the contents of this Brochure, please
contact DDK at the toll-free phone number listed above. The information contained in this Brochure
has not been approved or verified by the United States Securities and Exchange Commission or by
any state securities authority. Additional information about Baird is available on the SEC’s website at
www.adviserinfo.sec.gov.
Material Changes
The DDK Group (“DDK”), a team within the Private Wealth Management department of Robert W. Baird &
Co. Incorporated (“Baird”), updated its Form ADV Part 2A brochure (the “Brochure”) on March 27, 2026.
The following summary discusses the material changes that DDK has made to the Brochure since March 21,
2025, the date of the last annual update to the Brochure.
• In January 2026, Baird’s direct parent corporation, Baird Financial Corporation (“BFC”), made a
significant minority investment in Reinhart Partners, LLC (“Reinhart”), an investment advisor that offers
investment products and services through the Programs. As a result of the investment transaction, Baird
and Reinhart are affiliated, providing Baird a financial incentive to use, select or recommend Reinhart
investment products and services.
• In September 2025, Baird entered into a strategic partnership with Sagard Holdings Management, Inc.
(“Sagard”). Baird’s direct parent corporation, BFC, acquired a minority ownership interest in Sagard and
the right to appoint a member to Sagard’s board of directors. Baird agreed to use best efforts,
consistent with its fiduciary duties and other regulatory responsibilities, to offer investment products
managed or sponsored by affiliates of Sagard deemed suitable by Baird for its PWM clients, providing
Baird a financial incentive to recommend such investment products. See the Section of the Brochure
entitled “Other Financial Industry Activities and Affiliations—Certain Relationships and Arrangements—
Baird and Associated Parties” for more information.
• Baird updated information about Baird’s regulatory assets under management. See the Section of the
Brochure entitled “Advisory Business” for more information.
• Baird updated its description of the DC Program. The DC Program is designed to accommodate a client
who wishes to independently select an investment manager not available in the DDK Recommended
Managers Service or BSN Program to manage the assets in the client’s Account. The Program is also
designed for a client that wants to independently select a manager and negotiate the manager’s
Portfolio Fee rate directly with the manager. Certain managers offer lower Portfolio Fee rates to clients
through the DC Program compared to the BAM, DDK Recommended Managers, or BSN Programs. A
client considering an SMA Strategy should discuss with client’s DDK Consultant SMA Strategy availability
and the different Portfolio Fee rates, costs, and the types and levels of service provided in connection
with the different Programs. If a client has decided to participate in the DC Program, upon the client’s
request, the client’s DDK Consultant may assist the client with the client’s negotiation with the manager
of the Portfolio Fee rate for the applicable SMA Strategy. The Portfolio Fee negotiated by the client could
be higher or lower than the Portfolio Fee that applies to the same SMA Strategy that is available through
other Programs. The client is ultimately responsible for understanding the differences between the SMA
Programs, deciding to participate in the DC Program, selecting the SMA Strategy, and negotiating and
agreeing to the Portfolio Fee rate.
• Baird updated information about tax management and direct indexing strategies, including the
associated limitations and risks. See the Sections of the Brochure entitled “Advisory Business—
Additional Service Information—Tax Management Services” and “Methods of Analysis, Investment
Strategies and Risk of Loss—Investment Strategies” for more information.
• Baird provided additional information about possible tax consequences of a client’s investment activities.
See the Section of the Brochure entitled “Advisory Business—Additional Service Information—Legal and
Tax Considerations” for more information.
• Baird updated the rates of Portfolio Fees charged by managers under the Services. See the Section of
the Brochure entitled “Fees and Compensation—Advisory Fees” for more information.
• Baird updated its disclosures about the research, information and tools used by Baird PWM home office
investment professionals and DDK Consultants when formulating investment advice, which may include
Appendix A - ii
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the use of artificial intelligence (“AI”) tools, and the related risks. See the Section of the Brochure
entitled “Methods of Analysis, Investment Strategies and Risk of Loss—Methods of Analysis” for more
information.
• Baird included a description of the PWM Stock Opportunities List. See the Section of the Brochure
entitled “Methods of Analysis, Investment Strategies and Risk of Loss—Methods of Analysis—Certain
Eligible Product Lists” for more information.
• Baird updated investment risk information related to information security, cybersecurity, and other
technology‑related events, issuers’ use of AI, investments in digital assets, such as cryptocurrencies,
and those associated with recent events, such as those associated with the U.S. administration’s policy
initiatives, inflation, conflicts in Iran and the Middle East, the war between Ukraine and Russia, and the
strain in relationships between the U.S. and other countries. See the Section of the Brochure entitled
“Methods of Analysis, Investment Strategies and Risk of Loss—Principal Risks” for more specific
information.
• In March 2026, Baird entered into an Offer of Settlement with the Massachusetts Securities Division to
settle a regulatory matter relating to the timing of state investment adviser representative registration
approvals for two of Baird’s Financial Advisors located in Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals provided investment advisory services before their
Massachusetts registrations were completed as a form was missing from their application materials. 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.
• Baird updated information about firms affiliated with, related to, or otherwise associated with Baird. See
the Section of the Brochure entitled “Other Financial Industry Activities and Affiliations” and Appendix A
to the Brochure for more information.
A client should note that the foregoing summary only discusses material changes made to the Brochure
since March 21, 2025. The updated Brochure contains changes that are not listed above.
Appendix A - iii
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Table of Contents
Advisory Business ........................................................................................... 1
Robert W. Baird & Co. Incorporated ................................................................ 1
The Client-Baird Fiduciary Relationship ............................................................ 1
Summary of DDK’s Services .......................................................................... 2
Consulting Services ...................................................................................... 5
Financial Planning ................................................................................... 5
Risk Analysis .......................................................................................... 5
Asset Allocation and Investment Strategy Development ............................... 5
Consolidated Reporting ............................................................................ 5
Additional Consultant Services .................................................................. 5
Discretionary Services ................................................................................... 6
DDK Investment Management Service ....................................................... 6
SMA Services ............................................................................................... 7
DDK Recommended Managers Service ....................................................... 7
Baird SMA Network Program .................................................................... 9
Dual Contract Program .......................................................................... 11
Other SMA Strategy Information ............................................................. 13
Additional Service Information ..................................................................... 13
Conversion, Exchange or Sale of Certain Investments ............................... 13
Complex Strategies and Complex Investment Products .............................. 13
Permitted Investments .......................................................................... 16
Unsupervised Assets ............................................................................. 17
Special Considerations for the Services .................................................... 18
Goal Management ................................................................................. 18
Tax Management Services ..................................................................... 19
Investment Objectives ........................................................................... 21
Mutual Fund Share Class Policy ............................................................... 23
Custody Services .................................................................................. 24
Cash Sweep Program ............................................................................ 24
Trust Services Arrangements .................................................................. 25
Margin Loans ........................................................................................ 26
Securities-Based Lending Program .......................................................... 26
Other Non-Advisory Services .................................................................. 27
Client Responsibilities ............................................................................ 27
Retirement Accounts ............................................................................. 27
Legal and Tax Considerations ................................................................. 28
Account Requirements ........................................................................... 28
Fees and Compensation ................................................................................ 32
Advisory Fees ............................................................................................ 32
Fee Options and Fee Schedule ................................................................ 32
Service Account Minimums ..................................................................... 33
Calculation and Payment of Advisory Fees ................................................ 34
Obtaining Services Separately: Brokerage or Advisory? Factors
to Consider ...................................................................................... 36
Advisory Fee Payments to Baird, DDK Consultants and
Investment Managers ........................................................................ 37
Appendix A - iv
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Other Fees and Expenses ............................................................................ 39
Cost and Expense Information for Certain Investment Products .................. 39
Additional Account Fees and Charges ...................................................... 39
Other Fees and Charges ........................................................................ 39
Other Compensation Received by DDK and Baird ............................................ 40
Performance-Based Fees and Side-By-Side Management .............................. 41
Types of Clients............................................................................................. 41
Methods of Analysis, Investment Strategies and Risk of Loss ....................... 41
Investment Strategies ................................................................................. 41
Equity Strategies .................................................................................. 41
Fixed Income or Bond Strategies ............................................................ 41
Balanced Strategies .............................................................................. 42
Value Strategies ................................................................................... 42
Growth Strategies ................................................................................. 42
Income Strategies ................................................................................. 42
Economic Industry or Sector Focused Strategies ....................................... 42
International Strategies ......................................................................... 42
Global Strategies .................................................................................. 42
Geographic Region or Country Focused Strategies ..................................... 42
Tactical and Rotation Strategies .............................................................. 43
Opportunity or Opportunistic Strategies ................................................... 43
Tax Management Strategies ................................................................... 43
Direct Indexing Strategies ...................................................................... 44
Alternative Strategies and Complex Strategies ......................................... 44
Asset Allocation Strategies ..................................................................... 47
Important Information about Implementation of Investment
Objectives and Investment Strategies ................................................. 49
Methods of Analysis .................................................................................... 49
Certain PWM-Managed Portfolios ............................................................. 51
Certain Recommended Lists ................................................................... 52
Certain Eligible Product Lists .................................................................. 55
Baird Trust Strategies ............................................................................ 57
The DDK Investment Process ................................................................. 57
Service Information .................................................................................... 58
DDK Investment Management Service ..................................................... 58
DDK Recommended Managers Service ..................................................... 58
Baird SMA Network and Dual Contract Programs ....................................... 59
Portfolio Management by DDK, Baird and Associated Managers ........................ 60
Principal Risks ............................................................................................ 61
Investment Risk Information .................................................................. 61
Risks Associated with Certain Investment Strategies ................................. 68
Non-Traditional Assets and Complex Strategies Risks ................................ 69
Complex Investment Product Risks ......................................................... 70
Risks Associated with Certain Investment Objectives and Asset
Allocation Strategies ......................................................................... 76
Available Investment Product Risks ......................................................... 79
Recent Events ...................................................................................... 79
Appendix A - v
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Disciplinary Information ............................................................................... 79
Other Financial Industry Activities and Affiliations ....................................... 82
Baird’s Broker-Dealer Activities .................................................................... 82
Certain Relationships and Arrangements ....................................................... 82
Baird and Associated Parties................................................................... 82
Associated Investment Products and Services ........................................... 83
Relationships and Arrangements with Investment Managers ............................ 84
Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading ................................................................................ 84
Code of Ethics ............................................................................................ 84
Participation or Interest in Client Transactions ............................................... 85
Investment Advisory Accounts ................................................................ 85
Accounts and Investments Provide Different Levels of
Compensation .................................................................................. 85
Recommendations of Associated Investment Products and
Services .......................................................................................... 85
Referral Compensation Paid to DDK Consultants ....................................... 85
Ongoing Product Fees ............................................................................ 86
Marketing Support and Revenue Sharing from Mutual Fund and
UIT Sponsors ................................................................................... 86
Schwab Clearing Arrangement ................................................................ 87
Baird Conference Sponsorships ............................................................... 87
DDK Consultants Receive Benefits from Product Providers .......................... 87
Cash Sweep Program ............................................................................ 87
Trust Services Arrangements .................................................................. 87
Margin Loans ........................................................................................ 88
Securities-Based Lending Program .......................................................... 88
Investment Advisory and Brokerage Account and Service
Recommendations............................................................................. 88
Account Transfers and New Accounts ...................................................... 88
Recommendations to Open Different Types of Accounts ............................. 88
Baird Stock Ownership .......................................................................... 88
Other Client Relationships ...................................................................... 89
Relationships with Issuers of Securities ................................................... 89
DDK Consultants Transferring to Baird ..................................................... 89
Principal Trading ................................................................................... 89
Baird Underwritten Offerings .................................................................. 89
Allocations of IPOs and Other Public Offerings .......................................... 89
Trade Error Correction ........................................................................... 89
Baird’s Other Broker-Dealer and Related Activities .................................... 90
Other Conflicts of Interest ...................................................................... 91
Addressing Conflicts .............................................................................. 91
Duration Compensation Will Be Received ................................................. 91
Brokerage Practices ...................................................................................... 91
DDK’s and Baird’s Trading Practices .............................................................. 91
Broker-Dealer Selection ......................................................................... 91
Trade Aggregation, Allocation and Rotation Practices ................................. 92
Appendix A - vi
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Directed Brokerage Arrangements........................................................... 93
Cross Trading Involving Advisory Accounts ............................................... 93
Trade Error Correction ........................................................................... 94
Soft Dollar Benefits ............................................................................... 94
Trading Practices of Investment Managers ..................................................... 94
Trade Execution Services Performed by Baird ................................................. 95
Agency Cross Transactions ..................................................................... 95
Principal Transactions ............................................................................ 96
Review of Accounts ....................................................................................... 96
Client Account Review ................................................................................. 96
Account Statements and Performance Reports ............................................... 97
Client Referrals and Other Compensation ..................................................... 98
Custody ......................................................................................................... 98
Investment Discretion .................................................................................. 99
Investment Selection and Trading Authorizations ........................................... 99
Client Investment Restrictions ..................................................................... 100
Associated Investment Products .................................................................. 101
Investment Policy Statements ..................................................................... 101
Conversion, Exchange or Sale of Certain Investments .................................... 101
Voting Client Securities ............................................................................... 102
Non-Discretionary Accounts ........................................................................ 102
Separately Managed Accounts ..................................................................... 102
Discretionary Services ................................................................................ 102
Other Proxy Voting Information ................................................................... 103
Providing Baird Voting Instructions .............................................................. 104
Legal Proceedings and Corporate Actions ...................................................... 104
Financial Information.................................................................................. 104
Special Considerations for Retirement Accounts ......................................... 104
Associated Investment Products and Services ............................. Appendix A-1
Appendix A - vii
DDK F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird is owned indirectly by its associates through
several holding companies. Baird
is owned
directly by Baird Financial Corporation (“BFC”).
BFC is, in turn, owned by Baird Financial Group,
Inc. (“BFG”), which
is the ultimate parent
company of Baird. Associates of Baird own
substantially all of the outstanding stock of BFG.
those other
analysis
and
research,
analysis
planning;
investment
and
account
transactions
and
that website
Baird offers various investment advisory services
to clients, including services not described in this
Brochure. The investment advisory services Baird
include: portfolio management and
offers
recommendations
analysis;
investment
regarding asset allocation and
strategies;
and
recommendations regarding investment managers
and individual securities; investment consulting;
policy
financial
development;
performance
monitoring. Baird also offers clients execution of
brokerage
administrative
services, including maintaining custody of account
assets. Clients may also negotiate other services
with Baird. Baird offers its services separately or
in combination with other services.
retirement
accounts, which
Baird participates in wrap fee programs, including
programs not described in this Brochure and it
provides portfolio management services
in
connection with those programs. Baird receives a
portion of the wrap fee paid by clients for
providing portfolio management services under
those wrap fee programs.
(“IRC”)
(collectively,
under management,
As of December 31, 2025, Baird had
approximately $394.0688 billion in regulatory
assets
approximately
$289.4898 billion of which was managed on a
discretionary basis and approximately $104.5790
billion of which was managed on a non-
discretionary basis.
including
Advisory Business
This Brochure describes some of the investment
advisory services that Robert W. Baird & Co.
Incorporated (“Baird”) offers to its clients through
the DDK Group (“DDK”), a team of Baird Financial
Advisors (“DDK Consultants”) within Baird’s
Private Wealth Management (“PWM”) department.
Baird and DDK offer other investment advisory
services not described in this Brochure. Separate
brochures describe
investment
advisory services and discuss the terms and
conditions, fees and costs and potential conflicts
of interest associated with those services. This
Brochure also references other documents that
contain additional important information about
Baird. Those documents describe the types of
investment products and services that Baird
makes available to clients, including the terms,
conditions, fees, costs, risks, and conflicts of
interest applicable to those investment products
and services. Those documents are available on
Baird’s website at bairdwealth.com/retailinvestor.
Included on
is Baird’s Client
Relationship Booklet, which contains Baird’s Form
CRS Client Relationship Summary and Baird’s
Client Relationship Details document. The Client
Relationship Booklet also contains an important
disclosure document for retirement investors that
have
include
employee pension benefit plan accounts that are
subject to the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”) and
individual retirement accounts (“IRAs”) that are
subject to the Internal Revenue Code of 1986, as
amended
“Retirement
Accounts”). A client of Baird should have already
received a copy of the Client Relationship Booklet.
A client or prospective client who wishes to obtain
a brochure for another investment advisory
service provided by Baird, or a paper copy of any
of the other documents referenced
in this
Brochure,
the Client Relationship
Booklet, should contact a DDK Consultant or call
Baird toll-free at 1-800-792-2473.
The information contained in this Brochure is
current as of the date above and is subject to
change at Baird’s discretion. Please retain this
Brochure for your records.
The Client-Baird Fiduciary Relationship
is registered with the Securities and
Baird
Exchange Commission (“SEC”) as an investment
adviser under the Investment Advisers Act of
1940, as amended (the “Advisers Act”). DDK and
Baird are deemed to have a fiduciary relationship
with a client when providing the investment
advisory services that are described in this
Brochure. That means that DDK and Baird are
required to act in the best interest of the client
when providing investment advisory services.
From time to time DDK and Baird may engage in
Robert W. Baird & Co. Incorporated
Baird is privately-held, employee-owned global
investment and wealth management firm formed
in the State of Wisconsin in 1919.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
provide
investment
advice
client’s
Account
• non-discretionary services, whereby DDK or
Baird
and
recommendations but the client retains full
authority with respect to the management of
the
(“Non-Discretionary
Services”); and
contain
information about
• separately managed account (“SMA”) programs
and services, whereby an investment manager
manages the client’s Account according to a
strategy (each, an “SMA Strategy”) with full
discretionary authority, and DDK and Baird
provide additional consulting services to the
client (collectively, “SMA Services”).
Depending on their particular needs or objectives,
clients may use one or more of these Services.
certain business practices or may
receive
compensation or other benefits that create a
potential for conflict between the interests of
clients and the interests of DDK and Baird. DDK
and Baird generally address potential conflicts of
interest by disclosing them to clients through
documents provided to clients, including, without
limitation, this Brochure, Brochure supplements
individuals
that
providing investment advice to clients and the
services they provide, and the agreements clients
enter into with DDK and Baird. In addition, Baird
has adopted internal policies and procedures for
DDK and Baird that require them to: provide
investment advice that is suitable for advisory
clients (based upon the information provided by
such clients); make full disclosure of all potential,
material conflicts of interest; act with utmost care
and good faith in dealings with advisory clients;
and seek to obtain “best execution” of advisory
client transactions. The specific business practices
that create potential conflicts of interest with
clients and additional measures used by DDK and
Baird to address them are discussed in other
sections of this Brochure.
A client should note that registration as an
investment adviser does not imply a certain level
of skill or training.
The Consulting Services
include: Financial
Planning; Risk Analysis; Asset Allocation and
Investment Strategy Development; Consolidated
Reporting; and Additional Consultant Services
described below. The Discretionary Services
include: DDK Investment Management. The SMA
Services include: DDK Recommended Managers;
Baird SMA Network (“BSN”); and Dual Contract
(“DC”). The Additional Consultant Services are
only provided to certain clients upon request by a
client and agreement to do so by DDK. DDK
primarily provides Consulting Services and
recommends the DDK Investment Management
Service and DDK Recommended Managers
Service to clients when appropriate. DDK will
infrequently recommend the other Services when
DDK believes it is appropriate for a particular
client.
funds and exchange
traded
Summary of DDK’s Services
This Brochure describes certain
investment
advisory programs and services that DDK and
Baird offer to clients (“Services”) and applies to
each advisory account advised by DDK
(“Account”). The investment advisory services
offered under the Services generally include
investment advice and consulting services, which
are provided by Baird PWM’s home office
investment professionals or DDK, and, depending
upon the Service that a client selects, the Service
may include portfolio management. The Services
consist of:
consulting
services
(“Consulting
• certain
Services”);
Generally, DDK provides clients with analysis and
recommendations on investment managers and
strategies. Investment strategies typically may
include either public or private securities, private
institutional
placements,
limited partnerships,
mutual
funds
(“ETFs”). Often these investment managers or
strategies may be affiliated with external
custodians. DDK will assist clients in evaluating
custodians and negotiating custodial fees, trading
commissions, as well as, investment management
fees.
• discretionary services, whereby a client gives
DDK or Baird (including Baird PWM’s home
office investment professionals or the client’s
DDK Consultant) full discretionary authority to
manage the client’s Account (“Discretionary
Services”);
The SMA Services are generally offered under a
“single contract” arrangement. Under a single
contract arrangement, a client enters into an
advisory agreement with DDK and Baird, and
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the investment manager will directly manage the
client’s Account with full discretionary authority as
more fully described below.
the client has
Baird, in turn, enters into a subadvisory or similar
agreement with the investment manager on the
client’s behalf. This type of arrangement is
frequently referred to as a single contract
arrangement because there is only one contract
between the client and DDK and Baird; the client
does not have an agreement directly with the
client’s investment manager. Under the Dual
Contract Program, a client has a “dual contract”
arrangement, meaning
two
contracts; one contract with DDK and Baird and
another contract with the client’s investment
manager.
Baird is also registered with the SEC as a broker-
dealer under Securities Exchange Act of 1934, as
amended (the “Exchange Act”). Baird, in its
capacity as broker-dealer, may also provide
clients with trade execution, custody and other
standard brokerage services. However, trade
execution services, whether provided by Baird or
another firm, are not included in the advisory fee
the client pays for the Services (“Advisory Fee”).
A client should note that the client will incur costs
in addition to the Advisory Fee. See “Fees and
Compensation—Other Fees and Expenses” below
for more information.
Certain Programs may allow a client to invest in
groups of mutual funds and ETFs (referred to as
“sleeves”) and other model portfolios of securities
managed by Baird PWM (such sleeves and model
portfolios collectively, “PWM-Managed Portfolios”).
The SMA Programs allow a client to select among
a variety of SMA Strategies offered by third party
investment managers (“Other Managers”), which
may include Other Managers affiliated with,
related to, or otherwise associated with Baird
(“Associated Managers”), or Baird to manage the
client’s Account.
tend
DDK and Baird tailor advisory services to the
individual needs of clients. Each Service is
designed to address different investment needs of
clients. All of the Services discussed in this
Brochure may not be appropriate for every client.
For example, the Services may not be appropriate
for clients who have low or no trading activity,
who desire to pay transaction-based fees, who
maintain their accounts invested in high levels of
cash or other concentrated positions, who do not
want ongoing professional investment advice or
account monitoring, who
to execute
transactions without the recommendation or
advice of an advisor, which are commonly
referred to as “unsolicited” transactions, or who
intend to utilize an investment strategy, product
or solution that is not available in a Service.
and bonds
(collectively,
Manager,
and
investment products
Baird has engaged an overlay management firm,
Envestnet Asset Management, Inc. (the “Overlay
Manager”) to provide certain subadvisory services
to clients that participate in certain SMA Services.
The SMA Services make available two types of
SMA Strategies: (1) manager-traded strategies,
whereby the manager itself manages a client’s
Account and conducts the trading to implement
the SMA Strategy selected by the client (a
“Manager-Traded Strategy”); and (2) model-
traded strategies, whereby the manager does not
manage a client’s Account (a “Model Provider”)
but instead provides a model portfolio (“Model
Portfolio”) to an overlay management firm, which
may include the Overlay Manager, Baird or other
third party
firm (each, an “Implementation
Manager”), that in turn manages a client’s
Account and conducts the trading to implement
the SMA Strategy selected by the client (a
“Model-Traded Strategy”). If a client selects a
Model-Traded Strategy, the Model Provider will
provide the Model Portfolio and updates to the
Implementation
the
Implementation Manager will manage the client’s
Account with full discretionary authority according
to the strategy selected by the client. Otherwise,
if the client selects a Manager-Traded Strategy,
Some Services offer clients the ability to pursue
alternative investment strategies (“Alternative
Strategies”) or other non-traditional or complex
investment strategies that involve special risks
not apparent in more traditional investments like
stocks
“Complex
Strategies”). Similarly, some Programs offer
clients the ability to invest in non-traditional or
real assets (“Non-Traditional Assets”). Some
Programs also offer the ability to invest in
investment products
that pursue Alternative
Strategies (“Alternative Investment Products”) or
other Complex Strategies (collectively, “Complex
these
Investment Products”). The use of
strategies and
involves
special risks, and a client should not engage in a
strategy or purchase an investment product
unless the client understands the related risks.
See “Additional Service Information—Complex
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Strategies and Complex Investment Products”
and “Methods of Analysis, Investment Strategies
and Risk of Loss—Principal Risks” below for more
information.
allocation
strategies
have
Services generally consist Funds managed,
advised or sponsored by Baird or Associated
Parties (“Associated Funds”) and other investment
products managed, advised or sponsored by Baird
or Associated Parties (collectively, “Associated
Investment Products”), and SMA Strategies
managed or advised by Baird or Associated
Managers (“Associated SMA Strategies”). Baird
and DDK Consultants may use, select or
recommend Associated Investment Products and
Services. This may present a conflict of interest. A
client is free at any time to select investment
products and services that are not associated with
Baird. For specific information about Associated
Parties and Associated Investment Products and
Services, see “Other Financial Industry Activities
and Affiliations” below.
include
a
client’s
age,
the
A client’s DDK Consultant will offer or recommend
appropriate Services, investment strategies, and
investment products and services based upon a
investment profile and an Account’s
client’s
investment objective, which establishes an
Account’s investment return objective and risk
investment profile will
tolerance. A client’s
generally
other
investments, financial situation and needs, tax
status, investment goals, investment experience,
investment time horizon, liquidity needs, risk
tolerance and other relevant information provided
by a client and updated from time to time.
Although a DDK Consultant may offer or
recommend appropriate options, a client will
ultimately select
investment objective,
Services, investment strategies, and investment
products and services for an Account.
Certain Services make available asset allocation
investment strategies. Asset allocation strategies
involve investing in one or more categories of
assets, such as equity securities, fixed income
securities, Non-Traditional Assets, Alternative
Investment Products and cash, and one or more
subcategories of assets, called asset classes.
varying
Asset
investment objectives and investment strategies.
Some asset allocation strategies use strategic
investment strategies, which involve investing
accounts in accordance with a predetermined
target allocation to different asset classes. Some
asset allocation strategies use tactical investing,
which typically involves tactically and actively
adjusting account allocations to different asset
classes based upon the manager’s perception of
how those asset classes will perform in the short-
term. Some asset allocation strategies involve the
use of both strategic and tactical investment
strategies, sometimes referred to as dynamic
strategies. Asset allocation strategies may be
implemented using a variety of investment types,
such as individual securities, mutual funds and
exchange traded products (“ETPs”), including
ETFs and exchange traded notes (“ETNs”). The
amount allocated to an asset class or investment
type varies by strategy, and some strategies may
have little or no allocation to one or more asset
classes or types of investments described above.
See “Methods of Analysis, Investment Strategies
and Risk of Loss—Investment Strategies—Asset
Allocation Strategies” below for more information.
funds, ETFs, unit
Service
A client that wishes to participate in a Service will
enter into a client relationship agreement or other
investment advisory agreement with DDK and
Baird
client’s
(“advisory agreement”). The
advisory agreement will contain the specific terms
applicable to the services selected by the client,
fees payable by the client, and other terms
applicable to the client’s advisory relationship with
DDK and Baird. A client should note that the
client’s advisory relationship with DDK and Baird
does not begin until they enter into the applicable
advisory agreement with the client, which occurs
when Baird PWM’s Home Office has accepted the
client’s advisory agreement and determined that
all of the client’s paperwork is in order. See
“Additional
Information—Account
Requirements” below for more information.
The Services make available many different
investment products and services offered by third
parties that are not associated with Baird, such as
mutual
investment trusts
(“UITs”), collective investment trusts (“CITs”),
private equity funds, hedge funds, private funds
and other investment pools (collectively “Funds”).
However, certain
investment products and
services managed, advised or sponsored by Baird
or other parties affiliated with, related to, or
otherwise associated with Baird,
including
Associated Managers (“Associated Parties”), have
been selected for inclusion in certain Services or
are made available to clients through Service
Accounts (“Associated Investment Products and
Services”). Associated Investment Products and
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Robert W. Baird & Co. Incorporated
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in
Subject to the agreement of DDK, a client may
impose reasonable restrictions on the securities or
types of securities to be held in the client’s
Account. Please see “Investment Discretion”
below for more information. Clients may negotiate
with DDK to provide other investment advisory
services.
Risk Analysis
When performing risk analysis services, DDK
seeks to analyze and review with a client the risks
financial planning process
the
identified
described above. DDK seeks
to minimize
investment risk through an asset allocation and
investment strategy.
strategic
asset
allocation
As mentioned above, Baird, in its capacity as
broker-dealer, may also provide DDK clients with
trade execution, custody and other standard
brokerage services. For this reason, a client may
also enter into a client relationship agreement or
other account agreement with DDK and Baird
(“account agreement”) if the client has not
already done so. The client’s account agreement
authorizes DDK and Baird to execute trades for,
and perform related brokerage and custody
services to, the client’s Account. Baird generally
does not permit a client to include assets in the
client’s Account that are held by a third party
custodian or that are otherwise held outside of a
Baird account (“Held-Away Assets”), although
DDK will provide Consulting Services on Held-
Away Assets when requested by a client and
agreed to by DDK.
Service
has
different
Asset Allocation and Investment Strategy
Development
Using a variety of tools, including the financial
framework, DDK will develop and recommend a
and
long-term,
investment strategy appropriate for the client’s
risk and return objectives. Investment strategies
may involve the use of different equity styles or
strategies, such as: large cap growth, large cap
value, mid cap growth, mid cap value, small cap
growth, small cap value,
international and
emerging market equities strategies; different
fixed income styles or strategies, such as short or
intermediate, taxable and tax-exempt bond,
international and emerging market bond, and
high yield bond strategies; and Complex
Strategies, such as real estate and real estate
funds (including private real estate funds and
private real estate fund of funds), commodity
strategies, hedge funds, funds of hedge funds,
private equity funds, funds of private equity
funds, private debt funds and managed futures.
and
ongoing
research,
Each
structures,
administration, types and levels of service, and
fees and expenses. In particular, a client should
investment advisory services
note that the
provided by DDK and Baird, including the depth of
initial
evaluation,
monitoring and review of the investments in a
client’s Account, varies by Service and the
investments selected for the Account.
include
The foregoing discussion of the Services is only a
summary. More specific information about the
Services and the particular investment advisory
services that DDK and Baird provide in connection
with each Service are further described below and
in the client’s advisory agreement. Clients are
encouraged to review this Brochure and their
advisory agreement carefully.
Consolidated Reporting
Clients of DDK generally receive a performance
report and asset allocation report each quarter.
Generally, this report covers all accounts and
asset classes specified in the advisory agreement.
For the convenience of clients of DDK, reports
may
information, usually related to
client’s personal assets, that is provided by the
is not covered by the advisory
client and
agreement. If a third party reporting company is
used, Baird, DDK or the client may pay an
additional fee to the third party for this service.
DDK provides analysis of both performance and
asset allocation decision to the client on a
quarterly basis.
Additional Consultant Services
DDK offers the following additional consultant
services.
in preparing an
Consulting Services
Financial Planning
includes a
The Financial Planning Service
comprehensive development of a needs analysis
that is based upon an analysis of the client’s cash
flow. Generally, this service includes tax and
estate planning review and coordination with the
client’s external professional providers.
Investment Policy Statement. DDK will assist a
Investment Policy
client
investment
Statement reflecting
the client’s
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
provided by the client or its agent(s) for the
agreed upon time period. DDK is not responsible
for verifying information supplied by the client or
its agent(s).
provide
a
the
accurately
reflects
the
objectives, policies, constraints, and risk profile.
The Investment Policy Statement is designed to
provide guidance to the client’s
investment
manager(s). The Investment Policy Statement is
a product of information and data provided by the
client; therefore, the client is responsible for
review and final approval of the Investment Policy
Statement. The client is solely responsible for
Investment Policy
determining whether
Statement
client’s
investment objectives, policies, constraints, and
risk profile.
Performance Monitoring Reports. DDK will
periodically
client written
to
Performance Monitoring Reports which include
calculations of the performance of the client’s
Account(s) over various
time periods and
compare various aspects of such performance to
one or more benchmark indices.
Discretionary Services
DDK Investment Management Service
Under the DDK Investment Management Service,
a client grants full discretionary authority and
management of the client’s Account to Baird and
the client’s DDK Consultant.
for
determining whether
into account by DDK
Asset Allocation Report. DDK provides to a client
or its fiduciaries an Asset Allocation Report which
identifies one or more investment portfolios for
the client (in terms of risk and return) based on
information requested by DDK and
certain
provided by the client. The client is solely
the
responsible
information taken
in
formulating an Asset Allocation Report is accurate
and complete.
reviews
the client’s
investment
objectives,
Consultant makes
a
Investment Manager Search Report. DDK
provides to a client an Investment Manager
Search Report that lists investment managers
with investment philosophies and investment
strategies believed to be consistent with the
client’s
policies,
constraints, and risk profile, as specified by the
client to DDK. DDK does not assume responsibility
for the client’s choice of any investment manager
or for any investment manager’s performance
when providing this service to the client, nor is
DDK responsible for an unassociated investment
manager’s compliance with applicable law or for
matters beyond DDK’s reasonable control.
In the DDK Investment Management Service, a
client’s DDK Consultant seeks to meet the client’s
particular investment needs by developing a
customized
investment strategy based upon
guidelines that are jointly established by the client
the
the client’s DDK Consultant. At
and
commencement of services, the client’s DDK
Consultant
investment
objectives and risk tolerance using the Consulting
Services described above. Based upon that review
and other information provided by the client, the
DDK
subsequent
recommendation to the client as to which
investment style the DDK Consultant believes is
best suited for the client. A client makes the final
decision as to which investment style is chosen
for the client’s Account. More specific information
as to how the client’s DDK Consultant will manage
the client’s Account is provided to the client in
connection with the opening of the Account.
Investment Manager Search Interviews. DDK
coordinates client interviews with a select number
of investment managers listed on the Investment
Manager Search Report. The interviews enable
the client to gain additional information regarding
such investment managers’ respective investment
philosophies, policies and business operations.
the heading
and
in various
compares
various
aspects
of
Past Performance Reviews. DDK provides to a
client a Past Performance Review which, based on
information supplied by the client, includes the
historical performance of the client’s portfolios
and
such
performance to one or more benchmark indices.
Account data will be derived from information
A DDK Consultant typically recommends or
selects for client accounts investments in mutual
funds and ETFs that pursue the strategies
“Consulting
described under
Services—Asset Allocation
Investment
Strategy Development” above. However, from
time to time, a DDK Consultant may make direct
types of securities,
investments
including, but not limited to, equity securities,
fixed income securities, Non-Traditional Assets
and certain Alternative Investment Products. All
or a portion of the assets in a client’s Account
may be held in cash or cash equivalents, including
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the
Service
Under the DDK Recommended Managers Service,
DDK and Baird determine
investment
managers (“DDK Recommended Managers”) and
their strategies (“DDK RM Strategies”) eligible to
participate in the Service through an initial and
ongoing evaluation process.
of
securities issued by money market mutual funds,
or may be deposited in interest-bearing bank
accounts. Additional information about the types
of investments a DDK Consultant may use for
client accounts is contained under the heading
“Additional
Information—Permitted
Investments” below. For more information about
the DDK Investment Management Service, see
“Methods of Analysis, Investment Strategies and
Risk
Information—DDK
Loss—Service
Investment Management Service” below.
of
For more specific information about the managers
and SMA Strategies made available through the
DDK Recommended Managers Service and the
level of initial and ongoing research, evaluation,
monitoring and review performed by Baird on
those managers and SMA Strategies, see
“Methods of Analysis, Investment Strategies and
Risk
Information—DDK
Loss—Service
Recommended Managers Service” below.
Baird may remove any DDK Consultant or
strategy from the Service at any time and
transfer day-to-day management responsibility of
a client’s Account to another DDK Consultant or
Baird Financial Advisor at any time without
providing prior notice to, or obtaining the consent
of, a client.
DDK Recommended Managers have varying
investment objectives, styles and strategies, and
they may invest a client’s Account in various
types of securities, which will be chosen by the
DDK Recommended Manager and which may
include mutual funds, ETFs or other investment
products associated with the manager or Baird.
involve
special,
are urged
review
investing
in
Service
information
about
Important Information about DDK Investment
Management Service Accounts. DDK Consultants
may invest client accounts in illiquid securities
and Complex Investment Products. These types of
investments
sometimes
significant, risks and are not appropriate for all
clients. A client should understand those risks
those products. See
before
“Additional
Information—Complex
Strategies and Complex Investment Products”
and “Methods of Analysis, Investment Strategies
and Risk of Loss—Principal Risks” below for more
information.
the DDK
to
Clients
Recommended Manager’s Form ADV Part 2A
contain additional
Brochure, which
should
important
DDK
the
Recommended Manager, including information
the DDK Recommended Manager’s
about
strategies, the types of investments the DDK
Recommended Manager may use for a client’s
Account, and the risks associated with investing in
a DDK RM Strategy. Such brochures are available
upon request.
Associated Investment Products are available to
clients under the DDK Investment Management
Service. This presents a conflict of interest. For
more information, see “Other Financial Industry
Activities and Affiliations” below.
initially selects
RM
Strategy with
Some of the services provided under the DDK
Recommended Managers Service will be provided
to a client by a DDK Consultant assigned to the
client’s Account. A client, typically working with a
DDK Consultant,
the DDK
Recommended Manager and DDK RM Strategy for
the client’s Account. Thereafter, whenever Baird
it
the client’s DDK Consultant deems
or
necessary, Baird or the client’s DDK Consultant
will replace a DDK Recommended Manager or
DDK
another DDK
Recommended Manager or DDK RM Strategy for
the client’s Account.
SMA Services
DDK Recommended Managers Service
The DDK Recommended Managers Service is a
program whereby a client provides Baird and the
client’s DDK Consultant with discretionary
authority to appoint investment managers to
manage the client’s Account with full discretionary
authority and to terminate or replace investment
managers for the client’s Account. The DDK
Recommended Managers Service is designed for a
client who wishes to have the client’s Account
managed by
investment managers that are
monitored by DDK and Baird on an ongoing basis.
If a client participates in the DDK Recommended
Managers Service, the client authorizes and
to appoint DDK
directs DDK and Baird
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
full discretionary authority
Recommended Managers to serve as sub-adviser
to the client’s Account and to otherwise manage
the client’s Account in accordance with the terms
of the DDK Recommended Managers Service. The
client also authorizes and directs the DDK
Recommended Managers to manage the client’s
Account with
in
accordance with the DDK RM Strategy selected.
RM
Strategies
offered
below
Certain managers of Model-Traded Strategies
offered
through the Overlay Manager have
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a DDK client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of other
those Model
client accounts managed by
Providers. See “Additional Service Information—
Trading for Client Accounts—Trading Practices of
Investment Managers”
for more
information.
the client should understand
the discretionary
full discretionary authority
recommendation or
full discretionary authority
Certain DDK RM Strategies are only made
available through Implementation Managers. The
DDK
through
Implementation Managers consist of Manager-
Traded Strategies and Model-Traded Strategies. If
a DDK RM Strategy offered
through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs DDK
and Baird to appoint the Implementation Manager
to serve as sub-adviser to the client’s Account. If
a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to manage the client’s
Account with
in
accordance with the selected DDK RM Strategy. If
a Manager-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to appoint the applicable
DDK Recommended Manager as sub-adviser, and
the client also authorizes and directs such DDK
Recommended Manager to manage the client’s
Account with
in
accordance with the selected DDK RM Strategy.
If a client’s Account is managed by an Other
Manager under the DDK Recommended Managers
that,
Service,
authority
notwithstanding
granted to Baird and the client’s DDK Consultant
under the Service: Baird and the client’s DDK
Consultant do not manage the Account and do not
otherwise have any influence over the Other
investment decisions or securities
Manager’s
selections, and therefore, Baird and the client’s
DDK Consultant are not responsible for the
decisions made by the Other Manager; and Baird
and the client’s DDK Consultant do not provide
any
investment advice
regarding the purchase or sale of investment
products made for the client’s Account.
from
the
the
implement
the direction of
the
client’s Account,
the prior manager and
From time to time, DDK or Baird may remove
investment managers
DDK
Recommended Managers Service, and DDK or
Baird may select a replacement manager to
manage the client’s Account. In such event, DDK
or Baird, at
the client’s
replacement manager, or the client’s replacement
manager may sell all or a portion of the securities
or other investments in the Account that were
the
managed by
replacement manager will reinvest the cash
proceeds of those sales. Sales of securities or
other investments could result in adverse tax
consequences for the client.
faithfully
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Implementation Manager will
Account,
typically
the Model Portfolio as
proposed by the Model Provider. However, since
the Implementation Manager has discretionary
authority over
the
Implementation Manager may implement the
Model Portfolio differently than proposed by the
Model Provider if the Implementation Manager
determines such action to be necessary and in the
client’s best interest. A client should note that
DDK and Baird do not monitor or ascertain
whether a third party Implementation Manager is
fully and
implementing the Model
Portfolio on a continuous basis. The client should
periodically discuss the Account’s performance
with the client’s DDK Consultant.
If DDK or Baird terminates an
investment
manager from the DDK Recommended Managers
Service, a client authorizes DDK and Baird to
invest, with full discretionary authority, the assets
in the client’s Account previously managed by the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in
investment adviser or abilities to manage client
assets.
terminated
other
investment manager
securities, including, but not limited to, mutual
funds and ETPs. DDK’s and Baird’s discretionary
authority to make such other investments will
continue until a replacement investment manager
is selected or alternative arrangements are made
for the management of the client’s assets.
For more specific information about the managers
and SMA Strategies made available through the
BSN Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those managers and SMA
Strategies, if any, see “Methods of Analysis,
Investment Strategies and Risk of Loss—Service
Information—Baird SMA Network and Dual
Contract Programs” below.
the
A client should only participate in the BSN
Program if the client wishes to take more
responsibility for monitoring the client’s Account,
the DDK Recommended Managers Program does
not contain an SMA Strategy that meets the
client’s particular needs, and
client
understands the risks of doing so.
A client who prefers to continue using an
investment manager that has been removed from
the DDK Recommended Managers Service, or who
directs or otherwise requests that a particular
investment manager not recommended by DDK
be selected to manage the client’s Account, will
need to move to another Service, such as the
BSN Program. See “Baird SMA Network Program”
below for more information. Clients who elect to
do so will no longer receive the same level of
rigorous ongoing monitoring, evaluation, or
review of that investment manager from DDK or
Baird.
have
varying
Industry
Activities
investment
BSN Managers
objectives, styles and strategies, and they may
invest a client’s Account in various types of
securities, which will be chosen by the BSN
Manager and which may include mutual funds,
ETFs or other investment products associated with
the manager or Baird. Certain managers offer
strategies that exclusively invest in Funds (“Fund
Strategist Portfolios”).
Important
Information about Affiliated
Managers. The DDK Recommended Managers
Service makes available to clients investment
services that are offered by Baird Advisors and
investment
Baird Equity Asset Management,
management departments of Baird. This presents
a conflict of interest. For more information, see
“Other
and
Financial
Affiliations” below.
a
is designed
client who wishes
Clients are urged to review the BSN Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the BSN
Manager, including information about the BSN
Manager’s strategies, the types of investments
the BSN Manager may use for a client’s Account,
and the risks associated with investing in a BSN
Strategy. Such brochures are available upon
request.
Baird SMA Network Program
The BSN Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
to
client. The BSN Program
accommodate
to
independently select an investment manager not
available in the DDK Recommended Managers
Program to manage the assets in the client’s
Account.
Some of the services provided under the BSN
Program may be provided to a client by a DDK
Consultant assigned to the client’s Account, and
the client’s DDK Consultant may provide his or
her own advice and recommendations about BSN
Managers.
(“BSN
Strategies”)
eligible
Under the BSN Program, Baird determines the
investment managers (“BSN Managers”) and their
strategies
to
participate in the Program through a significantly
less rigorous evaluation process compared to the
DDK Recommended Managers Service. However,
a client should note that DDK and Baird do not
make any recommendation to clients regarding
any BSN Strategy or any
representations
regarding a BSN Manager’s qualifications as an
If a client participates in the BSN Program, the
client authorizes and directs DDK and Baird to
appoint the BSN Manager selected by the client to
serve as sub-adviser to the client’s Account. The
client also authorizes and directs the BSN
Manager to manage client’s Account with full
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
discretionary authority in accordance with the
BSN Strategy selected by the client.
Information—Trading
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by those Model Providers. See
“Additional Service
for
Client Accounts—Trading Practices of Investment
Managers” below for more information.
influence over
reviewing
the
Certain BSN Strategies are only made available
through the Overlay Manager. The BSN Strategies
offered through the Overlay Manager consist of
Manager-Traded Strategies and Model-Traded
Strategies. If a client selects a BSN Strategy
offered through the Overlay Manager for the
client’s Account, the client authorizes and directs
DDK and Baird to appoint the Overlay Manager to
serve as sub-adviser to the client’s Account. If a
client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to manage the client’s Account
with full discretionary authority in accordance
with the BSN Strategy selected by the client. If a
client selects a Manager-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to appoint the applicable BSN
Manager as sub-adviser, and the client also
authorizes and directs such BSN Manager to
manage the client’s Account with full discretionary
authority in accordance with the BSN Strategy
selected by the client.
If a client’s Account is managed by an Other
Manager under the BSN Program, the client
should understand that: DDK and Baird do not
manage the Account and do not otherwise have
the Other Manager’s
any
investment decisions or securities selections, and
therefore, DDK and Baird are not responsible for
the decisions made by the Other Manager; DDK
and Baird do not provide any recommendation or
investment advice regarding the purchase or sale
of investment products made for the client’s
Account; and DDK and Baird only provide the
client with certain consulting services, which may
include the client’s DDK Consultant’s assistance
with determining the client’s financial needs,
investment goals and investment restrictions and
periodically
manager’s
performance. DDK and Baird do not undertake to
investment
provide any other consulting or
advisory services under the BSN Program unless
DDK and Baird agree to do so in writing.
the Account and
its
regarding
If a client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the Overlay Manager will typically
implement the Model Portfolio as proposed by the
Model Provider. However, since the Overlay
Manager has discretionary authority over the
client’s Account, the Overlay Manager may
implement the Model Portfolio differently than
proposed by the Model Provider if the Overlay
Manager determines such action to be necessary
and in the client’s best interest. A client should
note that DDK and Baird do not monitor or
ascertain whether the Overlay Manager is fully
and faithfully implementing the Model Portfolio on
a continuous basis. The client should periodically
discuss the Account’s performance with the
client’s DDK Consultant.
A client that participates in the BSN Program is
strongly encouraged to contact the client’s DDK
Consultant or BSN Manager on a periodic basis to
discuss:
investment
performance; the BSN Manager’s investment
philosophy and style (to determine if the BSN
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information
the BSN Manager,
described on the manager’s Form ADV, which is
available on the SEC's website at www.adviser
info.sec.gov.
Certain managers of Model-Traded Strategies
offered
through the Overlay Manager have
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a DDK client Account pursuing a
The BSN Strategies and BSN Managers made
available under the BSN Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the BSN Program,
DDK and Baird cannot appoint a replacement
manager or otherwise manage a client’s Account
assets. Given the terms of the BSN Program,
upon the withdrawal or removal of an investment
manager from the BSN Program, a client’s BSN
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
a
client who wishes
Program Account will be automatically removed
from the BSN Program and the Account will
become an unmanaged brokerage account, unless
the client provides contrary instructions to DDK.
See “Methods of Analysis, Investment Strategies
and Risk of Loss—Service Information—Baird SMA
Network and Dual Contract Programs” below for
further information.
accommodate
to
independently select an investment manager not
available in the DDK Recommended Managers
Service or BSN Program to manage the assets in
the client’s Account. The Program is also designed
for a client that wants to independently select a
manager and negotiate the manager’s Portfolio
Fee rate directly with the manager.
Important Information about
the BSN
Program. Portfolios managed by 55I, LLC (d/b/a
55ip, “55ip”) are made available under the BSN
Program. 55ip uses research and other services
from Riverfront, an affiliate of Baird, in the
development of certain of those portfolios, and
Riverfront receives compensation from 55ip with
respect to those portfolios. This presents a conflict
of interest. For more information, see “Other
Financial Industry Activities and Affiliations”
below.
Under the DC Program, Baird determines the
investment managers (“DC Managers”) and their
strategies (“DC Strategies”) eligible to participate
in the Program through a significantly less
rigorous evaluation process compared to the DDK
Recommended Managers Service. However, a
client should note that DDK and Baird do not
make any recommendation to clients regarding
any DC Strategy or any representations regarding
a DC Manager’s qualifications as an investment
adviser or abilities to manage client assets.
appointment
For more specific information about the managers
and SMA Strategies made available through the
DC Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those managers and SMA
Strategies, if any, see “Methods of Analysis,
Investment Strategies and Risk of Loss—Service
Information—Baird SMA Network and Dual
Contract Programs” below.
in managing
the client’s Account
A client should only participate in the DC Program
if the client wishes to take more responsibility for
monitoring
the DDK
the client’s Account,
Recommended Managers Program does not
contain an SMA Strategy that meets the client’s
particular needs, and the client understands the
risks of doing so.
the
foregoing when deciding
DC Managers have varying investment objectives,
styles and strategies, and they may invest a
client’s Account in various types of securities,
which will be chosen by the DC Manager and
which may include mutual funds, ETFs or other
investment products associated with the manager
or Baird.
The BSN Program is designed to accommodate a
client who wishes to independently select an
investment manager that is not available in the
DDK Recommended Managers Service to manage
the client’s Account. The client assumes ultimate
responsibility for monitoring the client’s BSN
the BSN Manager’s
Program Account and
performance. A
and
client’s
continued retention of a BSN Manager to manage
the client’s Account are based ultimately upon the
client’s independent review of the BSN Manager
and the BSN Manager’s services. The client
ultimately determines that the BSN Strategy to be
used
is
consistent with the client’s stated investment
objectives and financial needs and risk tolerance.
Once retained by the client, a BSN Manager will
only be removed from managing the client’s BSN
Program Account upon the manager’s withdrawal,
removal from the BSN Program, or the client’s
direction to do so. A client should carefully
consider
to
participate in the BSN Program and also consider
whether another Service, such as the DDK
Recommended Managers Service, may be more
appropriate for the client.
Dual Contract Program
The DC Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
to
client. The DC Program
is designed
Clients are urged to review the DC Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the DC
Manager, including information about the DC
Manager’s strategies, the types of investments
the DC Manager may use for a client’s Account,
and the risks associated with investing in a DC
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Strategy. Such brochures are available upon
request.
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information regarding the DC Manager, described
on the manager’s Form ADV, which is available on
the SEC's website at www.adviserinfo.sec.gov.
Some of the services provided under the DC
Program may be provided to a client by a DDK
Consultant assigned to the client’s Account, and
the client’s DDK Consultant may provide his or
her own advice and recommendations about DC
Managers.
Under the DC Program, DC Managers are offered
to clients through a dual contract arrangement,
and a client will need to enter into a separate
agreement with the DC Manager in addition to the
advisory agreement the client enters into with
DDK and Baird. A client participating in the DC
Program is solely responsible for negotiating the
client’s agreement with the client’s DC Manager,
and neither DDK nor Baird will participate or
advise a client regarding the terms of such an
agreement, the advisability of entering into such
an agreement, or the retention of the client’s DC
Manager unless DDK and Baird agree to do so in
writing.
The DC Strategies and DC Managers made
available under the DC Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the DC Program,
DDK and Baird cannot appoint a replacement
manager or otherwise manage a client’s Account
assets. Given the terms of the DC Program, upon
the withdrawal or removal of an investment
manager from the DC Program, a client’s DC
Program Account will be automatically removed
from the DC Program and the Account will
become an unmanaged brokerage account, unless
the client provides contrary instructions to DDK.
See “Methods of Analysis, Investment Strategies
and Risk of Loss—Service Information—Baird SMA
Network and Dual Contract Programs” below for
more information.
Information about
“Other Financial
the DC
Important
Program. Other
investment management
departments of Baird and Associated Managers
are available to clients under the DC Program.
This presents a conflict of interest. For more
information,
Industry
see
Activities and Affiliations” below.
appointment
reviewing
the
If a client’s Account is managed by an Other
Manager under the DC Program, the client should
understand that: DDK and Baird do not manage
the Account and do not otherwise have any
influence over the Other Manager’s investment
decisions or securities selections, and therefore,
DDK and Baird are not responsible for the
decisions made by the Other Manager; DDK and
Baird do not provide any recommendation or
investment advice regarding the purchase or sale
of investment products made for the client’s
Account; and DDK and Baird only provide the
client with certain consulting services, which may
include the client’s DDK Consultant’s assistance
with determining the client’s financial needs,
investment goals and investment restrictions and
periodically
manager’s
performance. DDK and Baird do not undertake to
provide any other consulting or
investment
advisory services under the DC Program unless
DDK and Baird agree to do so in writing.
in managing
the client’s Account
the Account and
its
the DC Manager’s
the
foregoing when deciding
A client that participates in the DC Program is
strongly encouraged to contact the client’s DDK
Consultant or DC Manager on a periodic basis to
investment
discuss:
performance;
investment
philosophy and style (to determine if the DC
Strategy remains appropriate for the client); any
The DC Program is designed to accommodate a
client who wishes to independently select an
investment manager. The client assumes ultimate
for monitoring the client’s DC
responsibility
the DC Manager’s
Program Account and
and
client’s
performance. A
continued retention of a DC Manager to manage
the client’s Account are based ultimately upon the
client’s independent review of the DC Manager
and the DC Manager’s services. The client
ultimately determines that the DC Strategy to be
used
is
consistent with the client’s stated investment
objectives and financial needs and risk tolerance.
Once retained by the client, a DC Manager will
only be removed from managing the client’s DC
Program Account upon the manager’s withdrawal,
removal from the DC Program, or the client’s
direction to do so. A client should carefully
to
consider
participate in the DC Program and also consider
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
including by
investing
whether another Service, such as the DDK
Recommended Managers Service, may be more
appropriate for the client.
and
venture
capital
and
such
as
options,
is contained under
“Methods of Analysis,
and Risk
of
Other SMA Strategy Information
Certain SMA Strategies are available through
multiple Services. The overall cost of an SMA
Strategy and the types and levels of service
provided to a client in connection with an SMA
Strategy will vary depending upon the particular
Service selected by the client. Certain managers
offer lower Portfolio Fee rates to clients through
the DC Program compared to the BAM, DDK
Recommended Managers or BSN Programs. A
client considering an SMA Strategy should discuss
with client’s DDK Consultant SMA Strategy
availability and the different Portfolio Fee rates,
costs, and the types and levels of service
provided in connection with the different Services.
A client is solely responsible for selecting the SMA
Strategy and the Service in which the client’s
Account will participate.
invested
in concentrated and
multiple ways,
in
alternative mutual funds, ETFs, hedge funds,
managed futures, private equity funds and SMAs
third party managers. Some
managed by
Complex Strategies
in Non-Traditional
invest
Assets, such as real estate, commodities (which
may
include metals, mining, energy and
agricultural products), currencies, movements in
securities indices, credit spreads and interest
rates,
buyout
investments in private companies. Some Complex
Strategies engage in the use of margin or
leverage or selling securities short (“short sales”).
Some Complex Strategies invest in derivative
instruments
convertible
securities, futures, swaps, or forward contracts.
Complex Investment Products generally engage in
one or more Complex Strategies. Additional
information about Alternative Strategies and
Complex Strategies
the
heading
Investment
Loss—Investment
Strategies
Strategies—Alternative Strategies and Complex
Strategies” below. Additional information about
Complex Strategies and Complex Investment
Products, generally, is provided below.
Non-Traditional Assets
currencies,
securities
information about
A client should note that certain SMA Strategies
may be
less
diversified portfolios of securities and may involve
the use of leverage, margin, and options. A client
should discuss with the client’s DDK Consultant
the specific strategies and investments used by a
manager. Additional
the
strategies and investments used by a manager
are available in a manager’s Form ADV Part 2A
Brochure.
tokens
investment
“Investment
Additional Service Information
Conversion, Exchange or Sale of Certain
Investments
By participating in a Service, a client authorizes
DDK and Baird to convert or exchange any shares
of Funds, such as mutual funds, ETFs, closed-end
funds, UITs, Complex Investment Products, and
other similar investment pools, held in the client’s
Account to a class of shares of the same fund.
Discretion—Conversion,
See
Exchange or Sale of Certain Investments” below
for more information.
Non-Traditional Assets, such as investments in
commodities,
indices,
interest rates, credit spreads, private companies,
and digital assets, such as cryptocurrencies, non-
stablecoins, and
fungible
(“NFTs”),
tokenized
products (collectively,
“Digital Assets”) may be used for diversification
purposes. They may also be used to try to reduce
market and inflation risk. The performance of
Non-Traditional Assets may not correspond to the
performance of the stock markets generally, and
in Non-Traditional Assets will
investments
generally impact an account’s returns differently
than more traditional investments like stocks or
bonds. Non-Traditional Assets are subject to risks
that are different from, and in some instances,
greater than, other assets like stocks and bonds.
Non-Traditional Assets are generally more difficult
to value, less liquid, and subject to greater
volatility compared to stocks and bonds.
Margin and Leverage
Margin
or
Margin involves borrowing money from a firm,
such as Baird, to buy securities or other property.
If a client wishes to pay for securities by
Complex Strategies and Complex Investment
Products
Some Services offer clients the ability to pursue
Alternative Strategies
other Complex
Strategies that involve special risks not apparent
in more traditional investments like stocks and
bonds. Complex Strategies may be pursued in
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in
the client’s Account
investment product
engages in short sales.
Options and Other Derivative Instruments
Derivative Instruments
instruments,
securities,
futures,
borrowing part of the purchase price from Baird, a
client must open a margin account with Baird, and
Baird may provide the client with a margin loan.
Securities held in a client’s margin account are
used as Baird’s collateral for the margin loan. The
value of the collateral in the margin account must
be maintained at a certain level relative to the
margin loan for the duration of the loan. If the
securities in the margin account decline in value,
so does the value of the collateral supporting the
margin loan, and as a result, Baird may take
action, such as issue a margin call and sell
securities in the account.
Leverage
than,
the
instruments. While
returns,
traditional
investments.
Investing
involves
Leverage generally attempts to obtain investment
exposure in excess of available assets through the
use of borrowings, short sales and other
leverage can
derivative
potentially enhance
can also
it
exacerbate losses if changes in the markets, or
the values of the investments subject to the
leverage, are adverse to the strategy being
pursued. The use of leverage may also increase
an Account’s volatility.
such as options,
Derivatives
convertible
swaps, and
forward contracts are financial contracts that
derive value based upon the value of an
underlying asset, such as a security, commodity,
currency, or index. Derivative instruments may be
used as a substitute for taking a position in the
underlying asset. Derivative instruments may also
be used to try to hedge or reduce exposure to
other risks. They may also be used to make
speculative investments on the movement of the
value of an underlying asset. The use of
derivative instruments involves risks different
from, or possibly greater
risks
associated with investing directly in securities and
other
in
leverage.
derivatives also generally
Derivatives are also generally less liquid, and
subject to greater volatility compared to stocks
and bonds.
Short Sales
Options
to benefit
Options transactions may involve the buying or
writing of puts or calls on securities. In some
cases, Baird may require clients to open a margin
account to engage in options trading.
security or
With a call option, the purchaser has the right to
buy, and the seller (writer) the obligation to sell,
index at a
the underlying
predetermined price (i.e., the exercise or strike
price) prior to expiration of the option. The
premium paid to the seller (writer) for the option
is in consideration for the underlying obligations
imposed on the seller should the option be
exercised. With a put option, the purchaser has
the right to sell, and the seller has the obligation
to buy, the underlying security or index at the
exercise price prior to expiration of the option.
Short selling attempts
from an
anticipated decline in the market value of a
security. To affect a short sale, a client sells a
security the client does not own. When a client
sells a security short, Baird borrows the security
from a lender and makes delivery to the buyer on
the client’s behalf. Because short sales involve an
extension of credit from Baird to the client, a
client must use a margin account. A client must
also eventually purchase the same shares sold
short and return them back to the lender. It is
possible that the prices of securities that a client
sells short may increase in value, in which case
the client may lose money on the short position.
Short selling thus runs the risk of loss if the price
of the securities sold short does not decline below
the price at which they were originally sold. This
risk of loss is theoretically unlimited, as there is
no cap on the amount that the price of a security
may appreciate.
Clients should note that investment managers
managing a client’s Account or
investment
products in the client’s Account may also engage
in short sales. Thus, a client’s Account will be
subject to short sales risks if the investment
manager managing the client’s Account or an
In buying a call option, the purchaser expects
that the market value of the underlying security
or index will appreciate, which would enable the
purchaser of a call to buy the underlying security
or index at a strike price lower than the prevailing
market price. The purchaser of the call option
makes a profit if the prevailing market price is
greater than the sum of the strike price plus the
premium paid for the option. The seller of a call
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Complex Investment Products
Products
include
option earns income in the form of the premium
received from the purchaser for the option and
expects that the market value of the underlying
security or index will depreciate such that the
option will expire without being exercised. The
seller of a call option makes a profit if the
prevailing market price of the underlying security
or index is less than the sum of the strike price
plus the premium received.
futures, but also
ETNs,
business
Complex Investment Products typically invest
primarily in Non-Traditional Assets or engage in
one or more Complex Strategies. Complex
Investment
Alternative
Investment Products, such as hedge funds, funds
of hedge funds, private equity funds, funds of
private equity funds, private debt funds, and
managed
include other
investments
pursuing Complex Strategies,
including but not limited to, exchange or swap
funds, leveraged funds, inverse funds, and other
special situation funds, structured certificates of
(“structured
deposit and
structured notes
products”),
development
companies (“BDCs”), real estate investment trusts
limited partnerships
(“REITs”), and master
(“MLPs”).
thereby making
In buying a put option, the purchaser expects that
the market value of the underlying security or
index will depreciate, which would enable the
purchaser of a put to sell the underlying security
or index at a strike price higher than the
prevailing market price. The purchaser of the put
option makes a profit if the prevailing market
price is less than the sum of the strike price and
the premium paid for the option. The seller of a
put option earns income in the form of the
premium received from the purchaser for the
option and expects that the market value of the
underlying security or index will appreciate such
that
the option will expire without being
exercised. The seller of a put option makes a
profit if the prevailing market price of the
underlying security or index is greater than the
difference between the strike price and the
premium.
website
In addition, a client should be aware that more
traditional investments, such as mutual funds,
ETFs, UITs and variable annuities may also pursue
Complex Strategies,
them
Complex Investment Products. A client should
carefully review the prospectus or other offering
document for each investment and understand
the strategy being pursued before deciding to
invest. More detailed information about mutual
funds, ETFs, UITs and variable annuities is
available
at
Baird’s
on
bairdwealth.com/retailinvestor.
Additional Important Information
losses
in
In purchasing a put or call option, the purchaser
faces the risk of loss of the premium paid for the
option if the market price moves in a direction
opposite to what the purchaser had expected. In
selling or writing an option, the seller faces
significantly more risk. A seller of a call option
faces the risk of significant loss if the prevailing
market price of the underlying security or index
increases above the strike price, and a seller of a
put option faces the risk of significant loss if the
prevailing market price of the underlying security
or index decreased below the strike price.
and
any
Clients should note that investment managers
investment
managing a client’s Account or
products in the client’s Account may also engage
in options transactions. Thus, a client’s Account
will be subject to options risks if the investment
manager managing the client’s Account or an
investment product
the client’s Account
in
engages in options transactions.
The use of Complex Strategies or Complex
Investment Products is not appropriate for some
clients because they involve special risks. A client
should not engage in those strategies or invest in
those products unless the client is prepared to
experience significant
the client’s
Account. This is especially true for short selling,
which can result in unlimited losses as there is no
limit to the amount borrowed securities can rise in
value. See “Methods of Analysis, Investment
Strategies and Risk of Loss—Principal Risks”
below for more information. Before using those
types of strategies or products, a client is strongly
urged to discuss them with the client’s DDK
Consultant
investment manager
managing the client’s Account. A client should
also carefully review the client’s agreements with
Baird and related disclosure documents, which the
client should have received when opening the
Account. Additional information about Complex
Strategies and Complex Investment Products is
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
“Methods
of Analysis,
Service under “Advisory Business” above and
under
Investment
Strategies and Risk of Loss—Service Information”
below.
provided under the heading “Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment Strategies—Alternative Strategies and
Complex Strategies” below and on Baird’s website
at bairdwealth.com/retailinvestor.
DDK or Baird may add Permitted Investments or
restrict client access to a Permitted Investment at
any time in their sole discretion.
for notifying
and
any
Service
Some Permitted Investments contain restrictions
that limit their use, and clients will not be
permitted to purchase or hold such investments
outside of an Account. See “Advisory Business—
Additional
Information—Account
Requirements” below for more information.
A client assumes responsibility for engaging in
Complex Strategies and investing in Complex
Investment Products. If a client determines that
the client no longer wants to engage in those
strategies or invest in those products, the client is
responsible
the client’s DDK
investment manager
Consultant
managing the client’s Account. DDK and Baird are
not responsible for any losses resulting from any
Other Manager’s failure or delay in implementing
any such instructions.
In certain limited instances, Baird may allow a
client to hold an investment in an Account that is
an Unpermitted Investment.
DDK
Investment Management Service.
Permitted Investments for the DDK Investment
Management Service generally include, but are
not limited to, the following types of investments:
Complex
Strategies
or
• equity securities, including, but not limited to,
common stocks, American Depositary Receipts
(“ADRs”), and ordinary shares,
including
whether exchange-traded, or over-the-counter
traded;
The use of Complex Strategies or Complex
Investment Products has a unique impact upon
the calculation of a client’s asset-based Advisory
Fee. See “Fees and Compensation—Calculation
and Payment of Advisory Fees” below for more
information. A client should also understand that
Baird and the client’s DDK Consultant have a
financial incentive to use, select or recommend
Complex
certain
Investment Products, including margin and short
sales. See “Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
stocks,
As a creditor, Baird may have interests that are
adverse to a client. Neither DDK nor Baird will act
as investment adviser to a client with respect to
the liquidation of securities held in an Account to
meet a call on a margin loan. Any such sale of
assets will be executed in Baird’s capacity as
broker-dealer and creditor and may, as permitted
by law, result in executions on a principal basis.
• fixed income securities, including but not limited
to, debt securities issued by domestic and
corporations and other entities;
foreign
securities
asset-backed
preferred
(including mortgage-backed securities and
collateralized mortgage obligations (“CMOs”));
convertible debt securities; obligations issued
by U.S., state, or foreign governments or their
agencies, instrumentalities, or authorities, such
as securities issued by the U.S. Treasury,
federal
federal government agencies or
government-sponsored enterprises
(“Agency
securities”), or foreign governments; municipal
securities; money market mutual
funds;
certificates of deposit (“CDs”) (primary or
secondary); commercial paper;
Investments”).
• rights or warrants on equity securities and
written covered call equity options;
Permitted Investments
Under the Discretionary and Non-Discretionary
Services, Baird determines the asset categories
and investment products that clients may access
for investment (“Permitted Investments”) and
those that are not permitted in Program Accounts
(“Unpermitted
Permitted
Investments vary by Service. Although Baird
determines the Permitted Investments under
those Services, the level of initial and ongoing
evaluation, monitoring and review that DDK and
Baird perform on Permitted Investments varies.
For more information, see the descriptions of each
• open-end mutual funds shares that Baird has
selected for use in the Service, which generally
includes only those funds with which Baird has a
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• put options;
load-waived, or
for purchase; shares
• all annuities and insurance products;
or
options
on
• commodities,
futures
commodities, and commodity pools; and
investment
funds
• private
and Complex
Investment Products that Baird has not selected
for use in the Services.
selling agreement and only those funds that are
institutional are
no-load,
allowed
that were
in a Baird brokerage
originally purchased
account and not sold when transitioned to an
advisory account will held in the account as
non-billable assets when the original purchase
was subject to a
front-end sales charge
(typically 36 months) or until the Contingent
Deferred Sales Charge (CDSC) expires (typically
13 months) if subject to a back-end sales
charge after which time they will be converted
to the appropriate advisory share class and
become billable assets;
for use
in
SMA Services. Investment products under the
the
SMA Services are selected solely by
investment manager providing services to the
client. The investment products used by an
investment manager may include products that
Baird does not permit to be used in connection
with the DDK Investment Management Service
described above. A client should review the
investment manager’s Form ADV Part 2A
Brochure for more information.
• closed-end funds, ETFs, and UITs that have cost
structures designed
fee-based
investment advisory programs; UITs originally
purchased in a brokerage account and not sold
when transitioned to an advisory account will be
held as non-billable assets until the UIT
termination date at which time they will be
liquidated and the proceeds are billable;
• BDCs, publicly-traded REITs, certain non
publicly-traded (or private) REITs, and MLPs
(which may be organized as limited liability
companies (“LLCs”));
leveraged
• ETNs,
Consulting Services. From time to time, DDK
may advise clients with respect to, or may
manage, certain Held-Away Assets such as
investments, and
private REITs, real estate
insurance products held by custodians other than
Baird even though those assets may not be
eligible for Accounts held at Baird. Any such
arrangement will be set forth in the client’s
advisory agreement.
funds, and other special
situation mutual funds, and exchange or swap
funds;
• certain hedge funds, funds of hedge funds,
private equity funds, funds of private equity
funds, funds of real estate, structured products,
private debt funds and managed futures that
Baird has selected for use in the Services; and
or
supervised
by
them
• cash and cash equivalents.
The types of investments that are not permitted
for the DDK Investment Management Service
generally include, but are not limited to:
• Class B or Class C shares offered by mutual
funds or any other class of mutual fund shares
that impose a contingent deferred or level sales
charge (back-end or level load);
• inverse funds;
If
a
client
holds
• UITs that impose an initial or deferred sales
Unsupervised Assets
Under certain circumstances, Baird, in its sole
discretion, may accept a client request to hold an
asset in an Account that is not included in the
investment advisory services provided by Baird or
a DDK Consultant or otherwise monitored,
overseen
(an
“Unsupervised Asset”). For example, if Baird
permits a client
to hold an Unpermitted
Investment in an Account, the asset is typically
also considered an Unsupervised Asset. Baird, in
its sole discretion, may also designate an asset
that is otherwise a Permitted Investment as an
Unsupervised Asset under certain circumstances,
such as when a client acquires the asset in an
unsolicited transaction, transfers the asset from
firm or Baird
an account held at another
brokerage account, or continues to hold the asset
against Baird’s or the client’s DDK Consultant’s
recommendation.
an
Unsupervised Asset in an Account, the client
should understand that the Unsupervised Asset
charge (load);
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
or
for
overall goal or
investment objective (“Goal
Management Objective”) chosen by the client.
Each individual Account included in a Goal
Management Plan will also be managed or advised
by Baird and client’s DDK Consultant
in
accordance with the terms of the applicable
Advisory Program or Service and any investment
strategy or objective applicable to the Account.
However, to the extent consistent with the terms
applicable to an Account included in a Goal
Management Plan, each
individual Account
included in the Goal Management Plan may be
managed or advised in any manner believed by
Baird or the client’s DDK Consultant to be
necessary
the Goal
appropriate
Management Accounts, taken together, to seek to
achieve the Goal Management Objective.
may not be included in performance reports
provided to the client and that Baird and DDK
Consultants do not manage, provide investment
advice, or otherwise act as an investment adviser
with respect to the Unsupervised Asset, even if
the Unsupervised Asset is included in account
statements or performance reports provided to
the client. Because Baird and DDK Consultants do
not manage or provide investment advisory
services regarding Unsupervised Assets, no asset-
based Advisory Fee is charged on Unsupervised
Assets. While Unsupervised Assets are not subject
to the asset-based Advisory Fee, Baird may
impose additional fees upon Accounts holding
Unsupervised Assets. See “Other Fees and
Expenses” below for more information. A client
should also understand
that holding an
Unsupervised Asset in an Account may increase
the risk of trade errors, overinvestment, and
negative Account performance. A client should
consult the client’s DDK Consultant for further
information.
is contained under
Special Considerations for the Services
Third Party Information
The Goal Management Objectives that Baird
makes available to clients as part of Goal
Management include: (1) All Growth; (2) Capital
Growth; (3) Growth with Income; (4) Income
with Growth; (5) Conservative Income; and (6)
Capital Preservation. A description of those
objectives
the heading
“Methods of Analysis, Investment Strategies and
Loss—Investment Strategies—Asset
Risk of
Allocation Strategies” below.
When providing services to a client, DDK and
Baird rely on information provided by third parties
and other external sources believed to be reliable,
including, but not limited to, information provided
by investment managers. DDK and Baird assume
that all such information is accurate, complete
and current. DDK and Baird do not conduct an in-
depth review of, or verify, such information, and
they do not guarantee the accuracy of the
information used. See “Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis” below for more information.
service
In certain circumstances, clients that are part of
the same household may include their eligible
Advisory Accounts in the same Goal Management
Plan (a “Household Goal Management Plan”). It is
the client’s sole responsibility to notify DDK that
the client is part of a household so that DDK is
aware of the client’s eligibility for a Household
Goal Management Plan. It is also the client’s sole
responsibility to notify DDK whenever the client
ceases to be part of a household if an Account is
part of a Household Goal Management Plan.
Failure to do so could have a materially negative
impact on applicable Accounts.
An Account will be removed
from a Goal
Management Plan: (1) upon request or consent of
the client, (2) if the Account ceases to be an
eligible Advisory Account, (3) in the event the
Account is part of a Household Goal Management
Plan, if the client notifies DDK that the client
ceases to be a member of the applicable
household, or (4) upon written notice from Baird
that it is no longer able to manage the Account
according to the Goal Management Plan.
Goal Management
DDK and Baird make available to clients an
optional goal management
(“Goal
Management”). Goal Management provides clients
the ability to set a single, overall investment
objective for all or a portion of assets selected by
the client with the flexibility of using multiple,
eligible Advisory Accounts that may have different
investment strategies or objectives. If a client
elects to have Baird implement a plan of Goal
Management (a “Goal Management Plan”) using
two or more eligible Advisory Accounts (“Goal
Management Accounts”), the Goal Management
Accounts, taken together, will be managed or
advised by Baird and client’s DDK Consultant in
such a way so as to seek to achieve a single,
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
tax management service should contact the
client’s DDK Consultant.
Tax management services are provided solely
based upon
information
the direction and
provided by a
client. The offering and
performance of tax management services to a
client’s Account does not constitute tax advice. A
client is ultimately responsible for all tax-related
consequences resulting from the client’s decision
to enroll in a Service or select a manager that
utilizes tax management services.
risks,
and
Given the nature of Goal Management, a client
enrolling Accounts in a Goal Management Plan
should understand that each Account enrolled in a
Goal Management Plan may not be invested in a
manner such that the individual Account alone
would be able to achieve the Goal Management
Objective. It is likely that one or more Accounts
included in a Goal Management Plan, taken alone,
will be managed or advised differently and will be
subject to greater or enhanced risks than would
be the case if the Account alone had the same
objective as the Goal Management Objective.
Such enhanced risks include, without limitation,
market risks, investment objective and asset
allocation risks, capitalization risks, investment
style risks, illiquid securities and liquidity risks,
concentration risks, frequent trading and portfolio
risks, Non-Traditional Assets and
turnover
Complex
Complex
Strategies
Investment Product risks.
for
tax
purposes
in
Information—Legal
and
included
in
Tax management strategies are not intended to,
and likely will not, eliminate a client’s U.S. federal
income tax obligations relating to investments in
an Account. Like all investment strategies, there
is no guarantee that the implementation of a tax
management strategy will be successful. A client’s
use of a tax management strategy may not
actually
lower a client’s tax obligations or
otherwise achieve a client’s tax goals. The
effectiveness of tax managed strategies and
services may be negatively
impacted by
applicable tax rules, such as the IRS wash sales
rules and straddle rules, which will disallow, limit
or defer a client’s ability to recognize losses in an
Account
specified
circumstances. Tax management strategies and
services also involve special risks. See “Additional
Tax
Service
Considerations” and
“Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment
Management
Strategies—Tax
Strategies” below for more information.
A client should note, particularly if the client
elects to include eligible Advisory Accounts in a
Household Goal Management Plan, that: if an
Account is removed from a Goal Management
Plan for any reason, including if the client ceases
to be a member of the same household, the
Service and strategy for the Account removed
from the Goal Management Plan will remain
unchanged unless a change is requested by the
client; further, the Account removed from the
Goal Management Plan will not be allocated assets
from other Accounts
the Goal
Management Plan unless the client and all other
applicable clients, if any, consent and direct Baird
to do so and then only to the extent permitted by
applicable law; and DDK and Baird will have no
liability for implementing a Goal Management Plan
as requested by the client.
A client should understand the terms of the tax
management services that will be implemented,
including the associated limitations, risks and
additional costs, if any, before enrolling an
Account in a Service or selecting a manager for
that Account. A client is strongly urged to consult
with the client’s tax advisor about potential tax
implications before enrolling an Account in a
Service or selecting a manager for that Account. A
client is also encouraged to discuss the client’s tax
management needs with
the client’s DDK
Consultant.
Tax Management Services
Many Services and managers make available tax
management strategies and services that are
intended to reduce the negative impact of U.S.
federal income taxes on an Account and enhance
Account performance by selectively
trading
investments in the Account to recognize or avoid
investment gains and losses.
DDK Tax Management Strategies
Certain Services and managers
include tax
management services as a default feature of the
Services or the manager’s services. A client that
wishes to opt an Account out of participation in a
Certain DDK Consultants offer tax management
investment strategies (“DDK TM Strategies”),
described below, to non-Retirement Accounts
enrolled in DDK Consultant-directed Services,
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the DDK
the sale, and within a reasonable time thereafter,
the proceeds will be reinvested in a manner
consistent with the way the Account was invested
prior to the employment of the tax harvesting
strategy.
the
implementation of
the
implementation of
including
Investment Management
Service. A client is encouraged to ask the client’s
DDK Consultant if DDK TM Strategies will be used
if the Account is enrolled in a Service. DDK
Consultants who offer DDK TM Strategies will
generally implement such strategies for Accounts
they manage on a discretionary basis unless a
client opts out by contacting the client’s DDK
Consultant. The Baird PWM Home Office will assist
with
the DDK TM
the
Strategies.
Generally,
tax
harvesting strategy is limited to open end mutual
fund and ETF positions with unrealized capital
losses over $1,000 for U.S. federal income tax
purposes, unless Baird and the client otherwise
agree.
Capital Gains Avoidance Strategy
investment strategies
Each DDK TM Strategy is a secondary investment
strategy designed
to achieve a secondary
objective of an Account to reduce the negative
impact of U.S. federal income taxes and each
such strategy is implemented together with the
for the
other primary
Account that are designed to achieve the client’s
primary investment objectives or goals.
The DDK TM Strategies features are not available
to Retirement Accounts.
Tax Harvesting Strategy
identified as part of
A capital gains avoidance strategy seeks to avoid
capital gains attributable to an investment in the
Account for U.S. federal income tax purposes by
selling the investment before the capital gain is
distributed by the issuer. When implementing a
capital gains avoidance strategy, the Baird PWM
Home Office or the DDK Consultant, as applicable,
periodically, but at least annually, monitors the
issuers of investments held in the Account for
capital gains distributions announcements and
capital gains avoidance opportunities. When an
opportunity is identified, the Baird PWM Home
Office or the DDK Consultant, as applicable, sells
(or recommends the sale of) such securities in the
client’s Account
the
monitoring process in order for the Account to
avoid a capital gain distribution made by the
issuer. The Baird PWM Home Office or the DDK
Consultant will then reinvest (or recommend the
reinvestment of) the proceeds of such sale in cash
until the capital gain distribution has been paid by
the issuer, and then the securities will be
purchased again. If the securities are sold at a
loss, then Baird PWM or the DDK Consultant may
employ (or recommend the employment of) the
tax harvesting strategy described above.
Generally, the capital gains avoidance strategy is
limited to open end mutual fund positions in a
client Account, and a mutual fund position will be
included in the implementation of the strategy
only if the potential net U.S. federal income tax
benefit to the Account related to such position is
estimated by Baird to be $1,000 or more. For
purposes of calculating the $1,000 threshold, the
Account’s current unrealized gain or loss in each
mutual fund position is analyzed in light of the
applicable amount of capital gains distribution
announced by the mutual fund company.
A tax harvesting strategy seeks to improve the
value of an Account, on a post U.S. federal
income tax basis, by offsetting capital losses in
the Account with capital gains. This strategy is
oftentimes referred to a “tax harvesting” or “tax
implementing a tax
loss harvesting”. When
harvesting strategy, the Baird PWM Home Office
or the DDK Consultant, as applicable, periodically,
but at least annually, conducts an assessment of
the Account to identify capital losses for tax
harvesting opportunities. When an opportunity is
identified, the Baird PWM Home Office or the DDK
Consultant, as applicable, sells (or recommends
the sale of) certain securities in the client’s
Account in order for the Account to recognize the
unrealized capital losses identified as part of the
assessment process. The Baird PWM Home Office
or the DDK Consultant will then reinvest (or
recommend the reinvestment of) the proceeds of
such sale in one or more replacement securities
that the DDK Consultant believes are not
“substantially identical” for purposes of the IRS
wash sales rules. Replacement securities may
include, without limitation, ETFs, cash, cash
equivalents or other securities. Unless the client
instructs otherwise, investment in replacement
securities will be made on a temporary basis and
generally only for the duration of any applicable
IRS wash sale rule period, currently 30 days after
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Client-Directed Tax Management Strategies
Additional Important Information about DDK’s Tax
Management Strategies.
implementation of a
A client may direct DDK and Baird, and DDK and
Baird may agree, to implement an investment
strategy designed by the client or client’s tax
advisors for the client’s specific tax purposes (a
“client-designed strategy”). DDK and Baird do not
undertake any responsibility for the development,
evaluation or efficacy of any client-designed
strategy.
The
tax management
strategy is based upon Baird’s or the DDK
Consultant’s, as applicable, estimates of capital
gains and losses associated with investments in
client’s Account and information provided to them
by third parties, such as issuers of securities.
Capital losses will remain in an Account following
the implementation of a tax harvesting strategy,
and the Account will realize capital gains following
the implementation of a capital gains avoidance
the extent such estimates or
to
strategy,
information are incorrect.
for an Account based upon
responsible
for
selecting
for
Investment Objectives
Generally, every Account will have one of the
investment objectives described below. Although
a DDK Consultant may recommend an investment
objective
the
information provided by a client, the client is
the
ultimately
investment objective
the Account. The
investment objective will determine, in part, and
limit the Services, investment products and
services that will be made available to the
Account.
The implementation of the tax harvesting strategy
and capital gains avoidance strategy (or the
recommendation to implement a strategy) is done
in the sole discretion of the Baird PWM Home
Office or DDK Consultant, as applicable, and
securities may be excluded from implementation
of such strategies for a number of reasons,
including without limitation, the length of time the
security has been in the Account, the lack of a
replacement security acceptable to Baird or the
DDK Consultant, withdrawal and deposit activity
in
the Account, market conditions deemed
unfavorable by Baird or the DDK Consultant, or if
doing so would, in Baird’s or the DDK Consultant’s
judgment, negatively impact management of the
Account.
All Growth. An All Growth investment objective
typically seeks to provide growth of capital.
Typically, an Account pursuing an All Growth
investment objective will experience high
fluctuations in annual returns and overall market
value. Under normal market conditions, such an
Account generally invests nearly all of its assets in
equity securities. Such an Account may also hold
other types of investments.
The tax harvesting and capital gains avoidance
strategies are provided by Baird and DDK
Consultants on an Account-by-Account basis.
When employing such strategies for a client
Account, Baird does not monitor or consider the
trading activity in any other client account,
including any Account held at Baird or another
firm.
Capital Growth. A Capital Growth investment
objective typically seeks to provide growth of
capital. Typically, an Account pursuing a Capital
Growth
investment objective will experience
moderately high fluctuations in annual returns
and overall market value. Generally, under
normal market conditions, such an Account will
primarily invest in a mix of equity securities and
fixed income securities, with a significantly higher
allocation to equity securities. Such an Account
may also hold other types of investments.
A client should also note that when normal
trading activity
for the client’s
is resumed
Account, such activity could generate taxable
gains or losses.
Third Party Manager Tax Management
Services
review
the
Growth with Income. A Growth with Income
investment objective typically seeks to provide
moderate growth of capital and some current
income. Typically, an Account pursuing a Growth
with Income investment objective will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of equity securities and fixed
Some investment managers participating in the
SMA Services offer tax management services and
others do not. A client should consult the client’s
DDK Consultant or
investment
manager’s Form ADV Part 2A Brochure for specific
information.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
income securities, with a bias towards equity
securities. Such an Account may also hold other
types of investments.
investment
objective
intermediate and long term investment and/or
cash flow needs. Depending upon the investment
strategy used, an Account pursuing an
could
Opportunistic
experience high fluctuations in annual returns and
overall market value. The types of investments in
which such an Account may invest will also vary
widely, depending upon the particular investment
strategy used.
long-term growth by
investments based upon
Income with Growth. An Income with Growth
investment objective typically seeks to provide
current income and some growth of capital.
Typically, an Account pursuing an Income with
Growth
investment objective will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of fixed income securities and
equity securities, with a bias towards fixed income
securities. Such an Account may also hold other
types of investments.
in
to
implement a
typically
objective
and
overweighting
index or
Tactical. A tactical investment objective seeks to
provide
tactically and
actively adjusting account allocations to different
categories of
the
manager’s perception of how those investment
the short-term.
categories will perform
tactical
Strategies used
involve
investment
underweighting
account
allocations to certain asset classes, geographic
locations or market sectors relative to an
applicable long-term strategic asset allocation,
benchmark
the market generally.
Accounts with a tactical investment objective may
have investments focused or concentrated in
certain asset classes, geographic locations or
market sectors and they often experience higher
levels of trading and portfolio turnover relative to
accounts with other investment objectives.
Conservative Income. A Conservative Income
investment objective typically seeks to provide
current income. Typically, an Account pursuing a
Conservative Income investment objective will
experience relatively small fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, such an Account
will primarily invest in a mix of fixed income
securities, cash and equity securities, with a
significantly higher allocation to fixed income
securities. Such an Account may also hold other
types of investments.
A
Tax-Managed
indicates
that
the
account
investment
Tax-Managed.
objective
is
transitioning from one investment strategy to
another using one or more tax management
strategies or tax management considerations. The
primary investment strategy or consideration for
Accounts with a Tax-Managed
investment
objective will involve tax management, and such
accounts may not be successful in pursuing any
other investment strategies, objectives or goals.
Capital Preservation. A Capital Preservation
investment objective typically seeks to preserve
capital while generating current income. Typically,
an Account pursuing a Capital Preservation
investment objective will experience relatively
small fluctuations in annual returns and overall
market value. Under normal market conditions,
such an Account generally invests nearly all of its
assets in a mix of fixed income securities and
cash. Such an Account may also hold other types
of investments.
Goal. A Goal investment objective indicates that
the Account is a Goal Management Account that is
part of a Goal Management Plan and the Account
will be managed or advised in accordance with
the applicable Goal Management Objective.
Investment Objectives
Opportunistic. An Opportunistic
investment
objective typically seeks to provide long term
through capital appreciation and/or
growth
income by utilizing an active management style
that shifts the percentage of assets held in
various investment categories to take advantage
of the manager’s perception of market pricing
anomalies, market sectors deemed favorable for
investment by the manager, the current interest
rate environment or other macro-economic trends
identified by the manager to achieve growth while
short,
accounting
for
a
client’s
specific
For information about the risks associated with
the investment objectives described above, see
the section of the Brochure entitled “Methods of
Analysis, Investment Strategies and Risk of
Loss—Principal Risks—Risks Associated with
Certain
and Asset
Allocation Strategies” below.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
across all mutual funds in the fund family and not
on a fund-by-fund basis. Further, the expenses of
every mutual fund can and will vary over time.
Therefore, while Baird has endeavored to select
the lowest cost share classes as described above,
in some instances, the Approved Share Class is
not the least expensive share class for a particular
mutual fund. Clients may be able to obtain a less
expensive share class in other Programs or at
another firm.
payments,
revenue
sharing
the applicable mutual
Interest
Baird receives certain compensation from mutual
fund families in the form of distribution (12b-1)
fees, shareholder servicing fees, transfer agency
fees, networking fees, accounting fees, marketing
support
and
administration fees. The amount of compensation
paid to Baird generally varies based upon the
share class of
fund
purchased by clients. Because the compensation
that Baird receives from certain mutual funds is
based upon share class purchased by clients,
Baird has a financial incentive to make available
to clients those share classes that provide Baird
greater compensation, which, in many instances,
would cause clients investing in those share
classes to incur higher ongoing costs relative to
other share classes made available by the fund
families. This presents a conflict of interest. Baird
addresses this conflict through the Share Class
Policy described above and through disclosure in
this Brochure. For more information about the
compensation that Baird receives from mutual
funds, see “Code of Ethics, Participation or
Interest in Client Transactions and Personal
in Client
Trading—Participation or
Transactions—Investment Product Selling and
Servicing—Mutual Funds” below.
Shares of mutual funds held in client Accounts
that do not meet the requirements of the Share
Class Policy will generally be converted to the
applicable Approved Share Class subject to
certain restrictions. The Share Class Policy is
subject to change at Baird’s discretion without
notice to clients. Additional information about the
Share Class Policy is available on Baird’s website
at bairdwealth.com/retailinvestor.
The Share Class Policy does not apply to the
portion of a UAS Account managed by third party
managers. Third party managers are responsible
for establishing their own criteria for selecting
investments, including mutual funds, if any.
Mutual Fund Share Class Policy
Most mutual funds offer different share classes.
While each share class of a given mutual fund has
the same underlying investments, those share
classes have different fees, costs and investment
minimums, and they provide different levels of
compensation to Baird. In an effort to provide
clients with appropriate low cost mutual fund
investment options for their fee-based investment
advisory accounts, Baird has established a mutual
fund share class policy (“Share Class Policy”) for
certain DDK-directed Services, including DDK
Investment Management (the “Share Class Policy
Services”). Typically, only one share class of a
given mutual fund family will be made available
for purchase by clients in the Share Class Policy
Services pursuant to the Share Class Policy (the
“Approved Share Class”). When selecting the
Approved Share Class for a mutual fund family,
Baird endeavors to select the share class with the
lowest expense ratio, based upon the average
expense ratio of the class across all mutual funds
in the mutual fund family, that are widely
available for trading on the mutual fund trading
platform of Charles Schwab & Co.,
Inc.
(“Schwab”). In selecting the share class for a
mutual fund family to be made available for
purchase by clients in the Share Class Policy
Services, Baird considers a number of factors,
including the number of funds within the fund
family that offer the share class, client positions
in and demand
funds, and the
for those
availability of the share classes and funds for
purchase on the Schwab mutual fund trading
platform. Generally, share classes designed for
retirement plans and those that pay a distribution
(12b-1) fee to Baird will not be permitted in those
Services, or, if such share classes are permitted
and the client’s Account is subject to an asset-
based fee arrangement, Baird will either: (1)
rebate the distribution (12b-1) fees to a client if
the client is paying an asset-based Advisory Fee
on such investment; or (2) exclude such fund
shares from the calculation of the client’s asset-
based Advisory Fee (sometimes referred to as
“unbillable assets”) for such period of time that
Baird collects and retains the distribution (12b-1)
fee as further described under the heading “Code
of Ethics, Participation or Interest in Client
Transactions and Personal Trading—Participation
or Interest in Client Transactions—Investment
Product Selling or Servicing—Mutual Funds”
below. Clients should note that the Approved
Share Class for a mutual fund family is based
upon the average expense ratio for the class
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Custody Services
Baird may provide custody services in connection
with the Services. See “Custody” below for more
specific information.
household may opt out of the Bank Sweep
Feature and instead have all of their cash
balances automatically swept into an institutional
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the program. More information about the Money
Market Fund Feature of Baird’s Cash Sweep
Program is available at rwbaird.com/cashsweeps.
to provide FDIC
The Bank Sweep Feature seeks to provide FDIC
insurance protection for a client’s cash balances
up to an aggregate deposit limit determined
under the program. Any deposits, including CDs,
that a client maintains, directly or indirectly
through an intermediary (such as us or another
broker), with a bank participating in the Cash
Sweep Program in the same capacity with the
bank will be aggregated with the client’s cash
balances deposited with the bank under the Cash
Sweep Program for purposes of calculating the
$250,000 FDIC insurance limit. Total deposits
exceeding $250,000 at a bank may not be fully
insured by the FDIC. A client is responsible for
monitoring the total amount of other deposits that
the client has with a bank outside the Cash Sweep
Program in order to determine the extent of
deposit insurance coverage available. Baird is not
responsible for any insured or uninsured portion
of a client’s deposits at a bank. Cash invested in a
money market mutual fund under the Money
Market Fund Feature is not FDIC insured, but is
protected by Securities
Investor Protection
Corporation (“SIPC”) coverage up to applicable
limits.
receives
compensation
for
is
available
Cash Sweep Program
Baird maintains a Cash Sweep Program that is
intended for clients who want to earn interest and
receive FDIC insurance protection on their cash
over short periods of
time while awaiting
investment. If a client participates in Baird’s Cash
Sweep Program, uninvested cash in the client’s
accounts will be automatically deposited or swept,
on a daily basis, into one or more FDIC-insured
deposit accounts at participating banks (the “Bank
Sweep Feature”) or, under certain conditions, will
be automatically invested in shares of a money
market mutual fund that Baird makes available in
the program (the “Money Market Fund Feature”),
subject to the terms and conditions of the
program. By using multiple participating banks as
opposed to a single bank, the Bank Sweep
Feature seeks
insurance
protection for a client’s cash balances of up to an
aggregate deposit limit determined under the
program (currently, $2,500,000 for most account
types and $5,000,000 for joint accounts). A client
receives interest on cash balances in deposit
accounts under the Bank Sweep Feature at tiered
rates that are based on the aggregate value of
the accounts within the client’s household. The
applicable client household tier values are: less
than $1 million; at least $1 million but less than
$2 million; at least $2 million but less than $5
million; and $5 million are more. Current rate
at
information
rwbaird.com/cashsweeps. Each deposit account at
a bank constitutes a direct obligation of the bank
and is not directly or indirectly Baird’s obligation.
account
values
of
less. For
Any aggregate cash balances held by a client in
excess of the applicable aggregate deposit limit
are automatically invested in shares of a money
market mutual fund that Baird makes available in
the Money Market Fund feature of the program.
Cash held in employee benefit plan accounts,
employee health and welfare plan accounts, donor
advised fund accounts, and SEP and SIMPLE IRAs
will be automatically invested or swept into a
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the program. In addition, clients with aggregate
cash balances of $5 million or more across all of
their accounts with Baird within the same
the
Baird
administrative, accounting and other services that
Baird provides under the program, which is paid
out of the aggregate interest that is paid by the
participating banks on the aggregate client
balances in the deposit accounts participating in
the Bank Sweep Feature. Baird’s annual rate of
compensation may be up to 3.60% of the
for clients with
aggregate client balances
than
less
household
$1,000,000, 2.45% for clients with household
account values of $1,000,000 but less than
$2,000,000, 2.00% for clients with household
account values of $2,000,000 but less than
$5,000,000, and 1.75% for clients with household
account values of $5,000,000 or more. In a lower
interest rate environment Baird’s annual rate of
compensation will be
fee-based
investment advisory IRA accounts participating in
the Bank Sweep Feature, Baird’s compensation is
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
investment allocation advice provided to the client
and thus the amount of such cash and cash
equivalents included in the calculation of the
Advisory Fee for the client’s advisory Account.
on
website
More detailed information about the Cash Sweep
Program and the compensation Baird receives is
at
Baird’s
available
www.rwbaird.com/cashsweeps. A
client also
receives information about the compensation
Baird receives from the Cash Sweep Program
through a client’s account statements.
trust administration
trust administration, custody,
its
related
to
those assets, and
a monthly per account fee (which is the same
regardless of client balances in bank deposit
accounts). The per account fee for these advisory
IRA accounts is generally paid out of the interest
that the banks pay on aggregate client balances
in the deposit accounts, and the per account fee
varies based on the applicable Fed Funds Target
Rate but in no event will it exceed $19.00 per
month. Baird also receives an annual rate of
compensation of up to 0.50% of the aggregate
client balances automatically invested into money
market mutual funds under the Money Market
Fund Feature. A client should note that the client
will be charged the asset-based Advisory Fee on
the value of all of the assets in the client’s
Accounts, including cash that is swept into a bank
deposit account or invested into a money market
mutual fund under the Cash Sweep Program. As a
result, Baird receives two layers of fees on a
client’s assets swept or invested in the Cash
Sweep Program:
the Advisory Fee, which
compensates Baird for the investment advice,
trading and custody services provided to the
client
the
compensation paid by the banks or money market
funds related to those assets, which compensates
Baird for the services Baird provides to the banks
and funds and for Baird’s efforts in maintaining
the Cash Sweep Program. The compensation that
Baird receives from the Cash Sweep Program
gives Baird a financial incentive to recommend
that a client participate in the Cash Sweep
Program and maintain high levels of uninvested
cash balances in the client’s accounts.
any
trust
financial
incentive
to
As an alternative to the Cash Sweep Program,
Baird makes available other money market
mutual funds and other cash alternatives in which
a client may invest, often at a higher yield,
although these investments do not have an
automatic sweep feature. In addition, instead of
maintaining cash balances in an advisory Account,
a client has the option to maintain such cash
balances in a brokerage account that is not
subject to an asset-based Advisory Fee.
it
Trust Services Arrangements
Baird maintains an alliance with
certain
institutions, both non-affiliated and affiliated,
including Baird Trust Company (“Baird Trust”),
services,
that provide
including
tax
reporting and recordkeeping. DDK Consultants at
times refer clients seeking trust services to
institutions that are members of the alliance.
Subject to
fiduciary duties, the trustee
oftentimes retains Baird to provide investment
advisory services to the client trust. A client
should understand that any such referral for trust
services under the Trust Alliance Program made
by Baird and its DDK Consultants is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
oversee
services
such
arrangement. Baird has a financial incentive to
recommend that clients use Baird Trust, an
affiliate, over other non-affiliated trust companies.
As a result of this affiliation, Baird Trust also has
a financial incentive to retain Baird to provide
investment advisory or other services on behalf of
the client. In addition, Baird and DDK Consultants
have a
recommend
arrangements that involve Baird and the DDK
Consultant providing investment advisory services
to the client and the trust company only providing
trust administration services compared to an
arrangement whereby a trust company would
investment advisory and trust
provide both
is more
administration services because
profitable to Baird and the DDK Consultant.
in connection with
In addition, outside of the Trust Alliance Program,
DDK Consultants may refer a client to Baird Trust
to provide investment management and trust
A client should understand that the Cash Sweep
Program is an ancillary account service and it is
not nor is it part of any advisory program or
investment advisory service. DDK and Baird do
not act as investment adviser or a fiduciary to a
client
the Cash Sweep
Program. However, a client should note that the
amount of the client’s advisory Account dedicated
to cash and cash equivalents is part of the overall
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DDK F+C Brochure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
ongoing
Baird
Trust
generally
account value in calculating the client’s asset-
based Advisory Fee, which gives Baird and DDK
Consultants further incentive to recommend client
use of margin instead of liquidating assets to fund
a cash need. Because the interest Baird receives
and fees Baird earns on a client’s Accounts
increase as the amount of the client’s margin loan
increases, Baird and DDK Consultants also have
incentive to recommend that the client
an
continue to maintain a margin loan balance with
Baird at high levels. Baird has the right to lend
the securities a client pledges as collateral for the
client’s margin loan, and Baird receives additional
compensation for lending those securities, which
provides Baird a further incentive to recommend
margin to a client.
administration services to the client. If a client
enters into such a relationship with Baird Trust,
Baird and the client’s DDK Consultant typically
relationship management
provide
services.
provides
compensation to Baird and the client’s DDK
Consultant for the referral and providing ongoing
services, which may be up to 50% of the ongoing
fees that a client pays to Baird Trust, and which is
credited to the client’s DDK Consultant for
purposes of determining the DDK Consultant’s
compensation. The compensation paid to Baird
and a client’s DDK Consultant does not increase
the fees that the client pays to Baird Trust. Due to
Baird’s affiliation with Baird Trust and the
compensation paid to Baird and DDK Consultants,
Baird and DDK Consultants have a financial
incentive to favor Baird Trust over other trust
companies.
A client should note that Baird’s margin loan
program is generally intended to be used to fund
additional purchases of securities. or short-term
liquidity needs. If a client wishes to obtain a loan
for some other purpose, a client should instead
consider whether the client is eligible for Baird’s
Securities-Based Lending Program, which involves
clients obtaining loans from third-party lenders for
general use purposes. Baird and DDK Consultants
have a conflict to the extent they would
recommend that a client use the Baird margin
loan program instead of the Securities-Based
Lending Program because a client pays interest
and other fees to Baird instead of a third-party
lender.
visit
website
Additional important information about margin,
including the risks and margin interest rates that
apply, is set forth in the “Margin” section of
Baird’s website at bairdwealth.com/retailinvestor.
contact
loan, Baird has an
incentive
that any margin balance
(i.e.,
the
loan or
Securities-Based Lending Program
Baird offers clients an opportunity to borrow
money from a third party lender under Baird’s
Securities-Based Lending Program. These loans, if
made, can be used for any personal or business
purpose other than to purchase, carry or trade
securities, or to repay margin debt. These loans
are secured by the investments and other assets
in the client’s accounts with Baird. A client will
pay interest on the outstanding balance of the
client’s loan. The rates of interest charged by the
bank depends on many factors, such as the
prevailing interest rate environment, the amount
of
line of credit, a client’s
creditworthiness, and the aggregate assets in a
client’s Baird accounts in the client’s household
Margin Loans
Margin involves borrowing money from Baird
using eligible securities as collateral, including for
the purpose of buying securities. If a client uses
margin, the client will pay Baird interest on the
amount the client borrows. The rate of interest
that a client pays on a margin loan will be at a
base rate determined by Baird plus or minus a
specified percentage that varies based on the
outstanding debit balance of the margin loan and
the client’s household account value. Interest
rates are lower for larger debit balances and
those with higher household account balances. As
a result, rates will vary. To determine the actual
interest rate that may apply to a client’s margin
at
Baird’s
loan,
rwbaird.com/loanrates
a DDK
or
Consultant. Because a client will pay interest to
Baird on the outstanding balance of the client’s
to
margin
recommend to the client investment products and
services that involve the use of margin. Baird and
DDK Consultants also have an incentive to
recommend investment products and services
that involve the use of margin, because a margin
loan allows a client to make larger securities
purchases and retain assets
in the client’s
Accounts
that pay an ongoing asset-based
Advisory Fee instead of liquidating them to fund a
cash need, which increases the asset-based fees
Baird earns on a client’s Accounts. A client should
note
the
outstanding amounts of the margin loan the client
owes to Baird) in the client’s advisory Accounts
will not be applied to reduce the client’s billable
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Other Non-Advisory Services
Certain Baird associates from time to time may
provide clients with tax return preparation, bill
pay or related services. In some instances, the
fee for those services may be bundled with the
Advisory Fee. A client should understand that the
provision of such services is separate from, and
not related to, the Services offered under this
Brochure and will be governed by an agreement
separate from the client’s advisory agreement
with Baird. A client should understand that Baird
and its associates do not act as investment
advisor or fiduciary to the client when providing
tax return preparation, bill pay or related non-
advisory services to the client.
informing
the
financial
incentive
Client Responsibilities
A client is responsible for providing information to
Baird and the client’s DDK Consultant reasonably
requested by them in order to provide the
services selected by the client. Baird, the client’s
DDK Consultant and investment managers, if any,
will rely on this information when providing
services to the client. A client is also responsible
for promptly
client’s DDK
Consultant of any significant life changes (e.g.,
change in marital status, significant health issue,
or change in employment) or if there is any
change to the client’s investment objectives, risk
tolerance,
investment
financial circumstances,
needs, or other circumstances that may affect the
manner in which the client’s assets are invested.
None of Baird, the client’s DDK Consultant or any
investment manager managing a client’s Account
for any adverse consequence
is responsible
arising out of the client’s failure to promptly
inform the client’s DDK Consultant of any such
changes. Since investment goals and financial
circumstances change over time, a client should
review the client’s participation in a Service with
the client’s DDK Consultant at least annually.
of
website
(“relationship size”). The interest rates are based
on a benchmark
rate, plus an applicable
percentage that varies based on the approved
loan amount and the relationship size. Rates are
generally higher for smaller loans and relationship
sizes and lower for larger loans and relationship
sizes. The interest rate that will apply to a client’s
loan will be set forth in the loan agreement the
client enters into with the bank. Baird receives an
ongoing administrative fee from the bank, at an
annual rate of up to 2.50% of the outstanding
balance under a client’s loan, which is paid by the
bank out of the interest the client pays to the
bank. A client’s DDK Consultant typically receives
an ongoing referral fee at an annual rate of up to
0.25% of the outstanding balance of the client’s
loan, which is paid out of Baird’s administrative
fee. A client should note that Baird and DDK
Consultants will continue to receive compensation
on assets held in the client’s accounts that serve
as collateral for the client’s loans, including
receives an
Advisory Fees. Because Baird
administrative fee and DDK Consultants receive a
referral fee if a client obtains a loan from a third
party
lender under Baird’s Securities-Based
Lending Program, Baird and DDK Consultants
have an incentive to recommend that a client
obtain loans under that program. Baird and DDK
Consultants will continue to receive compensation
on assets held in a client’s accounts that are
collateral for such loans, including Advisory Fees
on such assets if those assets are in the client’s
advisory Account. As a result, Baird and DDK
Consultants have a
to
recommend that a client obtain a loan under the
program to provide for the client’s needs instead
of liquidating assets in the client’s accounts with
Baird because a decline in the amounts the client
has in the client’s accounts will result in lower
revenues to Baird and compensation paid to the
client’s DDK Consultant. Additional important
information about securities-based lending is set
forth in the “Securities-Based Lending Program”
section
at
Baird’s
bairdwealth.com/retailinvestor.
Retirement Accounts
Additional laws, regulations and other conditions
apply to Retirement Accounts. Each owner,
trustee, plan
sponsor, adopting employer,
responsible plan fiduciary, named fiduciary, or
other fiduciary acting on behalf of a Retirement
Account (“Retirement Account Fiduciary”) should
understand that DDK and Baird do not provide
legal advice regarding Retirement Accounts. A
Retirement Account Fiduciary is urged to consult
with his or her own legal advisor about the laws
and regulations that may apply to Retirement
A client should understand that any referral made
by Baird and DDK Consultants under
the
Securities-Based Lending Program is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
oversee any such lending arrangement.
27
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Accounts. ERISA and the IRC prohibit DDK and
Baird from offering certain types of investment
products and services to Retirement Accounts.
the Services,
the
tax
implications of
Legal and Tax Considerations
A client’s investment activities may have legal
and tax consequences to the client.
purchases,
sales,
The investment strategies used for a client’s
Account and transactions in a client’s Account,
including
liquidations,
redemptions, and rebalancing transactions, may
cause the client to realize gains or losses for
income
tax purposes. Funds often make
distributions of income and capital gains to
investors, which may cause the client to realize
income for tax purposes.
DDK and Baird do not offer legal or tax advice to
clients. The information, recommendations, and
services provided by DDK and Baird to clients
including, without
through
limitation, tax management strategies, do not
constitute tax advice. A client is responsible for
understanding
the
investment activities in the client’s accounts
(whether held at Baird or another firm) and
complying with applicable tax rules. A client is
strongly urged to consult with the client’s tax
advisor about potential tax implications before
making investment or trading decisions. DDK and
Baird do not undertake any responsibility to
monitor or verify a client’s compliance with
applicable tax rules, and they are not responsible
for any tax‑related effects or obligations resulting
from the investments or transactions in a client’s
Account.
Account Requirements
Opening an Account
Certain investment products, such as Alternative
Investments and Complex Investments, are
classified as partnerships. Clients invested in such
investment products will be treated as partners
for U.S. federal income tax purposes, which has
tax implications different from other types of
investments, including Schedule K-1 reporting.
A client that wishes to engage DDK will enter into
an advisory agreement with DDK and Baird. The
client’s advisory agreement will contain the
specific terms applicable to the services selected
by the client, Advisory Fees payable by the client,
and other terms applicable to the client’s advisory
relationship with DDK and Baird.
taxable
Clients with tax-exempt Accounts, such as certain
Retirement Accounts or charitable or religious
organization Accounts, should be aware that some
investments, such as some Non-Traditional
Assets, Alternative Investments and Complex
Investments, may produce
income,
referred to as unrelated business taxable income
(“UBTI”). In such circumstances, such clients will
be required to pay tax on the UBTI produced by
the tax-exempt Accounts.
is a brokerage agreement
In addition to the investment advisory services
that DDK and Baird provide in connection with
each Service, Baird, in its capacity as broker-
dealer, may provide clients with trade execution,
custody and other standard brokerage services.
For this reason, a client may also enter into a
client account agreement with Baird if the client
has not already done so. The client account
agreement
that
authorizes Baird to execute trades for, and
perform related brokerage and custody services
to, the client’s Account.
Baird generally requires that assets in a client’s
Account be held in a Baird account, for which
Baird acts as custodian. However, in certain
limited circumstances when requested by a client,
Baird may permit a client to include Held-Away
Assets in the client’s Account.
A client’s ability to recognize losses in an Account
for tax purposes may be disallowed, limited or
deferred by applicable tax rules. For example, IRS
wash sales rules will disallow a client’s tax
deductions for a loss in an Account related to the
sale of an investment if the client purchases
(whether through Baird or another firm) a
“substantially identical” investment within the
wash sale period (currently 30 days before or 30
days after the date of the sale). Similarly, IRS
straddle rules limit and defer a client’s ability to
claim tax deductions related to the loss on a sale
of an investment in an Account if the client holds
an offsetting position in any account held at Baird
or another firm.
After a client has signed and delivered an
advisory agreement to Baird, the agreement is
subject to review and acceptance by the client’s
DDK Consultant, his or her Market Director or
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Account Contributions and Withdrawals
in
to
investment manager until
A client may fund an Account with cash and with
securities that DDK, Baird and the client’s
to be
if any, deem
investment manager,
acceptable
their sole discretion. Funds
deposited or transferred to a client’s SMAs from
another Baird account and funds deposited or
transferred to a client’s SMAs from outside of
Baird will not be available for investment by the
client’s
the next
business day and therefore the investment of
such funds, at the discretion of the manager, will
occur no earlier than the next business day.
PWM Supervision department supervisor (or his or
her respective designee), and Baird PWM’s Home
Office. The agreement and Baird’s advisory
relationship with a client will become effective
when the client’s paperwork is accepted by Baird
PWM’s Home Office and following such acceptance
Baird has delivered
the client written
confirmation of the Account’s enrollment in the
applicable Service. A client should understand
that the advisory agreement will not become
effective, and Baird will not provide any advisory
services to the client, until such time that Baird
has accepted the advisory agreement. Baird may
delay acceptance of the advisory agreement and
the provision of advisory services to the client for
various reasons, including deficiencies in the
client’s paperwork. Once it has become effective,
the agreement shall continue until it is terminated
in accordance with the terms described in the
advisory agreement.
certain
retain
those documents
for
The terms of a client’s agreements and this
Brochure apply to all Accounts that a client
establishes with DDK, including any Accounts that
a client may open with Baird in the future. Some
of the information in those documents may not
apply to a client now, but may apply in the future
if a client changes services or establishes other
Accounts with DDK. DDK will generally not
provide a client another copy of the agreements
or this Brochure when a client changes services or
establishes new Accounts unless
the client
requests a copy from DDK. Therefore, a client
should
future
reference as they contain important information if
a client changes services or establishes other
Accounts with DDK.
Certain Account Requirements
Minimum Account Size
Some DDK Consultants will invest, or recommend
investing, cash contributions made to an Account
over a period of time. This method of investment
is sometimes referred to dollar cost averaging
(“DCA”). The goal of this method of investment is
to reduce the risk of making large purchases of
securities at an inopportune time or price. The
investment
and
Overlay Manager
managers also offer an optional DCA service for
Accounts they manage. Additional information will
be provided to a client if the client enrolls in a
DCA service. A client should note that, if dollar
cost averaging is used to invest cash in the
client’s Account, the returns for the Account
could, depending upon market and other
conditions, be lower than the returns that could
have been obtained had all the cash in the
Account been fully invested upon contribution to
the Account. In addition, a client should note that,
when dollar cost averaging is used, the amount of
cash in the client’s Account will be included in the
value of the Account for fee calculation purposes.
Whenever assets are contributed to an Account, a
client should discuss with the client’s DDK
Consultant the timing of when the assets will be
invested. If DCA will be used to invest the assets,
a client should ask for more specific information
about how the assets will be invested and the
associated timing for investing.
Each Service has a minimum account size and
may have a minimum Advisory Fee, which are
described in the section entitled “Fees and
Compensation—Advisory Fees” below. DDK or
Baird may remove an Account from a Service and
immediately terminate the advisory agreement
with respect to an Account upon written notice to
the client if the client fails to maintain the
required minimum asset levels in an Account or if
the client fails to otherwise abide by the terms of
a Service as determined by DDK or Baird in their
sole discretion.
that
When a client funds an Account with securities,
including when a client changes Services for an
Account or changes investment managers for an
Account within the same Service, the client should
understand that DDK’s, Baird’s or the client’s
investment manager’s review of securities used to
fund the Account may delay
investing. In
addition, DDK, Baird or the client’s investment
manager,
the
if any, may determine
securities contributed to the Account may not be
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
A client may also incur additional expenses and
liabilities, including tax related liabilities, when
transferring assets out of an Account or Baird’s
custody. See “Termination of Accounts” below.
Liens and Use of Account Assets as Collateral
sale
could
in adverse
As security for the full and complete payment
when due of any debts and other obligations that
a client owes to DDK and Baird, and to the extent
permitted by applicable law or regulation, all
assets in a client’s Account held at Baird will be
subject to a first priority security interest, lien and
right of setoff in favor of Baird. Baird may sell
assets in an Account to satisfy the lien. As a
secured party, Baird may have interests that are
adverse to a client. Neither DDK nor Baird will act
as investment adviser to a client with respect to
such sale of assets held in an Account. Any such
sale of assets will be executed in Baird’s capacity
as broker-dealer and creditor and may, as
permitted by law, result in executions on a
principal basis. Such sales could have adverse tax
consequences, disrupt a client’s
investment
strategy, and have an adverse impact on the
Account’s performance. A client should review the
client’s agreements for more information.
appropriate for the client’s strategy, and DDK,
Baird or the investment manager, if any, may
sell, or recommend the sale of, such securities.
Further, an investment manager may be removed
from the management of a client’s Account and a
replacement
investment manager may be
appointed. In such event, Baird, at the direction
of the client’s replacement manager, or the
client’s replacement manager may sell all or a
portion of the securities or other investments in
the Account that were managed by the prior
manager and the replacement manager will
reinvest the cash proceeds of those sales. Any
such
tax
result
consequences for the client. A client should note
that securities transferred into an Account may be
subject to the Advisory Fee immediately upon its
transfer into the Account, even if the client paid a
commission or front-end sales charge on the
security prior to its transfer into the Account. In
addition, if the securities are subject to deferred
sales charges or redemption fees, the client will
be responsible for paying those charges and fees.
To the extent permitted by applicable law, certain
funding transactions may be handled by Baird on
a principal basis, and such transactions are not
considered investment advisory services of DDK,
Baird or the client’s investment manager.
All of the assets in a client’s Account must be free
and clear from any security interest, lien, charge
or other encumbrance (other than a security
interest, lien, charge or other encumbrance in
favor of Baird) and must remain so for the
duration of the client’s relationship with Baird,
unless Baird otherwise specifically agrees in
writing.
Business—Additional
If an asset transferred to an Account is an
Unpermitted Investment under the terms of the
applicable Service, DDK, Baird or the client’s
investment manager may sell the asset or
transfer it into a separate brokerage account.
Alternatively, they may designate such asset as
an Unsupervised Asset as further described under
“Advisory
Service
Information—Unsupervised Assets” above.
If a client wishes to obtain loans secured by
assets in the client’s Account (commonly referred
to as “securities-based lending”) and DDK and
Baird agree to the arrangement, the client should
understand that the lender may exercise certain
rights and powers over the assets in the Account,
including the disposition and sale of any and all
assets pledged as collateral for the loan to meet a
collateral call, which may occur without prior
notice to the client. A collateral call could have
adverse tax consequences, disrupt a client’s
investment strategy, and have an adverse impact
on the Account’s performance. A client should be
aware of these and other potential adverse effects
of securities-based lending and collateralizing
Accounts before deciding to do so.
A client is responsible for notifying DDK and any
investment manager managing
the client’s
Account of any contributions made into the
Account and instructing DDK and any investment
manager to liquidate positions in the event the
from the
client wishes to withdraw assets
Account. DDK and Baird have no responsibility to
invest cash deposits (other than complying with a
client’s cash sweep instructions) or liquidate
positions with respect to an Account managed by
an Other Manager, and they are not responsible
for any losses that may result from a client’s
failure to notify DDK and any investment manager
managing the client’s Account regarding deposits
or withdrawals.
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
A client is required to disclose the terms of the
client’s agreements with Baird to any lender
seeking to use Account assets as collateral. A
client must promptly notify DDK and Baird of any
default or similar event under the client’s
collateral arrangements.
any such change or, if Baird determines that it is
unable to continue to provide advisory services to
the client, Baird may remove the applicable
Account from a Service or Program and convert
the Account to a brokerage account upon notice
to the client.
DDK or Baird may remove an Account from a
Service and immediately close an Account upon
written notice to a client if the client fails to abide
by the terms of the Service. DDK or Baird may
also remove an Account from a Service at any
time upon written notice to a client if the client
fails to maintain the required minimum asset
levels in such Account.
A client should understand that neither DDK nor
Baird will provide advice on or oversee a
securities-based lending or collateral arrangement
and they will not act as investment adviser or a
fiduciary to the client with respect to the
liquidation of securities held in the client’s
Account to meet a collateral call. Any such
liquidation will be executed in Baird’s capacity as
broker-dealer and may, as permitted by law,
result in executions on a principal basis.
“Additional
In some instances, Baird and DDK Consultants
may refer a client to a third party lender under
Baird’s Securities-Based Lending Program that
certain
pays Baird and DDK Consultants
compensation.
Service
See
Information—Securities-Based Lending Program”
above for more information.
exclusive
responsibility
to
Business—Additional
in
writing,
Upon the termination of an Account’s enrollment
in a Service, DDK, Baird and, if relevant, any
other
investment manager managing such
Account, shall have no obligation to act as
investment adviser to such Account. If such
Account is custodied at Baird, the Account shall
be converted to and designated as a brokerage
account. DDK, Baird, and, if relevant, any other
investment manager managing such Account,
shall be under no obligation to recommend any
action with regard to, or to liquidate the securities
or other investments in, such Account. After an
Account is removed from a Service, it is the
issue
client’s
the
regarding
instructions,
management of any assets in such Account.
Securities purchased on margin are used as
Baird’s collateral for the margin loan. Clients that
have a margin account should review the section
“Advisory
Service
Information—Complex Strategies and Complex
Investment Products” above
for additional
information.
Electronic Delivery of Documents
By signing an advisory agreement, a client
consents to the electronic delivery of documents
that DDK or Baird may deliver to the client. The
term of the consent to electronic delivery is
indefinite but a client may revoke the consent at
any time by notifying DDK.
Termination of Accounts
If a client directs Baird to liquidate assets in
connection with a closure of an Account, the client
should understand that Baird acts as broker-
dealer, and not
investment adviser, when
processing such a liquidation request and that the
client will generally be charged commissions,
sales charges, sales “loads”, or other applicable
transaction-based fees in accordance with the
applicable Baird fee schedule or other third-party
transaction-based fee schedule for the particular
investment then in effect. Additional information
about the compensation that a client pays to
Baird for effecting brokerage transactions is
contained in Baird’s Client Relationship Details
document, available on Baird’s website at
bairdwealth.com/retailinvestor.
A client may incur significant expenses and
liabilities, including tax-related liabilities for which
the client will be solely liable, if the client closes
an Account, terminates an advisory agreement, or
The client’s advisory agreement will survive any
event that causes the client’s DDK Consultant to
be unable to provide services to the client (either
on a temporary or permanent basis), including if
the client’s DDK Consultant ceases
to be
employed by Baird. In any such event, Baird will
endeavor to continue to provide services to the
client and will as promptly as practicable assign
another DDK Consultant or Baird Financial Advisor
to the client’s Accounts (either on a temporary or
permanent basis) and the client will be notified of
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
transfers assets out of Baird’s custody. DDK and
Baird will not be liable to a client in any way with
respect to the termination, closure, transfer or
liquidation of the client’s Accounts.
The typical asset-based fee varies depending
upon the Service and the fee option selected by
the client. Fee options and rates may also differ
among different Accounts held by the same client,
depending on the services selected
for an
Account.
All new client Accounts paying an asset-based fee
are generally subject to a unified advice fee
arrangement (“Unified Advice Fee Arrangement”),
which is described below.
Unified Advice Fee Arrangement
Some of the investments offered in connection
with the Services contain restrictions that limit
investments may be
their use, and such
unavailable for purchase or holding outside of an
Account. For example, certain mutual funds, ETFs
or other Funds held in an Account may only be
available to a client through a DDK Service or
may not be held at another firm. If such
restrictions apply and the client terminates a
Service or closes an Account, the Client will be
required to sell or redeem such Funds or
exchange them for other Funds that may be more
costly to the client or have poorer performance. A
client should consider restrictions applicable to
investments carefully before participating in a
Service. A client should contact the client’s DDK
Consultant for specific information as to how
Account closure, termination of an agreement, or
asset transfers might impact the assets in the
client’s Accounts.
Under a Unified Advice Fee Arrangement, the
asset-based Advisory Fee is comprised of an
advice fee (“Advice Fee”) and, for some Services,
an additional portfolio fee (“Portfolio Fee”). The
Advice Fee covers certain investment advisory
and custody services provided by DDK and Baird.
The Portfolio Fee covers portfolio management
and other services provided by Baird and the
manager to the client’s Account, which may
include departments or affiliates of Baird. If a
client has a Unified Advice Fee Arrangement, the
client’s Advisory Fee rate will be equal to the sum
of the applicable Advice Fee rate and the
applicable Portfolio Fee rate, if any.
Clients with a Unified Advice Fee Arrangement
generally choose a tiered fee schedule for the
Advice Fee portion of the Advisory Fee.
Tiered Advice Fee Schedule
following
fee schedule sets
tiered Advice Fee rates
forth
for
the
the
The
maximum
Services.
Fees and Compensation
Advisory Fees
Fee Options and Fee Schedule
A client’s advisory agreement will set forth the
actual compensation the client will pay to Baird.
In most instances, a client pays an ongoing
Advisory Fee based upon the value of assets in
the client’s Account (an “asset-based
fee”),
although other options, such as a flat fee, are
available.
Asset-Based Fee Arrangement
Tiered Advice Fee Schedule
fee
Value of Assets
Annual Fee Rate
DDK generally offers one asset-based
arrangement: a tiered fee schedule.
On the first $10 million
Negotiable
On next $15 million
0.60%
On next $25 million
0.45%
On next $25 million
0.30%
On next $25 million
0.15%
Above $100 million
Negotiable
Under a tiered fee schedule, the asset-based fee
will vary for different segments of client assets,
gradually decreasing as the Account balance
increases. For example, a client with an Account
value of $50 million may pay one rate on the first
$10 million of assets in the Account, a lower rate
on the next $15 million of assets in the Account
and a still lower rate on the remaining $25 million
of assets. Use of a tiered fee schedule will result
in a blended asset-based fee rate.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Portfolio Fee Schedule
Funds or other investment products used in
connection with a strategy, the costs of which are
borne by a client in addition to the Advisory Fee.
See “Other Fees and Expenses” below.
following
fee schedule sets
forth
The Portfolio Fee
rate varies by Service,
investment vehicle, and the type of investment
strategy or style being pursued by the Account.
The
the
maximum Portfolio Fee rates or range of rates for
the Services.
Portfolio Fee Schedule
Service
Annual Fee Rate
or Range of Rates
titled
“Administrative
DDK Investment
Management
0.00%
DDK Recommended
Managers
In some instances, Baird provides operational and
administrative services to third party managers in
connection with their management of client
Accounts. As compensation for those services,
Baird receives a portion of the Portfolio Fee at an
annual rate of up to 0.02% of the value of the
Account. Additional information is contained in the
Servicing,
document
Revenue Sharing, and Other Third Party
Payments” available on Baird’s website at
bairdwealth.com/retailinvestor.
0.20% - 0.75%
Equity SMA Strategies
0.20% - 0.52%
Balanced SMA Strategies
0.25% - 0.40%
Fixed Income SMA Strategies
0.25% - 0.52%
Global and International SMA
Strategies
0.35% - 0.60%
Alternative SMA Strategies
0.10%
Tax Managed Strategies
Baird SMA Network (BSN)
0.22% - 0.77%
Equity SMA Strategies
0.22% - 0.52%
Balanced SMA Strategies
0.10% - 0.27%
Fixed Income SMA Strategies
0.27% - 0.52%
Global and International SMA
Strategies
Certain managers offer lower Portfolio Fee rates
for SMA Strategies to clients through the DC
Program compared to the DDK Recommended
Managers or BSN Programs. If a client has
decided to participate in the DC Program, upon
the client’s request, the client’s DDK Consultant
may assist the client with the client’s negotiation
with the manager of the Portfolio Fee rate for the
applicable SMA Strategy. The Portfolio Fee
negotiated by the client could be higher or lower
than the Portfolio Fee that applies to the same
SMA Strategy that is available through other
Services. The client is ultimately responsible for
understanding the differences between the SMA
Programs, deciding to participate in the DC
Program, selecting
the SMA Strategy, and
negotiating and agreeing to the Portfolio Fee rate.
0.37% - 0.77%
Alternative SMA Strategies
Flat or Hourly Fee Arrangement
—1
Dual Contract (DC)
1 Fees charged by managers under the DC Program are
negotiated by each client pursuant to a separate
agreement that does not include Baird. Baird, therefore,
does not have the necessary information to provide a
definitive range of fees paid to managers under the DC
Program.
Under a flat fee or hourly fee arrangement, the
applicable fee may be determined according to a
fixed asset-based or hourly fee rate or may be a
fixed dollar amount. Specific services may each
have their own, separately-stated, flat fee, or
several services may be grouped together under a
single flat fee. Some services may entail a flat fee
per usage. Flat fees are negotiable and vary by
client. The details of flat fee arrangements,
including fee amounts, the billing schedule, and
the services covered, will be included in the
client’s advisory agreement.
The Portfolio Fee rates are current as of the date
of this Brochure. A client’s actual Portfolio Fees
could be higher or lower than the amounts shown
above if Baird adds new investment managers to
the Services with higher or lower fees or if Baird
and a manager renegotiate the amount of the
subadvisory fee.
Service Account Minimums
The minimum asset value to open an Account in a
Service is set forth in the table below.
The Advice Fee and Portfolio Fee rates do not
reflect the internal fees and expenses of any
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Account Minimum
Service
Asset Level
Consulting Services
Negotiable
Baird SMA Network
$100,000(1)
DDK Investment Management
$50,000
DDK Recommended Managers
$100,000(1)
Dual Contract
$100,000(1)
If requested by a client and approved by Baird, a
client’s Advisory Fee may be determined by also
including the aggregate value of assets in certain
other Advisory accounts held by a client and
certain members of the client’s household or
family (a “household fee arrangement”). A client
should note that Retirement Accounts may not be
included in a household fee arrangement to the
extent a prohibited transaction under ERISA or
the IRC may result. The terms of any such
household fee arrangement will be set forth in the
client’s advisory agreement.
(1) BSN Fund Strategist Portfolios have a minimum
account requirement of $10,000. Other SMA
Strategies typically have an account minimum of
$100,000. However, each investment manager sets
its own minimum account size requirements, which
can range from $25,000 to more than $1,000,000.
As a result, some investment managers may not be
available to clients with smaller accounts.
A client’s Account may also be subject to a
minimum quarterly Advisory Fee that will be set
forth in the client’s advisory agreement regardless
of the value of the assets in the client’s Account.
In addition, if a third party custodian has custody
of the client’s Account assets, Baird may impose
Account requirements different than those set
forth above, including but not limited to higher
minimums, and it may impose additional fees due
to the increase in resources needed to administer
the Account.
While DDK and Baird may perform an analysis as
to whether any client Accounts may be eligible for
a household fee arrangement, a client should note
that it is client’s sole responsibility to inform the
client’s DDK Consultant that client’s household or
family has two or more Advisory accounts that
are eligible for a household fee arrangement. DDK
and Baird do not undertake any obligation to
ensure client Accounts are eligible for a household
fee arrangement. By agreeing to a household fee
arrangement, each client subject
to such
household fee arrangement consents to DDK and
Baird providing to each other client subject to
such household fee arrangement, in DDK’s or
Baird’s sole discretion, information about the
aggregate level, or range, of household assets
used for fee calculation purposes. As a result,
each such client should understand that the other
clients included in the household fee arrangement
may be able to ascertain the amount of the
client’s assets at Baird.
A client is encouraged to periodically review with
the client’s DDK Consultant the client’s Advisory
Fee and the services provided to determine if the
services and fees continue to meet the client’s
needs.
Calculation and Payment of Advisory Fees
Baird will calculate a client’s Advisory Fee by
applying the applicable fee rate to the value of all
of the assets in the client’s Accounts, including
cash and its equivalent and including all Held-
Away Assets, unless otherwise agreed to in
writing. Liabilities held in a client's Accounts,
including the value of margin debit balances, open
short sale positions and open options positions
with a negative market value will be excluded
from the calculation of a client's Advisory Fee. The
value of cash balances held in a client’s Account
will be excluded from the calculation of a client's
Advisory Fees in an amount equal to the value of
any open short sale positions and options
positions with a negative market value held in the
margin account.
For purposes of calculating a client’s asset-based
Advisory Fee, the value of a client’s assets is
generally determined by Baird. Baird generally
relies upon third party sources, such as third
party pricing services when valuing Account
assets. In some instances, such as when Baird is
unable to obtain a price for an asset from a
pricing service, Baird may obtain a price from its
trading desk or it may elect to not price the asset.
Obtaining a price from its trading desk may
present a conflict of interest. In some cases, Baird
obtains prices from the issuers or sponsors of
investment products in the client’s Account when
prices are not otherwise readily available. This
frequently occurs with respect to the valuation of
annuities and Complex Investment Products. If
the assets in the client’s Account are held by a
custodian other than Baird, Baird may also use
valuation information provided by the client’s
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
third party custodian in determining the value of
the assets in the client’s Account.
The Account value used for the Advisory Fee
calculation may differ from that shown on a
client’s Account statement or performance report
due to a variety of factors, including the client’s
use of margin, options, short sales, and other
considerations. If a client has assets held by a
third party custodian, the prices shown on a
client’s Account statements provided by the
custodian could be different from the prices
shown on statements and reports provided by
Baird. See “Custody” below for more information.
is unreliable. Valuation data
third party pricing services,
the
Neither DDK nor Baird conducts a review of
valuation information provided by third party
pricing services, issuers, sponsors, or custodians,
and they do not verify or guarantee the accuracy
of such information. DDK and Baird do not accept
responsibility for valuations provided by third
parties that are inaccurate unless they have a
reason to believe that the source of such
valuations
for
investments, particularly annuities and Complex
Investment Products, may not be provided to
Baird in a timely manner, resulting in valuations
that are not current. The prices obtained by Baird
from
issuers,
sponsors and custodians may differ from prices
that could be obtained from other sources.
Values used for fee-calculation purposes may vary
from prices received in actual transactions and
are not firm bids, offers or guarantees of any type
with respect to the value of assets in an Account,
and the Advisory Fee for some securities may be
calculated based on values that are greater than
the amount a client would receive if the securities
were actually sold from the client’s Account.
A client’s Advisory Fees are payable in accordance
with the terms of the client’s advisory agreement.
Typically, Advisory Fees are payable on a calendar
quarterly basis, in advance. The initial billing
period begins when
client’s advisory
agreement is accepted by Baird and the Account
is opened by Baird (the “Opening Date”). The
initial Advisory Fee payment will be adjusted for
the number of days remaining in the then current
quarter. The initial Advisory Fee will be based on
the value of assets in the client’s Account on the
Opening Date. The period which such payment
covers shall run from the Opening Date through
the last business day of the then current calendar
quarterly billing period. Thereafter, the quarterly
Advisory Fees shall be calculated based upon the
Account’s asset value on the last business day of
the prior calendar quarter and shall become
payable on the first business day of the then
current calendar quarter.
As mentioned above, Baird will include cash and
cash equivalent balances in a client’s Account
when calculating a client’s asset-based Advisory
Fee. Baird has adopted internal policies that
monitor the percentage of an Account swept into
cash under the Cash Sweep Program. These
internal policies are designed to inform DDK
Consultants and their clients who hold large cash
sweep balances in their Accounts for sustained
periods that those Accounts are holding large
cash sweep balances and that there may be other
investment or account options for their cash and
that Baird receives direct compensation
in
addition to the Advisory Fee from client balances
in the Cash Sweep Program.
the
client’s Account may
A client’s Advisory Fees and other charges will be
automatically deducted from the client’s Account,
unless the client requests, and DDK and Baird
agree, to an alternate arrangement, such as
having Baird issue the client an invoice for the
Advisory Fees (“direct billing”). A client should
understand that the client’s Advisory Fees and
other charges relating to the client’s Account may
be satisfied from free credit balances and other
assets in the client’s Account. If free credit
balances in a client’s Account are insufficient to
pay the Advisory Fees or other charges when due,
investment manager
DDK, Baird and any
managing
sell
investments from the client’s Account to the
extent they deem necessary and appropriate, in
their sole discretion, to pay the client’s Advisory
Fees and other charges.
If a client maintains a debit balance in the client’s
margin account with Baird, such balance has no
bearing on the asset-based Advisory Fees charged
on client’s Account. In other words, the margin
balance (i.e., the outstanding amounts of the
margin loan a client owes to Baird) in client’s
Account will not be applied to reduce the client’s
billable Account value in calculating the Advisory
Fee.
If a client’s Account is subject to direct billing, the
client is required to pay each bill within 30 days of
the date of the invoice. DDK and Baird may
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
schedule above. The fees paid by a client may
differ from the fees paid by other clients based on
a number of factors, including but not limited to
the factors identified above.
automatically deduct a client’s Advisory Fees and
other charges from the client’s Account as
described above in the event that Baird does not
receive payment from the client within 30 days of
the date of the invoice. DDK or Baird may rescind
a direct billing arrangement with a client at any
time. Direct billing may not be available for
Retirement Accounts.
To the extent permitted by applicable law, DDK or
Baird may modify a client’s existing fees and
other charges or add additional fees or charges by
providing the client with 30 days’ prior written
notice.
The fee schedule set forth above is the current
fee schedule for the Services. Each Service has
had other fee schedules in effect, which may
reflect fees that are lower or higher, as the case
may be, than those shown above. As new fee
schedules are put into effect, they are made
applicable only to new clients, and fee schedules
applicable to existing clients may not be affected.
Therefore, some clients may pay different fees
than those shown above.
Obtaining Services Separately: Brokerage or
Advisory? Factors to Consider
Baird offers brokerage accounts and other
services to clients, and certain services provided
to a client in connection with a particular Service
may be available to a client outside of the Service
separately. Thus, a client’s participation in a
Service could cost the client more or less than if
the client purchased each service separately. A
number of factors bear upon the relative cost of
each Service. In comparing the Services to
brokerage accounts or other services, a client
should consider a number of factors, including,
but not limited to:
If DDK, Baird or the client terminates the client’s
advisory agreement or the client’s participation in
a Service, a pro-rated refund from the date of
termination through the end of the applicable
billing period will generally be made to the client
in the client’s affected Accounts. DDK and Baird
will not implement a decrease in the client’s fee
rate during a billing period or otherwise reimburse
or adjust Advisory Fees during any such period for
asset value appreciation or depreciation in a
client’s Account during such period. For example,
if a client’s Account is subject to a tiered or
breakpoint fee schedule and the asset levels of
the Account move into a new tier or cross a
breakpoint during such period, no rebate or fee
adjustment will be made. However, DDK and
Baird, in their sole discretion, may make fee
adjustments in response to asset fluctuations in a
client’s Account occurring during a billing period
that result from contributions to, or withdrawals
from, the client’s Account.
• whether a client prefers to have ongoing
monitoring, investment advice or professional
management of the client’s investments, which
are provided to Service Accounts, or whether
the client does not want or need such services;
• whether the types of investment strategies,
products and solutions the client seeks are
available;
The minimum asset value in order to retain the
services of DDK is $10 million, and a minimum
annual Advisory Fee of $60,000 may be assessed
to a client regardless of the level of assets
advised by DDK. DDK may waive the minimum
asset value or minimum Advisory Fee at its
discretion. The minimum Advisory Fee is subject
to change upon notice to the client.
• whether there are limitations on the types of
securities and other investments available for
purchase and whether those limitations are
significant to the client;
• whether the nature and level of transaction
services, account performance reporting, or
other ancillary services the client wants are
available;
• whether the client prefers to pay an ongoing
Advisory Fee for continuous advice or pay
The Advisory Fee and minimum account value are
negotiable in certain instances and may vary
based upon a number of factors, including but not
limited to the size and nature of the assets in the
client’s Account, the client’s particular investment
strategy or objective, and any particular services
requested by the client. In some instances, clients
may pay a higher fee than indicated in the fee
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
commissions and other fees on a transaction-
by-transaction basis;
• the relative costs and expenses of a Service
Account and a brokerage account, which will
vary depending upon:
fee or commission rate
the client
o the
negotiates;
o the size of the client’s account;
o the level of trading activity and size of trade
orders;
Client Accounts are generally subject to a Unified
Advice Fee Arrangement in which the Advisory
Fee consists of an Advice Fee and a separate
Portfolio Fee. Baird pays the manager out of the
Portfolio Fee paid by the client. The Portfolio Fee
rates are set forth under “Fee Options and Fee
Schedules—Unified Advice Fee Arrangement—
Portfolio Fee” above. However, Baird, in many
instances, retains a portion of the Portfolio Fee
when a client’s Account is managed by an Other
Manager. The maximum portion of the Portfolio
Fee retained by Baird in those instances is equal
to an annual rate of 0.10% of the value of a
client’s Account. Such amounts are retained by
Baird for the services it provides.
o applicable account fees and charges;
o the client’s use of third party managers who
charge their own fees for managing accounts
in addition to DDK’s Advice Fee; and
As the portion of the Advisory Fee or Portfolio Fee
paid to an Other Manager increases, the portion
of the Advisory Fee or Portfolio Fee that is
retained by Baird decreases. Thus, Baird (but not
DDK) has an incentive to recommend or favor
investment managers that are paid less, because
Baird will receive a higher portion of the Advisory
Fee or Portfolio Fee.
o the amount of the client’s account invested in
investment products that have additional
internal ongoing operating fees and expenses
(e.g., Funds).
Additional important information about brokerage
accounts and facts to consider when making
account type decisions is contained in the Client
Relationship Details document, which should have
been delivered to the client and is available on
Baird’s website at bairdwealth.com/retailinvestor.
In addition, Baird has an incentive to favor
Associated SMA Strategies over other SMA
Strategies because the entire Advisory Fee is
retained by Baird and Associated Managers and
because Baird benefits from its receipt of Advisory
Fees and the overall success of Associated
Managers. For more information, see “Other
Financial Industry Activities and Affiliations”
below.
A client should review other account types and
programs with the client’s DDK Consultant to
determine whether they are more appropriate or
should be used in addition to a Service.
Advisory Fee Payments to Baird, DDK
Consultants and Investment Managers
DDK and Baird and Associated Managers benefit
from the Advisory Fees and charges that clients
pay for the services described in this Brochure.
to
Fee or
subadvisory
Baird retains the entire Advisory Fee paid by
clients, except as further described below. With
respect to SMA Strategies available under the
SMA Programs managed by Other Managers,
Baird pays Other Managers (including Associated
Managers and Implementation Managers, if any)
a Portfolio
fee as
compensation for the manager’s services as
further described below.
A DDK Consultant is primarily compensated on a
monthly basis based upon a percentage of the
DDK Consultant’s total production each month,
which primarily consists of the total advisory fees
and transaction-based fees paid to Baird by the
DDK Consultant’s clients and any other fees Baird
earns on advisory and brokerage accounts held by
those clients, including trail fees paid by third
parties. The percentage of the DDK Consultant’s
the DDK
total production actually paid
Consultant will increase as the total amount of the
DDK Consultant’s production increases, meaning
that, as the total amount of the DDK Consultant’s
production increases, the rate and amount of
compensation that Baird pays to the DDK
Consultant also
increase. DDK Consultants
generally also receive deferred compensation or
bonuses based on various criteria, including net
new assets they gather, performing certain wealth
management activities, such as financial planning,
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
recognition
trips
for
achievement
of
and their total production levels. DDK Consultants
who achieve certain production thresholds are
eligible for professional development conferences,
business development coaching, reimbursements,
awards and
to attractive
destinations. DDK Consultants are also eligible for
bonuses
professional
designations depending on a DDK Consultant’s
total production level. Thus, DDK Consultants
have a general incentive to generate financial and
other plans and charge higher fees for advisory
accounts and recommend larger investments in
advisory accounts.
include
invitations
in
the
Given the structure of their compensation, they
also have an incentive to recommend that a client
transfer the client’s accounts to Baird, establish
new accounts with Baird (including IRA rollovers)
and add more money into the client’s accounts. In
addition, most DDK Consultants are shareholders
of Baird Financial Group, Inc. (“BFG”), Baird’s
ultimate parent company, and thus benefit
financially from the overall success of Baird and
its Associated Parties. The number of shares of
BFG stock that a DDK Consultant may purchase is
based in part on the DDK Consultant’s total
level. DDK Consultants generally
production
receive compensation for referrals to certain
affiliated managers and products and for referrals
to a limited number of other firms. More specific
information is provided under the headings “Other
Financial Industry Activities and Affiliations” and
“Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading—Participation
or Interest in Client Transactions” below. They
also generally receive non-cash compensation and
other benefits from Baird and from sponsors of
investment products with which Baird does
business. Such non-cash compensation and other
to attend
benefits may
conferences or educational seminars, payment of
related travel,
lodging and meal expenses,
reimbursement for branch and client events, and
receipt of gifts and entertainment. Receipt of such
compensation and benefits provides DDK
Consultants an incentive to favor investment
products and their sponsors that provide the
greatest levels of compensation and benefits.
to DDK Consultants
Baird or on the level of the DDK Consultant’s
client assets at the prior firm. All or a substantial
portion of the special compensation is paid in the
form of an upfront bonus when the DDK
Consultant joins Baird, and the remaining portion,
if any, is paid in the form of back end bonuses
generally in equal installments on an annual basis
thereafter
for a certain number of years
(generally from one to three years). Installment
payments are generally contingent upon the DDK
Consultant achieving annual production or client
asset levels that exceed a significant percentage
of the DDK Consultant’s annual production for the
1-year period prior to joining Baird or the client
assets that the DDK Consultant had prior to
joining Baird. The special compensation
is
intended to compensate DDK Consultants for the
significant effort involved in transitioning their
business from the prior firm. This compensation
provides DDK Consultants who have left another
firm additional incentive to recommend that
clients of the prior firm become Baird clients and
to recommend investment products and services
that increase their production, and thus presents
a conflict of interest. The special compensation is
generally structured in the form of a forgivable
loan from Baird to the DDK Consultant. Under the
terms of the forgivable loan, Baird makes the
upfront or installment payment to the DDK
Consultant in the form of a loan, and Baird
forgives a portion of the loan made to the DDK
Consultant each month for so long as the DDK
Consultant remains Baird’s employee. Should the
DDK Consultant cease to be Baird’s employee
prior to the maturity date of the loan, the DDK
Consultant is required to repay Baird the amount
of the loan outstanding and not forgiven by Baird.
In other words, upon leaving Baird, the DDK
Consultant would be required to repay to Baird a
portion of the special compensation that the DDK
Consultant had received and that had not been
forgiven. The amount of such repayment declines
over time in proportion to the time the DDK
Consultant remains Baird’s employee. Structuring
form of
this special compensation
forgivable loans provides the DDK Consultant
added incentive to remain Baird’s employee and
to recommend that persons become and remain a
Baird client. Additional information about referral
and non-cash compensation and other financial
incentives provided
is
provided under the heading “Code of Ethics,
Participation or Interest in Client Transactions and
in
Personal Trading—Participation or Interest
Client Transactions” below.
DDK Consultants generally receive recruitment
bonuses and/or special compensation from Baird
when they join Baird from another firm. The
amount of such special compensation is typically
based on the DDK Consultant’s production at the
prior firm for the 1-year period prior to joining
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
refer
In
those
their clients
instances,
From time to time, Baird DDK Consultants outside
to DDK
of DDK may
Consultants.
the DDK
Consultant generally shares a portion of his or her
compensation with the referring Baird Financial
Advisor.
website
Additional Account Fees and Charges
If the client’s Account is custodied at Baird, the
client is also responsible for all applicable account
fees and service charges Baird may impose in
connection with the client’s agreements with
Baird. A schedule of fees and service charges is
available
at
Baird’s
on
bairdwealth.com/retailinvestor.
Baird addresses the conflicts described above
through disclosure in this Brochure and by
adopting internal policies and procedures for DDK
and Baird and their associates that require them
to provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients).
Other Fees and Charges
In addition to the Advisory Fee described above, a
client of DDK will incur other fees and expenses.
The asset-based fee only covers investment
advice provided by DDK, and a client will pay for
other services, such as custody and trade
execution, separately in addition to the Advisory
Fee. Please see the section “Brokerage Practices”
below for more information about DDK’s trading
practices.
A client is responsible for bearing or paying, in
addition to the Advisory Fee, the costs of all:
front-end or deferred sales
• commissions,
charges, redemption fees, or other charges;
• markups, markdowns, and spreads charged by
Baird in a principal transaction with a client or
charged by other broker-dealers that buy
securities from, or sell securities to, the client’s
Account (such costs are inherently reflected in
the price the client pays or receives for such
securities);
• redemption fees, surrender charges or similar
fees that an investment product or its sponsor
may impose;
• underwriting discounts, dealer concessions or
similar fees related to the public offering of
investment products;
• extra or special fees or expenses that may
result from the execution of odd lot trade orders
(i.e., “odd-lot differential”);
important
• electronic fund fees, wire transfer fees, fees for
transferring an investment between firms, and
similar fees or expenses related to account
transfers (including any such fees imposed by
Baird);
• currency conversions and transactions;
Other Fees and Expenses
Cost and Expense Information for Certain
Investment Products
A client should be aware that certain investment
products in which the client invests, such as
mutual funds and other Funds, annuities and
their own ongoing
other products, have
management and other operating
fees and
expenses that are deducted from the assets of the
product (or income or gains generated by the
product on its investments) and thus reduce the
value or return of the client’s investment in the
product. These fees and expenses may include
investment management fees, distribution (12b-
1) fees, shareholder servicing fees, transfer
agency fees, networking fees, accounting fees,
marketing support payments, administration fees,
custody
fees, expense reimbursements, and
expenses associated with executing securities
transactions for the investment product’s portfolio
(“ongoing operating expenses”). These ongoing
operating expenses are separate from, and in
addition to, the Advisory Fees. As a result of
making investments in these types of products, a
client should be aware that the client is paying
multiple layers of fees and expenses on the
amount of the client’s assets so invested—the
ongoing operating expenses and the Advisory
information about
Fee. Additional
ongoing fees and expenses that apply to those
types of investments is provided in Baird’s Client
Relationship Details document and Baird’s website
at bairdwealth.com/retailinvestor. A client can
find the actual ongoing fees and expenses of an
investment product that the client will pay or bear
in the product’s prospectus or offering document.
conversions,
• securities
including, without
limitation, the conversion of ADRs to or from
foreign ordinary shares;
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• interest, fees and other costs related to margin
accounts, short sales and options trades;
related
to
the
• fees
establishment,
administration or termination of Retirement
Accounts, retirement or profit sharing plans,
trusts or any other legal entity, including,
without limitation, the calculation and payment
of unrelated business income tax (“UBIT”);
excluded for purposes of determining the asset-
based Advisory Fee beginning at the start of the
next quarterly billing period, and no portion of the
asset-based Advisory Fee paid by a client in
advance for the quarter will be refunded or
rebated to the client. Additionally, Unsupervised
Assets in an Account are subject to any applicable
set-up, maintenance and administrative
fees
established by Baird. Baird may waive such fees
in its discretion.
• fees imposed by the SEC or securities markets,
including transaction fees imposed by electronic
trading platforms, which fees may be imbedded
in the price the client receives for the security;
and
imposed upon or
resulting
• taxes
Clients who have Accounts managed by DDK may
also have other accounts with Baird that are not
managed by DDK. Those accounts may be subject
to fees, commissions or other expenses that are
entirely separate from the payment of fees and
expenses for the services provided by DDK.
from
transactions effected for a client’s Account, such
as income, transfer or transaction taxes, foreign
stamp duties, or any other costs or fees
mandated by law or regulation.
Clients who use a custodian other than, or in
addition to, Baird will pay the other custodian’s
fees and expenses in addition to the Advisory Fee.
In addition, if a third party custodian has custody
of the client’s Account assets, the Account is
subject to any applicable set-up, maintenance and
administrative fees established by Baird. Baird
may waive such fees in its discretion.
In addition to the Advisory Fee, a client will also
be responsible for paying the fees charged by
each investment manager selected by the client
under the Dual Contract Program. If a client
directs DDK or Baird to pay the client’s DC
Manager’s fee out of the client’s Account, and
DDK or Baird agree to do so, DDK and Baird will
not be responsible for verifying the calculation or
accuracy of such fee.
needs. However, when
To the extent mutually agreed by a client and
DDK, the client may also incur additional costs to
reimburse DDK for extraordinary travel expenses
it incurs to attend meetings at the request of the
client.
specific
about
If a client holds an Unsupervised Asset in the
client’s Account, the client may be charged a
commission, markup or markdown in connection
with its purchase or sale. The cash proceeds from
the sale of an Unsupervised Asset that remain in
a client’s Account are considered Permitted
Investments subject to the asset-based Advisory
Fee. If an asset becomes an Unsupervised Asset
during a quarterly billing period, that asset will be
Other Compensation Received by DDK and
Baird
Baird is registered as a broker-dealer under the
Securities Exchange Act, and DDK Consultants are
registered broker-dealer representatives of Baird.
In such capacities, Baird and DDK Consultants
provide brokerage and related services to clients,
including the purchase and sale of individual
stocks, bonds, mutual funds, private investment
funds, and other securities, and sales of annuities.
At times, Baird and DDK Consultants provide such
brokerage and related services to clients in
connection with the Services described in this
Brochure. Baird and DDK Consultants receive
compensation based upon the sale of such
securities and other
investment products,
including asset-based sales charges and service
fees on the sale of mutual funds. This practice
presents a conflict of interest because it gives
Baird and DDK Consultants an incentive to use,
select or recommend investment products based
upon the compensation received rather than on a
client’s
providing
investment advisory services to clients, Baird and
DDK Consultants are fiduciaries and are required
to act solely in the best interest of clients. Baird
addresses this conflict through disclosure in this
Brochure and by adopting internal policies and
procedures for DDK and Baird and their associates
that require them to provide investment advice
that is suitable for advisory clients (based upon
the information provided by such clients). For
more
Baird’s
information
compensation and other benefit arrangements
and how Baird addresses the potential conflicts of
the sections “Advisory
interest, please see
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
that all such clients receive fair and equitable
treatment over time.
Business” and “Fees and Compensation” above,
and “Other Financial Industry Activities and
Affiliations” and “Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
individuals and
their
requirements
for
opening
DDK will purchase for client accounts, or will
recommend the purchase of, various investment
products, including “no load” mutual funds or
mutual funds with waived sales loads. A client has
the option to purchase investment products
through other brokers or agents that are not
affiliated with Baird.
Types of Clients
DDK offers the Services primarily to: high net
worth
families and
businesses. DDK also provides services to other
types of current or prospective clients, including,
but not limited to: pension and profit sharing
plans; trusts; estates; charitable organizations;
and corporations or other business entities.
Applicable
or
maintaining an Account, such as minimum
account size, are discussed in the section entitled
“Fees and Compensation—Advisory Fees” above.
Performance-Based Fees and Side-By-
Side Management
DDK does not advise any client accounts that are
subject to performance-based fee arrangements.
Methods of Analysis, Investment
Strategies and Risk of Loss
Investment Strategies
The investment styles, philosophies, strategies,
techniques and methods of analysis that DDK,
investment
Baird, Baird PWM’s home office
professionals, and Other Managers use
in
formulating investment advice for clients vary
widely by Service and the person providing the
advice. A brief description of commonly used
strategies is provided below.
Act.
Performance-based
Baird advises client accounts not participating in
services described in this Brochure that are
subject to performance-based fee arrangements.
Performance-based fee arrangements involve the
payment of fees based upon the capital gains or
capital appreciation of a client’s account. Any such
fee arrangements are made in compliance with
applicable provisions of Rule 205-3 under the
Advisers
fee
arrangements present a potential conflict of
interest for Baird (but not DDK) with respect to
other client accounts that are not subject to
performance-based fee arrangements because
such arrangements give Baird an incentive to
favor client accounts subject to performance-
based fees over client accounts that are not
subject to performance-based fees.
interest
focused,
the
arrangements
holdings
Equity Strategies
Equity strategies generally have an objective to
provide growth of capital and primarily invest in
equity securities, such as common stocks.
However, these strategies may also invest in
other types of investments, such as fixed income
securities and cash. Equity strategies may invest
in companies of all market capitalization ranges or
may
focus on any combination of specific
capitalization ranges, such as large cap, mid cap
or small cap companies. Equity strategies may be
combined with other strategies described below,
such as growth, value, income, economic industry
or sector
international, global, or
geographic region or country focused strategies.
inequitable
In addition to complying with its fiduciary duties
by disclosing this conflict of interest to clients
through this Brochure, Baird generally addresses
posed by
of
potential
conflicts
by
performance-based
fee
periodically monitoring
and
performance of performance-based fee accounts
and comparing them to accounts not subject to a
performance fee that are also managed using a
similar strategy in an attempt to detect any
possible
treatment. Baird also
attempts to minimize potential conflicts of interest
posed by performance-based fee arrangements
through internal trade allocation procedures that
are designed to make securities allocations to
discretionary client accounts in a manner such
Fixed Income or Bond Strategies
Fixed income or bond strategies generally have
one or more of the following objectives: (1)
provide current income; or (2) preservation of
capital. These strategies primarily invest in fixed
income securities, such as corporate bonds,
municipal securities, mortgage-backed or asset-
backed securities, or government or agency debt
obligations. However, these strategies may also
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
invest
securities. This strategy may
in a
combination of investment grade and high yield
bonds. This type of strategy may also invest in
income-producing, Non-Traditional
yield- or
Assets.
technology,
region or
country
invest in other types of investments, such as
equity securities or cash. Fixed income strategies
may invest in debt obligations having any credit
rating, maturity or duration, or they may focus on
specific credit ratings, maturities or durations,
such as investment grade, non-rated, or high
yield (“junk”) bonds, or bonds having short-term,
intermediate-term or long-term maturities. Fixed
income strategies may be combined with other
strategies described below, such as economic
industry or sector focused, international, global,
or geographic
focused
strategies.
Economic Industry or Sector Focused Strategies
Economic industry or sector focused strategies
primarily invest in companies in one or more
economic industries or sectors, such as the
telecommunications,
industrial,
materials, or financial sectors. These strategies
alone generally are not intended to satisfy a
client’s entire portfolio diversification needs.
These strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
include companies
ranges,
regions, credit
International Strategies
Generally, international strategies primarily invest
in securities issued by foreign companies, which
in developed and
may
emerging markets. International strategies may
invest in companies of all market capitalization
ranges and in investments having any credit
rating, maturity or duration, or they may focus on
industries or
specific capitalization
sectors, geographic
ratings,
maturities or durations.
region or market
Balanced Strategies
Balanced strategies generally have one or more of
the following objectives: (1) provide current
income; (2) growth of capital/principal or income;
or (3) preservation of capital. These strategies
primarily invest in a mix of equity, fixed income
securities and cash. Balanced strategies may
invest in companies of all market capitalization
ranges and in investments having any credit
rating, maturity or duration, or they may focus on
specific capitalization ranges, credit ratings,
maturities or durations as described above.
Balanced strategies may be combined with other
strategies described below, such as economic
industry or sector focused, international, global,
or geographic
focused
strategies.
ranges,
Value Strategies
A value strategy typically invests primarily in
equity securities of value companies, which are
those that the investment manager believes are
out of favor with investors, appear underpriced by
the market relative to their earnings or intrinsic
value, or have high dividend yields. This strategy
is subject to investment style risks.
regions, credit
Global Strategies
Generally, global strategies invest in a mix of
securities issued by U.S. and foreign companies,
which may include companies in developed and
emerging markets. Global strategies may invest
in companies of all market capitalization ranges
and in investments having any credit rating,
maturity or duration, or they may focus on
industries or
specific capitalization
ratings,
sectors, geographic
maturities or durations.
Growth Strategies
A growth strategy typically invests primarily in
equity securities of growth companies, which are
those that the investment manager believes
exhibit signs of above-average growth relative to
peers or the market, even if the share price is
high relative to earnings or intrinsic value. This
strategy is subject to investment style risks.
Income Strategies
An income strategy typically invests primarily in
income-producing securities, such as dividend-
income
paying equity securities and
fixed
Geographic Region or Country Focused Strategies
Geographic region or country focused strategies
primarily invest in companies located a particular
part of the world, such as Latin America, Europe
or Asia, in a group of similarly-situated countries,
such as developed or emerging markets, or one
or more specific countries. These strategies alone
generally are not intended to satisfy a client’s
entire portfolio diversification needs. These
strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
than other strategies. The
to
Opportunity strategies often experience higher
fluctuations in annual returns and overall market
value
types of
implement opportunity
investments used
strategies vary widely by manager and could
include equity securities, fixed income securities,
Non-Traditional Assets, Alternative Investment
Products and cash.
underweighting
and
taxable
Tax Management Strategies
Tax management strategies involve buying and
selling investments in a manner intended to
reduce the negative impact of U.S. federal income
taxes. They often involve buying or selling
investments to limit taxable investment gains or
to offset
investment gains with
investment losses or selling investments to avoid
recognition of taxable investment gains.
tax management strategy
is
strategies are often
subject
these
strategies
Tactical and Rotation Strategies
Tactical strategies typically tactically and actively
adjust account allocations to different categories
of investments, such as asset classes, geographic
locations or market sectors, based upon the
manager’s perception of how those investments
will perform in the short-term. Similarly, rotation
typically actively adjust account
strategies
allocations to different market sectors based upon
the manager’s perception of how those market
sectors will perform in the short-term. Tactical
and rotation strategies are often driven by
technical analysis or methodologies and typically
involve
overweighting
account allocations to certain asset classes,
geographic locations or market sectors relative to
an applicable long-term strategic asset allocation,
benchmark index or the market generally. These
strategies often will be focused or concentrated in
one or more asset classes, geographic locations or
market sectors from time to time, and it is likely
that they will have limited or no exposure to one
or more asset classes, geographic locations or
market sectors. For that reason, tactical and
rotation
to
concentration risk. Because the decision-making
for tactical and rotation strategies is based upon
the manager’s short-term market outlook,
accounts pursuing
often
experience higher levels of trading and portfolio
turnover relative to other strategies.
A
typically a
secondary strategy used to achieve a secondary
tax management objective and it is typically
together with other primary
implemented
investment
to achieve
strategies designed
primary investment objectives or goals. However,
managers in certain situations may use a tax
management strategy as the primary investment
strategy or tax management may be their primary
consideration when managing client Accounts,
such as when the manager is transitioning an
Account from one investment strategy to another.
the
strategy, particularly
utilizes
strategy
Accounts pursuing a tax management strategy in
some instances will be subject to additional or
different risks of loss, which may be material. The
holdings of Accounts pursuing tax management
strategies will often differ from the holdings of
similarly-managed accounts that do not utilize
if
such a
tax
replacement
management
securities. Therefore,
the performance of
Accounts utilizing a tax management strategy will
vary from similarly-managed accounts that do not
utilize such a strategy, possibly in a materially
negative manner, and such Accounts may not be
successful in pursuing any other investment
strategies, objectives or goals.
investment strategies, there
Opportunity or Opportunistic Strategies
Opportunity strategies will generally be invested
in a manner that seeks to provide long term
growth
through capital appreciation and/or
income by utilizing an active management style
that shifts the amount of investment made in
different asset classes and market sectors to take
advantage of the manager’s perception of market
pricing anomalies, those market or industry
sectors deemed favorable for investment by the
manager, the current interest rate environment
and/or other macro-economic trends identified by
the manager. Opportunity strategies often involve
the use of other strategies, particularly tactical or
rotation strategies, and will have the risks
associated with those strategies. Opportunity
Strategies may also involve investment in a more-
limited number of companies compared to other
strategies. As a result, a decline in value of one or
a few investments will more adversely impact
performance than if assets were more evenly
invested in a larger number of companies.
Tax management strategies are not intended to,
and likely will not, eliminate a client’s tax
obligations relating to investments in an Account.
Like all
is no
guarantee that the implementation of a tax
management strategy will be successful. A client’s
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
use of a tax management strategy may not
actually
lower a client’s tax obligations or
otherwise achieve a client’s tax goals.
A client is responsible for ensuring that the
holdings and transactions in the client’s other
accounts at Baird or another firm do not violate
appliable tax rules and bears the risk of such
violations. A client is strongly urged to consult the
client’s tax advisor prior to pursuing a tax
management strategy.
that
involve
the
The effectiveness of tax management strategies
will be reduced if a client’s ability to recognize
losses for tax purposes is disallowed, limited or
deferred under applicable tax rules, such as the
IRS wash sales rules, which disallow losses if
substantially identical securities are purchased by
a client (whether through Baird or another firm)
within 30 days before or after a sale, and IRS
straddle rules, which limit and defer a client’s
ability to claim tax deductions related to the loss
on a sale of an investment in an Account if the
client holds an offsetting position in any account
held at Baird or another
firm. Some tax
the sale of
management strategies
securities at a loss and the reinvestment of the
proceeds into a replacement security that the
manager believes
to not be “substantially
identical” for purposes of the IRS wash sales rule.
A manager’s belief may be incorrect, resulting in
a disallowance of the loss and reducing the
intended benefits of
tax management
strategy.
limitations of
Direct Indexing Strategies
Direct indexing strategies involve investing in a
basket of individual securities, such as stocks,
that seeks to track a selected benchmark index.
Direct indexing strategies may be more costly
than other
track
investment options
benchmark indices, such as mutual funds and
ETFs. Direct indexing strategies also generally
include the use of tax management strategies in
an attempt to enhance Account performance. The
use of tax management strategies will cause an
Account to deviate from the benchmark index,
which will cause the Account’s returns to vary
from that of the benchmark index. The use of tax
management strategies may not be successful
and the performance of Accounts pursuing a
direct index strategy could be materially lower
than the benchmark index. See “Tax Management
Strategies” above for more information about the
risks and
tax management
strategies.
the wash sales
resulting
losses. The
rules,
risk of
involved
invest
Trading activity in a client’s accounts (whether at
Baird or another firm) may also inadvertently
violate
in
inadvertent
disallowed
violations increases as the number of client
accounts and managers
increases
because there is a higher chance of uncoordinated
or conflicting trading activity in those accounts.
Automatic purchases in client accounts, such as
dividend
reinvestment programs, may also
inadvertently violate wash sales rules. A client’s
investments held in other accounts at Baird or
another firm may be deemed to be offsetting
positions for purposes of the IRS straddle rules,
which will also negatively impact the client’s
ability to deduct losses and will reduce the
intended benefit of the tax management strategy.
Alternative Strategies and Complex Strategies
Alternative Strategies and other Complex
Strategies may
in a wide range of
investments, which may include equity securities,
fixed income securities, Non-Traditional Assets,
Alternative
Investment Products and cash.
Alternative Strategies and other Complex
Strategies generally involve the use of margin,
leverage, short sales and derivative instruments.
Many Alternative Strategies and other Complex
Strategies have no substantive restrictions on the
types of investments that may be used. Examples
of Alternative Strategies and other Complex
Strategies include the following.
resulting
from
• Relative Value Strategies. Relative value
strategies generally involve the purchase of
traditional assets, such as stocks and bonds,
and Non-Traditional Assets and the use of short
sales and derivative instruments in an attempt
to exploit price differences among securities
that share similar economic or
financial
characteristics.
Managers do not consider the holdings or
transactions in other client accounts (whether
held at Baird or another firm) when implementing
tax management strategies. Managers do not
undertake any responsibility to monitor or verify a
client’s compliance with applicable tax rules, and
they are not responsible for any tax‑related
effects or obligations
the
investments or transactions in a client’s Account.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• Long/Short Strategies. Long/short strategies
generally involve the purchase of securities
believed to be undervalued and selling short
securities believed to be overvalued. They may
also involve the use of Non-Traditional Assets,
leverage and derivative instruments.
• Absolute Return, Total Return and Real Return
Strategies. Absolute return, total return and
real return strategies generally involve the
purchase of traditional assets, such as stocks
and bonds, and Non-Traditional Assets in an
attempt to generate performance that has low
correlation to the major equity markets over a
complete market cycle. They may also involve
the use of derivative instruments.
• Event-Driven
• Market Neutral Strategies. Market neutral
strategies generally involve the purchase of
securities and selling securities short in similar
dollar amounts in an attempt to produce returns
that are
independent of general market
performance. They may also involve the use of
Non-Traditional Assets, leverage and derivative
instruments.
events
(such
and
liquidations).
Event-driven
Strategies.
strategies generally involve the use of Non-
Traditional Assets, short sales and derivative
instruments in an attempt to seek arbitrage
opportunities, particularly those triggered by
as mergers,
corporate
restructurings,
These
strategies typically involve the assessment of if,
how and when an announced transaction will be
completed.
• Statistical Arbitrage Strategies. Statistical
Arbitrage is based on the theory that stocks
have a tendency to return to a short-term trend
line. This type of strategy typically involves the
“systematic” or automated trading of securities
based upon where a security is relative to its
trend line.
arbitrage
strategies
involve
in corporate
buy-outs,
restructurings
is
short
securities believed
• Merger Arbitrage/Special Situations Strategies.
Merger
the
purchase and sale of securities of companies
involved
reorganizations and
business combinations, such as mergers,
exchange offers, cash tender offers, spin-offs,
and
leveraged
liquidations. These strategies often
involve
short selling, options trading, and the use of
other derivative instruments.
• Convertible Arbitrage Strategies. Convertible
arbitrage involves the purchase and short sale
of multiple securities of the same company. The
strategy
implemented by purchasing
securities believed to be undervalued and
selling
to be
overvalued. Often, the strategy involves the
purchase of a convertible bond issued by a
company and selling short that company’s
common stock. This strategy may involve the
use of a wide range of derivative instruments.
• Fixed
• Distressed Strategies. Distressed strategies
generally involve the purchase of securities in
companies that are in financial distress, or
companies that are entering into or are already
in bankruptcy. They may also involve the use of
short sales and derivative instruments.
Income Arbitrage Strategies. Fixed
income arbitrage strategies generally seek to
profit from interest rate, credit spread and other
arbitrage opportunities by investing in fixed
income securities, interest rate instruments and
derivative instruments.
• Macro Strategies. Macro strategies generally
involve the purchase of traditional assets, such
as stocks and bonds, and Non-Traditional Assets
and the use of short sales and derivative
instruments in an attempt to profit from
in securities markets,
anticipated changes
commodities markets, currency values, and/or
interest rates.
and
Systematic
• Discretionary
• Capital Structure Arbitrage Strategies. Capital
structure arbitrage generally involves investing
in multiple levels of a single company’s capital
structure, often taking long and short positions
in a company’s debt or equity in order to
capitalize on perceived mispricings resulting
from market inefficiencies or different pricing
assumptions. This type of strategy typically
involves the use of derivatives and structured
products.
strategies
generally
rely
Trading
Strategies. Discretionary
trading strategies
generally attempt to identify and capitalize on
patterns or trends in the markets. Systematic
trading
on
computerized trading systems or models to
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
identify and capitalize on those patterns or
trends. These strategies often involve the use of
Non-Traditional Assets, short sales, derivative
instruments and significant leverage.
risks
related
• Private Investment Strategies.
economic sectors. Investments in private real
estate can be illiquid, meaning they may take
time to sell or refinance. Property values can
fluctuate due to market conditions, supply
and demand, and other factors. There are
also
tenant vacancies,
to
property damage, or environmental hazards.
Leverage is often used in private real estate
investments, which can increase potential
returns but also amplifies potential losses.
generally
in
companies
involve
in
o Private
invest
types. Examples of
include,
These
among
utilities,
investments
o Private Equity Strategies. Private equity
equity
strategies
investments
private
transactions. These investments are typically
made through participation in private equity
funds or funds of private equity funds. Private
equity strategies may invest in companies of
all market capitalization ranges or may focus
on any combination of specific capitalization
ranges. They may also focus on companies in
one or more economic industries or sectors or
geographic regions. Some private equity
strategies focus on companies that are newly
formed, in financial distress or already in
bankruptcy. The securities purchased are
typically unregistered and illiquid. Private
equity strategies may also involve the use of
leverage.
Infrastructure Strategies. Private
in
strategies
infrastructure
infrastructure projects and assets and may
involve exposure to a range of economic or
market sectors, geographic locations and
infrastructure
asset
others,
investments
and
telecommunication,
transportation.
are
typically made through participation in private
infrastructure funds. Investments in private
infrastructure strategies are often illiquid.
They may focus on certain sectors, industries,
geographic regions, size ranges or stages of
development or operations, or on certain
types and sizes of investments and may,
therefore, also lack diversification.
typically unrated or
• Leveraged Strategies. Leveraged strategies
generally involve the use of Non-Traditional
Assets, leverage, short sales and derivative
instruments in an attempt to amplify returns or
produce returns that are a multiple of a
benchmark index.
types of
referred
to as
floating
• Inverse Strategies. Inverse strategies generally
involve the use of Non-Traditional Assets,
leverage, short sales and derivative instruments
in an attempt to produce returns that are the
opposite of a benchmark index.
in
smaller
o Private Debt or Private Credit Strategies.
Private debt (also known as private credit)
strategies invest in loans or debt instruments
issued by companies in private transactions.
These investments are typically made through
participation in private debt funds or funds of
private debt funds. The investments involved
are
rated below
investment grade and are illiquid. Oftentimes,
the interest rate paid by the companies is
determined by a reference interest rate, such
as the federal funds rate, which is periodically
investments are
reset. These
rate
sometimes
corporate debt, floating rate loans or floating
rate bank loans. Private debt strategies often
involve the use of leverage and may involve
investment
capitalization,
distressed or bankrupt companies.
Business—Additional
industrial
typically made
Alternative Strategies and other Complex
Strategies are not appropriate for some clients
because they are subject to special risks. See
“Advisory
Service
Information—Complex Strategies and Complex
Investment Products” above and “Methods of
Analysis, Investment Strategies and Risk of
Loss—Principal Risks—Non-Traditional Assets and
Complex Strategies Risks” below
for more
information.
o Private Real Estate Strategies. Private real
estate strategies invest in physical properties,
such as office buildings, apartments, retail
facilities. These
centers, and
investments are
through
participation in private REITs. Private real
focus on specific
estate strategies may
types, or
geographic
regions, property
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and
actively
adjusting
tactical
Asset Allocation Strategies
Certain Services, including the DDK Investment
Management Service, make available asset
allocation strategies. Asset allocation strategies
involve investing in one or more of the following
categories of assets:
tactically
account
allocations to different asset classes based upon
the manager’s perception of how those asset
classes will perform in the short-term. Some asset
allocation strategies involve the use of both
strategic and
investment strategies,
sometimes referred to as dynamic strategies.
Asset allocation strategies may be implemented
using a variety of investment types, such as
individual securities, mutual funds and ETPs. The
amount allocated to an asset class or investment
type varies by strategy, and some strategies may
have little or no allocation to one or more asset
classes or types of investments described above.
companies; U.S.
cap
located
• the equity securities asset category, which is
comprised of certain asset classes, such as,
equity securities issued by: U.S. large cap
growth companies; U.S.
large cap value
companies; U.S. large cap core companies; U.S.
mid cap growth companies; U.S. mid cap value
companies; U.S. mid cap core companies; U.S.
small cap growth companies; U.S. small cap
core
small
value
in
foreign companies
companies;
developed markets; foreign companies located
in emerging markets; U.S. REITs; and foreign
REITs;
involves
as:
short-term
taxable
that are based upon
Baird’s
projections
• the fixed income securities asset category,
which is comprised of certain asset classes,
such
bonds;
intermediate term taxable bonds; long-term
taxable bonds; short-term tax-exempt bonds;
intermediate term tax-exempt bonds; long-term
tax-exempt bonds; high yield fixed income
securities; foreign fixed income securities; and
broad fixed income securities;
Baird uses its Capital Market Assumptions in
developing its proprietary model asset allocation
strategies, including those used by some DDK
Consultants. In determining its Capital Market
Assumptions, Baird conducts an analysis of
different asset classes and the different levels of
risk associated with those investments. That
analysis
the consideration of past
performance and the use of forward-looking
projections
certain
assumptions made by Baird about how markets
will perform in the future. There is no assurance
that asset classes or markets will perform in
accordance with
or
assumptions. For more information about Baird’s
Capital Market Assumptions, a client should
contact the client’s DDK Consultant.
and
• the Non-Traditional Assets category, which is
comprised of certain asset classes, such as:
commodities
commodity-linked
instruments; and currencies and currency-
linked instruments, and Digital Assets;
Baird’s most common asset allocation strategies
are described below. A client should note that the
specific investments in an Account following a
particular asset allocation strategy could vary
from the description below for a number of
reasons, including market conditions.
• the Alternative Investment Products category
which is comprised of certain asset classes,
such as: hedge funds, private equity funds and
managed futures; and
• cash.
allocation
strategies
have
also
have
varying
invest
All Growth Portfolio. An All Growth Portfolio
typically seeks to provide growth of capital.
Typically, an All Growth Portfolio will experience
high fluctuations in annual returns and overall
market value. Under normal market conditions,
this strategy generally invests nearly all of its
assets in equity securities. This strategy may also
invest in other asset classes, such as fixed income
securities, Non-Traditional Assets and cash. This
strategy may also
in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Asset
varying
investment objectives, ranging from growth of
capital to preservation of capital. Asset allocation
strategies
investment
strategies. Some asset allocation strategies use
strategic investment strategies, which involve
investing accounts
in accordance with a
predetermined target allocation to different asset
classes. Some asset allocation strategies use
involves
tactical
investing, which
typically
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
experience
relatively
Conservative Income Portfolio. A Conservative
Income Portfolio typically seeks to provide current
Income
income. Typically, a Conservative
small
Portfolio will
fluctuations in annual returns and overall market
value. Generally, under normal market conditions,
this strategy will primarily invest in a mix of fixed
income securities, cash and equity securities, with
a significantly higher allocation to fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets.
Generally, under normal market conditions, this
strategy will have a significantly higher allocation
to fixed income securities and cash than equity
securities.
Capital Growth Portfolio. A Capital Growth
Portfolio typically seeks to provide growth of
capital. Typically, a Capital Growth Portfolio will
experience moderately high fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, this strategy will
primarily invest in a mix of equity securities and
fixed income securities, with a significantly higher
allocation to equity securities. This strategy may
also invest in other asset classes, such as Non-
Traditional Assets and cash. This strategy may
also invest in Alternative Investment Products or
may involve the use of leverage, short sales and
derivative instruments. Generally, under normal
market conditions, this strategy will have a
significantly higher allocation to equity securities
than fixed income securities.
Preservation
A
Portfolio.
typically seeks
Capital
Capital
Preservation Portfolio typically seeks to preserve
capital while generating current income. Typically,
a Capital Preservation Portfolio will experience
relatively small fluctuations in annual returns and
overall market value. Under normal market
conditions, this strategy generally invests nearly
all of its assets in a mix of fixed income securities
and cash. This strategy may also invest in other
asset classes, such as equity securities and Non-
Traditional Assets.
income
investments
Growth with Income Portfolio. A Growth with
Income Portfolio
to provide
moderate growth of capital and some current
income. Typically, a Growth with Income Portfolio
will experience moderate fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, this strategy will
primarily invest in a mix of equity securities and
fixed income securities, with a bias towards equity
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
equity securities than fixed income securities.
Objectives
and
Some DDK Consultants and investment managers
use asset allocation strategies that include target
asset allocation percentages for equity and/or
fixed
in the names or
descriptions of the strategies (e.g., 80-20, 60-40,
40-60, 20-80, etc.). A client should note that
those percentages are intended to be asset
allocation targets only. There is no guarantee that
Accounts following asset allocation strategies will
be invested strictly in accordance with target
asset allocations. It is likely that the actual
investments in Accounts following those strategies
will vary, sometimes significantly, from the target
asset allocations and may include other asset
classes due to market conditions and the DDK
Consultant’s or investment manager’s assessment
of how to best invest a client’s Accounts. See
“Important Information about Implementation of
Investment
Investment
Strategies” below for more information.
Income with Growth Portfolio. An Income with
Growth Portfolio typically seeks to provide current
income and some growth of capital. Typically, an
Income with Growth Portfolio will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, this strategy will primarily
invest in a mix of fixed income securities and
equity securities, with a bias towards fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
fixed income securities than equity securities.
For information about the risks associated with
the asset allocation strategies described above,
see the section of the Brochure entitled “Principal
Risks—Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies” below.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
basis how the Account is being managed or
advised and whether any such conditions exist.
Methods of Analysis
Baird, its home office investment professionals,
and DDK Consultants may use various forms of
investment analyses, including the following:
Important Information about Implementation of
Investment Objectives and Investment Strategies
A client should note that, to implement an
investment strategy, a client’s DDK Consultant or
investment manager may use or recommend
mutual funds, ETPs or other Funds that primarily
invest in particular types of securities instead of
direct investment in those types of securities. A
client should also note that the client’s DDK
Consultant or investment manager may use a
strategy not described above or they may use a
strategy with the same or similar name that is
implemented differently. A client should ask the
client’s DDK Consultant or investment manager
for more specific information about the strategy
being used for the client’s Account.
• Fundamental Analysis. Fundamental analysis
involves an approach to investing through a
detailed analysis of specific companies, such as
their financial statements and financial ratios,
management, competitive advantages and
markets, in an attempt to determine the value
of an investment. Fundamental analysis may
include qualitative and quantitative analyses.
Analysis. Qualitative
• Qualitative
A client’s Account
is subject to the risks
associated with the Account’s particular strategies
and investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
analysis
involves the use of subjective judgment to
analyze factors that may be difficult to quantify
or measure objectively. As it pertains to
managers and investment products, qualitative
analysis may include review of the background
and experience of a manager or a mutual fund
company.
in an attempt
• Quantitative Analysis. Quantitative analysis is a
method of evaluating securities by analyzing a
large amount of data through the use of
algorithms or models
to
understand behavior, predict market events,
market prices, etc., and generate an investment
decision. As it pertains to managers and
investment products, quantitative analysis may
review of manager performance,
include
investment style, style consistency, risk, and
risk-adjusted performance.
• Technical Analysis. Technical analysis is a
method of analyzing past price and volume
patterns and trends in the trading markets to
attempt to predict the direction of both the
overall market and specific investments.
investment
restrictions,
• Top-Down Analysis. Top-down analysis involves
a consideration of certain macroeconomic
trends, such as general economic conditions,
geographic or market sector performance, fiscal
and monetary policy, taxes, or interest rates, to
make investment decisions.
Analysis. Bottom-up
• Bottom-Up
From time to time, the client’s DDK Consultant or
invest the client’s
investment manager will
Account, or recommend that the client invest the
Account, in a manner that is inconsistent with the
investment strategy or
investment objective
selected by the client for the Account when the
client’s DDK Consultant or investment manager
determines that it is appropriate to do so, such as
using defensive strategies in response to adverse
market or other conditions or engaging in tax
management. Similarly, a client’s Account may be
invested in a manner inconsistent with the
investment strategy or
investment objective
selected by the client for the Account in certain
other circumstances, such as when the client’s
is transitioning to a new Service,
Account
investment objective or investment strategy, or
due to other factors, such as market appreciation
or depreciation of the assets in the client’s
Account, deposits and withdrawals made by the
if any,
client, and
imposed by the client. A client’s Account may not
be able to achieve its investment objectives
during any such period of time and the Account
may be subject to different or enhanced risks
than would be the case had the Account been
invested in a manner wholly consistent with the
investment objective or
investment strategy
selected by the client. Clients are encouraged to
discuss with their DDK Consultant on a regular
analysis
involves consideration of factors particular to a
such as business
particular
investment,
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Consultants. All AI Tool-assisted outputs used in
formulating investment advice are subject to
human
inform
review before such outputs
recommendations or investment decisions.
financials (e.g., balance sheet strength and
cash flows), financial ratios (e.g., price-to-
earnings ratio), and business fundamentals
(e.g., management and product or services
performance) to make investment decisions.
could negatively
influence
When providing investment advice to clients, DDK
Consultants utilize research reports and other
research material created by Baird PWM Research
Groups, such as PWM Equity Research, PWM Fixed
Income Research, and Asset Manager Research.
DDK Consultants may also utilize research reports
Institutional Equities &
created by Baird’s
Research Department. It should be noted that
DDK Consultants are not obligated to act in a
manner consistent with those research reports
and they may act in a manner that is contrary to
those reports if they deem it to be in the client’s
best interest.
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations,
deceptive behaviors and other flaws due to the
construction of their underlying models and the
composition of their training data, which can
result in outputs that seem plausible but are in
fact inaccurate, incomplete, or misleading. The
use of AI Tools creates a risk that erroneous
information
the
investment-advice process. Baird has established
policies and procedures designed to address the
risks posed by AI Tools, which
include
requirements that AI Tools pass a firm-level due
diligence process and that Baird associates obtain
training and independently verify AI Tool outputs.
However, such measures cannot eliminate the
risks posed by AI Tools.
their
sponsors
(which may
Baird PWM Research Groups and DDK Consultants
use various third party information and tools
when formulating investment advice. The sources
of information and tools may include, among
others, information provided or created by issuers
and
include
information that is reported publicly, provided
directly to Baird, or reported through third party
platforms) and information and tools provided by
third party research firms, which may include
firms affiliated with Baird. Although Baird has
deemed the information and tools provided by
third party research firms to be generally reliable,
Baird does not independently verify or guarantee
the accuracy of the information or tools used.
(“AI”)
risks. See
When providing investment advice to clients, DDK
Consultants may also use the model portfolios or
recommended or eligible product lists (described
below) made available by Baird’s PWM Research
Groups, or they may use investment products
that Baird has generally deemed to be “available”
for use in its advisory programs (“Available
Investment Products”). The level of initial and
ongoing evaluation, monitoring and review that
DDK and Baird perform on managers and on
investment products varies. Available Investment
Products generally do not receive the same level
of initial or ongoing evaluation, monitoring or
review by Baird as those managers or products
that are included in a model portfolio or on a
recommended or eligible product list. As a result,
Available Investment Products are subject to
certain
“Methods of Analysis,
Investment Strategies and Risk of Loss—Principal
Risks—Available Investment Product Risks” below
for more information.
in
formulating
Baird PWM home office investment professionals
and DDK Consultants may use artificial
intelligence
tools, such as machine
learning, predictive analytics and probabilistic
modeling tools, data processing and automation
tools, generative AI tools, visual, speech and
audio tools, specialized domain tools, and other
similar technologies and tools (collectively, “AI
investment advice.
Tools”),
Generally, the use of AI Tools is limited to certain
aspects of Baird’s investment-advice process,
such as assisting with drafting of materials,
automation of workflow processes, and the
compilation,
organization,
reproduction,
summarization, analysis and interpretation of
information. The use of AI Tools is only supportive
of Baird’s investment-advice process and does not
replace the professional judgment of Baird PWM
home office investment professionals or DDK
More specific information about Baird PWM model
portfolios, recommended lists and eligible product
lists is provided below. A client should note that
investment products recommended to the client
or selected for the client’s Account, including
investment managers or products included on a
Baird PWM recommended or eligible product list,
are those which, in Baird’s professional judgment,
may be appropriate to help the client pursue the
client’s financial goals. DDK and Baird do not
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird Rising Dividend Portfolio
represent or guarantee that such investment
managers or products are or will be the best
investment managers or products available.
Under certain circumstances when requested by a
client, DDK and Baird may allow a client to
transfer from another firm or select an investment
product that is not on a Baird recommended or
eligible product list or that does not qualify as an
Available Investment Product. A client should note
that, unless DDK and Baird otherwise agree in
writing, DDK and Baird do not provide any initial
or ongoing evaluation, monitoring or review of
any such investment product and that the client’s
decision to transfer or select such investment
product is based solely upon the client’s review of
the investment product.
Certain PWM-Managed Portfolios
Baird Recommended Portfolio
investment
approach
The Baird Rising Dividend Portfolio, which is
managed by Baird’s PWM Equity Research team,
seeks to provide a core equity strategy with a
portfolio yield above that of the S&P 500 Index.
The team’s top–down investment approach begins
with macroeconomic and market outlooks from
Baird’s Investment Strategy team. The 30–50
stocks in the portfolio are primarily large cap
stocks—as defined by a market capitalization of
$10 billion or greater at the time of investment—
and all are above $5 billion at the time of
investment. The team looks for quality companies
with strong
fundamental characteristics and
management, attractive dividend yields, and the
ability to increase their dividends. Companies are
screened for dividend history and consistency,
earnings growth expectations, and balance sheet
quality. Each stock selected
is assigned a
weighting as a percentage of the portfolio. No
single company stock will comprise more than the
greater of 5% of the portfolio or 1.5 times the
stock’s market weight in the S&P 500 index;
provided that a stock will not be removed due to
capital appreciation. A position can be reduced or
removed due to changes in valuation, company
fundamentals or the perceived ability to continue
to raise its dividend in the future—among a
variety of other potential reasons for portfolio
changes including a change in industry sector
weighting. The Portfolio is intended as a long-
term investment strategy.
AQA Portfolios
to
clients
Analysis
performance.
The
analysis
The Baird Recommended Portfolio, which
is
managed by Baird’s PWM Equity Research team,
seeks to outperform the S&P 500 Index by
investing in a diversified core portfolio of 35–50
stocks. The portfolio invests primarily in stocks
with market capitalization greater than or equal to
$10 billion (large cap). The portfolio may also
contain stocks with market caps below $10 billion
but these stocks generally will not represent more
than 35% of the total portfolio. The team’s top–
begins with
down
macroeconomic and market outlooks from Baird’s
Investment Strategy team. This information is
used to underweight or overweight particular
industry sectors compared to the S&P 500 Index.
Individual stocks are selected with an emphasis
on higher quality companies that the team
believes have strong fundamental characteristics
and management
teams, attractive growth
reasonable price-appreciation
prospects, and
expectations. Each stock selected is assigned a
weighting as a percentage of the portfolio. No
single company stock will comprise more than the
greater of 5% of the portfolio or 1.5 times the
stock’s market weight in the S&P 500 index;
provided that a stock will not be removed due to
capital appreciation. Stocks can be sold or
positions reduced for a variety of reasons such as
valuation, a change in company or industry
fundamentals, or a change in industry sector
weighting. The Portfolio is intended as a long-
term investment strategy.
certain
Baird makes available
Automated Quantitative
(“AQA”)
Portfolios, which are managed by Baird’s PWM
Equity Research team. AQA is an analytical tool
that seeks to identify stocks of companies that
are undervalued by calculating the intrinsic values
for the stocks and comparing the calculated
values to current market prices. Focusing on a
company’s past
financial performance, AQA
analyzes fundamental ratios and trends of the
most recent eight-year history of a company and
each company in its peer group, excluding
estimates of future balance sheet and income
statement
is
ignores certain qualitative
quantitative and
information such as company-specific material
news and events. Stocks are ranked from the
most undervalued to the most overvalued based
on the difference between the values calculated
by AQA and current market prices. The stocks
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• reliability and consistency of their investment
process
• competitiveness of their investment
performance
Baird’s Asset Manager Research Department may
also employ the use of computers and third party
software to more readily display information and
assist with the evaluation and analysis.
identified by AQA as being the most undervalued
are then selected for investment. Baird offers the
following four (4) AQA Portfolio strategies, each of
which invest in undervalued stocks identified
using AQA, excluding securities issued by banks,
REITS and insurance companies: (1) the AQA All
Cap Strategy, which primarily invests in stocks
across market capitalizations, generally those
included in the S&P 500®, S&P MidCap 400® or
S&P SmallCap 600® Indices; (2) the AQA Large
Cap Strategy, which primarily invests in large cap
stocks, generally those included in the S&P 500®
Index; (3) the AQA Mid Cap Strategy, which
primarily invests in mid cap stocks, generally
those included in the S&P MidCap 400® Index;
and (4) the AQA Small Cap Strategy, which
primarily invests in small cap stocks, generally
those included in the S&P SmallCap 600® Index.
Certain Recommended Lists
Baird’s Recommended Managers List
Baird’s initial screening process begins with a
proprietary, multi-factor model that evaluates
managers on different factors including risk-
adjusted performance, consistency of returns and
downside protection. These factors are scored
over various time periods and relative to a
specific peer group universe, narrowing the pool
of managers for further evaluation. Baird’s Asset
Manager Research Department then performs a
more in-depth evaluation of managers that are
identified through the initial screening process,
which generally includes a review of the following
factors: stability of the firm/team, the robustness
and repeatability of the investment process, the
portfolio’s past returns pattern and tax-efficiency,
and how the manager adds value. The final
determination of Baird’s Recommended Managers
List
is subject to the approval of Baird’s
Investment Committee.
conference
calls,
for
removal
When selecting managers and BRM Strategies for
Baird’s Recommended Managers List, Baird often
seeks registered investment advisory firms having
portfolio managers with academic credentials
such as a master’s degree or participation or
completion of the Chartered Financial Analyst
(“CFA”) program. Baird also typically looks for a
portfolio manager with greater than three (3)
years of investment experience focusing on the
particular investment style that is offered by the
portfolio manager. Baird generally looks for
portfolio managers
that have demonstrated
success, that have performance histories showing
sufficient ability to achieve returns in excess of
their respective benchmarks, and that have
investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird
also considers other qualitative and quantitative
factors.
change
Ongoing manager evaluation generally includes
quarterly
performance
attribution and periodic onsite visits. Material
adverse changes affecting a manager may result
in the manager being placed on “watch” status.
Managers on “watch” status are scrutinized to see
if improvement or degradation is taking place.
Potential causes
from Baird’s
Recommended Managers List include fundamental
changes in the operations of the manager,
turnover in key personnel, substantial changes in
management or ownership, a
in
investment philosophy or style, significant drift
from stated objectives, major legal, regulatory or
compliance difficulties, impairment of financial
condition, sustained underperformance in relation
to its peers, or other adverse changes affecting
the manager that in Baird’s opinion warrants the
manager’s removal.
Baird’s Asset Manager Research Department is
primarily responsible for selecting and evaluating
included on Baird’s
investment managers
Recommended Managers List.
selecting
In
investment managers, Baird’s Asset Manager
Research Department utilizes quantitative and
qualitative measures to evaluate managers based
on the:
• quality and stability of their organization
• soundness and clarity of their investment
philosophy
If a Model-Traded BRM Strategy is selected for a
client’s Account, it is important to note that
Baird’s selection and ongoing evaluation of a BRM
Strategy is based upon an assumption that the
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Investment Committee
its discretion, decides
inclusion
Recommended Manager’s Model Portfolio will be
fully and faithfully implemented by the Overlay
Manager or Implementation Manager on a
continuous basis. A client should understand that
the Overlay Manager or Implementation Manager
has discretion over the client’s Account and may
invest the client’s Account in a manner that differs
from the Model Portfolio. Baird does not monitor
the Account’s performance nor does it ascertain
whether the Overlay Manager or Implementation
Manager is implementing the Model Portfolio as
provided by the Recommended Manager. If the
Overlay Manager or Implementation Manager, in
the exercise of
to
implement the Model Portfolio differently, the
performance of a client’s Account could be
negatively impacted. Baird is not monitoring,
evaluating or reviewing the Overlay Manager or
Implementation Manager or the performance of a
client’s Account under those circumstances.
Department utilizes a quantitative and qualitative
evaluation process of the investment managers of
such funds. The process Baird uses for selecting
and removing funds for the Baird Recommended
Fund List is similar to the process Baird uses to
select and remove BRM Strategies described
under “Baird’s Recommended Managers List”
above. Baird’s
is
ultimately responsible for selecting funds included
on the List. The Baird Ultra Short Bond Fund,
Baird Short-Term Bond Fund, Baird Aggregate
Bond Fund, Baird Quality Intermediate Municipal
Bond Fund, Baird Core Intermediate Municipal
Bond Fund, and Baird Mid Cap Growth Fund,
mutual funds affiliated with Baird, have been
selected by Baird
in Baird’s
for
Recommended Mutual Fund List. This presents a
conflict of interest. However, the criteria used by
Baird in deciding to select Associated Funds for
Baird’s Recommended Mutual Fund List are the
same as those used for unassociated funds.
Baird’s Recommended Funds of Hedge Fund List
SMA
Strategies
for
Certain SMA Strategies offered by Baird Equity
Asset Management have been selected by Baird
for inclusion on Baird’s Recommended Managers
List. This presents a conflict of interest. However,
the criteria used by Baird in deciding to select
Baird’s
Associated
Recommended Managers List are the same as
those used for unassociated SMA Strategies.
Baird’s Recommended Mutual Fund List
Baird’s Recommended Funds of Hedge Fund List
may contain several types of funds of hedge
funds (“FOHFs”) that pursue various Alternative
Strategies or other Complex Strategies. Some
FOHFs primarily use credit-oriented investment
strategies, which Baird classifies as fixed income
diversifiers. Some FOHFs primarily use equity-
oriented investment strategies and are classified
as equity diversifiers. Other FOHFs use a
combination of credit- and equity-oriented
strategies, which Baird views as balanced
diversifiers. In certain circumstances, FOHFs may
be an appropriate substitute for part of a client’s
allocation to traditional high yield fixed income or
equity investments.
that
to
the
for
the
fund; and
Baird’s Recommended Mutual Fund List
is
designed to include mutual funds and ETFs across
numerous asset classes. When selecting funds for
inclusion on the List, Baird generally seeks funds
that have investment managers with tenure of at
least three (3) years and have underlying
investments
fund’s
adhere
market capitalization policy and are consistent
with the manager’s stated investment process
and philosophy. Baird generally looks for funds
that are among the top-performing funds in a
style category in terms of risk-adjusted returns or
that are managed by individuals or firms that
have demonstrated success in other, related asset
classes; that have performance histories showing
sufficient ability to achieve returns in excess of
their respective style index; and that have
investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird’s
Asset Manager Research Department is primarily
responsible
for assisting with selecting and
evaluating funds included on the List. In selecting
Research
funds,
Baird’s
Asset Manager
To be added to Baird’s Recommended FOHF List,
a FOHF must generally meet the
following
requirements: the investment advisor to the FOHF
is registered as an Investment Adviser under the
Advisers Act; the fund has stable to growing
assets under management as determined by
Baird, principals of the fund have an appropriate
level of hedge fund management experience and
a sufficient network of contacts in the industry as
determined by to Baird; in Baird’s opinion, the
fund has adequate diversification by number of
hedge funds and type of hedge fund strategy;
effective risk management programs have been
established
the service
providers to the fund (e.g., auditor, administrator,
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and legal counsel) are deemed to be reputable in
the judgment of Baird. Baird also seeks FOHFs
that it believes possess one or more unique
attributes that may lead to favorable performance
relative to their peers going forward.
legal documents
notable change in the investment or compliance
teams, weakening performance, or regulatory
problems. Any firm that is placed on “watch”
status is evaluated more closely to determine if
the problem is likely to be temporary or long-
term, and whether it can be remedied. Baird will
remove a FOHF from “watch” status and return it
to active status if, in Baird’s opinion, the problem
has been or is in process of being adequately
addressed. However, Baird will terminate a FOHF
from the List if it believes the issue is likely to be
long-term and adversely affect the FOHF’s future
performance.
offering memorandum,
Baird’s Recommended Private Funds Lists
Baird maintains lists of recommended private
Funds (“Recommended Private Funds”), including
a Recommended Funds of Private Equity Funds
List, a Recommended Private Debt Fund List, and
a Recommended Private Real Assets Fund List.
In making
that determination,
funds,
funds
or
Before adding a prospective FOHF to the List,
Baird’s Asset Manager Research Department
conducts an in-depth due diligence process. The
process begins with a review of the FOHF’s
responses to a due diligence questionnaire and of
marketing and
(such as,
subscription documentation, investor agreements,
and
organizational
documents, and the investment advisor’s Form
ADV Part 2A Brochures). This is followed by an
onsite review, where Baird meets with one or
more principals and analysts to assess how the
FOHF identifies, hires, monitors, and terminates
individual hedge funds. Baird also evaluates how
the FOHF constructs its hedge fund portfolio and
manages risk. At the conclusion of the onsite
review, an investment thesis is presented to and
discussed with a Baird Investment Committee.
The Committee votes on whether to add the FOHF
to Baird’s Recommended Funds of Hedge Fund
the
List.
Committee considers the information presented,
taking into account the merits of the individual
FOHF, how that FOHF compares to other FOHFs
that Baird offers, and the level of expected
demand for the particular FOHF.
client’s allocation
to
and
onsite
Baird’s Recommended Funds of Private Equity
Funds List contains funds of private equity funds
that pursue certain Alternative Strategies or other
Complex Strategies. These strategies can include
buyout, growth equity, venture capital, special
situations or distressed
investments. The
investments are typically structured in the form of
primary
co-
secondary
investments. Most will be to “middle market”
companies, many of which have above average to
high levels of leverage, or debt relative to equity.
In certain circumstances, funds of private equity
funds may be an appropriate substitute for part of
traditional equity
a
investments.
changes
that pursue
or
After a FOHF is added to Baird’s Recommended
Funds of Hedge Fund List, it is monitored each
reviews
subsequent
quarter,
periodically take place. As part of its quarterly
monitoring, Baird evaluates a FOHF’s assets under
(subscriptions and
management and
flows
(e.g.,
redemptions), organizational
personnel changes or new offerings), recent
changes made to the FOHF portfolio (e.g., hedge
funds added or removed), and reasons for
performance differences between the FOHF and
its benchmark. Subsequent onsite reviews are
similar in nature and scope to the initial on-site
review.
Baird’s Recommended Private Debt Fund List
contains private debt funds (also known as
certain
funds)
credit
private
Alternative Strategies
other Complex
Strategies. The private debt funds on Baird’s
Private Debt Funds List generally make first lien,
second lien and unsecured loans, primarily to
middle market companies sponsored by private
equity firms. In certain circumstances, private
debt funds may be an appropriate substitute for
part of a client’s allocation to traditional high yield
fixed income or equity investments.
funds
Baird’s Recommended Private Real Assets Fund
List contains private real estate and private
pursue
infrastructure
certain
other Complex
Alternative Strategies
that
or
Baird may place a FOHF on “watch” status if it has
experienced a material event that, in Baird’s
opinion, may negatively affect
the FOHF’s
performance going forward or possibly lead to the
departure of an important member(s) of the
FOHF. Examples include a large decline in assets
under management, high rate of redemptions,
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the
the Committee
information
considers
presented, taking into account the merits of the
individual fund, how that fund compares to other
similar funds that Baird offers, and the level of
expected demand for that particular fund.
utilities,
telecommunication,
The
investments may
with
companies
that
Strategies. These strategies invest in different
real assets and may involve exposure to a range
of economic or market sectors, geographic
types. Examples of
locations and asset
investments may include, among others, real
and
estate,
transportation.
be
structured in the form of asset ownership or
leasing or include direct investment in or joint
ventures
control
infrastructure assets. In certain circumstances,
private real assets funds may be an appropriate
substitute for part of a client’s allocation to
traditional fixed income or equity investments.
After a fund is added to a Baird Recommended
Private Fund List, it is monitored each quarter,
and subsequent onsite reviews periodically take
place. As part of its quarterly monitoring, Baird
evaluates a fund’s assets under management and
fund
flows (subscriptions and redemptions),
organizational changes (e.g., personnel changes
or new offerings), recent changes made to the
portfolio, and reasons for performance differences
between the fund and its benchmark. Subsequent
onsite reviews are similar in nature and scope to
the initial on-site review.
To be added to a Baird Recommended Private
Fund List, a fund must generally meet the
following requirements: the investment advisor to
the fund is registered under the Advisers Act ; the
fund has stable
to growing assets under
management as determined by Baird; principals
of the fund have an appropriate level of applicable
experience and a sufficient network of contacts in
the industry as determined by Baird; effective risk
management programs have been established for
the fund; and the service providers to the fund
(e.g., auditor, administrator, and legal counsel)
are deemed to be reputable in the judgment of
Baird. Baird also seeks funds that it believes
possess one or more unique attributes that may
lead to favorable performance relative to their
peers going forward.
fund
Baird may place a Recommended Private Fund on
“watch” status if it has experienced a material
event that, in Baird’s opinion, may negatively
affect the fund’s performance going forward or
possibly lead to the departure of an important
member(s) of the
investment team.
fund’s
Examples include a large decline in assets under
management, high rate of redemptions, notable
change in the investment or compliance teams,
weakening performance, or regulatory problems.
Any fund that is placed on “watch” status is
evaluated more closely to determine if the
problem is likely to be temporary or long-term,
and whether it can be remedied. Baird will
remove a fund from “watch” status and return it
to active status if, in Baird’s opinion, the problem
has been or is in process of being adequately
addressed. However, Baird will remove a fund
from a Recommended Private Fund List if it
believes the issue is likely to be long-term and
adversely affect the fund’s future performance.
Certain Eligible Product Lists
Annuities
the
strength
ratings
When determining whether to make an annuity
product available to Baird clients, Baird reviews
the offering documents for the product and
considers: the size of the insurer and the insurer’s
credit rating,
insurer’s distribution and
support model, and product specifications and
features of the product. Baird favors highly-rated
insurers and evaluates them by using credit rating
agencies
and
financial
independent third-party research.
Before adding a prospective
to a
Recommended Private Fund List, Baird’s Asset
Manager Research Department conducts an in-
depth due diligence process. The process begins
with a review of the fund’s responses to a due
diligence questionnaire (known as a DDQ or RFI)
and of marketing and legal documents (such as,
subscription documentation, investor agreements,
offering memorandum, organizational documents,
and the investment advisor’s Form ADV Part 2A
Brochures). This is followed by an onsite review,
where Baird meets with one or more principals
and analysts to assess how the fund makes
investment decisions. Baird also evaluates how
the fund constructs its portfolio and manages risk.
In addition, Baird may undertake a brief review of
the fund’s third-party service providers. At the
conclusion of the onsite review, an investment
thesis is presented to and discussed with a Baird
Investment Committee. The Committee votes on
whether to add the fund to a Baird Recommended
Private Fund List. In making that determination,
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Baird’s ETF Focus List
indices,
Baird tends to favor larger-sized issuers of
structured products over smaller-sized issuers
and also tends to favor structured products that
have shorter maturities, less complex payout
structures, underlying assets that are more liquid
or transparent, and offer full or partial principal
protection. If a product does not offer full
principal protection, Baird also considers how
much principal is exposed to loss, whether, in
Baird’s judgment, there is reasonable risk/reward
trade-off for that exposure, as well as the events
that could trigger loss of principal and Baird’s
belief as to the likelihood of the occurrence of
such events.
Investment Solutions Department
Baird’s ETF Focus List is designed to encompass
numerous asset classes and varied investment
objectives. Baird generally seeks to include ETPs,
primarily ETFs, with transparent, experienced
sponsors that have stable or growing assets under
management and have demonstrated consistent
strategy performance over time. Baird tends to
favor ETPs that have well-known, diversified
benchmark
fees and tracking
lower
errors, and higher trading liquidity relative to
other ETPs. Inclusion on or exclusion from the
Baird ETF Focus List is not meant to be a buy or
sell recommendation. Rather, the List
is a
collection of ETPs that may be appropriate to
meet particular client investment goals.
PWM Stock Opportunities List
the
Programs.
Baird’s
Compliance,
Legal,
and
Baird’s
is
primarily responsible for selecting and evaluating
structured products made available to clients
under
Alternative
Investment Committee, which includes members
of Baird’s Investment Solutions, Asset Manager
Risk
Research,
Management Departments, ultimately determines
whether to make a structured product available to
Baird clients.
Available Hedge Funds
yield,
The PWM Stock Opportunities List is comprised of
stocks that Baird’s PWM Equity Research team
believes offer timely investment opportunities
fundamental
based on market, sector, and
analysis. Stocks on the list must be covered by
Baird, Evercore ISI, or Morningstar and are
screened to curb near-term fundamental risk. The
List focuses on large cap and mid/small cap
companies,
and
investments with
speculative investment opportunities.
Managed Futures
Effective March 1, 2018, Baird ceased maintaining
an official list of managed futures funds that are
structured as limited partnerships. Therefore,
Baird does not, and will not in the future, provide
any evaluation, monitoring or review of those
funds or their sponsors. A client’s decision to
invest in, or to maintain an investment in, a
managed futures fund is based solely upon the
client’s own review and evaluation of the fund.
Structured Products
Baird makes hedge funds available to clients in
certain Programs sponsored by, affiliated with or
offered by Capital Integration Systems LLC or
CAIS Capital LLC (“CAIS”). An independent third-
party research firm provides research and due
diligence materials to Baird on the hedge funds
available on the CAIS platform (“Available Hedge
Funds”). Clients interested in an Available Hedge
Fund or invested in an Available Hedge Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely
relies upon the independent third-party research
firm to provide an independent analysis of each
Available Hedge Fund, Baird does not conduct its
own research or due diligence on any Available
Hedge Fund, and Baird does not verify the
accuracy of the information contained in the
research and due diligence materials.
Available Private Funds
is calculated,
When determining whether to make a structured
product available to Baird clients, Baird reviews
the offering documents for the structured product
and considers: the size of the issuer and issuer’s
credit rating, the maturity of the product, how
interest
the underlying asset
category (e.g., a basket of securities or currencies
or a market index), applicable caps, barriers, and
participation rate, and whether the structured
product has principal protection.
In addition to Recommended Private Funds, Baird
makes available to clients in certain Programs
other private funds sponsored by, affiliated with,
or offered by CAIS (“Available Private Funds”),
including Available Private Equity Funds, Available
Private Debt Funds, Available Private REITs and
Available Private Infrastructure Funds. When
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third-party
research
firm
allocation of
the portfolio while providing
exposure to satellite asset classes (such as mid
cap and small cap companies) through the use of
ETFs that principally invest in equity securities.
This model does not include fixed income.
determining whether to make a fund an Available
Private Fund, Baird utilizes the services of an
independent
that
provides research and due diligence materials to
Baird on the private funds available on the CAIS
platform. Clients interested in an Available Private
Fund or invested in an Available Private Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely
relies upon the independent third-party research
firm to provide an independent analysis of each
Available Private Fund, Baird does not conduct its
own research or due diligence on any Available
Private Fund, and Baird does not verify the
accuracy of the information contained in the
research and due diligence materials.
(3)
The Baird Trust Core + Satellite 70/30
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation of the portfolio
while providing exposure to satellite asset classes
(such as mid cap and small cap companies) and
fixed income securities through the use of ETFs
that principally invest in equity securities and
fixed income securities. This strategy has a target
allocation of 70% of its assets to equity securities
and 30% of its assets to fixed income securities.
Affiliated Private Equity Funds
fixed
(4)
The Baird Trust Core + Satellite 50/50
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation portion of the
portfolio while providing exposure to satellite
asset classes (such as mid cap and small cap
companies) and fixed income securities through
the use of ETFs that principally invest in equity
securities and
income securities. This
strategy has a target allocation of 50% of its
assets to equity securities and 50% of its assets
to fixed income securities.
(5)
The Baird Trust Equity Income strategy
primarily invests in dividend paying companies
that Baird Trust believes have the ability to
consistently grow their dividend at attractive rates
over the long‑term.
In addition to Recommended Funds of Private
Equity Funds and Available Private Equity Funds,
Baird makes available to clients private equity
funds that are affiliated with Baird (“Affiliated
Private Equity Funds”). Baird does not subject
Affiliated Private Equity Funds to the criteria
imposed upon Recommended Funds of Private
Equity Funds or Available Private Equity Funds
described above when making them available to
clients, and Baird does not perform any
evaluation, monitoring or review of Affiliated
Private Equity Funds. This presents a potential
conflict of interest. See “Other Financial Industry
Activities and Affiliations—Certain Relationships
and Arrangements—Baird and Associated Parties”
below.
More specific information about the particular
investment strategies and methods of analysis
that Baird uses in connection with each Program
is further described below.
Baird Trust Strategies
Baird makes available to clients five (5) portfolio
strategies developed and maintained by Baird
Trust (“Baird Trust Strategies”) described below.
The Baird Trust Strategies invest in a mix of
equity securities and ETFs.
(1)
The Baird Trust Large Cap Equity strategy
invests in a fairly concentrated portfolio of large
cap equity securities. This strategy is intended for
clients seeking investment in large cap companies
as one part of their overall asset allocation. This
strategy is generally not intended to be a
complete investment program.
The DDK Investment Process
When providing advice to clients, DDK starts with
a needs analysis developed for a client in
connection with the financial planning process
described above. Using a variety of tools, DDK
then develops and recommends a long-term,
strategic asset allocation and investment strategy
for the client’s portfolio that is customized for the
client’s risk and return objectives. DDK diversifies
the client’s portfolio among different investments
in each asset class with the goal to manage risk.
Investment strategies may involve the use of
different equity styles or strategies, such as: large
cap growth, large cap value, mid cap growth, mid
(2)
The Baird Trust Core + Satellite 100
strategy is a diversified portfolio with a 100%
target equity allocation. The strategy uses the
Baird Trust Large Cap Equity strategy as the core
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Service Information
DDK Investment Management Service
Under the DDK Investment Management Service,
DDK may use various investment strategies. A
client’s particular investment strategy is typically
determined by DDK in consultation with the client
using the investment process described in the
section “The DDK Investment Process” above.
cap value, small cap growth, small cap value,
international and emerging market equities
strategies; different
income styles or
fixed
strategies, such as short or intermediate, taxable
and tax-exempt bond, international and emerging
market bond, and high yield bond strategies; ;
and Complex Strategies, such as real estate and
real estate funds (including private real estate
funds and private real estate fund of funds),
commodity strategies, hedge funds, funds of
hedge funds, private equity funds, funds of
private equity funds, private debt funds and
managed futures.
time
to
time, and depending on
From
macroeconomic
conditions, DDK may also
recommend or implement a slight, short-term
tactical tilt to the client’s chosen asset allocation
that is above or below the long-term strategic
asset allocation.
lists,
see
Investment
Management
DDK Consultants, as a group, utilize a variety of
investment styles and strategies, including the
investment strategies described in the sections
“Methods of Analysis, Investment Strategies and
Risk of Loss—Investment Strategies” and “The
DDK Investment Process” above. They may also
use the model portfolios or recommended or
eligible product lists made available by Baird’s
PWM Research Groups, or they may use lists of
investment products that Baird has generally
deemed to be “available” for use in its advisory
programs. For more information about Baird
model portfolios, recommended lists and eligible
product
“Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis” above.
DDK typically recommends or selects mutual
funds and ETFs for Advisory Choice Accounts and
DDK
Accounts.
However, other types of securities may be
recommended or selected for those Accounts.
for
the client. Once
Service
When recommending or selecting a particular
mutual fund or ETF for client Accounts, DDK
begins by reviewing a client’s asset allocation and
investment strategy needs and identifying the
characteristics of the types of mutual funds or
ETFs appropriate
the
characteristic types of mutual funds or ETFs are
identified, DDK looks for investments that meet
those requirements. DDK looks for funds that
have
lower expense ratios. Once DDK has
identified a potential fund for a client, DDK
conducts a quantitative and qualitative analysis of
the investment manager for the fund similar to
the analysis it performs on investment managers
described under “DDK Recommended Managers
Service” below.
DDK manages client assets using investment
strategies and investment products based upon a
client’s particular
investment objectives and
financial goals. DDK may use a wide variety of
investment products to implement the client’s
investment strategy, which
investments are
further described under “Advisory Business—
Additional
Information—Permitted
Investments” above. DDK may also use certain
investment strategies, such as concentrated
investment strategies and margin, and certain
types of investments, such as illiquid securities
and Complex Investment Products,
including
REITs, private equity funds, funds of private
equity funds, leveraged or inverse funds and
structured products. These investment strategies
and products involve special risks and may not be
appropriate for all clients. Please see “Principal
Risks” below for more information.
or
In order to implement the overall client portfolio
strategy, DDK may utilize one or more of the
Services and a
combination of different
investment vehicles, such as SMAs, mutual funds
and ETFs.
the heading
More specific information about the particular
investment strategies and methods of analysis
that DDK and Baird use in connection with each
Service is further described below.
DDK Recommended Managers Service
When
other
selecting
recommending
to manage a client’s
investment managers
Account in the DDK Recommended Managers
Service, DDK typically utilizes managers included
on Baird’s Recommended Managers List described
“Methods of Analysis,
under
Investment Strategies and Risk of Loss—Methods
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of Analysis—Certain Recommended Lists—Baird’s
Recommended Managers List” above. Although in
some circumstances, DDK may select a manager
to manage a client’s Account that is not included
on Baird’s Recommended Managers List.
DDK Recommended Managers Program (including
any third party Implementation Manager). DDK
and Baird assume no responsibility for the client’s
termination of an Other Manager (including any
third party Implementation Manager), the Other
Manager’s investment decisions, performance,
compliance with applicable laws or regulations, or
for any other matters involving or affecting the
Other Manager.
the manager,
focusing on
Baird SMA Network and Dual Contract
Programs
Clients participating in the BSN Program or the
DC Program should note that the level of initial
and ongoing review performed by DDK and Baird
on the managers and their SMA Strategies made
available under those Programs, including any
Associated SMA Strategies, is significantly less
than that performed by DDK and Baird with
respect to managers and their strategies eligible
for the DDK Recommended Managers Service.
DDK will select or replace, or recommend the
selection or replacement of, a particular manager
based upon the client’s particular goals and
circumstances and the client’s selected asset
allocation and
investment strategy. Before
selecting or recommending a manager to a client,
DDK performs its own quantitative and qualitative
analysis of
the
manager’s performance and factors DDK believes
will help a manager repeat historical performance
such as the investment process and personnel,
organizational and investment structure. DDK also
focuses on the risk and investment style relative
to other investment strategies already in a client’s
portfolio. DDK generally relies upon Baird’s
Advisory Research group to provide periodic
review and evaluation of managers on Baird’s
Recommended Managers List. To the extent a
manager
is not on Baird’s Recommended
Managers List, DDK will perform periodic review
and evaluation of the manager using its own
quantitative and qualitative analysis described
above. DDK will remove a manager
from
management of a client’s Account when the
manager is removed from Baird’s Recommended
Managers List or if DDK determines that removal
is in the client’s best interest.
BSN and DC Managers are subject to an initial
review by Baird that considers the manager’s
assets under management,
regulatory and
compliance history, and certain other limited
qualitative and quantitative
factors deemed
relevant by Baird. The ongoing review is generally
performed on an annual basis and is generally
limited to significant changes in the managers’
assets under management in the SMA Strategy
and a review of the SMA strategy in comparison
to a relevant peer group or benchmark.
a
client who wishes
Clients should note that an investment manager
managing the client’s Account under the DDK
Recommended Managers Service may not be on
Baird’s Recommended Managers List. A client
should understand that DDK and Baird do not
perform any due diligence or ongoing monitoring,
evaluation or reviews of investment managers
except to the extent DDK otherwise specifically
agrees to do so in writing.
The BSN and DC Programs are designed to
accommodate
to
independently select an investment manager not
available in the DDK Recommended Managers
Service to manage the assets in the client’s
Account. A client should note that DDK and Baird
do not make any recommendation to clients
regarding any BSN Strategy or DC Strategy or
any representations regarding a BSN Manager’s or
DC Manager’s qualifications as an investment
adviser or abilities to manage client assets.
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, a client should note that DDK and Baird
do not monitor or ascertain whether a third party
Implementation Manager is fully and faithfully
implementing the Model Portfolio on a continuous
basis.
The Overlay Manager may provide review and
ongoing evaluations of certain BSN Managers that
it makes available through the BSN Program.
Clients should review Overlay Manager’s Form
ADV Part 2A Brochure for more information, which
is available upon request, or contact their DDK
Consultant for more information.
A client assumes ultimate responsibility
for
client’s selection of an Other Manager under the
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is
organizations, such as the Financial Industry
Regulatory Authority,
Inc., exchanges, and
governmental agencies.
DDK and Baird do not monitor or ascertain
whether the Overlay Manager
fully and
faithfully implementing Model Portfolios under the
BSN Program on a continuous basis.
of
Loss—Principal
and
Associated Managers.
SMA Strategies offered under the BSN and DC
Programs are subject to certain risks. See
“Methods of Analysis, Investment Strategies and
Risks—Available
Risk
Investment Product Risks” below
for more
information.
Portfolio Management by DDK, Baird and
Associated Managers
Portfolio management services under the DDK
Investment Management, DDK Recommended
Managers and DC Programs may be provided by
Baird
Such
arrangements create a potential conflict of
interest because Baird and Associated Managers
may receive higher aggregate compensation if
clients retain Baird and Associated Managers
instead of retaining unassociated managers.
the
A client should only participate in the BSN or DC
Programs if the client wishes to take more
responsibility for monitoring the client’s Account,
the DDK Recommended Managers Program does
not contain an SMA Strategy that meets the
client’s particular needs, and
client
understands the risks of doing so.
departments,
retention of an
the heading
The following Services exclusively offer portfolio
management by Baird, its DDK Consultants, its
PWM home office investment professionals, its
investment management
or
investment managers that are affiliated with
Baird: DDK Investment Management Service. The
processes, if any, used by Baird for selecting and
reviewing those portfolio managers is described
under
“Methods of Analysis,
Investment Strategies and Risk of Loss—Service
Information” above.
A client should note that the client’s appointment
investment
and continued
manager to manage the client’s Account in
connection with the BSN and DC Programs are
based ultimately upon the client’s independent
review of the investment manager and the
investment manager’s services. Once retained by
the client, an investment manager will only be
removed from managing the client’s Account upon
the investment manager’s withdrawal, removal
from the Program, or the client’s direction to do
so.
(including any
performance,
compliance
A client assumes ultimate responsibility
for
client’s selection of a manager under the BSN or
third party
DC Programs
Implementation Manager). DDK and Baird assume
no responsibility for the client’s termination of a
the BSN or DC Programs
manager under
Implementation
third party
(including any
Manager). DDK and Baird also assume no
responsibility for any Other Manager’s investment
decisions,
with
applicable laws or regulations, or for any other
matters involving or affecting the Other Manager.
A client should note that the processes and
standards used by Baird in determining whether
to make affiliated investment options available
under the DDK Investment Management Service
differ from those processes and standards used
by Baird in determining whether to make non-
affiliated investment options available under other
Services. Baird approves, and continues to make
available, affiliated investment options under the
DDK Investment Management Service that would
not be approved for, or would have been removed
from, such other Services. This practice presents
a conflict of interest because Baird has a financial
incentive to maximize the number of affiliated
investment options it makes available under the
DDK Investment Management Service due to the
fact that, by increasing investment options, Baird
will likely attract more client assets and thereby
increase Baird’s revenues. A client participating in
the DDK Investment Management Service should
monitor the client’s Account performance and
periodically discuss the performance of such
Account with the client’s DDK Consultant.
Portfolio management services under the DC
Program may be provided by an investment
management department of Baird if the client
selects such an SMA Strategy. In order to provide
portfolio management services under the DC
Program, Baird requires that Baird associates
meet all applicable requirements set forth by
applicable law and regulations of self-regulatory
Portfolio management services under the DDK
Recommended Managers Service or DC Program
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professionals,
an
conditions and other
or
for
the associated
the heading
could be provided by Baird PWM home office
investment
investment
management department of Baird or an
Associated Manager should a client select an
Associated SMA Strategy. When Baird selects SMA
Strategies, or otherwise determines manager
availability
the Baird
eligibility,
Recommended Managers List or the DC Program,
Associated SMA Strategies and Associated
Managers are subject to the same selection and
review processes, if any, that Baird applies to
unassociated SMA Strategies and investment
managers participating in each respective Service.
The processes, if any, used by Baird for selecting
and reviewing SMA Strategies and Associated
SMA Strategies for those Services are further
described under
“Methods of
Analysis, Investment Strategies and Risk of
Loss—Service Information” above.
upon the nature of the client’s investments,
market
factors. By
participating in a Service, a client may be subject
to certain risks, including, but not limited to the
risks described below. The risks discussed below
vary by Service, investment style or strategy, and
the investments in the client’s Account, and each
risk may or may not apply to a client. Clients
should not pursue a strategy or invest in an
investment product unless they are prepared to
accept
risks. Clients are
encouraged to discuss with their DDK Consultant
the risks that apply to them. A client should also
review
the prospectus or other disclosure
document for any security or other investment
product in which the client invests, as it will
contain important information about the risks
associated with investing in such security or other
investment product.
Investment Risk Information
The investment risks of the Services generally
include the following:
Market Risks. A client’s Account may change in
value due to overall market fluctuations. General
economic conditions, political developments,
international events and other factors may cause
the overall market to decline, which in turn may
reduce the value of the client’s Account regardless
of the relative strength of the securities held in
the Account. Securities prices often vary for
reasons unrelated to matters directly affecting the
issuers of the securities.
When providing investment advisory services to
clients, DDK and Baird are fiduciaries and are
required to act solely in the best interest of
clients. Baird addresses the conflicts described
above through disclosure in this Brochure and by
adopting internal policies and procedures for DDK
and Baird and their associates that require them
to provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients). For more specific
information about these potential conflicts and
how Baird addresses them, please see the
sections “Other Financial Industry Activities and
Affiliations” and “Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
fluctuate
client
accounts
about
Management and Securities Selection Risks.
A client’s Account may
in value
differently than, or in the opposite direction as,
the overall market or applicable benchmark
because of the selection of individual securities for
the Account. The judgments made by the persons
managing
the
attractiveness, value and potential appreciation of
particular securities may prove to be incorrect.
For example, while the stock markets may
experience increases in value, the client’s Account
may experience a decline in value due to the
underperformance of the stocks selected for
investment in the client’s Account.
Principal Risks
Risk is inherent in any investment product and
DDK and Baird do not guarantee any level of
return on a client’s investments. There is no
assurance that a client’s investment objectives
will be achieved, and a client could lose all or a
portion of the amount invested. The management
of client accounts and recommendations made to
clients are based in part upon the use of forward-
looking projections, which in turn are based upon
certain assumptions about how markets will
perform in the future. There can be no guarantee
that markets will perform in the manner assumed
and the actual performance of markets and a
client’s Account could differ materially from those
assumptions. Also, a client’s Account value may
fluctuate, sometimes dramatically, depending
Investment Objective and Asset Allocation
Risks. A client’s investment objective and asset
allocation strategies involve the risk that certain
asset classes selected for the client’s Account may
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economic, monetary and fiscal policies; inflation
and
interest rates; economic expansion or
contraction; and global or regional political,
economic and banking crises. Holders of common
stocks are generally subject to greater risk than
holders of preferred stocks and debt obligations of
the same issuer because common stockholders
generally have inferior rights to receive payments
from issuers in comparison with the rights of
preferred stockholders, bondholders and other
creditors.
not perform as well as other asset classes during
varying periods. In addition, clients who pursue
more aggressive investment objectives and asset
allocation strategies, while hoping to achieve high
returns, may face greater risk of loss than clients
with more conservative objectives and strategies.
In developing investment objectives and asset
allocation strategies, clients should carefully
consider their financial situation and needs,
investment goals, investment time horizon and
risk tolerance. A client should inform the client’s
DDK Consultant of these considerations so the
DDK Consultant can assist in determining the
client’s investment objectives and asset allocation
strategies.
Fixed Income Security Risks. Fixed income
securities are subject to certain risks, including
interest rate risk, credit risk and liquidity risk. In
addition, they are subject to maturity risk.
Generally, the longer a bond’s maturity, the
greater the interest rate risk and the higher its
yield. Conversely, the shorter a bond’s maturity,
the lower the interest rate risk and the lower its
yield. Non-rated, split-rated, below investment
grade, and asset-backed securities, including
mortgage-backed securities and CMOs, have
additional, special risks.
Conflicts of Interest Risks. Issuers, advisors or
other sponsors of investment products or their
affiliates may engage in business practices that
conflict with the interests of investors. Among
other things, these business practices can have a
negative impact on the market price of the
investment product. Clients are encouraged to
review
the prospectus or other disclosure
document for the investment product and also
discuss with their DDK Consultant the conflicts of
interest risks that may apply to them.
Stock Market Risks. Equity security prices vary
and may fall, thus reducing the value of a client’s
investments. Certain stocks selected for a client’s
Account may decline in value more than the
overall stock market.
Interest Rate Risk. The value of some
investment products, particularly fixed income
securities, is affected significantly by changes in
interest rates. Generally, when interest rates rise,
the product’s market value declines and when
interest rates decline, its market value rises. In
addition, a rise in interest rates may have a
negative impact on the issuer, which, in turn,
could have a negative impact on the market value
of the investment product.
Equity Securities Risks. Equity securities may
experience sudden, unpredictable drops in value
or long periods of decline in value. This may occur
because of factors that affect the securities
markets in general, such as adverse changes in
economic conditions, the general outlook for
corporate earnings, interest rates or investor
sentiment. Equity securities may also lose value
because of factors affecting an entire industry or
sector, such as increases in production costs, or
factors directly related to a specific company,
such as decisions made by its management.
Common Stock Risks. Common stocks are
susceptible to general stock market fluctuations
and to volatile increases and decreases in value
as market confidence in and perceptions of their
issuers change. These investor perceptions are
based on various and unpredictable
factors
including: expectations regarding government,
Credit Risk. The value of some investment
products, particularly fixed income securities, is
affected by changes in the product’s credit quality
rating or the issuer’s financial condition. If the
credit quality rating or the issuer’s financial
condition declines, so may the value of the
investment product. Issuers may experience
unanticipated financial problems and may be
unable to meet its payment obligations. Municipal
obligations in particular may be adversely affected
by political and economic conditions and
developments (for example, legislation reducing
state aid to local governments.) Bonds receiving
the lowest investment grade rating or a non-
investment grade rating may have speculative
characteristics and, compared to higher grade
debt obligations, may have a weakened capacity
to make principal and interest payments due to
changes in economic conditions or other adverse
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are not subject to uniform accounting, auditing
and financial reporting standards comparable to
those applicable to domestic companies. With
respect to certain foreign countries, there is a
possibility of expropriation or
confiscatory
taxation, or diplomatic developments, which could
affect investment in those countries.
Investments
circumstances. Ratings agencies such as Moody’s,
Fitch and S&P provide ratings on bonds based on
their analyses of information they deem relevant.
Ratings are essentially opinions or judgments of
the credit quality of an issuer and may prove to
be inaccurate. In addition, there may be a delay
between events or circumstances adversely
affecting the ability of an issuer to pay interest
and/or repay principal and an agency’s decision to
downgrade a security.
less
liquid
market
depth,
larger companies. Therefore,
Emerging Markets Risks.
in
emerging markets can involve risks in addition to
and greater than those generally associated with
investing in more developed foreign markets. The
extent of economic development, political
stability,
infrastructure,
capitalization, and regulatory oversight can be
less than in more developed markets. Emerging
market economies can be subject to greater
regulatory, and political
social, economic,
uncertainties. All of these factors can make
emerging market securities more volatile and
potentially less liquid than securities issued in
more developed markets.
them more susceptible
Capitalization Size Risks. A client may be
invested in small and mid cap stocks, which are
often more volatile and
than
investments in larger companies. The frequency
and volume of trading in securities of such
companies may be substantially less than is
the
typical of
securities of such companies may be subject to
greater and more abrupt price fluctuations. In
addition, small- and mid-size companies may lack
the management experience, financial resources
and product diversification of larger companies,
making
to market
pressures and business failure.
the
foreign
that
could
compromise
technology
Such
incidents may
or
penalties,
reputational
Foreign Issuer and Investment Risks.
Securities of
issuers, ADRs, Global
Depositary Receipts (“GDRs”) and European
Depositary Receipts (“EDRs”), and investments in
foreign markets generally, are subject to certain
inherent risks, such as political or economic
instability of the country of issue, the difficulty of
predicting international trade patterns and the
possibility of imposition of exchange controls.
Such securities may also be subject to greater
fluctuations in price than securities of domestic
corporations. Investors in foreign markets may
face delayed settlements, currency controls and
adverse economic developments as well as higher
overall transaction costs. In addition, fluctuations
in the U.S. dollar’s value versus other currencies
may enhance, erode, reverse gains or widen
losses from investments denominated in foreign
currencies. For instance, foreign governments
may limit or prevent investors from transferring
their capital out of a country. This may affect the
value of a client’s investment in the country that
adopts such currency controls. Exchange rate
fluctuations also may impair an issuer’s ability to
repay U.S. dollar denominated debt, thereby
increasing the credit risk of such debt. In
addition, there may be less publicly available
information about a foreign company than about a
domestic company. Foreign companies generally
Information Security, Cybersecurity and
Technology-Related Risks. As issuers and their
service providers increasingly rely on digital
Internet, cloud
technologies, such as
computing, and AI‑enabled systems, they face
heightened information security, cybersecurity,
including
and other technology‑related risks,
the
incidents
confidentiality, integrity, or availability of their
systems, data, or
infrastructure.
Technology-related incidents may result from
deliberate adversarial actions (such as cyber
attacks) or unintentional events (such as systems
or human error) and could have a materially
adverse impact on the issuer’s performance and
operations.
involve
unauthorized access, disclosure, use, corruption,
degradation, or destruction of systems or data
(such as
through hacking, malware, social
engineering or theft of digital devices); or the
disruption of systems access to authorized users
(such as through denial of service attacks). Such
events can impede critical functions, compromise
sensitive business and protected customer
information, and may result in financial losses,
business interruptions, impediments to the ability
to process transactions, breaches of applicable
privacy, data protection, or other laws, regulatory
fines
harm,
reimbursement or other remediation costs, and
increased compliance or operational expenses.
Substantial costs may be incurred to prevent,
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investigate,
or
remediate
in
the
section
titled
their
own
information
related
incidents
use
protected
incidents,
detect,
future
technology related incidents. Issuers’ increasing
use of AI systems introduces additional risks
“Artificial
discussed
Intelligence Risks” below. Issuers may also rely
on third party or cloud based platforms that
present
security,
cybersecurity, and other technology‑related risks.
Similar adverse consequences may arise from
technology
affecting
governmental authorities,
regulatory bodies,
financial market systems, exchanges, brokers-
dealers, banks, insurance companies, custodians,
or other market participants. Although issuers and
their service providers may adopt business
continuity plans, information security controls,
and risk management programs designed to
these
prevent or mitigate such
measures are subject to inherent limitations,
including the possibility that certain risks may not
be identified or fully addressed. As a result, client
Accounts and investments may be negatively
affected.
involve inconsistent or conflicting requirements
across
jurisdictions. Compliance may require
significant investment, changes to AI systems, or
the discontinuation of certain AI‑enabled features.
Non‑compliance may lead to fines, enforcement
actions, or operational constraints. AI systems are
vulnerable to cyberattacks or other adversarial
actions that can impair system performance and
integrity and compromise sensitive business and
protected customer information. The impairment
of AI systems or the unauthorized disclosure of
sensitive business or protected information can
result in material disruption and damage to
legal and
significant
business operations,
regulatory
remediation
liabilities, substantial
expenses, and reputational harm. AI systems may
inadvertently
information,
potentially giving rise to intellectual property
infringement claims and substantial damages.
Public concerns regarding fairness, transparency,
and responsible use of AI may reduce demand for
an issuer’s products or services. Failure to use AI
responsibly may harm an issuer’s reputation and
competitive position.
Intelligence Risks.
increasingly use AI systems
issued by
in
fact
inaccurate,
regulatory
scrutiny,
Government Obligation Risks. Client assets
may be invested in securities issued, sponsored or
guaranteed by the U.S. Government, its agencies
and instrumentalities. However, no assurance can
be given that the U.S. Government will provide
financial support to U.S. Government-sponsored
agencies or instrumentalities where it is not
obligated to do so by law. For instance, securities
issued by the Government National Mortgage
Association (“Ginnie Mae”) are supported by the
faith and credit of the United States.
full
Securities
the Federal National
Mortgage Association (“Fannie Mae”) and the
Federal Home Loan Mortgage Corporation
(“Freddie Mac”) have historically been supported
only by the discretionary authority of the U.S.
Government. While the U.S. Government provides
financial support to various U.S. Government-
sponsored agencies and instrumentalities, such as
those listed above, no assurance can be given
that it will always do so.
rely
on
third-party
AI
falling. Since
interest
Issuers of
Artificial
investments
in
various aspects of their business operations,
creating competitive market pressures to increase
the development and use of AI systems. Failure to
effectively develop or use AI systems may place
an issuer at a competitive disadvantage. At the
same time, AI systems present significant risks
that could materially affect an issuer’s business
and financial performance. AI Tools rely on
complex models, large datasets, and evolving
algorithms. AI Tools are highly-useful but
complex and fallible systems that can exhibit bias,
hallucinations, deceptive behaviors and other
flaws due to the construction of their underlying
models and the composition of their training data,
which can result in outputs that seem plausible
but are
incomplete, or
misleading. The use of erroneous outputs can
undermine customer trust and expose issuers to
substantial
litigation,
remediation costs, and reputational harm. AI tools
require timely access to high‑quality, compliant
data, and any disruption in data availability can
impair or disable AI Tool functionality. Issuers
systems,
often
infrastructure, and data, which can create vendor
dependency, limit visibility into and validation of
AI model performance, and increase the risk of
disruption in data availability. The regulatory
environment for AI is rapidly evolving and may
Municipal Securities Risks. Repayment of
municipal securities depends on the ability of the
issuer or project backing such securities to
generate taxes or revenues. Municipal securities
may also decrease in value during times when tax
rates are
income on
municipal securities is normally not subject to
the
income
regular
federal
taxation,
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in such
for purchases or withdrawals.
redemptions
in
operations when the value of a fund drops. In
that event, the fund's holdings may be liquidated
and distributed to the fund's shareholders. This
liquidation process could take time to complete.
During that time, the amounts a client has
invested in the money market fund would not be
available
In
addition, retail and institutional money market
funds are required to impose redemption fees
(also known as liquidity fees) and suspend
redemptions (also known as redemption gates) in
certain
circumstances. Government money
market funds may also impose redemption fees
and suspend
those same
circumstances. More specific information about
how a money market fund calculates its NAV and
the circumstances under which it will impose a
redemption fee or suspend redemptions is set
forth in the prospectus for that money market
fund.
attractiveness of municipal securities in relation to
other investment alternatives is affected by
changes in federal income tax rates applicable to,
or the continuing federal tax-exempt status of,
such interest income. Any proposed or actual
changes
rates or exempt status,
therefore, can significantly affect the liquidity,
marketability and supply and demand
for
municipal securities, which would in turn affect
Baird’s ability to acquire and dispose of municipal
securities at desirable yield and price levels.
Investment in tax-exempt debt obligations poses
additional risks. In many cases, the IRS has not
ruled on whether the interest received on a tax-
exempt obligation is tax-exempt, and accordingly,
purchases of these municipal securities are based
on the opinion of bond counsel to the issuers at
the time of issuance. Thus, there is a risk that
interest may be taxable on a municipal security
that is otherwise expected to produce tax-exempt
interest.
to
lower
securities,
and/or
to make a market
for
Money Market Fund Risks. A money market
fund is a type of mutual fund that generally
invests in short-term debt instruments. Many
investors use money market funds to store cash.
There are three primary types of money market
funds: (1) government money market funds
(funds that invest nearly all assets in cash,
government
repurchase
agreements collateralized by cash or government
securities); (2) retail money market funds (funds
that have policies and procedures reasonably
designed to limit beneficial ownership to natural
persons); and (3) institutional money market
funds (funds that permit beneficial ownership by
institutions and natural persons). The rules
governing money market funds vary based on the
type of money market fund. Government and
retail money market funds generally try to keep
their net asset value (NAV) at a stable $1.00 per
share using special pricing and valuation
conventions. Institutional money market funds
are required to calculate their NAV in a manner
such that the NAV will vary based upon the
market value of assets and liabilities of the fund
(also known as a “floating NAV”). An investment
in a money market fund is not insured or
guaranteed by the FDIC or any other government
agency. Although some money market funds seek
to preserve the value of an investment at $1.00
per share, there can be no assurance that will
occur, and it is possible to lose money should the
fund value per share fall. In some circumstances,
money market funds may be forced to cease
Illiquid Securities and Liquidity Risks.
Liquidity risk is the risk that certain investments
may be difficult or impossible to sell at the time
and price that a client would like to sell. Clients
may have
the price, sell other
investments or forego an investment opportunity,
any of which may have a negative effect on the
management or performance of client accounts.
The liquidity of a particular investment depends
on the strength of demand for the investment,
which is generally related to the willingness of
broker-dealers
the
investment as well as the interest of other
investors to buy the investment. During periods of
economic uncertainty, significant economic and
market downturns and periods in which financial
services firms are unable to commit capital to
make a market in, or otherwise buy, certain
investments, a client may experience challenges
in selling such investments at optimal prices. In
addition, recent regulatory changes applicable to
financial intermediaries that make markets in
debt securities have restricted or made it less
desirable for those financial intermediaries to hold
large inventories of debt securities. Because
market makers provide stability to a market
through their intermediary services, a reduction in
dealer inventories may lead to decreased liquidity
and increased volatility in the fixed income
markets. In the event the client directs Baird to
liquidate an illiquid investment, the client should
understand that Baird may have difficulty finding
a buyer in the market for such investment and
such investment may be held in the Account for a
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period of time while Baird attempts to satisfy the
client’s liquidation request.
Asset-backed securities may be subject to greater
risk of default during periods of economic
downturn than other instruments. Asset-backed
securities also can be more sensitive to interest
rate risk than other types of fixed income
securities. Modest movements in interest rates
(both increases and decreases) may quickly and
significantly reduce the value of certain types of
these securities. Asset-backed securities are
subject to a number of other risks, including, but
not limited to, market and valuation risks,
liquidity risk, and prepayment risk.
Split-Rated,
and
Concentration Risks. A client’s Account may
consist of a portfolio of securities that
is
concentrated in an issuer or group of issuers, an
industry or economic sector or group of related
industries or sectors, or concentrated in limited
asset classes. Client accounts with concentrated
positions are susceptible to greater volatility and
increased risk of loss than an Account that is
diversified across several issuers and industries or
sectors and asset classes. A client should not
engage in strategies using concentration unless
the client is prepared to experience significant
losses in the value of the client’s Account.
Non-Rated,
Below
Investment Grade Securities (High Yield or
“Junk” Bonds) Risks. Investing in securities or
other investment products that are not rated,
split-rated or are below investment grade (also
known as high yield or “junk” bonds) involve
significant, special risks. As a result, they may not
be suitable for some clients. The risks associated
with these investments include, but not limited to,
price volatility risk, credit risk, default risk, and
liquidity risk. Clients investing in securities or
other investment products that are not rated,
split-rated or are below investment grade should
have a high tolerance for risk, including the
willingness and ability to accept significant price
volatility, potential lack of liquidity and potential
loss of their investment.
including equity,
fixed
Frequent Trading and Portfolio Turnover
Risks. Some of the investment strategies offered
to clients in this Brochure may involve frequent or
active trading for client accounts, which could
result in high portfolio turnover. Strategies that
involve frequent or active trading increase the
management and securities selection
risks
because the persons managing the accounts are
making more trading decisions, which may prove
to be incorrect. A portfolio with a high turnover
rate will also incur more transaction costs than
one with a lower rate. Higher transaction costs
may negatively impact the return of the portfolio.
High portfolio turnover may also cause a client to
experience adverse tax consequences due to the
fact that the client may have increased instances
of realized gains and losses and such gains and
losses may commonly be characterized as short
term gains and losses under applicable tax law.
investment
style,
securities
selection
credit
capitalization
risk,
foreign
Mutual Fund Risks. Mutual funds can have
investment objectives and
many different
strategies,
income,
balanced, international, and global strategies, and
strategies that focus on a particular market
capitalization,
economic
industry or sector, or geographic region. Mutual
funds have risks, which may include market risk,
risk,
management and
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate
risk,
risk,
risk,
issuer and
investment style
investment risk, and emerging market risk.
Certain mutual funds pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of mutual fund selected. Also, investment
return and principal value will fluctuate, and
shares, when redeemed, may be worth more or
less than their original cost.
Asset-Backed Securities Risks. Asset-backed
securities are securities secured or backed by
mortgage loans, student loans, automobile loans,
installment sale contracts, credit card receivables
or other assets and are issued by entities such as
commercial banks, trusts, financial companies,
finance subsidiaries of
industrial companies,
savings and loan associations, mortgage banks
and investment banks. These securities represent
interests in pools of assets in which periodic
payments of interest or principal on the securities
are made, thus, in effect passing through periodic
payments made by the individual borrowers on
the assets that underlie the securities, net of any
fees paid to the issuer or guarantor of the
securities. Asset-backed securities are issued in
multiple classes (or tranches) and their relative
payment rights may be structured in many ways.
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for purposes of making
equity,
securities
selection
credit
capitalization
risk,
foreign
closed-end
securities
include market
selection
credit
capitalization
risk,
foreign
require closed-end funds to buy back their shares,
although closed-end fund shares are listed and
traded on an exchange. For many reasons,
closed-end fund shares often trade at a discount
to their net asset value and the market prices of
closed end fund shares often fall below their
public offering prices. Clients are therefore
cautioned about buying shares of a closed-end
fund in its initial public offering. Closed-end funds
often engage in leverage to raise additional
capital
investments
through borrowings and issuances of senior
securities (such as preferred stock). Such
leverage may present the opportunity to enhance
potential returns but also involve the risk of
exacerbating losses and depreciation in the value
of the underlying securities. Closed-end funds
have other risks, which may include market risk,
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
rate
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk.
Certain
funds pursue Complex
Strategies, which are subject to special risks.
Some closed-end funds are organized as interval
funds, which differ from traditional closed-end
funds in that their shares do not trade on the
secondary market, but instead their shares are
subject to repurchase offers from the fund.
Closed-end funds structured as an interval fund
will, therefore be relatively less liquid. Interval
funds also often impose a redemption fee when
shares are sold back to the fund. The degree of
these and other risks will vary depending on the
type of close-end fund selected.
Exchange Traded Fund Risks. An ETF is
different from a mutual fund in that an ETF does
not sell its shares directly to public investors and
does not redeem shares from public investors.
Rather, shares of an ETF are commonly purchased
or sold in the secondary market on a securities
exchange, like common stocks. An ETF maintains
a net asset value but, based on demand and
other factors, the market price of shares of an
ETF may vary from its net asset value. ETFs
invest in and hold securities and other assets,
such as stocks, bonds, commodities and
currencies, and have stated investment objectives
and principal strategies. ETFs can have many
different investment objectives and strategies,
including
income, balanced,
fixed
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. Many ETFs seek to track the
performance of an index or other underlying
benchmark. Passively managed ETFs will not be
able to replicate exactly the performance of the
indices the ETFs track because the total return
generated by the securities will be reduced by
management fees, transaction costs and other
expenses incurred by the ETF. ETFs have other
risk,
risks, which may
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate
risk,
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk.
Certain ETFs pursue Complex Strategies, which
are subject to special risks. The degree of these
and other risks will vary depending on the type of
ETF selected.
is selected by
equity,
that
fund
Closed-End Fund Risks. Unlike mutual funds
which continuously offer and redeem their shares
on a daily basis at net asset value, closed-end
funds typically raise money by selling a fixed
number of shares of common stock in a single,
one-time offering, much the way a company
issues stock in an initial public offering. Closed-
end funds can have many different investment
objectives and strategies, including equity, fixed
international, and global
income, balanced,
strategies, and strategies
focus on a
particular market capitalization, investment style,
industry or sector, or geographic
economic
shares are not
region. Closed-end
investors cannot
redeemable, meaning
that
Unit Investment Trust Risks. A UIT is a pooled
in which a portfolio of
investment vehicle
securities
the sponsor and
deposited into the trust for a specified period of
time. The portfolio of a UIT is designed to follow
an investment objective over a specified time
period, although there is no guarantee that the
objective will be met. UITs can have many
different investment objectives and strategies,
including
income, balanced,
fixed
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. UITs are passively managed
and follow a “buy and hold” strategy, meaning
that UITs buy a fixed portfolio of securities and
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that are broader or more diversified. Similarly,
investment styles or strategies that focus on
value stocks may perform better or worse than
styles or strategies that focus on growth stocks or
that are broader or more diversified. A particular
style of investing may go out of favor at times
and for extended periods. Growth stocks are often
characterized by high price-to-earnings ratios and
may be more volatile than stocks with lower
price-to-earnings ratios. Value stocks are subject
to the risk that the broader market may not agree
with the manager’s assessment of, or recognize,
the investments’ intrinsic value.
hold on to that portfolio until their termination
date at which time the portfolio is liquidated with
the net proceeds paid to investors. UITs, thus,
generally have a relatively higher risk of loss than
other funds in the event of adverse changes in
market or economic conditions. UITs have other
risks, which may
include management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, and emerging market
risk. Certain UITs pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of UIT selected. Also, investment return and
principal value will fluctuate, and units, if and
when redeemed, may be worth more or less than
their original cost.
ESG Considerations Risk. Consideration of ESG
factors in the investment process may cause an
advisor or manager to forgo opportunities to
recommend or invest in certain companies or to
gain exposure to certain industries or regions.
Therefore, there is a risk that, under certain
market conditions, an Account pursuing strategies
that consider ESG factors may underperform
accounts that do not consider such factors. There
are not universally accepted ESG factors and
advisors and managers typically consider them in
their discretion.
an
investment
negative
tax
consequences.
Risks Common to All Funds; Purchase and
Redemption Risks. Funds are generally subject
to the same risks as the securities or other assets
in which they invest. In addition, from time to
time Baird, a DDK Consultant, or an investment
manager may decide to add or remove a Fund to
or from an investment strategy or Service. In
addition, they may decide to increase or decrease
their clients’ account allocations to a Fund. In
general, they will place transactions for all
affected Accounts at one time, which may cause
the Fund to experience relatively large purchases
or
redemptions. Significant purchases and
redemptions may adversely affect the Fund in
question and consequently, a client’s investment.
A Fund receiving large purchase orders may have
difficulty investing the cash, which may have a
negative impact on the Fund’s performance. A
Fund experiencing large redemption orders may
have to sell portfolio securities, which may
negatively impact performance and which may
have
Large
redemptions could also reduce liquidity as the
Fund may suspend or delay redemptions. These
risks are more pronounced with respect to newer
Funds and those with smaller asset sizes.
by
the
that were not predicted by
Risks Associated with Certain Investment
Strategies
Growth and Value Investment Style Risks.
Investment styles or strategies that focus on
growth stocks may perform better or worse than
styles or strategies that focus on value stocks or
Quantitative Strategy Risks. Some investment
managers may employ quantitative investment
methodologies or processes to make investment
the quantitative
decisions. The success of
investment methodologies and processes used by
investment managers depends on the analyses
and assessments that were used in developing
such methodologies and processes, as well as on
the accuracy and reliability of models and data
provided by third parties. Incorrect analyses and
assessments or inaccurate or incomplete models
and data would adversely affect performance.
manager’s
Additionally,
methodologies and processes are predictive in
nature, based on historical outcomes and trends.
Certain low-probability events or factors that are
assigned little weight may occur or prove to be
more likely or may have more relevance than
expected, for short or extended periods of time,
the portfolios
which may adversely affect
generated
investment manager’s
quantitative methodologies and processes. It is
also possible that prices of securities may move in
directions
the
investment manager’s quantitative methodologies
and processes or may fail to move as much as
predicted, for reasons that were not expected.
these
There
can be no assurance
that
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methodologies will enable a client to achieve the
client’s objective.
investment and
trading activities
or
consuming
commodities markets are impacted by a variety of
factors, including changes in overall market
movements, domestic and foreign political and
economic conditions, interest rates, inflation rates
and
in
commodities. Prices of commodities may also be
affected by factors such as drought, floods,
weather, livestock disease, embargoes, tariffs and
other regulatory developments. The prices of
commodities can also fluctuate widely due to
supply and demand disruptions
in major
producing
regions. Certain
commodities may be produced in a limited
number of countries and may be controlled by a
small number of producers or groups of
producers. As a result, political, economic and
supply related events in such countries could have
a disproportionate impact on the prices of such
commodities. No active trading market may exist
for certain commodities investments, which may
impair the value of the investments.
Technical Strategy Risks. Some investment
managers and DDK Consultants may employ
technical analysis or investment methodologies to
make investment decisions or recommendations.
The primary risk of using technical analysis is that
past price and volume patterns and trends in the
trading markets cannot predict future prices,
volume patterns or trends. There is no guarantee
that technical investment methods used are
designed properly, are updated with new data as
it becomes available, or can accurately predict
future market or investment performance. In
order for technical investment methods to work,
there must be sufficient data about the markets
available so that trends can be identified and
predictions can be made. A technical method may
fail to identify trends or be able to accurately
predict future prices if a market does not have
sufficient data or trends or if the market behaves
erratically.
the heading
Other Strategy Risks. The risks associated with
other types of investment strategies are described
“Methods of Analysis,
under
Investment Strategies and Risk of Loss—
Investment Strategies” above.
such as
commodities,
in
that
Currency Risks. Investments in currencies, and
investments in securities or other instruments
denominated in or indexed or linked to currencies,
are subject to certain risks. Those investments
are subject to all of the risks associated with
foreign investing generally. In addition, currency
markets generally are not as regulated as
securities markets. Also, changes in currency
impact the
exchange rates could adversely
investment. Devaluation of a currency by a
country will also have a significant negative
impact on
investment
the value of any
denominated
currency. Currency
investments may also be positively or negatively
affected by a country’s strategies intended to
make its currency stronger or weaker relative to
other currencies.
the
traditional
Non-Traditional Assets and Complex
Strategies Risks
Non-Traditional Assets Risks. Non-Traditional
Assets,
currencies,
securities indices, interest rates, credit spreads,
private companies, and Digital Assets, are subject
to risks that are different from, and in some
instances, greater than, other assets like stocks
and bonds. Some Non-Traditional Assets are less
transparent and more sensitive to domestic and
foreign political and economic conditions than
more
investments. Non-Traditional
Assets are also generally more difficult to value,
less liquid, and subject to greater volatility
compared to stocks and bonds.
Risks.
Investments
investments
Leverage and Margin Risks. Leveraging
strategies may amplify
impact of any
decrease in the value of underlying securities in
the client’s Account, thereby increasing a client’s
risk of loss. The use of leverage may also increase
an Account’s volatility. Strategies
involving
margin can cause a client to lose more money
than deposited in the client’s margin account. A
client should not engage in strategies involving
leverage or margin unless the client is prepared
to experience significant losses in the value of the
client’s Account.
Commodities
in
commodities markets or a particular sector of the
in
commodities markets, and
securities or other instruments denominated in or
indexed or linked to commodities, are subject to
certain risks. Those investments generally will
subject a client Account to greater volatility than
The
traditional
investments
in
securities.
Short Sales Risks. Short selling runs the risk of
loss if the price of the securities sold short does
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loss on the derivative instrument should be
substantially offset by gains on the hedged
investment, and vice versa. Although hedging can
be an effective way to reduce the investment risk,
it may not always perfectly offset one position
with another. As a result, there is no assurance
that hedging transactions will be effective.
not decline below the price at which they were
originally sold. This risk of loss is theoretically
unlimited, as there is no cap on the amount that
the price of a security may appreciate. In
addition, a
lender may request, or market
conditions may dictate, that securities sold short
be returned to the lender on short notice, which
may result having to buy the securities sold short
at an unfavorable price. A client should not
engage in short sales unless the client is prepared
to experience significant losses in the client’s
Account.
in
the marketplace and
contracts
other
Assets
involve
technological
trading,
settlement,
and
validators, miners,
or
instruments
limited number of
Derivative Instrument Risks. The values of
options, convertible securities, futures, swaps,
forward
derivative
and
instruments is derived from an underlying asset,
such as a security, commodity, currency, or
index. Derivative instruments often have risks
similar to the underlying asset, however, in
certain cases, those risks are greater than the
the underlying asset.
risks presented by
Derivative instruments may experience dramatic
price changes and imperfect correlations between
the price of the derivative and the underlying
asset, which may increase volatility. Derivatives
generally create leverage, and as a result, a small
movement in the underlying asset's value can
result in large change in the value of the
derivative instrument. Derivatives are also subject
to liquidity risk, interest rate risk, market risk,
credit risk, management risk and counterparty
risk. The use of these
is not
appropriate for some clients because they involve
special risks. A client should not invest in these
instruments unless the client is prepared to
experience volatility and significant losses in the
client’s Account.
Digital Assets Risks. Digital Assets are not
appropriate for some clients because they involve
substantial risk of loss including special risks not
present in traditional financial markets. Digital
Assets derive value primarily from the demand for
such assets
their
association with decentralized networks and other
technology. Digital Assets may lack an intrinsic
value and markets
for Digital Assets are
to extreme and sudden price
susceptible
movements and fragmented liquidity. Markets for
Digital Assets continue to evolve, but
lack
certainty regarding the status of regulation and
investor protections. The use and custody of
Digital
and
cybersecurity risks, including the potential for
system outages, protocol
flaws, operational
disruptions, hacking incidents, or failures of
third-party platforms and service providers that
support
storage
infrastructure. Many Digital Assets depend on
external
protocol
developers whose actions or inaction can impact
network stability or asset functionality and affect
value. Market structure risks—such as reliance on
a
trading venues or
counterparties—may impair the ability to transact
or liquidate positions during periods of market
stress. A client should not invest in these
instruments unless the client is prepared to
experience extreme volatility and significant
losses in the client’s Account.
funds have unique
the underlying security or
Options Risks. In purchasing a put or call
option, the purchaser faces the risk of loss of the
premium paid for the option if the market price
moves in a direction opposite to what the
purchaser had expected. In selling or writing an
option, the seller faces significantly more risk. A
seller of a call option faces the risk of significant
loss
if the prevailing market price of the
underlying security or index increases above the
strike price, and a seller of a put option faces the
risk of significant loss if the prevailing market
price of
index
decreased below the strike price.
Complex Investment Product Risks
Hedge Funds and Funds of Hedge Fund
Risks. Hedge funds typically engage in one or
more Complex Strategies, including the use of
Non-Traditional Assets, short sales, leverage and
other derivative instruments. Funds of hedge
funds typically invest substantially all of their
assets in other hedge funds. Hedge funds and
funds of hedge
tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Some
hedge funds and funds of hedge funds are subject
to limited regulation and offer limited disclosure
Hedging Risks. When a derivative instrument is
used as a hedge against an opposite position, any
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for those
fee
an
incentive
funds are subject to
to administrative service
limited
compared
short
sales,
other
expect
risks may
securities
include: market
selection
credit
capitalization
risk,
foreign
and transparency. Also, the costs of hedge funds
and funds of hedge funds are typically higher than
other types of funds. Investment advisers or
funds often receive a
managers
management
or
plus
performance-based fee. Because of the existence
of a performance-based fee, fund managers may
be motivated to make riskier investments that
have the potential for significant growth in value.
Hedge funds and funds of hedge funds are also
subject to a higher risk of incorrect valuations.
Many hedge funds hold investments for which
market quotations are not readily available, which
necessitates the use of “fair value” pricing. Fair
value pricing is an inherently subjective process
and may not accurately reflect the prices that can
actually be obtained upon sale of the assets for
which fair values are used. Investments in hedge
funds and funds of hedge funds also have reduced
liquidity compared to other investments and are
generally subject to a higher risk of volatility.
Investing in hedge funds and funds of hedge
funds involves other special risks, including, but
to, risks associated with Non-
not
Traditional Assets,
leverage,
derivative instruments, and Complex Strategies.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate
risk,
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk. Hedge
funds and funds of hedge funds are complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in hedge funds or funds
of hedge funds should have a high tolerance for
risk, including the willingness and ability to accept
significant price volatility, potential
lack of
liquidity and potential loss of their investment.
risk,
foreign
investments
and sizes of investments. Funds of private equity
funds typically invest substantially all of their
assets in other private equity funds. Private
equity funds and funds of private equity funds
have unique tax characteristics. A client should
consult with a tax advisor before investing in
those funds. Private equity funds and funds of
private equity
limited
limited disclosure and
regulation and offer
transparency. Also, the costs of private equity
funds and funds of private equity funds are
typically higher than other types of
funds.
Investment advisers or managers for those funds
often receive a management fee plus an incentive
fee or carried interest. Private equity funds and
funds of private equity fund are also generally
subject
fees and
portfolio company transaction fees. Because of
the existence of a carried interest, fund managers
may be motivated to make riskier investments
that have the potential for significant growth in
value. Investments in private equity funds and
funds of private equity funds also have reduced
investments.
liquidity
to
Investors
receive
to
should not
distributions from a fund for a number of years.
Private equity investing is very risky. Many
investments made in portfolio companies are not
profitable. In addition, investments made by
private equity funds and funds of private equity
funds may be concentrated in one or more
economic
industries or sectors, geographic
regions, stages of development or operation, or
sizes of companies. Investing in private equity
funds and funds of private equity funds involves
other special risks, including, but not limited to,
dependence upon key personnel and conflicts of
interest risks. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, and emerging market risk.
Private equity funds and funds of private equity
that have
funds are complex
significant, special risks. As a result, they may not
be suitable for some clients. Clients investing in
private equity funds and funds of private equity
funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
in
certain
that may
sectors,
Private Equity Funds and Funds of Private
Equity Funds Risks. Private equity funds are
pools of actively managed capital that invest
primarily in private companies with the intent of
creating value in the companies in which they
invest by improving operations, reducing costs,
selling non-core assets and maximizing cash flow.
Private equity funds usually have an investment
focus on
objective or strategy
companies
industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
Private Debt Funds (or Private Credit Funds)
and Funds of Private Debt Funds Risks.
Private debt funds (also known as private credit
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funds
involves special
risk,
foreign
fund
risks, currency
in certain sectors,
sizes. Investing in private debt funds and funds of
private debt
risks,
including, but not limited to, dependence upon
key personnel, conflicts of interest risks, market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
investment
risks and
leveraging risks. Private debt funds and funds of
private debt funds are complex investments that
have significant, special risks. As a result, they
may not be suitable for some clients. Clients
investing in private debt funds and funds of
private debt funds should have a high tolerance
for risk, including the willingness and ability to
accept lack of liquidity and potential loss of their
investment.
debt
funds
have
unique
warehouses,
receive a management
transaction
should not
expect
to
funds) are pools of actively managed capital that
invest primarily in loans or debt instruments
issued by companies in private transactions.
Sometimes, repayment of the loan is secured by
assets of the companies obtaining the loans.
However, the companies often have low or no
credit ratings. Thus, investments held by private
debt funds generally are subject the same risks as
below investment grade or “junk” bonds. Trading
markets for the investments held by those funds
are also limited and their investments may be
illiquid. Oftentimes, the interest rate paid by the
companies is determined by a reference interest
rate, such as the federal funds rate, which is
periodically reset. These types of investments are
sometimes referred to as floating rate corporate
debt, floating rate loans or floating rate bank
funds usually have an
loans. Private debt
investment objective or strategy that may focus
on companies
industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes, including focusing investments on
smaller capitalization, distressed or bankrupt
companies. Private debt funds commonly use
borrowings or leverage to make investments.
Funds of private debt funds typically invest
substantially all of their assets in other private
debt funds. Private debt funds and funds of
private
tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
debt funds and funds of private debt funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private debt funds and funds of private debt funds
are typically higher than other types of funds.
Investment advisers or managers for those funds
often
fee plus a
performance fee. Private debt funds and funds of
private debt fund are also generally subject to
operational expenses and
fees.
Because of the existence of a performance fee,
fund managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Investments in private debt
funds and funds of private debt funds also have
reduced liquidity compared to other investments.
Investors
receive
distributions from a fund for a number of years.
Private debt investing is very risky. Investments
made by private debt funds and funds of private
debt funds may be concentrated in one or more
industries or sectors, geographic
economic
regions, stages of development or operation, or
Real Estate Investment Trusts (“REITs”) and
Private REIT Risks. A REIT is a corporation,
trust or association that owns and typically
operates income-producing real estate or real
estate-related assets. The income-producing real
estate assets owned by a REIT may include office
buildings, shopping malls, multi-family housing,
student housing, hotels, resorts, hospitals and
health care facilities, self-storage facilities, data
telecommunications
centers,
facilities, and mortgages or loans. Many REITs are
registered with the SEC and their common stock
and preferred stock are publicly traded on a stock
exchange. These are known as publicly-traded
REITs. Others may be registered with the SEC but
are not publicly traded. These are known as
private REITs (also known as non-traded or non-
exchange traded REITs). There is no public
trading market for private REITs and the sole
method for disposing of the shares may be limited
to a periodic offer to redeem the shares by the
issuer, if the issuer offers a redemption program.
Private REITs are generally subject to limited
limited disclosure and
regulation and offer
transparency. The shareholders of a REIT are
responsible for paying taxes on the dividends that
they receive and on any capital gains associated
with their investment in the REIT. Dividends paid
by REITs generally are treated as ordinary income
and are not entitled to the reduced tax rates on
other types of corporate dividends. Prices of REIT
securities and trading volumes may be more
volatile that other investments. Many REITs focus
on a particular sector of the real estate market,
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in which
they are
for those
risk, growth
risk, credit
risk,
foreign
should not
expect
to
investing
such as apartments, student housing, hotels and
hospitality, health care, office buildings, shopping
malls, warehouses, self-storage facilities and the
like. Those REITs are subject to risks associated
with sectors
focused.
Additionally, many REITs may own properties that
are concentrated in a particular geographic region
or regions, which subject them to the risk of
deteriorating economic conditions in those areas.
Investing in REITs involves other special risks,
including, but not limited to, real estate portfolio
risk
(including development, environmental,
competition, occupancy and maintenance risk),
liquidity risk, leverage risk, distribution risk,
capital markets access
risk,
interest risk,
counterparty risk, conflicts of
dependence upon key personnel
risk, and
regulatory risk. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, interest
issuer and
rate
investment risk, and emerging market risk. REITs
involve significant, special risks and may not be
suitable for some clients. Clients investing in
REITs should have a high tolerance for risk,
including the willingness and ability to accept
significant price volatility and volatility of regular
distribution amounts, potential lack of liquidity
and potential loss of their investment.
fund
risks, currency
investments. Some may
in properties
industries,
involved
located
improved management
real estate funds. Private real estate funds and
funds of private real estate funds have unique tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
real estate funds and funds of private real estate
funds are subject to limited regulation and offer
limited disclosure and transparency. Also, the
costs of private real estate funds and funds of
private real estate funds are typically higher than
other types of funds. Investment advisers or
managers
funds often receive a
management fee plus a performance fee. Private
real estate funds and funds of private real estate
fund are also generally subject to operational
expenses and transaction fees. Because of the
existence of a performance fee, fund managers
may be motivated to make riskier investments
that have the potential for significant growth in
value. Investments in private real estate funds
and funds of private real estate funds also have
reduced liquidity compared to other investments.
receive
Investors
distributions from a fund for a number of years.
Private real estate
is very risky.
Investments made by private real estate funds
and funds of private real estate funds may be
concentrated in properties involved in one or
more economic industries or sectors, geographic
regions, stages of development or operation, or
sizes. Investing in private real estate funds and
funds of private real estate funds involves special
risks, including, but not limited to, dependence
upon key personnel, conflicts of interest risks,
market risk, management and securities selection
risk, investment objective and asset allocation
risk, interest rate risk, credit risk, capitalization
risk, investment style risk, foreign issuer and
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
risks and
investment
leveraging risks. Private real estate funds and
funds of private real estate funds are complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in private real estate
funds and funds of private real estate funds
should have a high tolerance for risk, including
the willingness and ability to accept lack of
liquidity and potential loss of their investment.
real estate
funds
typically
Private Real Estate Funds and Private Real
Estate Fund of Funds. Private real estate funds
are pools of actively managed capital that directly
invest primarily in investments in real estate and
investments. Private real
real estate-related
estate funds may invest in any number of types of
real estate, such as office, apartment, retail,
lodging, industrial and other real estate and real
focus
estate-related
in certain
investment
sectors or
certain
in
geographic regions or that have certain sizes of
operations or investment requirements. Some
may focus investment on properties the manager
or
sponsor believes are undervalued or
undercapitalized or that require repositioning,
redevelopment,
or
additional capital to reach their full value. Private
real estate funds commonly use borrowings or
leverage to make investments. Trading markets
for investments held by those funds are limited
and their investments may be illiquid. Funds of
invest
private
substantially all of their assets in other private
Private Infrastructure Funds Risks. Private
infrastructure funds are pools of actively managed
capital that invest primarily in infrastructure
projects and assets and may involve exposure to
range of economic or market sectors,
a
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telecommunication,
Private
utilities,
infrastructure
throughout
for those
fees and
for
significant growth
reduced
liquidity compared
investments made
by
industries or
risks may
securities
include: market
selection
credit
capitalization
risk,
foreign
risk,
foreign
infrastructure
funds
are
of an underlying benchmark. The underlying
benchmark can be a particular security, bond,
commodity, currency, or other Non-Traditional
Asset type, a group or basket of companies,
securities, commodities, currencies, derivative
instruments, Non-Traditional Asset investments or
other assets, or an index or other benchmark
linked to stocks, market volatility, bonds, interest
rates, Treasury yields, yield curves and spreads,
derivative instruments, strategies, commodities,
currencies or other assets. ETNs trade on
exchanges
the day at prices
determined by the market. Unlike ETFs, issuers of
ETNs do not buy or hold assets to replicate or
approximate the performance of the underlying
benchmark. Also in contrast to ETFs, ETNs also do
not calculate their net asset value, are generally
not redeemable on a daily basis, and are not
registered under the Investment Company Act of
1940. Issuers may also have the right and option
to redeem ETNs. Redemptions are made at the
ETN’s “indicative value” or “closing indicative
value”. An ETN's closing indicative value is
computed by the issuer and is distinct from an
ETN's market price, which is the price at which an
ETN trades in the secondary market. Issuers of
ETNs may also issue and redeem notes as a
means to keep the ETN’s market price in line with
its indicative value, which have caused significant
fluctuations in ETN prices. Investing in ETNs
involves special risks, including, but not limited
to, risks associated with Non-Traditional Assets
and derivative instruments and the risk that the
actual market price for an ETN may vary
significantly from the indicative value computed
by the issuer. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
rate
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk. ETNs
are complex investments and involve significant,
special risks. As a result, ETNs may not be
suitable for some clients.
pools
(typically
structured
geographic locations and asset types. Examples of
infrastructure investments may include, among
and
others,
funds
transportation.
usually have an investment objective or strategy
that may focus on certain sectors, industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes of investments. Private infrastructure
funds have unique tax characteristics. A client
should consult with a tax advisor before investing
in those funds. Private infrastructure funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private infrastructure funds are typically higher
than other types of funds. Investment advisers or
managers
funds often receive a
management fee plus an incentive fee. Private
infrastructure funds are also generally subject to
administrative service
investment
transaction fees. Because of the existence of
incentive fees, fund managers may be motivated
investments that have the
to make riskier
potential
in value.
Investments in private infrastructure funds also
have
to other
investments. Investors should not expect to
receive distributions from a fund for a number of
years. Private infrastructure investing is very
risky. Many investments are not profitable. In
private
addition,
infrastructure funds may be concentrated in one
or more economic
sectors,
geographic regions, stages of development or
operation, or sizes of companies. Investing in
private infrastructure funds involves other special
risks, including, but not limited to, dependence
upon key personnel and conflicts of interest risks.
risk,
Other
risk,
management and
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, and emerging market risk.
complex
Private
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in private infrastructure
funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
Exchange Traded Notes Risks. An ETN is a
type of debt security that trades on an exchange
and provides a return linked to the performance
Managed Futures Risks. Managed futures are
commodity
as
investment partnerships) managed by a futures
trading adviser that trade speculatively in various
derivative instruments and other investments.
There are significantly higher fees and expenses
associated with investments in managed futures
than other types of funds. Sponsors or managers
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in managed
currencies,
funds and they
Assets,
leverage,
benchmark during the same period of time. To
achieve their objectives, leveraged and inverse
funds typically employ aggressive investment
techniques, such as the use of leverage, short
sales, swap contracts, futures, options and other
derivative instruments. Investing in leveraged
funds and inverse funds involves special risks,
including, but not limited to, risks associated with
Non-Traditional Assets, short sales, leverage, and
derivative instruments. Other risks may include:
market risk, management and securities selection
risk, investment objective and asset allocation
risk, stock market risk, equity securities risk,
common stock risk, fixed income securities risk,
interest rate risk, credit risk, foreign issuer and
investment risk, and emerging market risk.
Leveraged funds and inverse funds are complex
investments that have an increased risk of loss
compared to other
involve
significant, special risks. As a result, they may not
be suitable for some clients. A client should not
invest in these securities unless the client is
prepared to experience significant losses in the
value of the client’s Account.
Investing
for these pools often receive a management fee
plus incentive or performance-based fee. Because
of the existence of a performance-based fee,
managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Managed futures may seek
exposure to different asset classes, such as equity
securities, fixed income securities, commodities
(such as metals, agricultural products, and energy
products), currencies, interest rates, and indices.
Managed futures often obtain this exposure
through derivative instruments, which may be
traded on U.S. or foreign exchanges or markets.
Managed futures often employ computerized,
systematic and often proprietary trading models
and systems. Investing
futures
involves special risks, including, but not limited
to, liquidity risks and risks associated with
and other Non-
commodities,
Traditional
derivative
instruments and Complex Strategies. Other risks
may include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
foreign issuer and investment risk, and emerging
market risk. Managed futures can be speculative
investments because of the types of investments
they make and they involve significant, special
risks. As a result, they may not be suitable for
some clients. Clients investing in these funds
should have a high tolerance for risk, including
the willingness and ability to accept significant
price volatility, potential lack of liquidity and
potential loss of their investment.
risks may
securities
include: market
selection
risk, credit
risk,
risk,
foreign
emerging market
inverse
Structured Products Risks. Structured products
are a hybrid between two asset classes (typically
issued in the form of a CD or note) but instead of
having a pre-determined rate of interest, the
return is linked to the performance of an
underlying asset class, such as single security or
basket or index of securities; a commodity or
basket or index of commodities, including futures;
and a foreign currency or basket of foreign
currencies.
in structured products
involves special risks, including, but not limited
to, risks associated with derivative instruments.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
issuer and
rate
investment
risk,
commodities risk and currency risk. Structured
products are complex investments and involve
special risks. As a result, they may not be suitable
for some clients.
is
Leveraged Fund and Inverse Fund Risks.
Leveraged funds and inverse funds may be
structured as ETNs, ETFs or open-end mutual
funds. Leveraged funds seek to deliver multiples
of the performance of the index or benchmark
they track. Inverse funds seek to deliver the
opposite of the performance of the index or
benchmark they track. Leveraged inverse funds
seek to achieve a return that is a multiple of the
inverse performance of the underlying index. Most
leveraged and
funds “reset” daily,
meaning that they are designed to achieve their
stated objectives on a daily basis. Because of the
effects of compounding, volatility and the fund
expenses, the returns of a leveraged or inverse
fund over longer periods of time can differ
significantly from the performance (or inverse of
the performance) of their underlying index or
Business Development Company Risks. A
BDC
closed-end
typically a domestic,
investment company that is operated for the
purpose of making equity and debt investments in
small and developing businesses, as well as
financially troubled businesses. As a result,
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those
including, but not
risk, capital markets access
dioxide and biofuels. An MLP
is generally
structured as a limited partnership or limited
liability company and managed and operated by a
general partner or manager. Owners of an MLP
are called “limited partners” or “unit holders”.
Unit holders own interests or units in the MLP
(“units”) that are traded on a stock exchange.
MLPs make distributions to unit holders of their
available cash flows. Many MLPs focus on a
particular sector or industry. Those MLPs are
subject to risks associated with sectors or
industries in which they are focused. The value of
an investment in an MLP and the amount of
distributions it makes may depend on the prices
of the underlying commodity, such as oil or
natural gas. Many MLPs are sensitive to changes
in the prevailing level of commodity prices. MLPs
have also shown sensitivity to interest rate
movements. Investing in MLPs involves other
special risks,
limited to,
macroeconomic risk, interest rate risk, liquidity
risk, operating risk, capital markets access risk,
growth risk, distribution risk, conflicts of interest
risk, and regulatory risk. MLPs are complex
investments that have significant, special risks. As
a result, MLPs may not be suitable for some
clients. Clients investing in MLPs should have a
high tolerance for risk, including the willingness
and ability to accept potential lack of liquidity and
potential loss of their investment.
information
about
Additional
certain
Complex Investment Products and other
investments pursuing Complex Strategies,
including the risks associated with those
investments, is available on Baird’s website
at bairdwealth.com/retailinvestor and on
FINRA’s website
at www.finra.org/
Investors. A client is encouraged to read the
included on those
disclosure documents
websites carefully before investing.
investments made by BDCs tend to be risky and
speculative. Investment advisers or managers for
BDCs often receive a management fee plus
incentive or performance-based fee. Because of
the existence of a performance-based
fee,
managers may be motivated to make riskier
investments that have the potential for significant
growth in value. BDCs commonly use borrowings
or leverage to make investments in portfolio
companies. Adverse interest rate movements can
negatively
impact a BDC’s ability to make
investments. Investments made by BDCs are
typically illiquid, and valuing such investments is
challenging. It is possible that valuations on
investments used are materially different from the
values that BDCs will ultimately receive upon
disposition of
investments. Changing
market and economic conditions affecting a BDC’s
investments may cause significant volatility in the
BDC’s net asset value and stock price. Due to the
nature of BDCs’ investments, securities issued by
BDCs are subject to greater liquidity risk than
other investments. A debt security or preferred
stock issued by a BDC, in many cases, is non-
rated or is rated below investment grade, which
can carry its own risks. Investing in BDCs involves
other special risks, including, but not limited to,
portfolio company credit and investment risk,
risk,
leverage
dependence upon key personnel
risk, and
regulatory risk. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, and
interest rate risk. BDCs can be speculative
investments because of the types of investments
they make and involve significant, special risks.
As a result, BDC investments may not be suitable
for some clients. Clients investing in BDCs should
have a high tolerance for risk, including the
willingness and ability to accept significant price
volatility, potential lack of liquidity and potential
loss of their investment.
Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies
Each Account is subject to the risks associated
with the investments in the Account. Generally,
an Account will be subject to the risks associated
with the portfolio listed below that corresponds to
the investment objective of the Account or the
asset allocation strategy pursued by the Account.
All Growth Portfolio. An All Growth Portfolio will
generally be invested in a manner that seeks to
provide growth of capital. All Growth Portfolios
Master Limited Partnership Risks. An MLP is a
form of publicly-traded partnership that is taxed
as a partnership. MLPs have unique
tax
characteristics. A client should consult with a tax
advisor before investing in MLPs. An MLP must
generally earn at least 90% of its income from
certain qualifying sources, which includes income
and gains from certain activities involving natural
resources such as oil, natural gas, natural gas
liquids, refined petroleum products, coal, carbon
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risk,
common
stock
to other primary
risks,
risks,
foreign
to other primary
risks,
risks,
foreign
have historically experienced high fluctuations in
annual returns and overall market value, typically
as a result of changes to market and economic
conditions. The Portfolio’s investments are subject
to a high risk of price declines, especially during
periods when stock markets in general are
declining. An All Growth Portfolio’s primary risks
generally include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities
risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
subject
including
investment style
issuer and
investment risks, emerging market risks, fixed
income security risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
overall market value, typically as a result of
changes to market and economic conditions and
interest rates. The Portfolio’s investments are
subject to a risk of price declines, especially
during periods when stock markets in general are
declining or when interest rates are rising. A
Growth with Income Portfolio’s primary risks
generally include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
upon
Portfolio’s
foreign
issuer and
investment
risks,
foreign
the headings
Capital Growth Portfolio. A Capital Growth
Portfolio will generally be invested in a manner
that seeks to provide growth of capital. Capital
Growth Portfolios have historically experienced
moderately high fluctuations in annual returns
and overall market value, typically as a result of
changes to market and economic conditions. The
Portfolio’s investments are subject to a risk of
price declines, especially during periods when
stock markets in general are declining. A Capital
Growth Portfolio’s primary risks generally include:
market risk, management and securities selection
risk, investment objective and asset allocation
risk, stock market risk, equity securities risk,
common stock risk, and capitalization risks.
Depending
specific
the
investments, the Portfolio may also be subject to
other primary risks, including investment style
risks,
risks,
emerging market risks, fixed income securities
risk, interest rate risk, credit risk, asset-backed
securities risks, below investment grade (high
yield or “junk” bonds) securities risks, and the
risks described under
“Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
Income with Growth Portfolio. An Income with
Growth Portfolio will generally be invested in a
manner that seeks to provide current income and
some growth of capital. Income with Growth
Portfolios have historically experienced moderate
fluctuations in annual returns and overall market
value, typically as a result of changes to interest
rates and market and economic conditions. The
Portfolio’s investments are subject to a risk of
price declines, especially during periods when
interest rates are rising or when stock markets in
general are declining. An Income with Growth
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
fixed income securities risk, interest rate risk,
credit risk, money market fund risk, stock market
risk, equity securities risk, common stock risk,
and capitalization risks. Depending upon the
Portfolio’s specific investments, the Portfolio may
also be subject to other primary risks, including
issuer and
investment style
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
Growth with Income Portfolio. A Growth with
Income Portfolio will generally be invested in a
manner that seeks to provide moderate growth of
capital and some current income. Growth with
Income Portfolios have historically experienced
moderate fluctuations in annual returns and
Conservative Income Portfolio. A Conservative
Income Portfolio will generally be invested in a
manner that seeks to provide current income.
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to
perception
of market
economic
The
the
Portfolios
have
the
investments made,
to other primary
risks,
risks,
foreign
Relative
the portfolios described above,
Conservative Income Portfolios have historically
experienced smaller fluctuations in annual returns
and overall market value as a result of changes in
stock market conditions, but have experienced
fluctuations in relation to changes in interest rates
and
Portfolio’s
conditions.
investments are subject to risk of price declines,
especially during periods when interest rates are
rising. A Conservative Income Portfolio’s primary
risks generally include: market risk, management
and securities selection risk, investment objective
and asset allocation risk, fixed income securities
risk, interest rate risk, credit risk, money market
fund risk, equity securities risk, and common
stock risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
income. Relative
to
fixed
income
security
manager’s
pricing
anomalies, those market or industry sectors
deemed favorable for investment by the manager,
the current interest rate environment and/or
other macro-economic trends identified by the
manager to achieve growth while accounting for a
client’s specific short, intermediate and long term
investment and/or cash flow needs. Depending
investment strategy used, some
upon
Opportunistic
historically
experienced high fluctuations in annual returns
and overall market value, typically as a result of
changes to market and economic conditions.
Depending upon the investment strategy used
and
the Portfolio’s
investments may be subject to a high risk of price
declines, especially during periods when stock
markets in general are declining. An Opportunistic
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, and capitalization risks. Depending
upon the Portfolio’s specific investments, the
Portfolio may also be subject to other primary
risks, including investment style risks, foreign
issuer and investment risks, emerging market
risks,
risks, below
investment grade (high yield or “junk” bonds)
securities risks, and the risks described under the
headings “Non-Traditional Assets and Complex
Strategies Risks” and “Complex
Investment
Product Risks” above.
interest
rates are
fixed
Capital Preservation Portfolio. A Capital
Preservation Portfolio will generally be invested in
a manner that seeks to preserve capital while
the
generating current
portfolios described above, Capital Preservation
Portfolios have historically experienced smaller
fluctuations in annual returns and overall market
value as a result of changes in stock market
conditions, but have experienced fluctuations in
relation to changes in interest rates and economic
conditions. The Portfolio’s investments are subject
to risk of price declines, especially during periods
rising. A Capital
when
Preservation Portfolio’s primary risks generally
include: market risk, management and securities
selection risk, investment objective and asset
income securities risk,
allocation risk,
interest rate risk, credit risk, and money market
fund risk. Depending upon the Portfolio’s specific
investments, the Portfolio may also be subject to
other primary risks, including foreign issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
Additional Considerations. A client should note
that an Account pursuing a particular investment
objective or asset allocation strategy will from
time to time be subject to actual risks that are
higher or lower than, or different from, the risks
described above under certain circumstances. See
“Investment Strategies—Important Information
about Implementation of Investment Objectives
and Investment Strategies” above for more
information. In addition to the specific risks
described above, a client’s Account may be
subject to additional risks, depending upon the
particular investments in the client’s Account. A
client should discuss the risks of particular
investments with the client’s DDK Consultant. A
client should also note that there is no guarantee
as to how an Account will perform in the future. It
is possible that an Account could experience more
dramatic return or market value fluctuations than
occurred in the past.
Opportunistic Portfolio. An Opportunistic
Portfolio will generally be invested in a manner
that seeks to provide long term growth through
capital appreciation and/or income by utilizing an
active management style that shifts the amount
of investment made in different asset classes and
the
market sectors
to
take advantage of
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that Baird
establishes
for
markets to assess, which may cause meaningful
inflation reduction
market uncertainty. While
remains a central
for policymakers,
focus
achieving the U.S. Federal Reserve Board’s long
term inflation target of 2% continues to prove
challenging. Although annual price increases have
generally moderated, the price of many goods
and services remains elevated compared to levels
from a few years ago. Leadership changes at the
Federal Reserve and political divisions and discord
add further uncertainty to the economic outlook.
less
if an Available
Product
experiences
organizational,
is a higher risk
that
Internationally, geopolitical risks have increased
as the U.S. and Israel are engaged in a military
conflict with Iran. The conflict has disrupted
global trade and caused an increase in the price
of oil. The continuation or escalation of military
strikes could lead to a lengthy period of military
conflict, and Iran’s military attacks and other
hostile actions against other countries present a
risk of widening the conflict. In addition, the war
between Ukraine and Russia is now passing its
fourth anniversary, instability in parts of the
Middle East persist, and relations between the
U.S. and other countries are strained.
Product
that
experiences
the
list of
Available Investment Product Risks
The use of Available Investment Products,
including SMA Strategies made available under
the BSN and DC Programs, are subject to
additional risks compared to the use of Baird
recommended
investment products. Available
Investment Products are investment products that
generally do not meet the qualifications and
standards
its
recommended product lists. As a result, there is a
higher likelihood that some Available Investment
Products will have poor performance and will
to an
significantly underperform compared
applicable benchmark
index or peer group.
Available Investment Products are also subject to
significantly
review by Baird
rigorous
compared to recommended investment products.
Thus,
Investment Product
experiences significant performance problems or
if the manager or sponsor of an Available
Investment
significant
operational,
management,
compliance, legal, regulatory or other problems,
there
the Available
Investment Product will be made available (and
will continue to be made available) to clients by
Baird. An investment by a client in an Available
Investment
the
occurrence of any such event could negatively
impact the client’s Account. Available Investment
Products should only be used by a client if the
client wishes to take more responsibility for
monitoring and managing the assets in the
client’s Account,
recommended
products does not contain an investment product
that meets the client’s particular needs, and the
client understands the risks of doing so.
Rapid advancements in artificial intelligence (AI)
and automation are increasingly influencing global
economic trends, corporate decision making, and
financial market dynamics. Expanding investment
in these technologies is contributing to shifts in
how industries operate, compete, and allocate
resources. The fast pace of technological change,
potential disruptions to existing business models,
and evolving regulatory responses
introduce
additional uncertainty and may contribute to
market volatility.
Taken together, these developments may have a
significant negative impact upon global economic
conditions and contribute to a heightened risk
environment. As a result, fluctuations in asset
prices may increase, and such volatility could
adversely affect the value of a client’s Account .
priorities,
changes
in
Recent Events
financial markets have continued to
Global
experience periods of elevated volatility, driven by
a combination of economic, political, and broader
macroeconomic developments. Conditions across
major economies have been influenced by shifting
geopolitical
policy
relationships, and evolving investor expectations.
Within the United States, the current U.S.
intent on
administration has demonstrated
implementing policy changes through executive
orders and legislation, contributing to a less
certain policy environment. Potential adjustments
to federal programs, regulatory initiatives, and
legislative priorities create additional factors for
Disciplinary Information
In April 2016, Baird, without admitting or denying
the findings, consented to the sanctions and
findings of the Financial Industry Regulatory
Authority, Inc. (“FINRA”) that it violated NASD
Conduct Rule 3010, FINRA Rule 3110, and FINRA
Rule 2010, by failing to establish and maintain a
supervisory system and procedures reasonably
designed to ensure that customers who purchased
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to adopt or
to
provide
designed
to Baird’s clients and
mutual fund shares received the benefit of
applicable sales charge waivers. In May 2015,
Baird began a review to determine whether Baird
had provided available sales charge waivers to
eligible customers. Based on this review, in May
2015, Baird self-reported to FINRA that various
eligible customers had not received available
sales charge waivers. Baird was found to have
retirement plan and
disadvantaged certain
charitable organization customers
that were
eligible to purchase Class A shares in certain
mutual funds without a front-end sales charge.
The findings also stated that these customers
were instead sold Class A shares with a front-end
sales charge or Class B or C shares with higher
ongoing fees and the potential application of a
contingent deferred sales charge. Baird was
censured and required to pay restitution to
affected customers estimated to be approximately
$2.1 million including interest.
supervisor within
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
implement policies and
failed
specific
procedures
information
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. Baird also was ordered to cease
and desist committing or causing any violations
and any future violations of Section 206(4) of the
Advisers Act and Rule 206(4)-7 thereunder and
pay a civil money penalty in the amount of
$250,000.
Initiative.” Under
In July 2016, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that the firm and a
its Private Wealth
firm
Management business did not
reasonably
supervise a former Financial Advisor who misused
a customer’s funds. The findings stated that the
supervisor did not reasonably follow-up on red
flags associated with a trade correction request
submitted by the Financial Advisor that should
have alerted him to the Financial Advisor's misuse
of a customer’s funds. The supervisor also did not
follow certain of Baird’s written supervisory
procedures (“WSPs”) relating to trade corrections.
After the supervisor realized that the Financial
Advisor misused the customer’s funds, Baird
reimbursed the customer for the loss. The
findings also included that Baird 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.
Baird was censured and fined $200,000.
firms bought
certain of
the
In March 2019, Baird, without admitting or
denying the findings, consented to an order of the
SEC, which found that it violated Sections 206(2)
and 207 of
for making
the Advisers Act
inadequate disclosures to advisory clients about
mutual fund share classes. The order was part of
a voluntary self-reporting program initiated by the
SEC called the “Share Class Selection Disclosure
(or SCSD)
the program,
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 settlement terms imposed by the
SEC,
including returning money to affected
investment advisory clients. The central issue
identified by the SEC was that, in many cases,
investment advisory
for or
recommended to their investment advisory 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
advisory clients, and the investment advisory
firms did not adequately disclose their receipt of
interest
12b-1
fees and/or
the conflict of
In September 2016, the SEC announced that
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
subadvisors
participating in Baird’s wrap fee programs offered
Private Wealth Management
through
its
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
efforts to ensure that it charges fair prices and
commissions on all securities transactions with its
customers. The brokerage customers identified by
FINRA did not include any DDK client and no DDK
client was alleged to have been charged an unfair
commission.
its
associated with those 12b-1 paying share classes.
Baird and many other firms self-reported under
the program and entered
into substantially
identical orders. By self-reporting and consenting
to the order, Baird agreed to a censure and to
cease and desist from committing or causing any
violations and future violations of Sections 206(2)
and 207 of the Advisers Act. Baird also agreed to
establish a distribution fund and to deposit into
that fund the improperly disclosed 12b-1 fees
received by Baird plus prejudgment interest,
which will be paid to affected advisory clients.
More information about the order is contained in
Baird’s Form ADV, which is available on the SEC’s
Investment Advisory Public Disclosure website at
https://www.adviserinfo.sec.gov/IAPD/Default.as
px or in the SEC’s press release about the SCSD
Initiative at https://www.sec.gov/news/press-
release/2019-28.
other
reports about an
reports was engaged
to disclose
In June 2019, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that between late
April 2013 and early July 2013 it published
research
issuer without
disclosing that the research analyst who authored
in employment
the
discussions with the issuer that constituted an
actual, material conflict of interest and that the
failure
research analyst’s
the
employment discussions with the issuer in the
research reports made those reports misleading.
Baird was censured and fined $150,000.
the
brokerage
customers
an
it charged
supervisory
system
communications. As part of
training,
In September 2023, Baird entered into an Offer of
Settlement with the SEC, 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
business-related
associates’
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
text and
properly retaining business-related
instant messages
off-channel
and
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.
While Baird had policies and procedures in place
prohibiting such off-channel communications, 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
findings were
adviser businesses, and
reported to the SEC. Baird took steps prior to and
after the SEC’s review, including implementing a
new communication tool designed
for Baird
associates’ personal devices, conducting training,
and periodically requiring requisite associates to
provide an attestation relating to their business-
related
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,
surveillance program,
technology solutions and similar matters related
to off-channel communications.
In August 2022, Baird, without admitting or
denying the findings, consented to the entry of
findings of FINRA, which found that it charged
certain
unfair
commission when
its published
minimum commission amount of $100 on 7,277
retail equity trades and failed to establish and
maintain a
reasonably
designed to prevent charging a customer a
commission that is unreasonable or unfair in
violation of FINRA Rules 3110, 2121, and 2010.
Baird also consented to a censure, a fine in the
amount of $150,000, and the payment of
restitution of $266,481 plus interest. The findings
related to FINRA’s routine examination of Baird in
2020. During that examination, Baird modified its
minimum commission schedule and supervisory
procedures. Baird also took steps to make
payments to the affected customers, which on
average amounted to $36.62 per trade and
$57.64 per customer. Baird will continue to make
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timing
of
state
investment
Financial
Advisors
located
to Baird and DDK Consultants to use, select or
recommend the investment products and services
of Baird and Associated Parties over those of
unassociated parties and those that pay the
greatest level of compensation. Baird addresses
this potential conflict through disclosure in this
Brochure. Further, when acting as fiduciaries,
Baird and DDK Consultants are required to select
or recommend investment products only when
they determine it to be in the client’s best interest
to do so.
Baird Asset Management
In March 2026, Baird entered into an Offer of
Settlement with the Massachusetts Securities
Division to settle a regulatory matter relating to
adviser
the
representative registration approvals for two of
Baird’s
in
Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals
provided investment advisory services before
their Massachusetts registrations were completed
as a form was missing from their application
materials. 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.
Additional information about Baird’s disciplinary
history is available on the SEC’s website at
www.adviserinfo.sec.gov.
Baird’s Asset Management business, Baird
Advisors, Baird Equity Asset Management, and
Chautauqua Capital Management (“CCM”), part of
provide
Baird Equity Asset Management,
investment management services to institutional
clients and Funds. DDK Consultants who refer
clients to Baird Asset Management are eligible for
referral compensation to be paid by Baird. DDK
Consultants, therefore, have a financial incentive
to favor the services provided by Baird Asset
Management over
those provided by other
managers.
Baird Funds
including
Other Financial Industry Activities and
Affiliations
Baird’s Broker-Dealer Activities
Baird PWM offers brokerage accounts and related
services to its clients. Baird is also engaged in a
broad range of broker-dealer activities through
its Global
other business units,
Investment Banking, Fixed
Income Capital
Markets (including Baird Public Finance) and
Institutional Equities and Research Departments.
Certain DDK and Baird associates and certain
management persons of Baird are registered, or
have an application pending to register, as
registered representatives and associated persons
of Baird to the extent necessary or appropriate to
perform their job responsibilities.
of
referral
including
Baird is the investment adviser and principal
underwriter for Baird Funds, Inc. (the “Baird
Funds”). Baird Advisors provides
investment
management, administrative, and other services
to certain Baird Funds investing primarily in fixed
income securities (the “Baird Bond Funds”). Baird
Equity Asset Management and CCM provide
investment management and other services to
certain Baird Funds investing primarily in equity
securities (the “Baird Equity Funds”), and
Greenhouse Funds LLLP, a party related to Baird,
is the investment subadvisor to one of those
Funds, the Baird Equity Opportunity Fund. In
certain instances, DDK Consultants who refer
clients to the Baird Funds are eligible for referral
compensation to be paid by Baird. Due to the
compensation, DDK
amount
Consultants have a financial incentive to favor the
Baird Equity Funds over the Baird Bond Funds.
for eligible
Baird Trust
the
those
amount
the
Certain Relationships and Arrangements
Baird and Associated Parties
Baird PWM has relationships or arrangements with
other Baird businesses units and the Associated
Parties described below,
referral
programs that pay special compensation to DDK
referrals. Additional
Consultants
referral programs,
information about
including
referral
of
compensation, is disclosed on Baird’s website at
bairdwealth.com/retailinvestor.
These
relationships or arrangements present a conflict of
interest because they provide a financial incentive
Baird is affiliated, and may be deemed to be
under common control, with Baird Trust, a
Kentucky-chartered trust company, because both
entities are indirectly wholly owned by BFG. Baird
and DDK Consultants receive compensation from
Baird Trust for referring clients and providing
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engaging
Trust
for
Services
ongoing relationship management services to
clients
trust
Baird
administration services as described under the
heading “Advisory Business—Additional Service
Information—Trust
Arrangements”
above.
Baird Capital
issued in those offerings. A DDK Consultant who
refers a corporation
to Baird’s Institutional
Equities business for a stock buy-back program
receives a portion of the commissions earned by
Baird’s Institutional Equities business. Baird and
its DDK Consultants may, therefore, have an
incentive to buy, and to recommend that clients
sell, the securities of issuers that are part of
Baird’s buyback services.
Sagard
Baird is engaged in a global private equity
business through Baird Capital (“Baird Capital”).
Baird and DDK Consultants may refer clients to
Baird Capital. DDK Consultants who assist in
obtaining a client’s investment in a private equity
fund offered through Baird Capital are eligible for
referral compensation.
Baird has a financial incentive to the extent it
would recommend that a client invest in a
portfolio company owned by a Baird Capital
private equity fund. A list of the portfolio
companies held by Baird Capital private equity
funds is located on Baird Capital’s website located
at https://www.bairdcapital.com/portfolio/baird-
capital-portfolio.aspx.
additional
compensation
Baird Global Investment Banking
Baird Institutional Equities and Research
Baird Public Finance
Sagard-affiliated
its Global
information
Baird’s direct parent corporation, BFC, has a
minority ownership interest (about 5%) in Sagard
Holdings Management, Inc. (“Sagard”) and the
right to appoint a member to Sagard’s board of
directors, which
is currently a management
person of Baird. Baird has agreed to use best
efforts, to the extent consistent with its fiduciary
duties, best
interest obligations, and other
regulatory responsibilities, to offer to clients
investment products managed by affiliates of
Sagard. Baird has an incentive to do so because
not reaching minimum thresholds would give
Sagard a right to redeem BFC’s ownership
interest
in Sagard and reaching significant
thresholds would give BFC the right to increase its
ownership interest. DDK Consultants do not
receive
for
any
investment
recommending
products. Additional
identifying
investment products will be
Sagard-affiliated
provided to clients prior to investment.
municipal
advisory,
55ip
55I, LLC (d/b/a 55ip, “55ip”) uses research and
other services from Riverfront, an affiliate of
Baird, in the development of its portfolios under
the BSN Program, and Riverfront
receives
compensation from 55ip with respect to those
portfolios. Due to its affiliation with Riverfront,
Baird has a financial incentive to favor 55ip
portfolios that use Riverfront services.
Through
Investment Banking,
Institutional Equities and Research, and Public
Finance Businesses, Baird provides investment
banking,
securities
underwriting, stock buyback and related services
to various corporate, municipal, and other issuers
of securities. Baird receives compensation from
such issuers in connection with the services it
provides, and the success of its services generally
depends upon Baird’s ability to sell the securities
of such issuers. Baird may, therefore, have an
incentive to favor the securities of issuers for
which Baird provides such services over the
securities of issuers for which Baird does not
provide such services.
Associated Investment Products and
Services
Baird and DDK Consultants may select or
recommend Associated Investment Products and
Services, including the Associated Funds and
Associated SMA Strategies, listed in Appendix A to
this Brochure.
A DDK Consultant who refers a client to Baird
Investment Banking for a possible transaction in
which Baird Investment Banking earns a financial
advisory or underwriting fee receives a portion of
such fee. A DDK Consultant who refers a client to
Baird Public Finance for a municipal advisory or
underwriting opportunity receives a portion of the
compensation earned by Baird Public Finance on
that opportunity. Baird and DDK Consultants thus
have an incentive to recommend the securities
Certain Associated Parties are associated with
Baird because BFC, Baird’s parent corporation,
owns some or all of the Associated Parties’ voting
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when they determine it to be in the client’s best
interest to do so. The criteria used by them in
deciding to select or recommend Associated
Investment Products are generally the same as
those used for unassociated investment products.
However, a client should note that certain
Services and certain categories of investment
products only offer investment products and
services of Associated Parties. In those cases,
Baird and DDK Consultants do not impose the
same criteria or level of review.
managers,
including
securities. BFC’s parent corporation (and Baird’s
ultimate parent corporation), BFG, may be
deemed to indirectly own or control such voting
securities. Baird is deemed to be under common
control and “affiliated” with an Associated Party
when BFG indirectly owns or controls 25% or
more of such Associated Party’s voting securities
(or of an entity deemed
to control such
Associated Party). Baird considers itself “related”
to an Associated Party when BFG indirectly owns
or controls at least 10% but less than 25% of
such Associated Party’s voting securities (or of an
entity deemed to control such Associated Party).
Baird considers
itself “associated” with an
Associated Party when certain other relationships
or other arrangements exist between Baird and
such Associated Party that might present a
conflict of interest with clients.
An Associated Party receives fees or other
compensation for investment advisory or other
services that it provides to an Associated Fund.
The amount of fees and other compensation paid
by an Associated Fund to an Associated Party is
disclosed in the Associated Fund’s prospectus or
other offering document. An Associated Party also
receives fees from a client for services that it
provides related to the client’s Associated SMA
Strategy. Information about the amount of fees
paid to an Associated Party with respect to an
SMA Strategy is contained in the applicable Baird
Form ADV Part 2A Brochure, the applicable
Program Account Schedule, or in some instances,
the client’s contract with the Associated Party.
Relationships and Arrangements with
Investment Managers
Investment
those
participating in the Services, may select Baird, in
its capacity as a broker-dealer, to execute
portfolio trades for their clients, including for
Funds they advise and in which Baird clients
invest. Investment managers may also select
Baird to provide custody, research or other
services. Baird receives compensation for those
services. This may create an incentive for Baird to
favor the investment products and services of
such investment managers. However, Baird is a
fiduciary that is required to act in the best
interest of advisory clients when selecting or
recommending investment managers or their
investment products and services to such clients.
Baird addresses this potential conflict through
disclosure in this Brochure. Baird does not
consider the extent to which an investment
manager directs or is expected to direct trading,
custody or research services to Baird when
considering
investment
the eligibility of an
manager or its investment products or services
for the Services.
incentive
to
favor
the
through disclosure
in
Code of Ethics, Participation or
Interest in Client Transactions and
Personal Trading
Code of Ethics
Subject to the restrictions described below, Baird
and its affiliates and associates may engage in
securities transactions for their own accounts,
including the same or related securities that are
recommended to or owned by Baird clients. These
transactions may include trading in securities in a
manner that differs from, or is inconsistent with,
the advice given to Baird clients, and the
transactions may occur at or about the same time
that such securities are recommended to or are
purchased or sold for client accounts. This creates
Baird and DDK Consultants have a financial
incentive to use, select or recommend Associated
Investment Products and Services because Baird
and BFG benefit financially if a client utilizes those
investment products and services rather than
unassociated investment products and services,
and DDK Consultants benefit financially from the
overall success of Baird and BFG. Similarly, Baird
and DDK Consultants also generally have a
investment
financial
products and services of Baird over Associated
Parties and to favor those of Associated Parties in
which BFG has a materially greater indirect
ownership interest over those of Associated
Parties in which BFG has a materially lesser
indirect ownership interest. Baird addresses this
potential conflict
this
Brochure. Further, when acting as fiduciaries,
Baird and its DDK Consultants are required to
select or recommend investment products only
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a potential for a conflict between the interest of
clients and the interests of Baird and its affiliates
and associates.
client’s account. Select clients may pay a fixed
dollar fee, which presents a conflict in that such
fee does not give the DDK Consultant an incentive
to make recommendations that could benefit the
client’s account, or a performance or incentive
fee, which presents a conflict because it gives the
DDK Consultant an incentive to recommend
riskier investments in order to achieve the level of
performance in the account that would result in
payment of the fee.
Accounts and Investments Provide Different
Levels of Compensation
The types of accounts and investment products
offered
to clients provide Baird and DDK
Consultants different levels of compensation.
Baird and DDK Consultants have an incentive to
generate revenues
from client accounts by
selecting and recommending account types and
investment products that will provide them the
greatest level of compensation.
or
by
Baird’s
the
Relationships
and
To address the potential for conflicts of interest,
Baird has adopted a Code of Ethics (the “Code”)
that applies to
its associates that provide
investment advisory services to clients, including
DDK Consultants, their supervisors, and certain
associates who have access
to non-public
information relating to advisory client accounts
(“Access Persons”). The Code prohibits Access
Persons from using knowledge about advisory
client account transactions to profit personally,
directly, or indirectly, by trading in his or her
personal accounts. The Code also generally
prohibits Access Persons
from executing a
security transaction for their personal accounts
during a blackout period one business day before
or after the date that a client transaction in that
same security is executed. The Code provides for
certain exceptions deemed appropriate by Baird
management
Compliance
Department. In addition, orders for the accounts
of Access Persons and other Baird associates that
are under discretionary management by Baird
may be aggregated with orders for other Baird
client accounts, so long as the order is executed
as part of a block transaction with client orders. A
copy of the Code is available to clients or
prospective clients upon request.
website
Recommendations of Associated Investment
Products and Services
Baird and DDK Consultants have an incentive to
investment
recommend
use, select or
products and services of Associated Parties
because they will benefit financially. See “Other
Financial Industry Activities and Affiliations—
Certain
Arrangements—
Associated Investment Products and Services”
above and “Certain Parties Associated with Baird”
on
at
Baird’s
bairdwealth.com/retailinvestor.
Baird has also implemented certain policies and
procedures relating to Baird’s and its associates’
trading activities that are designed to prevent
them from improperly benefiting from the trading
activities of Baird’s advisory clients. In addition,
Baird’s Compliance Department monitors the
personal trading activities of all of Baird’s
associates providing advisory-related services to
clients.
Service
incentive
to recommend an
Referral Compensation Paid to DDK Consultants
DDK Consultants receive additional compensation
for referring clients to certain Associated Parties
described above. See “Other Financial Industry
Activities and Affiliations—Certain Relationships
and Arrangements—Baird and Associated Parties”
above. DDK Consultants also receive additional
compensation for referring clients to unaffiliated
banks that make loans to clients under Baird’s
Securities-Based Lending Program. See “Advisory
Business—Additional
Information—
Securities-Based Lending Program” above. Such
compensation gives DDK Consultants an incentive
to recommend or refer clients to those Associated
Parties and to recommend that a client participate
in the Securities-Based Lending Program. For
more information about referral compensation
paid to DDK Consultants and related conflicts of
Participation or Interest in Client
Transactions
Investment Advisory Accounts
Asset-based Advisory Fee arrangements create an
incentive for Baird and DDK Consultants to set the
applicable fee rate at a high level and to
encourage clients to add more money into their
accounts. Baird and DDK Consultants also have
an
investment
advisory account to a client rather than a
brokerage account if the client has, or is expected
to have, lower levels of trading activity in the
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interest, please see “Baird Referral Programs” on
Baird’s website at bairdwealth.com/retailinvestor.
described above and by adopting internal policies
that limit the circumstances under which mutual
fund investments in client accounts can be
designated as unbillable assets and 12b-1 fees
can be retained.
receives ongoing
fees
invested
Ongoing Product Fees
Baird
from certain
investment products that are purchased and held
in client Accounts. Those fees, such as distribution
(12b-1) and/or service fees (“12b-1 fees”) from
mutual funds, are based on the value of client
assets
in those products. A DDK
Consultant’s compensation increases as those
fees increase. Thus, Baird and DDK Consultants
have an incentive to use, select or recommend
such products and to recommend such products
that pay the greatest ongoing fees.
Certain mutual funds charge 12b-1 fees, which
are paid to Baird. Baird receives 12b-1 fees on an
ongoing basis as compensation for the services
Baird provides to the applicable mutual fund. The
12b-1 fees paid by a mutual fund are disclosed in
the mutual fund’s prospectus.
Trust
Portfolios
and
Baird generally does not allow mutual funds with
12b-1 fees to be purchased for DDK Service
Accounts. If Baird receives 12b-1 fees from a fund
with respect to a client’s mutual fund investment
in the client’s Account and the client’s Account is
subject to an asset-based fee arrangement, Baird
either: (1) rebates such 12b-1 fees to the client’s
Account if the client is paying an asset-based
Advisory Fee on such investment; or (2) excludes
such fund shares from the calculation of the
client’s asset-based Advisory Fee (sometimes
referred to as “unbillable assets”) for such period
of time that Baird collects and retains the 12b-1
fee. 12b-1 fees rebated to a client’s Account are
estimated based on the average daily balance of
the mutual fund shares in the Account and the
annual rate of the 12b-1 fee paid by the
applicable fund. If any rebated fees remain in a
client’s Account at the time of billing, those
rebated amounts will be included in the Account
assets subject to the Advisory Fee.
Please
see
Marketing Support and Revenue Sharing from
Mutual Fund and UIT Sponsors
Baird receives marketing support or revenue
sharing payments (“marketing support”) from the
sponsors and investment advisers of certain
mutual funds. These payments, which are based
on sales of, or client assets invested in, such
funds, are intended to compensate Baird for
providing marketing, distribution and other
services for the mutual funds. Marketing support
is not paid by sponsors or investment advisers of
mutual funds on mutual fund assets held in
investment advisory Retirement Accounts to the
extent prohibited by applicable
law. Baird
received marketing support payments over the
past two calendar years from the sponsors or
investment advisers of Alliance Bernstein Funds,
American Funds, Franklin Templeton Funds,
Goldman Sachs Funds, Hartford Funds, Invesco
Funds, John Hancock Funds, JPMorgan Funds,
Lord Abbett Funds, MFS Funds, PIMCO Funds and
Principal Funds. Baird also generally receives
marketing support related to the sale of units of
UITs. Sponsors of UITs typically make marketing
or concession payments to the firms that sell their
UITs,
including Baird. These payments are
typically calculated as a percentage of the total
volume of sales of the sponsor’s UITs made by
the
firm during a particular period. That
percentage typically increases as higher sales
volume levels are achieved. Descriptions of these
additional payments are provided in a UIT’s
prospectus. UIT sponsors that have paid volume
concessions to Baird over the past two calendar
years include Advisors Asset Management (AAM),
First
Guggenheim
Investments. Receipt of marketing support
payments from sponsors and investment advisers
of mutual funds and UITs provides Baird an
incentive to use, select and recommend such
mutual funds and UITs and to favor mutual funds
and UITs with sponsors or investment advisers
that make the greatest levels of such payments.
Baird does not share these payments with DDK
Consultants.
“Revenue
Sharing/Marketing Support and Other Third Party
Payments” at bairdwealth.com/retailinvestor for
more information.
If Baird receives 12b-1 fees with respect to
mutual fund shares that are designated as
unbillable assets in a client’s Account, Baird will
retain such 12b-1 fees. This presents a conflict of
interest because it provides Baird and its DDK
Consultants an
incentive to use, select or
recommend mutual fund shares that pay greater
12b-1 fees. Baird addresses this conflict by
adopting a Mutual Fund Share Class Policy
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Payments” at bairdwealth.com/retailinvestor for
more information.
Party
Payments”
for
DDK Consultants Receive Benefits from Product
Providers
DDK Consultants generally receive non-cash
compensation and other benefits from Baird and
from sponsors of investment products with which
Baird does business. Such non-cash compensation
and other benefits may include invitations to
attend conferences or educational seminars,
payment of related travel, lodging and meal
expenses, and receipt of gifts and entertainment.
For example, DDK Consultants are invited to
educational conferences hosted by sponsors of
mutual funds, annuities and other investment
products, with the costs associated with such
conference (including travel and lodging) paid by
the sponsors. In addition, DDK Consultants hold
client events with some or all of the costs of such
events paid by sponsors of investment products.
Product sponsors may also provide gifts and
entertainment in connection with those or other
events. These benefits present a conflict of
interest in that they give DDK Consultants an
incentive to use, select or recommend investment
products and their sponsors that provide the
greatest levels of such benefits. Please see
“Revenue Sharing/Marketing Support and Other
Third
at
more
bairdwealth.com/retailinvestor
information.
Program
Baird
Schwab Clearing Arrangement
Baird has a clearing arrangement with Charles
Schwab & Co., Inc. (“Schwab”) whereby Schwab
maintains an omnibus account with certain
mutual fund families for Baird on behalf of Baird
clients. Under the clearing arrangement, Schwab
provides clearing services for most “no load”
funds and “load” funds held by Baird clients.
Although Baird pays Schwab a fee for its clearing
and omnibus services, Schwab generally passes
through to Baird the shareholder servicing fees
that Schwab receives from the funds. Shareholder
servicing fees are not paid by Schwab on mutual
fund assets held in Retirement Accounts to the
extent prohibited by applicable law. The amount
of the shareholder servicing fees paid to Baird is
based on the value of the client assets invested in
those funds. However, the shareholder servicing
fee rate varies based on the type of fund (load or
no load), the value of client assets in those funds,
and the relationship that Schwab has with those
funds (whether or not Schwab receives payments
from those funds or their sponsors, and the rates
of such payments). As a result, Baird has an
incentive to use, select or recommend mutual
funds from which Baird would receive higher
payments from Schwab. However, Baird generally
does not compensate DDK Consultants based
upon the amounts Baird receives from Schwab
except with respect to amounts attributable to
sales loads and 12b-1 fees that Baird would
otherwise receive directly from a fund if it were
not for the existence of the clearing arrangement
with Schwab. If Baird receives 12b-1 fees from
Schwab with respect to a mutual fund investment
in a client’s Account, Baird rebates or retains such
fees as further described under the heading
“Ongoing Product Fees” above.
Cash Sweep Program
Baird has an incentive to have clients participate
and maintain significant balances in Baird’s Cash
Sweep
receives
because
substantial compensation on client cash balances
that are automatically swept into bank deposit
accounts and invested in money market mutual
funds under the program. Please see “Advisory
Business—Additional Service Information—Cash
Sweep Program” above
for more detailed
information.
funds,
the opportunity
firm
and
to
seminars
supporting Baird
Please
see
Baird Conference Sponsorships
Baird hosts a number of seminars and
conferences for DDK Consultants in any given
year, including Baird’s PWM Symposium, which
gives sponsors of investment products, such as
to make
mutual
presentations at, and contribute money toward
the cost of, such seminars and conferences. This
presents a conflict of interest in that it gives Baird
an incentive to promote or market the sponsors’
investment products in order to persuade them to
and
continue
conferences.
“Revenue
Sharing/Marketing Support and Other Third Party
Trust Services Arrangements
Baird and DDK Consultants have an incentive to
recommend that a client retain Baird Trust for the
client’s trust services needs rather than an
unassociated
recommend
arrangements that involve Baird and the DDK
Consultant providing investment advisory services
to the client and Baird Trust only providing trust
is more
administration services because
it
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for
them. Please see
profitable
“Advisory
Business—Additional Service Information—Trust
Services Arrangements” above for more detailed
information.
to
recommend
account. However, because Baird’s revenues and
the compensation paid to DDK Consultants from
brokerage accounts increase as the level of
trading increases, Baird and DDK Consultants
have an incentive to recommend a brokerage
account to a client rather than an investment
advisory Account if the client has, or is expected
to have, significant trading activity in the client’s
account. DDK Consultants also have a financial
incentive
certain wealth
management services, such as financial planning.
Please see “Fees and Compensation—Advisory
Fees—Advisory Fee Payments to Baird, DDK
Consultants and Investment Managers” above for
more detailed information.
Margin Loans
Baird has an incentive to recommend that a client
use margin because Baird receives interest on
client margin
loans, and Baird and DDK
Consultants also have an incentive to recommend
that a client use margin, because a margin loan
allows the client to make larger and more
securities purchases. It also increases the value of
a client’s Account and thus the Advisory Fee
associated with that Account because the margin
loan is not deducted for purposes of calculating
the fee. Please see “Advisory Business—Additional
Service Information—Margin Loans” above for
more detailed information.
for
Account Transfers and New Accounts
Baird and a client’s DDK Consultant have an
incentive to recommend that the client transfer
the client’s accounts to Baird and establish new
accounts with Baird (including IRA rollovers)
because doing so will result in increased revenues
to Baird and compensation
the DDK
Consultant.
DDK
Consultants
receive
Service
Securities-Based Lending Program
Baird and DDK Consultants have an incentive to
recommend that a client participate in Baird’s
Securities-Based Lending Program because Baird
and
referral
compensation and such loans allow a client to
keep more assets in the client’s Accounts, which
result in more advisory fees for us and paid to the
client’s DDK Consultant. Please see “Advisory
Business—Additional
Information—
Securities-Based Lending Program” above for
more detailed information.
to
clients
rather
Recommendations to Open Different Types of
Accounts
Baird and DDK Consultants have an incentive to
recommend that a client open different types of
accounts with Baird, such as individual accounts,
IRA rollovers, joint accounts, 529 plan accounts
and UGMA/UTMA accounts, because if a client has
different types of accounts with Baird, the client
brings more of the client’s investable assets to
Baird, on which fees can be generated, thereby
increasing Baird’s revenues and the client’s DDK
Consultant’s compensation. Also, if a client has
more account types with Baird, the client is
statistically more likely to maintain the client’s
relationship with Baird and the client’s DDK
Consultant for longer periods of time.
Consultant
receive
that
increase
Investment Advisory and Brokerage Account and
Service Recommendations
Baird and DDK Consultants generally have a
financial incentive to recommend investment
advisory Accounts
than
brokerage accounts because Advisory Fee
is recurring, more predictable and
revenue
typically greater than the revenues Baird earns,
and the compensation DDK Consultants receive,
from brokerage accounts. In addition, because
Advisory Fees are paid by a client regardless of
the trade activity in the client’s advisory Account,
Baird will receive greater revenue, and the client’s
DDK
greater
will
compensation, from a low trade-activity advisory
Account than from a low trade-activity brokerage
account. Baird and DDK Consultants thus have an
incentive to recommend an investment advisory
Account to a client rather than a brokerage
account if the client has, or is expected to have,
lower levels of trading activity in the client’s
Baird Stock Ownership
Most DDK Consultants own common stock of BFG,
Baird’s ultimate parent, and when offered the
opportunity to buy BFG stock they usually do so.
The amount of BFG stock that a DDK Consultant
may purchase is based in part on the DDK
Consultant’s total production level. A client’s DDK
incentive to make
Consultant thus has an
recommendations
the DDK
Consultant’s total production on the client’s
accounts with Baird. Moreover, revenues from
in which DDK
Baird’s PWM department,
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Payments
to Baird, DDK Consultants and
Investment Managers” above for more detailed
information.
compensation
that Baird
with
Baird,
even
if
agent,
commissions.
Consultants operate, contribute substantially to
BFG’s overall revenues and profitability, and the
performance of BFG’s stock price is largely due to
the profitability of Baird’s PWM department. As a
result, a client’s DDK Consultant’s ownership of
BFG stock creates a financial incentive to make
recommendations to the client that increase the
amount of revenues generated from the client’s
those
accounts
recommendations will not increase the DDK
Consultant’s production, so as to increase the
revenues and profitability of Baird’s PWM
department and thus of BFG, which will serve to
grow the value of the BFG stock. For example,
ownership of BFG stock, the performance of which
is impacted by the success of Associated Parties,
provides a client’s DDK Consultant an incentive to
use, select or recommend Associated Investment
Products and Services to a client even though
such recommendation does not increase the
client’s DDK Consultant’s production.
Principal Trading
Baird and DDK Consultants have an incentive to
execute a trade for a client on a principal basis.
and DDK
The
Consultants receive on principal trades, such as a
markup or markdown, is often higher than the
compensation they receive when executing trades
as
The
as
such
received by Baird and DDK
compensation
Consultants is in addition to the asset-based
Advisory Fee a client pays on the client’s advisory
Accounts. Thus, Baird and DDK Consultants have
an incentive to trade as principal rather than as
agent. Principal trades also allow Baird to sell
securities from Baird’s account that Baird deems
undesirable and to buy securities for Baird’s
account that Baird deems desirable. For more
information, please see “Advisory Business—
Additional Service Information—Trading for Client
Accounts—Trade Execution Services Performed by
Baird—Principal Trades” above.
Other Client Relationships
Certain client accounts overseen by Baird and
DDK Consultants may have similar investment
objectives and strategies but may be subject to
different fee schedules or commission rates. Thus,
Baird and its DDK Consultants have an incentive
to favor client accounts that generate a higher
level of compensation.
in companies or
Baird Underwritten Offerings
Baird and DDK Consultants have an incentive to
recommend that clients purchase securities in
offerings underwritten by Baird because the
underwriting compensation that Baird and DDK
Consultants will earn on those offerings tends to
be higher than the compensation they would
normally receive if clients were to buy them in the
secondary market, and because the profitability of
underwritten offerings to Baird depends upon
Baird’s ability to sell the securities allocated to
Baird in the offering.
Relationships with Issuers of Securities
From time to time, Baird may have proprietary
investments
issuers whose
securities are offered and sold to clients, a DDK
Consultant or another Baird associate may have
significant investments in companies or issuers
whose securities are offered and sold to clients, or
a DDK Consultant or another other Baird
associate (or their spouses, partners or family
members) may have a position as an officer or
director of a company or issuer whose securities
are offered and sold to clients. In such cases,
Baird and/or a client’s DDK Consultant will have
an incentive to recommend that the client invest
in those companies.
Allocations of IPOs and Other Public Offerings
DDK Consultants have the incentive to favor some
clients over other clients when allocating shares
issued in public offerings, particularly those
clients with larger accounts or accounts that
generate high fees and compensation, as a
reward for their past business or to generate
future business.
DDK Consultants Transferring to Baird
A DDK Consultant joining Baird from another firm
has an incentive to recommend that a client to
transfer the client’s accounts from such firm to
Baird because doing so will increase the DDK
Consultant’s compensation. Please see “Fees and
Fee
Compensation—Advisory
Fees—Advisory
Trade Error Correction
It is Baird’s policy that a client’s account will be
fully compensated for any losses incurred as a
result of a trade error for which Baird is
responsible. If the trade error results in a gain,
the gain may be retained by Baird. For more
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information, please see “Advisory Business—
Additional Service Information—Trading for Client
Accounts—Baird’s Trading Practices—Trade Error
Correction” above.
A client may choose to hold cash balances in the
client’s eligible accounts as broker-dealer “free
credits.” To the extent a client elects to hold cash
balances as free credits, a client understands that
Baird does not pay interest on such balances and
Baird may benefit from the possession or use in
the ordinary course of its business of any free
credit balances in the client’s accounts, subject to
restrictions imposed by Rule 15c3-3 under the
Exchange Act.
the size of
the order,
Baird’s Other Broker-Dealer and Related Activities
The investment advice provided to a client may
be based on the research opinions of Baird’s
research departments. Baird does, and seeks to
do, business with companies covered by those
research departments and as a result, Baird may
have a conflict of interest that could affect the
content of its research reports.
automated
sell
investments
recommended
non-institutional
participants
in
Information—Trading
for
Baird and its Associated Parties and associates
may buy or
that are
recommended to or owned by a client for their
own accounts, or they may act as broker or agent
for other clients buying or selling
those
investments. Those transactions may include
buying or selling investments in a manner that
differs from, or is inconsistent with, the advice
given to a client, and those transactions may
occur at or about the same time that such
investments are
to or are
purchased or sold for a client’s account. Baird
may also engage in agency cross transactions and
principal transactions with clients as further
described under “Advisory Business—Additional
Service
Client
Accounts—Trade Execution Services Performed by
Baird” above.
Baird selects securities trade execution venues
trading
based on
characteristics of the security, speed of execution,
likelihood of price improvement, availability of
efficient
transaction processing,
guaranteed automatic execution levels and other
qualitative factors. Baird receives payment or
liquidity rebates on certain options or equity
securities orders
to some venues
routed
(commonly known as “payment for order flow”).
The existence and amount of payments are
dependent upon the size and type of the routed
order. The
source and amount of any
compensation received by Baird in connection
with payment for order flow will be disclosed to
the
the
transaction upon request. This compensation
gives Baird an incentive to route client orders for
securities transactions to those venues that
provide Baird the greatest levels of compensation,
but Baird’s routing decision is always based upon
obtaining favorable executions for clients rather
than the availability of payment for order flow.
Information about Baird’s order routing practices
at:
available
are
http://www.rwbaird.com/help/account-
disclosures/routing-equity-orders.aspx.
to
from
time
Relationships
Baird and DDK Consultants have an incentive to
favor the securities of issuers for which Baird’s
Global Investment Banking, Fixed Income Capital
Markets (including Baird Public Finance) and
Institutional Equities and Research Departments
provide services due
the compensation
received by Baird and Baird Financial Advisors.
See “Other Financial Industry Activities and
Affiliations—Certain
and
Arrangements—Baird and Associated Parties”
above.
Baird and its associates, by reason of Baird’s
investment banking or other
broker-dealer,
activities, may
time acquire
to
information deemed confidential, material and
non-public, about corporations or other entities
and their securities. Baird and its associates are
prohibited by applicable law or agreements from
disclosing such information to clients or acting
upon such information with respect to any client
Account. Baird’s other activities thus present a
potential conflict of
interest because such
activities may limit Baird’s ability to advise or
manage client Accounts.
As a registered broker-dealer, Baird effects
transactions in securities on a national exchange
and may receive and retain compensation for
such services, subject to the limitations and
restrictions made applicable to such transactions
by Section 11(a) of the Exchange Act and Rule
11a2-2(T) thereunder.
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• address and limit cash and non-cash benefits
provided to DDK Consultants by third parties in
an attempt to avoid any question of propriety or
any conduct inconsistent with Baird’s high
standards of ethics.
Other Conflicts of Interest
Baird offers to clients other investment products
and services not described in this Brochure. These
services provide
investment products and
different levels of compensation to Baird and its
DDK Consultants. Baird and its DDK Consultants
have an incentive to favor those investment
products and services that generate a higher level
of compensation than those that generate a lower
level of compensation. For more information
about the other investment products and services
offered by Baird, clients should contact Baird or a
DDK Consultant.
extend beyond
a
client’s
Duration Compensation Will Be Received
If a client holds any of the investment products
described above, Baird, its Associated Parties and
associates will receive the fees and payments
described above for the duration of the client’s
advisory
In some
relationship with Baird.
circumstances, the receipt of such compensation
may
advisory
relationship with Baird if the client continues to
hold those assets at Baird.
financial
interest or practices
Financial
Industry
Activities
Other sections of this Brochure also describe
instances when Baird and its DDK Consultants
may recommend to clients, and may buy and sell
for client’s Account, securities in which Baird and
its Associated Parties and associates have a
material
that
present a conflict of
interest. For more
information, please see “Advisory Business—
Advisory Fees—Advisory Fee Payments to Baird,
DDK Consultants and Investment Managers” and
“Other
and
Affiliations” above, and “Client Referrals and
Other Compensation” below.
If Baird, or an Associated Party or associate of
Baird, receives any compensation or benefit
described in this Brochure from or related to a
client’s investment, they will generally retain the
compensation or benefit. Except as otherwise
described above, Baird generally does not rebate
these amounts to a client’s Account or credit the
amount against the Advisory Fees payable by a
client unless such compensation may not be
retained under applicable law or regulation.
to DDK
to
for Baird and
Addressing Conflicts
The foregoing activities could create a conflict of
interest with clients. In addition to the measures
described above, Baird addresses conflicts posed
by those activities through disclosure in this
Brochure, the client’s agreements with Baird, the
Client Relationship Booklet and prospectuses,
offering documents or other disclosure documents
provided or made available to clients. Baird has
also adopted a Code of Ethics and other internal
policies and procedures
its
associates that:
• require them to provide investment advice that
is suitable for advisory clients (based upon the
information provided by such clients);
that
• are designed
securities
to ensure
allocations made to discretionary client accounts
are made in a manner such that all such clients
receive fair and equitable treatment over time;
• address Baird’s and its associates’ trading
activities and are designed to prevent them
from improperly benefiting from the trading
activities of Baird’s advisory clients; and
Brokerage Practices
DDK’s and Baird’s Trading Practices
Broker-Dealer Selection
DDK and Baird will select the broker-dealers,
which may include Baird, that will execute trade
orders for Non-Discretionary Accounts and with
respect to Accounts that are managed directly by
DDK or Baird unless the client has provided
instructions
the contrary. As
investment adviser, DDK and Baird have an
obligation to seek “best execution” of client trade
orders. “Best execution” means that they must
place client trade orders with those broker-
dealers that they believe are capable of providing
the best qualitative execution of client trade
orders under the circumstances, taking into
account the full range and quality of the services
offered by the broker-dealer, including the value
of the research provided (if any), the broker-
dealer’s execution capabilities, the cost of the
trade, the broker-dealer’s financial responsibility,
and its responsiveness to DDK and Baird. It is
important to note that DDK’s and Baird’s best
execution obligation does not require them to
solicit competitive bids for each transaction or to
seek the lowest available cost of trade orders, so
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
received had the transaction been effected for the
client independently from the block transaction.
long as they reasonably believe that the broker-
dealer selected can be reasonably expected to
provide clients with the best qualitative execution
under the circumstances.
in
treatment over
Trade Aggregation, Allocation and Rotation
Practices
DDK and Baird may aggregate contemporaneous
buy and sell orders for the accounts over which
they have discretionary authority (a practice also
known as bunching trades or block transactions).
This practice may enable them to obtain more
favorable execution, including better pricing and
enhanced investment opportunities, than would
otherwise be available
if orders were not
aggregated. Using block transactions may also
assist them in potentially avoiding an adverse
effect on the price of a security that could result
from simultaneously placing a number of
separate, successive or competing, client orders.
the
The amount of securities available
marketplace, at a particular price at a particular
time, may not satisfy the needs of all clients
participating in a block transaction and may be
insufficient to provide full allocation across all
client accounts. To address this possibility, Baird
has adopted
trade allocation policies and
procedures that are designed to make securities
allocations to discretionary client accounts in a
manner such that all such clients receive fair and
equitable
time. If a block
transaction cannot be executed in full at the same
price or time, the securities actually purchased or
sold by the close of each business day will
generally be allocated pro rata among the clients
participating in the block transaction. However,
DDK may also make random allocations to client
accounts in certain circumstances, such as when
Baird deems a partial fill for the total block order
to be low. Adjustments may also be made to
avoid a nominal allocation to client accounts.
under
their
direct
favorable net price
When DDK is not able to aggregate trades, DDK
generally uses a trade rotation process that is
designed to be fair and equitable to its advisory
clients over time. However, a client should be
aware that DDK’s trade rotation practices may at
times result in a transaction being effected for the
client’s Account that occurs near or at the end of
the rotation and, in such event, client’s trade
orders will significantly bear the market price
impact, if any, of those trades executed earlier in
the rotation, and, as a result, the client may
receive a
for the
less
applicable trade.
into
consideration
account
DDK and Baird generally aggregate buy and sell
orders when executing trades for client account
assets
discretionary
management when they have the opportunity to
do so. When utilizing block transactions, DDK and
Baird generally aggregate a client’s trade orders
with trade orders for clients who are participating
in the same Service and pursuing the same model
portfolio or strategy. In some cases, DDK or Baird
may aggregate a client’s trade orders with trade
orders for other advisory clients who are not
participants in the Services described in this
Brochure. However, DDK and Baird determine
whether or not to utilize block transactions for a
client in their sole discretion and DDK’s and
Baird’s decision is subject to their duty to seek
best execution. In determining the amount to be
allocated to an account, if any, DDK and Baird
specific
take
investment restrictions, undesirable position size,
account portfolio weightings, client tax status,
client cash positions and client preferences.
in a block
All advisory clients participating
transaction will receive the same execution price
for the security bought or sold. Average prices
may be used when allocating purchases and sales
to a client’s Account because such securities may
be purchased and sold at different prices in a
series of block transactions. As a result, the
average price received by a client may be higher
or lower than the price the client may have
Notwithstanding the foregoing, if an aggregated
trade order involves fixed income securities, DDK
and Baird may allocate the securities based on
the needs of client accounts. In addition, DDK and
Baird will at times place aggregated trade orders
for fixed income securities prior to determining
how the aggregated trade order will be allocated
to client accounts. In those instances when an
aggregated trade order for fixed income securities
is placed prior to determining client allocations or
when such trade order is only partially filled, DDK
or Baird will seek to allocate trades in manner
intended to be fair and equitable to applicable
clients over time. Furthermore, when a trade
order for fixed income securities is only partially
filled, DDK and Baird may place orders for other
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
income securities
fixed
that have similar
characteristics, such as issuer name, structure,
credit rating, or market sector.
dealer after DDK completes its trading for other
DDK client accounts. The client’s trade orders will
significantly bear the market price impact, if any,
of those trades executed earlier in DDK’s rotation.
As a result, the client may receive a less favorable
net price for the trade.
Because DDK and Baird are unable to buy or sell
any security for a client’s Non-Discretionary
Accounts without the client’s authorization, DDK
and Baird generally do not aggregate or bunch
trades for those Accounts with the same or similar
trades for other client accounts. Because similar
orders for the client and DDK’s or Baird’s other
clients may be placed and filled at different times,
the client may buy or sell securities at prices that
are different from the prices obtained by other
clients who received the same or similar advice
from DDK or Baird.
interest
If a client directs DDK to use a particular broker-
dealer, and if the particular broker-dealer referred
the client to DDK or if the particular broker-dealer
refers other clients to DDK or Baird in the future,
DDK and Baird may benefit from the client’s
directed brokerage arrangement. Because of
these potential benefits, DDK and Baird may have
an economic interest in having the client continue
the directed brokerage arrangement. The benefits
that DDK and Baird receive conflict with the
in having DDK or Baird
client’s
recommend that the client utilize another broker-
dealer to execute some or all transactions for the
client’s Account.
Before directing DDK to use a particular broker-
dealer, a client should carefully consider the
possible costs or disadvantages of directed
brokerage arrangements.
the purchase of
Cross Trading Involving Advisory Accounts
DDK generally does not in engage in cross
transactions, including agency cross transactions,
except in limited instances such as when clients
buy or sell variable rate demand obligations which
are also known as “put bonds”. When DDK
believes that the transaction is consistent with
interest, DDK, acting as
each client’s best
investment manager, may cause (or in the case
of Non-Discretionary accounts, recommend) the
sale of securities from the account of an advisory
client while at or about the same time causing
(or, in the case of Non-Discretionary accounts,
recommending)
the same
securities for the account of another DDK advisory
client. Such transactions may have the benefit of
reducing transaction and market impact costs.
Directed Brokerage Arrangements
In some cases, a client may direct DDK to use a
particular broker-dealer for execution of the
client’s trade orders (a “directed brokerage
arrangement”), and DDK may agree to the
arrangement. This may occur when a client’s
Account is held at another broker-dealer firm and
a client directs DDK to execute trades through
such firm, or when a client’s Retirement Account
or other account is maintained on a platform
operated and managed by a third party and
trades must be executed through that platform. A
client should understand that DDK and Baird
consider such arrangements to be directed
brokerage arrangements. A client should also
understand that if the client has a directed
brokerage arrangement, DDK and Baird may be
unable to achieve best execution for the client’s
transactions. A client should note that any costs
related to the directed brokerage arrangement
are not included in the Advisory Fee and that the
client will be solely responsible for monitoring,
evaluating and reviewing the arrangement with
the directed broker-dealer and paying any
commissions or markups or markdowns or other
costs imposed by the directed broker-dealer. A
client should also note that DDK generally will not
aggregate the client’s directed brokerage trade
orders with orders for other DDK clients. As a
result, a client’s transaction costs may be higher
because the client will not benefit from any
volume discounts or other reduced transaction
costs that DDK may obtain for its other clients. A
client should further note that DDK generally will
not include such client trade orders in its trade
rotation process and that DDK will generally place
the client’s trade orders with the directed broker-
In such cases, because Baird is acting as
investment adviser for both buyer and seller,
Baird is subject to potentially conflicting interests
in causing (or recommending) the transactions.
Also, because Baird is acting as investment
adviser for both buyer and seller, transaction
prices may be determined more by reference to
market information or dealer indications for the
securities involved, and less through the type of
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
independent arms-length negotiation that might
otherwise occur. Baird has adopted internal
policies and procedures that require DDK and
Baird to obtain approval of Baird’s Compliance
Department before affecting a cross trade.
the
investment manager,
Investment managers may participate in wrap fee
programs. In addition, investment managers may
manage institutional and other accounts not part
fee program. In the event an
of a wrap
investment manager purchases or sells a security
for all accounts using a particular SMA Strategy
offered by
the
investment manager may have to potentially
effect similar transactions through a number of
different broker-dealers. In some cases, to
address this situation, investment managers may
decide to aggregate all such client transactions
into a block trade that is executed through one
broker-dealer. This practice may enable the
investment manager to obtain more favorable
execution, including better pricing and enhanced
investment opportunities, than would otherwise
be available if orders were not aggregated. Using
block transactions may also assist the investment
manager in potentially avoiding an adverse effect
on the price of a security that could result from
simultaneously placing a number of separate,
successive or competing client orders.
Trade Error Correction
It is Baird’s policy that if there is a trade error for
which DDK or Baird is responsible, DDK or Baird
will take actions, based on the
facts and
circumstances surrounding the error, to put the
client’s Account in the position that it would have
been in as if the error had not occurred, including
by adjusting or reversing the transaction, entering
an offsetting transaction, or other methods that
may be deemed appropriate by Baird. Errors
caused by DDK or Baird will be corrected at no
cost to client’s Account, with the client’s Account
not recognizing any loss from the error. DDK and
Baird may net gains and losses from a single error
event involving more than one transaction in a
security or transactions in multiple securities. The
client’s Account will be fully compensated for any
losses incurred as a result of an error event. If
the trade error results in a gain, the gain may be
retained by Baird but such gain is not given to or
shared with any DDK or Baird associate.
DDK and Baird offer many services and, from
time to time, may have other clients in other
programs trading in opposition to a client. To
avoid favoring one client over another client,
Baird attempts to use objective market data in
the correction of any trading errors.
in
the
information
If a client’s Account is managed by an Other
Manager, the client should review the Other
Manager’s Brochure and contact
the Other
Manager for information about how the Other
Manager corrects trade errors.
Alternatively, an investment manager may utilize
a trade rotation process where one group of
clients may have a transaction effected before or
after another group of the investment manager’s
clients. A client should be aware that an
investment manager’s trade rotation practices
may at times result in a transaction being effected
for the client’s Account that occurs near or at the
end of the investment manager’s rotation and, in
such event, client’s trade orders will significantly
bear the market price impact, if any, of those
investment
trades executed earlier
manager’s rotation, and, as a result, the client
may receive a less favorable net price for the
trade. Additional
regarding an
investment manager’s trade rotation policies, if
any, is available in the investment manager’s
Form ADV Part 2A Brochure.
Soft Dollar Benefits
DDK and Baird receive no research or other
products from broker-dealers in connection with
DDK clients’ securities transactions.
Trading Practices of Investment Managers
If a client’s Account or a portion thereof is
managed by an investment manager, the client
should note that, like Baird, such investment
manager has a duty to seek best execution for
the client’s Account.
on
website
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after
they have
implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. The Overlay Manager has
provided to Baird a list of Model Providers that
have such trade rotation policies, which list is
available
at
Baird’s
bairdwealth.com/retailinvestor. A DDK client
should understand that an Account pursuing a
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
See “Trade Execution Services Performed by
Baird—Principal Transactions” below for more
information.
Trade Execution Services Performed by
Baird
If Baird provides trade execution services for a
client’s Account, Baird will generally act as agent
when routing client trade orders for execution.
However, Baird may cross trades between client
accounts or may act as principal for its own
account in certain circumstances to the extent
permitted by applicable law as is more fully
described below.
in
A client should understand that certain securities,
such as securities traded over-the-counter and
fixed income securities, are primarily traded in
dealer markets. When Baird purchases or sells
these types of securities for client accounts, it
generally does so through broker-dealer firms
acting as a dealer or principal. Dealers executing
principal trades typically
include a markup,
markdown or spread in the net price at which
transactions are executed. A client bears such
costs in addition to the Advisory Fee.
except
in
limited
the Model Provider’s
Model Portfolio strategy offered by those Model
Providers will have trades executed for the client’s
Account at the end of the Model Provider’s trade
rotation on a regular and consistent basis. As a
result, trade orders for such an Account will
significantly bear the market price impact, if any,
of those trades executed earlier in the Model
Provider’s rotation and the performance of the
Account will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by the Model Provider. In
addition and for the same reasons described
above, the performance of a Model Portfolio, as
reported by the Model Provider, will differ,
perhaps in a materially negative manner, from
the actual performance realized by DDK client
Accounts pursuing the Model Portfolio strategy.
DDK and Baird do not make or control any
investment manager’s trade rotation policies, and
they do not monitor, evaluate or review any
investment manager’s compliance with
the
manager’s trade rotation policies or whether such
trade rotation policies result
inequitable
performance of client Accounts. A client selecting
a Model Portfolio offered by such a Model Provider
is urged to obtain a copy of the Model Provider’s
Form ADV Part 2A Brochure and review the
description of the Model Provider’s trade rotation
policy contained in that document. A copy of a
Model Provider’s Brochure can be obtained by
contacting a DDK Consultant. A client should also
monitor the performance of an Account pursuing
such a Model Portfolio strategy and compare that
performance with the performance reported for
the Model Portfolio by the Model Provider. A client
about Account
questions
discuss
should
performance or
trade
rotation policy with the client’s DDK Consultant.
in accordance with
investment
A client should note that each
manager is solely responsible for ensuring that it
complies with its best execution obligations to the
client. A client should review the manager’s
trading for the client’s Account because DDK and
Baird do not monitor, review or evaluate whether
the manager is complying with its best execution
obligations to the client. A client should review
the manager’s Form ADV Part 2A Brochure,
inquire about the manager’s trading practices,
and consider that information carefully, before
selecting a manager.
Agency Cross Transactions
DDK generally does not in engage in agency cross
transactions,
instances.
However, in certain circumstances and to the
extent permitted by applicable law and regulation,
Baird and DDK Consultants may effect “agency
cross” transactions with respect to a client’s
Account. An “agency cross” transaction is a
transaction in which Baird or its affiliates act as
broker for the party or parties on both sides of
the transaction. As compensation for brokerage
services, Baird may receive compensation from
parties on both sides of an agency cross
transaction, the amount of which may vary. DDK
Consultants may receive compensation from Baird
related to agency cross transactions. Therefore,
Baird and DDK Consultants may have a conflicting
division of loyalties and responsibilities. However,
in all cases, Baird and DDK Consultants will seek
to obtain the best execution for each respective
advisory client and will effect agency cross
the
transactions only
requirements of Rule 206(3)-2 under the Advisers
Act. Furthermore, Baird will comply with
additional regulations applicable to Retirement
Accounts.
A client should note that the client’s advisory
agreement permits DDK and Baird to trade as
principal on orders received from Other Managers.
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agency
transactions
“agency
Where applicable, a client’s advisory agreement
discusses
and
cross
authorizes Baird and DDK Consultants to effect
agency cross transactions for a client’s Account. A
client’s authorization to Baird and DDK
to effect
Consultants
cross”
transactions
is given pursuant to Rule
206(3)-2 under the Advisers Act and may be
revoked at any time by the client in client’s
sole discretion by notifying the client’s DDK
Consultant in writing.
act as principal over other
transactions.
Nonetheless, Baird and DDK Consultants have a
fiduciary duty to act in the client’s best interest
and to seek best execution for advisory clients.
Baird addresses this conflict through disclosure in
this Brochure. Furthermore, Baird has adopted
internal procedures that require Baird and DDK
Consultants, when acting in a principal capacity,
to disclose all material information regarding
Baird’s interest in the transaction, and obtain the
client’s approval of the transaction prior to
settlement.
A client’s advisory agreement discloses, where
applicable, the possibility of Baird’s role in
potential principal
transactions, and each
transaction confirmation sent to DDK clients
discloses the capacity in which Baird served in the
transaction and whether Baird is a market maker
in each security the client bought or sold.
or
if
other
the Account
transactions.
Riskless
Principal Transactions
Subject to the requirements of applicable law,
Baird and DDK Consultants may execute
transactions for a client’s Account while acting as
principal for Baird’s own account. Baird and DDK
Consultants act as principal when they sell a
security from Baird’s inventory to a client or they
purchase a security from a client for Baird’s
inventory. Baird and DDK Consultants also act as
principal when they sell new issue securities to
clients in securities offerings underwritten by
Baird. Baird also acts as principal in riskless
principal
principal
transactions refer to transactions in which Baird,
after having received a client’s order, executes an
identical order in the marketplace to fill the
client’s order while acting as principal.
realize profits
To the extent permitted by applicable law and
regulation, if a client’s Account participates in a
non-
Non-Discretionary Service
discretionary service, or
is
managed by an Other Manager, the client’s
advisory agreement provides Baird and DDK
Consultants with a blanket authorization to act as
principal for Baird’s own account in selling any
security to, or purchasing any security from, the
client’s Account. With this authorization, Baird
and DDK Consultants may effect any and all
principal transactions with the client’s Account
without having
to provide specific written
disclosures or obtain written client consent prior
to completion of each proposed principal trade,
subject to the requirements of an exemptive
order issued by the SEC to Baird (Rel. No. IA-
4596) and other applicable law and regulation.
This authorization to enable Baird and DDK
Consultants to trade as principal with a
client’s Account may be revoked at any time
by the client in client’s sole discretion by
notifying the client’s DDK Consultant in
writing.
interests of
incentive
to
from principal
Baird may
transactions with a client based on the difference
between the price Baird paid for the security and
the price at which Baird sold the security, which
may include a markup, markdown or spread from
the prevailing market price, an underwriting fee,
selling dealer concession, or other incentive to
execute the transaction. DDK Consultants may
receive compensation
from Baird related to
principal trades of securities underwritten by
Baird. Any compensation received by Baird or a
DDK Consultant in a principal transaction is in
addition to the Advisory Fee paid by the client.
Principal trades also allow Baird to sell securities
from its account that it deems undesirable and to
buy securities for its account that it deem
desirable. Thus, in trading as principal with a
client, Baird and DDK Consultants will have
potentially conflicting division of loyalties and
responsibilities regarding their own interests and
the
the client. This potential
compensation may give Baird and DDK
Consultants an
recommend a
transaction in which Baird and DDK Consultants
Review of Accounts
Client Account Review
Client accounts are monitored on a periodic basis
by the client’s DDK Consultant and are subject to
review by the Baird Market Director or PWM
Supervision department supervisor (or his or her
respective designee) responsible for supervising
the client’s DDK Consultant. A client’s DDK
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Consultant generally reviews the performance of
the client’s Account at least annually. However,
the client’s DDK Consultant may not review the
performance of a client’s SMAs managed by Other
Managers under the Baird SMA Network Program
or Dual Contract Program. Baird has designated
individuals who are responsible for monitoring a
client’s DDK Consultant with respect to the client
account’s trading activity and attempting to
ascertain whether client accounts within each
composite are being treated equitably.
Benchmarks shown in performance reports are for
informational purposes only. DDK’s selection and
use of benchmarks is not a promise or guarantee
that the performance of a client’s Account will
meet or exceed the stated benchmark. When the
client compares Account performance to the
performance of a market index, the client should
recognize that a market index merely reflects the
performance of a list of unmanaged securities
included in the index and the index performance
does not take into account management fees,
execution costs, and other expenses related to
investing for a client’s Account. The securities
included in a client’s Account generally do not
exactly mirror the securities included in the index.
performance
comparisons
Account Statements and Performance
Reports
If Baird provides transaction execution services to
a client, Baird will generally provide the client
with a monthly brokerage account statement
when activity occurs during
that month.
Otherwise, Baird will provide the client with a
quarterly statement if there has not been any
intervening monthly transaction activity.
The benchmarks used by Baird with respect to a
client’s SMA may differ from the benchmarks used
by the manager of the client’s SMA. As a result,
the
in Baird’s
performance reports may differ from reports
provided to clients directly by the investment
manager for the client’s SMA.
A client’s DDK Consultant will provide the client
with a written report on the client’s Account’s
performance as often as the client and the DDK
Consultant may from time to time mutually agree.
Performance reporting may not be available for
Account assets that are not custodied at Baird.
For more information about performance reports
provided by DDK, see “Advisory Business—
Description of Advisory Services” above. DDK or
Baird may change or discontinue performance
reporting to a client at any time for any reason
upon notice.
calculation of
Client performance reports usually contain a
portfolio valuation and typically show the asset
allocation of the client’s portfolio, changes in a
client’s portfolio, and account performance
compared to a benchmark market index or indices
(such as the S&P 500® Index or the Bloomberg
U.S.
Intermediate Government/Credit Bond
Index). The benchmark may be a blended
benchmark that combines the returns for two or
more indices.
The performance of investment managers may,
under certain circumstances, be presented to
clients on a “gross” or “gross of fees” basis, which
means the performance results being presented
does not reflect the deduction of Advisory Fees
and other costs that clients have incurred and will
incur when retaining the manager. Had applicable
Advisory Fees and other costs been included in
the performance calculation,
the manager’s
performance results would have been lower than
the performance results presented. Documents
presenting a manager’s performance results on a
gross of
fees basis should contain certain
disclosures about the performance results being
presented. Clients are urged to review carefully
those disclosures because they contain important
information about
the
the
performance results. If a client is presented
performance information for a manager’s strategy
on a gross of fees basis and the client has an
Account managed by that manager pursuant to
that strategy,
the client should obtain a
performance report for the Account and review
that performance information carefully because
the performance report for the Account will reflect
the deduction of applicable Advisory Fees and
other costs.
A client should note that past performance does
not indicate or guarantee future results. None of
DDK, Baird, or investment managers managing
the client’s Account promise or guarantee any
level of investment returns or that the client’s
investment objective will be achieved.
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after
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client would receive if the securities were actually
sold from the client’s Account.
If a client has assets held by a third party
custodian, the prices shown on a client’s Account
statements provided by the custodian could be
different from the prices shown on statements
and reports provided by DDK or Baird. See
“Custody” below for more information.
they have
implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. As a result, the performance of a
Model Portfolio, as reported by the Model
Provider, will differ, perhaps in a materially
negative manner, from the actual performance
realized by Baird client Accounts pursuing the
Model Portfolio strategy. See “Additional Service
Information—Trading for Client Accounts—Trading
Practices of Investment Managers” above for
more information.
including, but not
limited
to,
role
in developing
the
these
fees
to
Client Referrals and Other
Compensation
DDK or Baird may provide compensation to
individuals who refer clients in some instances.
When applicable, the compensation paid is a
percentage of the client’s fee payments or the
value of the client’s Account. The amount of
compensation will vary, with the specific level
determined based upon consideration of various
factors
the
individual’s
client
relationship and the assets under management.
Baird may pay
registered
representatives of Baird and its Associated Parties
as well as to unassociated solicitors that have
entered into a written agreement with Baird.
When preparing a client’s Account statements and
performance reports, DDK and Baird generally
rely upon third party sources, such as third party
pricing services. In some instances, such as when
Baird is unable to obtain a price for an asset from
a pricing service, Baird may obtain a price from
its trading desk or it may elect to not price the
asset. Obtaining a price from its trading desk may
present a conflict of interest. In some cases, Baird
obtains prices from the issuers or sponsors of
investment products in the client’s Account when
prices are not otherwise readily available. This
frequently occurs with respect to the valuation of
annuities and Complex Investment Products. If
the assets in the client’s Account are held by a
custodian other than Baird, Baird may also use
valuation information provided by the client’s
third party custodian.
and
Personal
Trading”
DDK and Baird and Baird’s Associated Parties and
associates may receive certain economic benefits
in connection with providing advisory services to
clients, which are described in the sections
entitled “Advisory Business—Additional Service
Information”, “Fees and Compensation”, “Other
Financial Industry Activities and Affiliations”,
“Code of Ethics, Participation or Interest in Client
Transactions
and
“Brokerage Practices” above.
is unreliable. Valuation data
from
Custody
Certain Services may require clients to custody
their Account assets at Baird. If Baird is the
custodian of a client’s assets, Baird will provide
certain custody services, including holding the
client’s Account assets, crediting contributions
and interest and dividends received on securities
held in a client’s Account, and making or
“debiting” distributions
the Account.
Information about account statements and
performance reports, if any, that DDK and Baird
provide to clients is contained under the heading
“Advisory Business–Consulting Services” and
“Review of Accounts” above.
DDK and Baird do not conduct a review of
valuation information provided by third party
pricing services, issuers, sponsors, or custodians,
and they do not verify or guarantee the accuracy
of such information. DDK and Baird do not accept
responsibility for valuations provided by third
parties that are inaccurate unless they have a
reason to believe that the source of such
valuations
for
investments, particularly annuities and Complex
Investment Products, may not be provided to
DDK or Baird in a timely manner, resulting in
valuations that are not current. The prices
obtained by DDK and Baird from the third party
pricing services, issuers, sponsors and custodians
may differ from prices that could be obtained
from other sources. Values used in account
statements and performance reports may vary
from prices received in actual transactions and
are not firm bids, offers or guarantees of any type
with respect to the value of assets in an Account,
and the values may be greater than the amount a
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Baird. Clients using a third party custodian are
encouraged to establish appropriate cash sweep
arrangements.
As custodian, Baird may hold a client’s Account
assets in nominee or “street” name, a practice
that refers
to securities and assets being
registered in Baird’s name or in a name that Baird
designates, rather than in a client’s name directly.
Baird will be the holder of record in those
instances.
Baird may utilize one or more subcustodians to
provide for the custody of a client’s assets in
certain circumstances. For instance, Baird utilizes
subcustodians to maintain custody of certain
client assets participating in the Cash Sweep
Program (described below) and securities that are
traded on foreign exchanges.
(e.g.,
A client who uses a third party custodian
authorizes DDK and Baird to give instructions to
the client’s custodian for all actions necessary or
incidental to the purchase, sale, exchange, and
delivery of securities held in the client’s Account.
Also, the client will receive account statements
directly from the client’s selected custodian. A
client should carefully review those account
them with any
compare
statements and
statements provided by DDK or Baird. A client
should note that the prices shown on a client’s
Account statements provided by the custodian
could be different from the prices shown on
statements and reports provided by DDK or Baird
due to a variety of factors, including the use of
different valuation sources and accounting
methods
settlement date
trade or
accounting) by the custodian and Baird.
Investment Discretion
Investment Selection and Trading
Authorizations
A client
retains complete discretion over
investment selection and trading decisions with
respect to assets in a client’s Non-Discretionary
Service Accounts, and DDK and Baird will only
execute transactions for such Accounts pursuant
to the client’s instruction or authorization.
to client Accounts on
If a client’s Account participates in a Discretionary
Service, the client’s advisory agreement provides
Baird and the client’s DDK Consultant, as
applicable, discretionary authority to manage the
assets in the client’s Account in accordance with
the terms of the Service selected by the client.
a
If a client’s Account participates in the DDK
Recommended Managers Service, the client’s
advisory agreement provides Baird and the
client’s DDK Consultant discretionary authority to
appoint investment managers to manage the
client’s Account and to terminate or replace
investment managers for the client’s Account for
any reason without prior notice to the client. If
DDK or Baird terminates an investment manager
from management
client’s DDK
of
Recommended Managers Service Account, the
client’s advisory agreement provides DDK and
Baird discretionary authority to manage the
assets in the client’s Account until a replacement
DDK and Baird in their sole discretion may accept
into a client’s Account,
Held-Away Assets
including assets
that are held by another
custodian (a “third party custodian”). A client who
uses a third party custodian to hold Account
assets does so at the client’s risk. A client should
understand that DDK and Baird do not monitor,
evaluate or review any third party custodian
unless they otherwise agree to do so in writing.
The client should also understand that the client
will pay a custody fee to the third party custodian
in addition to the Advisory Fee. Baird may also
impose additional fees on Accounts with assets
held by a third party custodian due to the
increase in resources needed to administer those
Accounts. Further, such third party custody
arrangements may
limit the Services made
available to the client. In addition, a client should
understand that: (a) each third party custodian
has exclusive control over the investment options
made available
the
custodian’s platform; (b) DDK and Baird have no
authority or ability to add to, or remove from, a
custodian’s platform any investment option; (c)
any advice given by DDK or Baird with respect to
the Account is inherently limited by the options
available through a custodian’s platform; (d) DDK
or Baird may have provided different investment
advice with respect to the Account had they not
been limited to the investment options made
available through the custodian’s platform; and
(e) certain investments, such as mutual fund
shares, could be more or less expensive than if
the investment was obtained from Baird or
another firm. A client should further note that
DDK and Baird may not provide performance
review or reporting for Held-Away Assets. In
addition, a client who uses a third party custodian
is not eligible for cash sweep services offered by
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investment manager is selected or alternative
arrangements are made for the management of
the client’s assets.
include
If a client’s Account participates in an SMA
Service, the client’s advisory agreement provides
the investment manager selected to manage the
an
client’s Account, which may
Implementation Manager, discretionary authority
to manage the assets in the client’s Account in
accordance with the terms of the SMA Service
selected by the client.
heading “Brokerage Practices” above, unless
Baird’s duty to seek to obtain best execution
otherwise requires or unless the client has
provided other instructions to Baird in writing.
DDK and Baird do not have discretionary
authority over the assets in a client’s SMAs that
are managed by an Other Manager and cannot
purchase or sell such assets without the consent
of the client or such Other Manager. The
investment manager for a client’s SMAs may
initiate securities transactions through Baird, in its
capacity as broker-dealer, as further described
under the heading “Brokerage Practices” above,
subject to the manager’s duty to seek to obtain
best execution, or unless a client has provided
other instructions in writing. Baird, as broker-
dealer, will rely upon any such instructions of any
investment managers selected to manage the
client’s Account.
for
buying,
holding,
If a client participates in an SMA Service, the
client authorizes DDK and Baird to share client’s
information with the Overlay Manager and any
Other Manager or
Implementation Manager
managing the client’s Account. The client also
authorizes and directs DDK and Baird to transmit
to the Overlay Manager and any such Other
Manager or
Implementation Manager any
instructions that the client may provide to DDK or
Baird to the extent necessary to carry out the
client’s instructions.
the client. Pursuant
Client Investment Restrictions
The Discretionary and the SMA Services offer a
client the ability to impose reasonable investment
restrictions on the management of an Account,
including the designation of particular securities
or types of securities that should not be
purchased for the client’s Account, but a client
may not require that particular funds or securities
(or types) be purchased for the client’s Account.
Reasonable investment restrictions requested by
a client will apply only to those assets over which
DDK, Baird or a client’s investment manager has
discretion.
investments
to
those
If a client grants discretionary authority over the
client’s Account to DDK, Baird, the client’s DDK
Consultant or the client’s investment manager,
the client’s advisory agreement authorizes DDK,
Baird, the client’s DDK Consultant and the client’s
investment manager, as applicable, to manage
the client’s Account and to make investment
decisions for the client’s Account, with the
authority to determine the amount, type and
timing
exchanging,
converting and selling securities and other assets
for the client’s Account, subject to the terms of
the Service selected by the client. The client’s
advisory agreement also grants to DDK, Baird,
the client’s DDK Consultant and the client’s
investment manager, as applicable, complete and
unlimited trading authorization and appoints them
as the client’s agents and attorneys-in-fact to
manage the assets in the client’s Account on the
client’s behalf, subject to the terms of the Service
selected by
to such
authorization and powers of attorney, DDK, Baird,
the client’s DDK Consultant and the client’s
investment manager may, in their sole discretion
and at the client’s risk, purchase, sell, exchange,
convert and otherwise trade the securities and
other assets in the client’s Account, as well as
arrange for delivery and payment in connection
with the above, and act on the client’s behalf in
all matters necessary or incidental to the handling
of the client’s Account without prior notice to the
client. Such trading authorizations and powers of
attorney, whether granted to DDK, Baird, the
client’s DDK Consultant or the client’s investment
manager, shall remain in full force and effect until
terminated by the client, the client’s investment
manager, DDK or Baird.
DDK may also offer clients a socially responsible
investing (“SRI”) service, which assists a client in
that are
restricting
consistent with the client’s social investment
guidelines or objectives. Clients electing the SRI
service generally bear the cost of the SRI service
as it is generally included in the Advisory Fee.
Orders for the purchase and sale of securities in a
client’s Discretionary Service Accounts will
generally be executed by Baird, in its capacity as
broker-dealer, as further described under the
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accounts without
restrictions
deciding to invest in Associated Investment
Products are the same as those used in deciding
to invest a client’s assets in investment products
unassociated with Baird. For more information
about the criteria used by DDK and Baird, clients
should review the section of the Brochure entitled
“Methods of Analysis, Investment Strategies and
Risk of Loss” above. A client’s consent may be
revoked at any time.
The Services allow Other Managers, including
Associated Managers, to use the discretionary
authority granted to them by a client to invest the
client’s Account in investment products managed
or sponsored by the Other Manager or any of its
associated firms, which may include Baird. The
Other Manager or its associated firms receive
investment management or advisory fees or other
compensation from such products for the services
they provide, the amount of which generally
increases when clients invest in such products.
In the event that a client’s Account is restricted
from investing in certain securities, DDK, Baird or
the client’s investment manager, as applicable,
will select such other replacement securities, if
any, as they deem appropriate. Accounts with
investment restrictions may perform differently
from
and
performance may be poorer. In addition, in the
event there is a change in the classification or
credit rating of a security held in the client’s
Account, a client’s investment restrictions may
force DDK, Baird or the client’s investment
manager to sell such security at an inopportune
time, possibly negatively
impacting Account
performance and causing the client’s Account to
realize taxable gains or losses, which could be
significant. A client should also be aware that, if
the client’s Account holds any investment vehicle
(such as a mutual fund or ETF), any investment
restrictions the client places on the client’s
Account may not flow through to the securities
owned by that investment vehicle.
Should a client wish to impose or modify existing
restrictions, or the client’s financial condition or
investment objectives have changed, the client
should contact the client’s DDK Consultant.
other
from
the services
By signing an advisory agreement with Baird or
participating in a Service, a client consents to
each Other Manager, including each Associated
Manager, managing client’s Account investing all
or a portion of the client’s Account in investment
products managed or sponsored by the Other
Manager or any of its associated firms, which may
include Baird. Each Other Manager is responsible
for providing to the client information about the
amount of fees received by the Other Manager
and its associated firms and the criteria used by
the Other Manager in deciding to invest in
products managed or sponsored by the Other
Manager or any of its associated firms. A client
should contact the Other Manager and review the
Other Manager’s Form ADV Part 2A Brochure for
more information. A client’s consent may be
revoked at any time.
Associated Investment Products
The Services allow DDK and Baird to use the
discretionary authority granted to them by a
client to invest the client’s Account in Associated
Investment Products. Baird and Associated Parties
receive investment management or advisory fees
compensation
Associated
or
Investment Products
they
for
provide, the amount of which generally increases
when clients invest in such products. The amount
of fees or other compensation received by Baird
and Associated Parties is generally described in
the prospectus or other offering or disclosure
documents for the investment product. Additional
information is also available on Baird’s website at
bairdwealth.com/retailinvestor.
in Associated
Investment Policy Statements
DDK and Baird will not review, monitor, accept or
adhere to an investment policy statement or
similar document that was not prepared by DDK
or Baird, unless they otherwise specifically agree
to do so in writing. Adherence to any such
investment policy statement or similar document
is solely a client’s responsibility.
By signing an advisory agreement with Baird or
participating in a Service, a client consents to
DDK and Baird investing all or a portion of the
Investment
client’s Account
Products. DDK and Baird will use
their
discretionary authority to invest the client’s
Account in Associated Investment Products when
they determine it to be in the client’s best interest
to do so. Generally, the criteria used by them in
Conversion, Exchange or Sale of Certain
Investments
By participating in a Service, a client authorizes
DDK and Baird to convert or exchange any shares
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instances. For
Dual Contract Program, by providing proper
instructions to the manager directly). Some
managers do not offer proxy voting services in
connection with certain strategies, such as option
strategies. Clients pursuing those strategies will
automatically retain the right to vote proxies in
those
information about a
manager’s voting policies and procedures, clients
should review the manager’s Form ADV Part 2A
Brochure.
of mutual funds and other Funds held in the
client’s Account to a class of shares of the same
fund, such as advisory class shares, institutional
class shares, financial intermediary class shares,
or another class of shares primarily designed for
use in advisory programs (collectively, “Advisory
Class Shares”), to the extent made available by
the mutual fund or other Fund in accordance with
policies established by Baird from time to time,
including, without limitation the Mutual Fund
Share Class Policy that is described above.
Discretionary Services
Under the DDK Investment Management Service,
a client may retain the right to vote proxies with
respect to the securities held in the client’s
Account, or a client may delegate such right to
Baird.
If a client retains proxy voting authority, Baird will
forward proxy materials that Baird actually
receives to the client. The client will then be
solely responsible for analyzing the materials and
casting the vote.
A client should understand that, the client may
not hold Advisory Class Shares in a non-Advisory
Account and that the client may not be able to
hold certain Advisory Class Shares in an account
held at another firm. Upon the termination of a
Service for an Account or the closure of an
Account for any reason, DDK and Baird may
convert or exchange the Advisory Class Shares
held in the Account to an appropriate non-
Advisory Class Shares issued by the same fund,
or, if an appropriate non-Advisory Class Shares is
not available, DDK and Baird may redeem or sell
such Advisory Class Shares.
If a client delegates voting authority to Baird,
Baird will vote proxies solicited by, or with respect
to, securities held in the client’s Account for the
exclusive benefit of the client and in accordance
with policies and procedures adopted by Baird.
Voting Client Securities
Non-Discretionary Accounts
With respect to any Accounts over which the
client retains discretionary investment authority,
a client retains the right to vote proxies with
respect to the securities held in such Accounts.
Accordingly, the client is responsible for voting
proxies and otherwise addressing all matters
submitted for consideration by security holders,
and DDK and Baird are under no obligation to
take any action or render any advice regarding
such matters. The client’s DDK Consultant may,
upon the client’s request, provide advice on proxy
voting or what other action the client could take.
Baird has adopted written policies and procedures
that are reasonably designed to ensure that it
votes client securities in the best interests of
clients. Those procedures address material
conflicts of interest that may arise between
Baird’s interests and those of its clients. Although
a description of Baird’s proxy voting policies and
procedures is provided below, Baird will furnish a
copy of its proxy voting policies and procedures to
clients upon their request. Additionally, clients
may obtain information on how Baird actually
voted proxies with respect to the securities held in
their accounts by contacting their DDK Consultant
or by calling (414) 765-3500.
interests. Baird utilizes
governance
services,
In situations in which a client has delegated to
Baird voting authority with respect to securities in
the client’s Account, Baird will vote proxies in a
manner that Baird believes is consistent with the
client’s best
an
independent provider of proxy voting and
corporate
currently
Institutional Shareholder Services (“ISS”), to
analyze proxy materials and votes and make
Separately Managed Accounts
Under the DDK Recommended Managers Service,
Baird SMA Network Program and Dual Contract
Program, a client may retain the right to vote
proxies with respect to the securities held in the
client’s Account, or, in most instances, the client
may delegate such right to the investment
manager selected to manage the client’s Account
(which may include Baird, the Overlay Manager or
an Implementation Manager). A client may select
either option by making the appropriate election
in the client’s advisory agreement (and in the
case of a dual contract arrangement under the
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voting
recommendations.
interests of
administer) a corporate retirement, pension or
employee benefit plan or providing (or seeking to
provide) advisory or other services to a company
whose management is soliciting proxies. In such
instances, there may be a concern that Baird
would be inclined to vote in favor of management
because of Baird’s relationship or pursuit of a
relationship with the company. In situations
where there is a potential conflict of interest,
Baird’s
Proxy Voting Sub-Committee will
determine the nature and materiality of the
conflict. If the conflict is determined to not be
material, the Sub-Committee will vote the proxy
in a manner the Sub-Committee believes is in the
best
the client and without
consideration of any benefit to Baird or its
affiliates. If the potential conflict is determined to
be material, Baird’s Proxy Voting Sub-Committee
will take one of the following steps to address the
potential conflict: (1) cast the vote in accordance
with the recommendations of ISS or other
independent third party; (2) refer the proxy to
the client or to a fiduciary of the client for voting
purposes; (3) suggest that the client engage
another party to determine how the proxy should
be voted; (4) if the matter is not addressed by
ISS, vote in accordance with management’s
recommendation; or (5) abstain from voting.
independent
ISS
provides proxy voting guidelines regarding its
position on various matters presented by
companies to their shareholders for consideration.
Baird will typically vote shares in accordance with
the recommendations made by ISS. However,
ISS’s guidelines are not exhaustive, do not
address all potential voting issues, and do not
necessarily correspond with the opinions of DDK
Consultants. In the event the client’s DDK
Consultant believes the ISS recommendation is
not in the best interest of the client, the DDK
Consultant will bring the issue to Baird’s Proxy
Voting Sub-Committee through a proxy challenge
process. The Sub-Committee will
then be
responsible for determining how the vote will be
cast. The decision made by the Proxy Voting Sub-
Committee on the proxy challenge applies to all
advisory accounts managed by
the DDK
Consultant (or team of DDK Consultants), unless
the client has directed Baird to utilize specific
voting guidelines (e.g., Taft-Hartley guidelines).
For those matters for which the independent
proxy voting service does not provide a specific
voting recommendation, each DDK Consultant will
cast the vote in a manner he or she believes is in
the best interest of clients. The votes cast for a
client’s Account may differ from those votes cast
for other Baird clients based on differing views of
DDK Consultants and other Baird portfolio
managers.
While Baird uses its best efforts to vote proxies,
there are instances when voting is not practical or
is not, in Baird’s or DDK Consultants’ view, in the
best interest of clients. For example, casting a
vote on a foreign security may involve additional
costs or may prevent, for a period of time, sales
of shares that have been voted. Also, when a
client has entered into a securities lending
program, Baird generally will not seek to recall
the securities on loan for the purpose of voting
the securities; however, Baird reserves the right
to recall the shares on loan on a best efforts basis
if the client’s DDK Consultant becomes aware of a
proxy proposal where the proxy vote is materially
important to the client’s Account.
In addition to the services described above, Baird
has engaged ISS for vote execution and record-
keeping services.
Baird uses ISS’s electronic vote management
system to cast votes on behalf of clients. In
connection with Baird’s use of that system, ISS
pre-populates how client votes should be cast
based upon ISS’s voting recommendations. The
system allows Baird to change the pre-populated
vote (to the extent permitted by Baird’s proxy
voting policies) up until a certain time prior to the
applicable meeting (the “voting cut-off time”).
Baird’s proxy voting policies are designed to
address situations when additional information
becomes available after the votes are pre-
populated in the system and before the voting
cut-off time. However, there is no guarantee that
all information that could affect Baird’s proxy
voting decision will be received or considered by
Baird prior to a vote being cast.
Other Proxy Voting Information
Clients wishing to direct particular votes once
they have granted Baird discretionary voting
authority may do so by contacting their DDK
Consultant. However, if Baird has been granted
The proxy voting policies and procedures also
address instances in which Baird’s interests may
appear to conflict with client interests, such as
when Baird or an affiliate of Baird is managing or
to manage or
seeking
administering
(or
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
bankruptcy petition at any time during the past
ten years.
discretionary voting authority, neither DDK nor
Baird will provide a client with notice that Baird
has received a proxy solicitation, nor will they
consult with the client before casting a vote,
unless the client otherwise directs them to do so.
investment
Except to the extent a client has delegated proxy
voting authority to Baird, DDK and Baird have no
authority, direct or implicit, and accept no
responsibility for taking any action or rendering
any advice with respect to the voting of proxies
related to securities held in a client’s Accounts.
other
compensation
related
to
to
Special Considerations for Retirement
Accounts
Each Retirement Account Fiduciary of a client
should understand that DDK or Baird may invest
for the client, recommend that the client invest in,
or make available
to plan
for
participants, Associated Investment Products, that
Baird and its Associated Parties will receive fees
such
or
investments, and that they will retain such
compensation
the extent permitted by
applicable law, rule or regulation, including,
without limitation, Department of Labor (“DOL”)
Prohibited Transaction Exemption (“PTE”) 77-4,
DOL PTE 2020-02 or other advisory opinions
issued by the DOL.
Providing Baird Voting Instructions
As mentioned above, Baird may be the holder of
record for certain securities in a client’s Account.
If the client retains voting authority over such
securities (or delegates such authority to party
other than Baird), and a proxy is solicited with
respect to any such securities, the client (or other
authorized party) will need to provide voting
instructions to Baird. To the extent the client (or
other authorized party) does not provide timely
voting instructions, Baird will vote such securities
to the extent permitted by law and in compliance
with the rules of the New York Stock Exchange
and the SEC relating to such matters.
Parties
from
Legal Proceedings and Corporate Actions
Generally, none of DDK, Baird or any Other
Manager responsible for managing all or a portion
of the assets in a client’s Account will render
advice or take action on a client’s behalf with
respect to securities that are or were held in the
client’s Account, or the issuers thereof, which go
into default or become the subject of legal
proceedings, such as class action claims, defaults
or bankruptcies. Also, they may or may not vote
or advise clients on other corporate actions, like
tender offers, that are not solicited by a proxy
statement. At a client’s request, Baird will forward
information that Baird actually receives to the
client.
for
the Associated
Financial Information
DDK does not require or solicit prepayment of
more than $1,200 in fees per client six months or
more in advance and, thus, has not included a
balance sheet of Baird’s most recent fiscal year.
Neither Baird nor DDK is aware of any financial
condition that is reasonably likely to impair their
ability to meet their contractual commitments to
clients, nor has either been the subject of a
To the extent Baird and its Associated Parties rely
upon PTE 77-4, each Retirement Account
Fiduciary should also understand that when DDK
or Baird invests the assets of a Retirement
Account in an Associated Investment Product that
pays investment advisory fees to Baird or any of
its Associated Parties, Baird and its Associated
Parties will receive such investment advisory fees
in accordance with the terms of DOL PTE 77-4,
and, as required thereby, DDK and Baird will
waive the asset-based Advisory Fees on that
portion of the assets invested in the Associated
Investment Product for such period of time so
invested or Baird will offset the investment
advisory fees received by Baird or any of its
Associated
the
Associated
Investment Product against
the asset-based
Advisory Fee that DDK and Baird charge to the
client. For the purpose of complying with the
terms of DOL PTE 77-4, the client and each
Retirement Account Fiduciary of
the client
acknowledge in the client’s advisory agreement
that: (i) the investment in Associated Investment
Products for the client’s Account is appropriate
because of, among other things, the investment
goals, redeemability, liquidity, and diversification
of those products; (ii) subject to the terms of the
applicable Service, all assets of the client’s
Account may be invested in one or more of the
Associated Investment Products; (iii) the client
and such Retirement Account Fiduciary received
prospectuses or other offering or disclosure
documents
Investment
Products that may be used in connection with the
Account, each of which include a summary of all
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
directed broker-dealer is capable of providing best
execution.
the applicable
fees that may be paid by the Associated
Investment Products to Baird or its Associated
Parties; and (iv) the client received information
the nature and extent of any
concerning
differential between the rate of such Associated
Investment Product fees and the Advisory Fees
payable by the client. The differential between the
fees to be charged by DDK and Baird for the
investment advisory services they provide to the
client and, if applicable, the investment advisory
and other similar fees paid by the Associated
Investment Product to Baird or its Associated
Parties with respect to the services Baird or any of
its Associated Parties provides to the Associated
Investment Product is the difference between the
Advisory Fee disclosed in the client’s advisory
agreement and
investment
management, investment advisory and other
similar fees detailed in the applicable prospectus
or other offering or disclosure documents for the
Associated Investment Product.
If the client’s Account is a Retirement Account,
the client and each Retirement Account Fiduciary
of the client should note that the advisory
agreement authorizes Baird, in its capacity as
broker-dealer, to effect or execute securities
transactions for the client’s Account and to
receive commissions for such services, subject to
DOL PTE 86-128. In order to assist the client and
each Retirement Account Fiduciary of the client
with the determination as to whether such
authorization should be made, DDK will provide
the client with a copy of DOL PTE 86-128 and the
form to be used to terminate such authorization,
as well as the description of Baird’s brokerage
placement practices, which is set forth below.
DDK also will provide such other reasonably
available information that the client may request
for such purpose.
that
directed
the
fiduciary
Fiduciary
such Fiduciary
is
that
for complying with all
likelihood of price
transactions, and
the duty
in certain
broker-dealer,
and
terminating
monitoring
a
funds. Baird may place orders
When placing orders for securities transactions for
clients as a broker-dealer pursuant to DOL PTE
86-128, Baird has an obligation to use reasonable
diligence to ascertain the best market for the
subject security and to buy or sell in such market
so that the resultant price to the client is as
favorable as possible under prevailing market
conditions. Baird routes or places client orders to
various market makers, exchanges and other
execution venues based on their quality of
execution and execution capabilities in order to
obtain the best possible price and speed of
execution
for clients. Baird selects market
makers, exchanges and other execution venues
based on the size of the order, the trading
characteristics of the particular security, speed of
execution,
improvement,
availability of efficient automated transaction
processing, guaranteed automatic execution level
and other qualitative
factors. Order routing
decisions are not based on the availability of
payment for order flow or other remuneration,
although Baird receives payments for order flow
or other remuneration
instances.
Additional information about Baird’s routing of
equity orders is available on Baird’s website at
bairdwealth.com/retailinvestor. Baird does not
place orders with market makers or other third
parties for the purpose of compensating such
firms for their efforts in marketing Baird-affiliated
mutual
for
securities transactions with third party broker-
If the client’s Account is a Retirement Account
and if DDK is directed to implement a directed
brokerage arrangement for the Account, each
Retirement Account Fiduciary of the client should
brokerage
the
understand:
arrangement must be for the exclusive benefit of
participants and beneficiaries of the Retirement
Account; and
responsibilities
discussed in ERISA Technical Bulletin 86-1. Each
should also
Retirement Account
solely
understand
responsible
fiduciary
responsibilities discussed
in ERISA Technical
Bulletin 86-1, including, without limitation, the
duty to make an initial determination that the
directed broker-dealer is capable of providing best
execution for the client’s brokerage transactions,
the duty to monitor the services provided by the
directed broker-dealer so as to assure that the
client has received best execution of the client’s
brokerage
to
determine that the commissions paid by the client
and any other fees or costs incurred by the client
are reasonable in relation to the value of the
brokerage and other services received by the
client. The client and each Retirement Account
Fiduciary of the client should also understand that
the client and the client’s Retirement Account
Fiduciaries are solely responsible for engaging a
its
directed
performance
directed
brokerage arrangement, and that DDK and Baird
are not responsible for determining whether a
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
dealers and other firms that provide research
products and services to Baird.
than
the
client
If a client’s Account is a Retirement Account and if
the client is selecting Associated Investment
Products and Services, each Retirement Account
Fiduciary of the client understands and agrees
that in making such selection: (a) Baird and its
Associated Parties may receive higher aggregate
compensation
selected
if
investment managers, funds or other products
not associated with Baird and thus Baird may
have an incentive to offer Associated Investment
Products and Services; (b) Baird makes available
to the client investment managers, funds and
products not associated with Baird and the client
may obtain additional information about such
unassociated investment managers, funds or
products at any time by contacting the client’s
DDK Consultant; and (c) the client is free to
choose another investment option or participate
in another Baird advisory program that does not
use investment managers, funds or products
associated with Baird at any time by contacting
the client’s DDK Consultant. For more information
about Associated
Investment Products and
Services, please see “Other Financial Industry
Activities and Affiliations” above.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Appendix A
Associated Investment Products and Services
Entity Type
Name
Relationship
Baird Advisors1
Baird Department
Baird Equity Asset Management1
Baird Department
Chautauqua Capital Management1
Baird Department
55I, LLC (d/b/a 55ip, “55ip”)
Associated
Investment Advisor
GAMMA Investing, LLC
Affiliated
Greenhouse Fund GP LLC
Related
Greenhouse Funds LLLP
Related
LoCorr Fund Management, LLC
Related
Reinhart Partners, LLC
Affiliated
Riverfront Investment Group, LLC
Affiliated
Dual Registrant2
Strategas Securities, LLC
Affiliated
Trust Company
Baird Trust Company1
Affiliated
Baird Funds, Inc.1
Affiliated
Bridge Builder Trust (Baird series)
Affiliated
Mutual Fund
Financial Investors Trust (Riverfront series)
Affiliated
LoCorr Investment Trust
Related
Managed Portfolio Series Trust (Reinhart series)
Affiliated
Pace® Select Advisors Trust (Baird Series)
Affiliated
Advisors’ Inner Circle Fund III (Strategas series)
Affiliated
ETF
ALPS ETF Trust (Riverfront Series)
Affiliated
First Trust Exchange-Traded Fund III (Riverfront series)
Affiliated
Automated Quantitative Analysis (AQA®) Portfolio Series
Affiliated
UIT
Dividend Income Trust (DIT) Series
Affiliated
Strategas Trust, Series 1-1
Affiliated
CIT
Reliance Trust Institutional Retirement Trust (Baird/Chautauqua series)
Affiliated
Greenhouse Master Fund LP
Related
Hedge Fund
Greenhouse Onshore Fund LP
Related
Greenhouse Overseas Fund Ltd.
Related
Chautauqua Global Growth Equity QP Fund, LP
Affiliated
Private Fund
Chautauqua International Growth Equity QP Fund, LP
Affiliated
Chautauqua Series Fund, LLC
Affiliated
Appendix A - 1
DDK F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Venture Partners Management Company III, LLC
Baird Venture Partners III Limited Partnership
Affiliated
BVP III Affiliates Fund Limited Partnership
BVP III Special Affiliates Limited Partnership
Baird Venture Partners Management Company IV, LLC
Baird Venture Partners IV Limited Partnership
Affiliated
BVP IV Affiliates Fund Limited Partnership
BVP IV Special Affiliates Limited Partnership
Baird Venture Partners Management Company V, LLC
Baird Venture Partners V Limited Partnership
Affiliated
BVP V Affiliates Fund Limited Partnership
BVP V Special Affiliates Fund Limited Partnership
Baird Capital Partners Management Company V, LLC
Baird Capital1,3
Baird Capital Partners V Limited Partnership
Affiliated
Investment Advisor
BCP V Affiliates Fund Limited Partnership
Private Equity Fund
BCP V Special Affiliates Limited Partnership
Baird Capital Management Company, LLC
Baird Venture Partners GP VI, LLC
Baird Venture Partners VI LP
Affiliated
BVP VI Affiliates Fund LP
BVP VI Special Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management I LP
Baird Capital Global Fund I LP
Affiliated
Baird Capital Global Fund I-DE LP
BCGF I Special Affiliates LP
BCGF I Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management II LLC
Baird Capital Global Fund II Limited Partnership
Affiliated
BCGF II Affiliates Fund Limited Partnership
BCGF II Special Affiliates Limited Partnership
Appendix A - 2
DDK F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Capital Management Company, LLC
Baird Capital Global GP III LLC
Baird Capital Global Fund III LP
Affiliated
Baird Capital1,3
BCGF III Affiliates Fund LP
Investment Advisor
BCGF III Special Affiliates LP
Private Equity Fund
Baird Capital Partners Europe Limited4
Baird Capital Partners Europe II LP
Affiliated
Baird Capital Partners Europe II Special Affiliates LP
The Growth Fund
Baird Principal Group Management Company I, LLC
Baird Principal Group5
Baird Principal Group Partners Fund I Limited Partnership
Investment Advisor
Baird Principal Group Management Company II, LLC
Affiliated
Private Equity Fund
Baird Principal Group Partners Fund II Limited Partnership
Baird Principal Group Management Company, LLC
Baird Principal Group Partners Fund III, LP
Holding Company
Sagard Holdings Management, Inc.6
Associated
1. Participates in a Baird PWM Referral Program that pays compensation to DDK Consultants for eligible referrals.
2. Registered with the SEC as a broker-dealer and investment advisor.
3. Baird Capital, Baird’s private equity business.
4. Baird Capital Partners Europe Limited, an English limited company, is regulated and authorized by the Financial
Conduct Authority.
5. Baird Principal Group, a group within Baird that has private equity funds only available to Baird employees.
6. Baird has a contractual relationship with and a small minority investment in Sagard Holdings Management, Inc., a
holding company for various financial services businesses whose investment products are made available to clients under
the Services. See “Other Financial Industry Activities and Affiliations—Certain Relationships and Arrangements—Baird and
Associated Parties” above for more information.
Appendix A - 3
DDK F+C Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Additional Brochure: THE DDK GROUP - WRAP (2026-03-27)
View Document Text
The DDK Group
Wrap Fee Program Brochure
March 27, 2026
The DDK Group
777 East Wisconsin Avenue
Milwaukee, Wisconsin 53202
Toll Free: 800-792-2473
www.rwbaird.com
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue
Milwaukee, WI 53202
1-800-792-2473
rwbaird.com
Member FINRA & SIPC
SEC File No. 801-7571
This wrap fee program brochure (“Brochure”) provides information about the qualifications and
business practices of Robert W. Baird & Co. Incorporated (“Baird”) and the DDK Group (“DDK”), a
team within Baird’s Private Wealth Management department. Clients should carefully consider this
information before becoming a client of DDK. If you have any questions about the contents of this
Brochure, please contact DDK at the toll-free phone number listed above. The information contained
in this Brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority. Additional information about Baird is available on
the SEC’s website at www.adviserinfo.sec.gov.
Material Changes
The DDK Group (“DDK”), a team within the Private Wealth Management department of Robert W. Baird &
Co. Incorporated (“Baird”), updated its Form ADV Part 2A wrap fee program brochure (the “Brochure”) on
March 27, 2026. The following summary discusses the material changes that DDK has made to the Brochure
since March 21, 2025, the date of the last annual update to the Brochure.
• In January 2026, Baird’s direct parent corporation, Baird Financial Corporation (“BFC”), made a
significant minority investment in Reinhart Partners, LLC (“Reinhart”), an investment advisor that offers
investment products and services through the Programs. As a result of the investment transaction, Baird
and Reinhart are affiliated, providing Baird a financial incentive to use, select or recommend Reinhart
investment products and services.
“Additional
Information—Other Financial
• In September 2025, Baird entered into a strategic partnership with Sagard Holdings Management, Inc.
(“Sagard”). Baird’s direct parent corporation, BFC, acquired a minority ownership interest in Sagard and
the right to appoint a member to Sagard’s board of directors. Baird agreed to use best efforts,
consistent with its fiduciary duties and other regulatory responsibilities, to offer investment products
managed or sponsored by affiliates of Sagard deemed suitable by Baird for its PWM clients, providing
Baird a financial incentive to recommend such investment products. See the Section of the Brochure
entitled
Industry Activities and Affiliations—Certain
Relationships and Arrangements—Baird and Associated Parties” for more information.
• Baird updated its description of the DC Program. The DC Program is designed to accommodate a client
who wishes to independently select an investment manager not available in the DDK Recommended
Managers Service or BSN Program to manage the assets in the client’s Account. The Program is also
designed for a client that wants to independently select a manager and negotiate the manager’s
Portfolio Fee rate directly with the manager. Certain managers offer lower Portfolio Fee rates to clients
through the DC Program compared to the BAM, DDK Recommended Managers, or BSN Programs. A
client considering an SMA Strategy should discuss with client’s DDK Consultant SMA Strategy availability
and the different Portfolio Fee rates, costs, and the types and levels of service provided in connection
with the different Programs. If a client has decided to participate in the DC Program, upon the client’s
request, the client’s DDK Consultant may assist the client with the client’s negotiation with the manager
of the Portfolio Fee rate for the applicable SMA Strategy. The Portfolio Fee negotiated by the client could
be higher or lower than the Portfolio Fee that applies to the same SMA Strategy that is available through
other Programs. The client is ultimately responsible for understanding the differences between the SMA
Programs, deciding to participate in the DC Program, selecting the SMA Strategy, and negotiating and
agreeing to the Portfolio Fee rate.
• For the ALIGN Program, the BairdNext Portfolios Program, the Russell Program, and the UMA Programs,
Baird no longer offers clients the option to rebalance the client’s Account upon DDK Consultant review
after the Account’s allocation to an asset class drifts by 3% or more from the target allocation. Clients
must select one of the following rebalancing options: (1) annually on the Account’s anniversary date; or
(2) quarterly whenever the Account’s allocation to an asset class drifts by 3% or more from the target
allocation.
• Baird updated information about tax management and direct indexing strategies, including the
associated limitations and risks. See the Sections of the Brochure entitled “Services, Fees and
Compensation—Additional Service Information—Tax Management and Values Overlay Services” and
“Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and Risk of
Loss—Investment Strategies” for more information.
• Baird provided additional information about possible tax consequences of a client’s investment activities.
See the Section of the Brochure entitled “Services, Fees and Compensation—Additional Service
Information—Legal and Tax Considerations” for more information.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• Baird updated the rates of Portfolio Fees charged by managers under the Services. See the Section of
the Brochure entitled “Services, Fees and Compensation—Advisory Fees” for more information.
• Baird updated information about Baird’s regulatory assets under management. See the Section of the
Brochure entitled “Portfolio Manager Selection and Evaluation—Selection and Evaluation—Advisory
Business” for more information.
• Baird updated its disclosures about the research, information and tools used by Baird PWM home office
investment professionals and DDK Consultants when formulating investment advice, which may include
the use of artificial intelligence (“AI”) tools, and the related risks. See the Section of the Brochure
entitled “Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and
Risk of Loss—Methods of Analysis” for more information.
• Baird included a description of the PWM Stock Opportunities List. See the Section of the Brochure
entitled “Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and
Risk of Loss—Methods of Analysis—Certain Eligible Product Lists” for more information.
• Baird now offers four (4) new ALIGN UMA Select Portfolios: the Baird Research Equity ETF Portfolio;
Baird Research Capital Growth ETF (Taxable) Portfolio; Baird Research Growth with Income ETF
(Taxable) Portfolio; and Baird Research Income with Growth ETF (Taxable) Portfolio. See the Section of
the Brochure entitled “Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment
Strategies and Risk of Loss—Program Portfolio Strategies—UMA Programs—ALIGN UMA Select Portfolios”
for more information.
• Baird updated investment risk information related to information security, cybersecurity, and other
technology‑related events, issuers’ use of AI, investments in digital assets, such as cryptocurrencies,
and those associated with recent events, such as those associated with the U.S. administration’s policy
initiatives, inflation, conflicts in Iran and the Middle East, the war between Ukraine and Russia, and the
strain in relationships between the U.S. and other countries. See the Section of the Brochure entitled
“Portfolio Manager Selection and Evaluation—Methods of Analysis, Investment Strategies and Risk of
Loss—Principal Risks” for more specific information.
• In March 2026, Baird entered into an Offer of Settlement with the Massachusetts Securities Division to
settle a regulatory matter relating to the timing of state investment adviser representative registration
approvals for two of Baird’s Financial Advisors located in Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals provided investment advisory services before their
Massachusetts registrations were completed as a form was missing from their application materials. 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.
• Baird updated information about firms affiliated with, related to, or otherwise associated with Baird. See
the Section of the Brochure entitled “Additional Information—Other Financial Industry Activities and
Affiliations” and Appendix A to the Brochure for more information.
A client should note that the foregoing summary only discusses material changes made to the Brochure
since March 21, 2025. The updated Brochure contains changes that are not listed above.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Table of Contents
Services, Fees and Compensation ................................................................... 1
The Client-Baird Fiduciary Relationship ............................................................ 1
Summary of DDK’s Services .......................................................................... 1
Consulting Services ...................................................................................... 5
Financial Planning ................................................................................... 5
Risk Analysis .......................................................................................... 5
Asset Allocation and Investment Strategy Development ............................... 5
Consolidated Reporting ............................................................................ 5
Additional Consultant Services .................................................................. 5
Discretionary Services ................................................................................... 6
ALIGN Strategic Portfolios Program ........................................................... 6
BairdNext Portfolios Program .................................................................... 7
DDK Investment Management Service ....................................................... 7
Russell Model Strategies Program ............................................................. 8
Non-Discretionary Services ............................................................................ 9
Baird Advisory Choice Program ................................................................. 9
SMA Services ............................................................................................. 11
Baird Affiliated Managers Program .......................................................... 11
DDK Recommended Managers Service ..................................................... 15
Baird SMA Network Program .................................................................. 18
Dual Contract Program .......................................................................... 20
Other SMA Strategy Information ............................................................. 21
UMA Programs ........................................................................................... 22
ALIGN UMA Select Portfolios Program ...................................................... 22
Unified Advisory Select Portfolios Program ............................................... 23
SMA Strategy Information ...................................................................... 27
Additional Service Information ..................................................................... 27
Investment Discretion ........................................................................... 27
Trading for Client Accounts .................................................................... 30
Complex Strategies and Complex Investment Products .............................. 36
Permitted Investments .......................................................................... 39
Unsupervised Assets ............................................................................. 41
Special Considerations for the Services .................................................... 41
Goal Management ................................................................................. 42
Tax Management and Values Overlay Services ......................................... 43
Investment Objectives ........................................................................... 46
Mutual Fund Share Class Policy ............................................................... 48
Custody Services .................................................................................. 49
Cash Sweep Program ............................................................................ 50
Trust Services Arrangements .................................................................. 51
Margin Loans ........................................................................................ 52
Securities-Based Lending Program .......................................................... 52
Other Non-Advisory Services .................................................................. 53
Client Responsibilities ............................................................................ 53
Retirement Accounts ............................................................................. 53
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Legal and Tax Considerations ................................................................. 54
Advisory Fees ............................................................................................ 54
Fee Options and Fee Schedule ................................................................ 54
Service Account Minimums ..................................................................... 57
Calculation and Payment of Advisory Fees ................................................ 58
Obtaining Services Separately: Brokerage or Advisory? Factors
to Consider ...................................................................................... 60
Advisory Fee Payments to Baird, DDK Consultants and
Investment Managers ........................................................................ 61
Other Fees and Expenses ............................................................................ 63
Cost and Expense Information for Certain Investment Products .................. 63
Additional Account Fees and Charges ...................................................... 63
Other Fees and Charges ........................................................................ 63
Compensation Received by DDK and Baird .................................................... 64
Account Requirements and Types of Clients .................................................. 65
Opening an Account .................................................................................... 65
Certain Account Requirements ..................................................................... 65
Minimum Account Size ........................................................................... 65
Account Contributions and Withdrawals ................................................... 66
Liens and Use of Account Assets as Collateral ........................................... 67
Electronic Delivery of Documents ............................................................ 67
Termination of Accounts .............................................................................. 68
Types of Clients.......................................................................................... 68
Portfolio Manager Selection and Evaluation .................................................. 68
Selection and Evaluation ............................................................................. 69
Baird Affiliated Managers Program .......................................................... 69
DDK Recommended Managers Service ..................................................... 69
Baird SMA Network and Dual Contract Programs ....................................... 70
ALIGN, BairdNext Portfolios, DDK Investment Management and
Russell Programs .............................................................................. 71
UMA Programs ...................................................................................... 71
Oversight of the Services ....................................................................... 73
Performance Calculation .............................................................................. 73
Portfolio Management by DDK, Baird and Associated Managers ........................ 74
Advisory Business ....................................................................................... 75
Performance-Based Fees and Side-By-Side Management ................................. 76
Methods of Analysis, Investment Strategies and Risk of Loss ........................... 76
Investment Strategies ........................................................................... 76
Methods of Analysis .............................................................................. 84
Program Portfolio Strategies ................................................................... 93
Principal Risks ..................................................................................... 112
Voting Client Securities .............................................................................. 131
Baird Advisory Choice Program and Other Non-Discretionary
Accounts ......................................................................................... 131
UMA Programs ..................................................................................... 131
Separately Managed Accounts ............................................................... 131
Discretionary Services .......................................................................... 131
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Other Proxy Voting Information ............................................................. 133
Providing Baird Voting Instructions......................................................... 133
Legal Proceedings and Corporate Actions ................................................ 133
Client Information Provided to Portfolio Managers ..................................... 133
Client Contact with Portfolio Managers ....................................................... 134
Additional Information ................................................................................ 134
Disciplinary Information ............................................................................. 134
Other Financial Industry Activities and Affiliations .......................................... 136
Baird’s Broker-Dealer Activities .............................................................. 136
Certain Relationships and Arrangements ................................................. 136
Relationships and Arrangements with Investment Managers ...................... 138
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading ................................................................................... 139
Code of Ethics ..................................................................................... 139
Participation or Interest in Client Transactions ......................................... 139
Review of Accounts .................................................................................... 146
Client Account Review .......................................................................... 146
Account Statements and Performance Reports ......................................... 146
Client Referrals and Other Compensation ..................................................... 147
Financial Information ................................................................................. 147
Special Considerations for Retirement Accounts ............................................ 148
Associated Investment Products and Services ............................. Appendix A-1
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
those other
contain
information about
that website
retirement
accounts, which
(“IRC”)
(collectively,
Services, Fees and Compensation
This Brochure describes some of the investment
advisory services that Robert W. Baird & Co.
Incorporated (“Baird”) offers to its clients through
the DDK Group (“DDK”), a team of Baird Financial
Advisors (“DDK Consultants”) within Baird’s
Private Wealth Management (“PWM”) department.
Baird and DDK offer other investment advisory
services not described in this Brochure. Separate
brochures describe
investment
advisory services and discuss the terms and
conditions, fees and costs and potential conflicts
of interest associated with those services. This
Brochure also references other documents that
contain additional important information about
Baird. Those documents describe the types of
investment products and services that Baird
makes available to clients, including the terms,
conditions, fees, costs, risks, and conflicts of
interest applicable to those investment products
and services. Those documents are available on
Baird’s website at bairdwealth.com/retailinvestor.
Included on
is Baird’s Client
Relationship Booklet, which contains Baird’s Form
CRS Client Relationship Summary and Baird’s
Client Relationship Details document. The Client
Relationship Booklet also contains an important
disclosure document for retirement investors that
have
include
employee pension benefit plan accounts that are
subject to the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”) and
individual retirement accounts (“IRAs”) that are
subject to the Internal Revenue Code of 1986, as
amended
“Retirement
Accounts”).
The Client-Baird Fiduciary Relationship
Baird
is registered with the Securities and
Exchange Commission (“SEC”) as an investment
adviser under the Investment Advisers Act of
1940, as amended (the “Advisers Act”). DDK and
Baird are deemed to have a fiduciary relationship
with a client when providing the investment
advisory services that are described in this
Brochure. That means that DDK and Baird are
required to act in the best interest of the client
when providing investment advisory services.
From time to time DDK and Baird may engage in
receive
certain business practices or may
compensation or other benefits that create a
potential for conflict between the interests of
clients and the interests of DDK and Baird. DDK
and Baird generally address potential conflicts of
interest by disclosing them to clients through
documents provided to clients, including, without
limitation, this Brochure, Brochure supplements
that
individuals
providing investment advice to clients and the
services they provide, and the agreements clients
enter into with DDK and Baird. In addition, Baird
has adopted internal policies and procedures for
DDK and Baird that require them to: provide
investment advice that is suitable for advisory
clients (based upon the information provided by
such clients); make full disclosure of all potential,
material conflicts of interest; act with utmost care
and good faith in dealings with advisory clients;
and seek to obtain “best execution” of advisory
client transactions. The specific business practices
that create potential conflicts of interest with
clients and additional measures used by DDK and
Baird to address them are discussed in other
sections of this Brochure.
A client should note that registration as an
investment adviser does not imply a certain level
of skill or training.
A client of Baird should have already received a
copy of the Client Relationship Booklet. A client or
prospective client who wishes to obtain a
brochure for another investment advisory service
provided by Baird, or a paper copy of any of the
other documents referenced in this Brochure,
including the Client Relationship Booklet, should
contact a DDK Consultant or call Baird toll-free at
1-800-792-2473.
The information contained in this Brochure is
current as of the date above and is subject to
change at Baird’s discretion. Please retain this
Brochure for your records.
Summary of DDK’s Services
investment
This Brochure describes certain
advisory programs and services that DDK and
Baird offer to clients (“Services”) and applies to
each advisory account advised by DDK
(“Account”). The investment advisory services
offered under the Services generally include
investment advice and consulting services, which
are provided by Baird PWM’s home office
investment professionals or DDK, and, depending
upon the Service that a client selects, the Service
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
may include portfolio management. The Services
consist of:
consulting
services
(“Consulting
• certain
Services”);
Portfolios. The Additional Consultant Services are
only provided to certain clients upon request by a
client and agreement to do so by DDK. DDK
primarily provides Consulting Services and
recommends the DDK Investment Management
Service and DDK Recommended Managers
Service to clients when appropriate. DDK will
infrequently recommend the other Services when
DDK believes it is appropriate for a particular
client.
• discretionary services, whereby a client gives
DDK or Baird (including Baird PWM’s home
office investment professionals or the client’s
DDK Consultant) full discretionary authority to
manage the client’s Account (“Discretionary
Services”);
provide
investment
advice
funds and exchange
traded
client’s
Account
• non-discretionary services, whereby DDK or
Baird
and
recommendations but the client retains full
authority with respect to the management of
the
(“Non-Discretionary
Services”);
Generally, DDK provides clients with analysis and
recommendations on investment managers and
strategies. Investment strategies typically may
include either public or private securities, private
institutional
placements,
limited partnerships,
mutual
funds
(“ETFs”). Often these investment managers or
strategies may be affiliated with external
custodians. DDK will assist clients in evaluating
custodians and negotiating custodial fees, trading
commissions, as well as, investment management
fees.
• separately managed account (“SMA”) programs
and services, whereby an investment manager
manages the client’s Account according to a
strategy (each, an “SMA Strategy”) with full
discretionary authority, and DDK and Baird
provide additional consulting services to the
client (collectively, “SMA Services”); and
firm,
Envestnet
• unified managed account (“UMA”) Programs,
whereby the client gives Baird and an overlay
Asset
management
Management, Inc. (the “Overlay Manager”),
selected by Baird authority to manage the
client’s Account according to a strategy (each, a
“UMA Strategy”) selected by the client (“UMA
Programs”).
the client has
Depending on their particular needs or objectives,
clients may use one or more of these Services.
The SMA Services are generally offered under a
“single contract” arrangement. Under a single
contract arrangement, a client enters into an
advisory agreement with DDK and Baird, and
Baird, in turn, enters into a subadvisory or similar
agreement with the investment manager on the
client’s behalf. This type of arrangement is
frequently referred to as a single contract
arrangement because there is only one contract
between the client and DDK and Baird; the client
does not have an agreement directly with the
client’s investment manager. Under the Dual
Contract Program, a client has a “dual contract”
arrangement, meaning
two
contracts; one contract with DDK and Baird and
another contract with the client’s investment
manager.
The UMA Programs allow a client to invest in a
combination of mutual funds, exchange traded
products (“ETPs”), primarily ETFs and exchange
traded notes (“ETNs”), SMA Strategies, and
groups of mutual funds and ETFs (referred to as
“sleeves”) and other model portfolios of securities
managed by Baird PWM (such sleeves and model
portfolios collectively, “PWM-Managed Portfolios”)
using a single Account.
The SMA Services and UMA Programs allow a
client to select among a variety of SMA Strategies
The Consulting Services
include: Financial
Planning; Risk Analysis; Asset Allocation and
Investment Strategy Development; Consolidated
Reporting; and Additional Consultant Services
described below. The Discretionary Services
include: ALIGN Strategic Portfolios; BairdNext
Portfolios; DDK Investment Management; and
Russell Model Strategies. The Non-Discretionary
Services include: Baird Advisory Choice. The SMA
Services
include: Baird Affiliated Managers
(“BAM”); DDK Recommended Managers; Baird
SMA Network (“BSN”); and Dual Contract (“DC”).
The UMA Programs include: ALIGN UMA Select
Portfolios and Unified Advisory Select (“UAS”)
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
offered by third party investment managers
(“Other Managers”), which may include Other
Managers affiliated with, related to, or otherwise
associated with Baird (“Associated Managers”), or
Baird to manage the client’s Account.
to execute
transactions without
referred
intend
Each Service is designed to address different
investment needs of clients. All of the Services
discussed in this Brochure may not be appropriate
for every client. For example, the Services may
not be appropriate for clients who have low or no
trading activity, who desire to pay transaction-
based fees, who maintain their accounts invested
in high levels of cash or other concentrated
positions, who do not want ongoing professional
investment advice or account monitoring, who
tend
the
recommendation or advice of an advisor, which
to as “unsolicited”
are commonly
transactions, or who
to utilize an
investment strategy, product or solution that is
not available in a Service.
and bonds
(collectively,
Manager,
and
investment products
Baird has engaged the Overlay Manager to
provide certain subadvisory services to clients
that participate in certain SMA Services and the
UMA Programs. The SMA Services and UMA
Programs make available two types of SMA
Strategies:
strategies,
(1) manager-traded
whereby the manager itself manages a client’s
Account and conducts the trading to implement
the SMA Strategy selected by the client (a
“Manager-Traded Strategy”); and (2) model-
traded strategies, whereby the manager does not
manage a client’s Account (a “Model Provider”)
but instead provides a model portfolio (“Model
Portfolio”) to an overlay management firm, which
may include the Overlay Manager, Baird or other
firm (each, an “Implementation
third party
Manager”), that in turn manages a client’s
Account and conducts the trading to implement
the SMA Strategy selected by the client (a
“Model-Traded Strategy”). If a client selects a
Model-Traded Strategy, the Model Provider will
provide the Model Portfolio and updates to the
Implementation
the
Implementation Manager will manage the client’s
Account with full discretionary authority according
to the strategy selected by the client. Otherwise,
if the client selects a Manager-Traded Strategy,
the investment manager will directly manage the
client’s Account with full discretionary authority as
more fully described below.
Some Services offer clients the ability to pursue
alternative investment strategies (“Alternative
Strategies”) or other non-traditional or complex
investment strategies that involve special risks
not apparent in more traditional investments like
stocks
“Complex
Strategies”). Similarly, some Programs offer
clients the ability to invest in non-traditional or
real assets (“Non-Traditional Assets”). Some
Programs also offer the ability to invest in
investment products
that pursue Alternative
Strategies (“Alternative Investment Products”) or
other Complex Strategies (collectively, “Complex
these
Investment Products”). The use of
strategies and
involves
special risks, and a client should not engage in a
strategy or purchase an investment product
unless the client understands the related risks.
See “Additional Service Information—Complex
Strategies and Complex Investment Products”
and “Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks” below for more
information.
Fee.
See
“Additional
allocation
strategies
have
Baird is also registered with the SEC as a broker-
dealer under Securities Exchange Act of 1934, as
amended (the “Exchange Act”). DDK and Baird
provide the Services described in this Brochure
under a “wrap fee” arrangement. This means that
in addition to the investment advisory services
that DDK and Baird provide in connection with
each Service, Baird, in its capacity as broker-
dealer, also provides clients with trade execution,
custody and other standard brokerage services for
a single fee (“Advisory Fee”). A client should note
that the client may incur costs in addition to the
Advisory
Service
Information—Trading for Client Accounts” and
“Other Fees and Expenses” below for more
information.
Certain Services make available asset allocation
investment strategies. Asset allocation strategies
involve investing in one or more categories of
assets, such as equity securities, fixed income
securities, Non-Traditional Assets, Alternative
Investment Products and cash, and one or more
subcategories of assets, called asset classes.
Asset
varying
investment objectives and investment strategies.
Some asset allocation strategies use strategic
investment strategies, which involve investing
accounts in accordance with a predetermined
target allocation to different asset classes. Some
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
include
a
client’s
age,
the
A client’s DDK Consultant will offer or recommend
appropriate Services, investment strategies, and
investment products and services based upon a
investment profile and an Account’s
client’s
investment objective, which establishes an
Account’s investment return objective and risk
investment profile will
tolerance. A client’s
generally
other
investments, financial situation and needs, tax
status, investment goals, investment experience,
investment time horizon, liquidity needs, risk
tolerance and other relevant information provided
by a client and updated from time to time.
Although a DDK Consultant may offer or
recommend appropriate options, a client will
ultimately select
investment objective,
Services, investment strategies, and investment
products and services for an Account.
asset allocation strategies use tactical investing,
which typically involves tactically and actively
adjusting account allocations to different asset
classes based upon the manager’s perception of
how those asset classes will perform in the short-
term. Some asset allocation strategies involve the
use of both strategic and tactical investment
strategies, sometimes referred to as dynamic
strategies. Asset allocation strategies may be
implemented using a variety of investment types,
such as individual securities, mutual funds and
ETPs, including ETFs and ETNs. The amount
allocated to an asset class or investment type
varies by strategy, and some strategies may have
little or no allocation to one or more asset classes
or types of investments described above. See
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of
Loss—Investment Strategies—Asset
Allocation Strategies” below for more information.
funds, ETFs, unit
A client that wishes to participate in a Service will
enter into a client relationship agreement or other
investment advisory agreement with DDK and
Baird
client’s
(“advisory agreement”). The
advisory agreement will contain the specific terms
applicable to the services selected by the client,
fees payable by the client, and other terms
applicable to the client’s advisory relationship with
DDK and Baird. A client should note that the
client’s advisory relationship with DDK and Baird
does not begin until they enter into the applicable
advisory agreement with the client, which occurs
when Baird PWM’s Home Office has accepted the
client’s advisory agreement and determined that
all of the client’s paperwork is in order. See
“Account Requirements and Types of Clients”
below for more information.
“Additional
The Services make available many different
investment products and services offered by third
parties that are not associated with Baird, such as
mutual
investment trusts
(“UITs”), collective investment trusts (“CITs”),
private equity funds, hedge funds, private funds
and other investment pools (collectively “Funds”).
However, certain
investment products and
services managed, advised or sponsored by Baird
or other parties affiliated with, related to, or
otherwise associated with Baird,
including
Associated Managers (“Associated Parties”), have
been selected for inclusion in certain Services or
are made available to clients through Service
Accounts (“Associated Investment Products and
Services”). Associated Investment Products and
Services generally consist Funds managed,
advised or sponsored by Baird or Associated
Parties (“Associated Funds”) and other investment
products managed, advised or sponsored by Baird
or Associated Parties (collectively, “Associated
Investment Products”), and SMA Strategies
managed or advised by Baird or Associated
Managers (“Associated SMA Strategies”). Baird
and DDK Consultants may use, select or
recommend Associated Investment Products and
Services. This may present a conflict of interest. A
client is free at any time to select investment
products and services that are not associated with
Baird. For specific information about Associated
Parties and Associated Investment Products and
Services, see
Information—Other
Financial Industry Activities and Affiliations”
below.
As mentioned above, Baird, in its capacity as
broker-dealer, also provides DDK clients with
trade execution, custody and other standard
brokerage services. For this reason, a client will
also enter into a client relationship agreement or
other account agreement with DDK and Baird
(“account agreement”) if the client has not
already done so. The client’s account agreement
authorizes DDK and Baird to execute trades for,
and perform related brokerage and custody
services to, the client’s Account. Baird generally
does not permit a client to include assets in the
client’s Account that are held by a third party
custodian or that are otherwise held outside of a
Baird account (“Held-Away Assets”), although
DDK will provide Consulting Services on Held-
Away Assets when requested by a client and
agreed to by DDK.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Service
has
different
the
funds (including private real estate funds and
private real estate fund of funds), commodity
strategies, hedge funds, funds of hedge funds,
private equity funds, funds of private equity
funds, private debt funds and managed futures.
and
ongoing
research,
Consolidated Reporting
Each
structures,
administration, types and levels of service, and
fees and expenses. In particular, a client should
investment advisory services
note that
provided by DDK and Baird, including the depth of
initial
evaluation,
monitoring and review of the investments in a
client’s Account, varies by Service and the
investments selected for the Account.
include
The foregoing discussion of the Services is only a
summary. More specific information about the
Services and the particular investment advisory
services that DDK and Baird provide in connection
with each Service are further described below and
in the client’s advisory agreement. Clients are
encouraged to review this Brochure and their
advisory agreement carefully.
Clients of DDK generally receive a performance
report and asset allocation report each quarter.
Generally, this report covers all accounts and
asset classes specified in the advisory agreement.
For the convenience of clients of DDK, reports
information, usually related to
may
client’s personal assets, that is provided by the
client and
is not covered by the advisory
agreement. If a third party reporting company is
used, Baird, DDK or the client may pay an
additional fee to the third party for this service.
DDK provides analysis of both performance and
asset allocation decision to the client on a
quarterly basis.
Consulting Services
Financial Planning
Additional Consultant Services
DDK offers the following additional consultant
services.
includes a
The Financial Planning Service
comprehensive development of a needs analysis
that is based upon an analysis of the client’s cash
flow. Generally, this service includes tax and
estate planning review and coordination with the
client’s external professional providers.
in preparing an
Risk Analysis
the client’s
in
When performing risk analysis services, DDK
seeks to analyze and review with a client the risks
financial planning process
identified
the
described above. DDK seeks
to minimize
investment risk through an asset allocation and
investment strategy.
the
Asset Allocation and Investment Strategy
Development
accurately
reflects
the
Investment Policy Statement. DDK will assist a
Investment Policy
client
Statement reflecting
investment
objectives, policies, constraints, and risk profile.
The Investment Policy Statement is designed to
provide guidance to the client’s
investment
manager(s). The Investment Policy Statement is
a product of information and data provided by the
client; therefore, the client is responsible for
review and final approval of the Investment Policy
Statement. The client is solely responsible for
Investment Policy
determining whether
Statement
client’s
investment objectives, policies, constraints, and
risk profile.
strategic
asset
allocation
for
determining whether
into account by DDK
Asset Allocation Report. DDK provides to a client
or its fiduciaries an Asset Allocation Report which
identifies one or more investment portfolios for
the client (in terms of risk and return) based on
certain
information requested by DDK and
provided by the client. The client is solely
the
responsible
information taken
in
formulating an Asset Allocation Report is accurate
and complete.
Using a variety of tools, including the financial
framework, DDK will develop and recommend a
long-term,
and
investment strategy appropriate for the client’s
risk and return objectives. Investment strategies
may involve the use of different equity styles or
strategies, such as: large cap growth, large cap
value, mid cap growth, mid cap value, small cap
growth, small cap value,
international and
emerging market equities strategies; different
fixed income styles or strategies, such as short or
intermediate, taxable and tax-exempt bond,
international and emerging market bond, and
high yield bond strategies; and Complex
Strategies, such as real estate and real estate
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Assets,
Alternative
investment
objectives,
strategic
investment strategies. Each ALIGN
Strategic Portfolio provides for specific levels of
investment across different asset classes, such as
equity securities, fixed income securities, Non-
Traditional
Investment
Products and cash. Each Portfolio generally uses
mutual funds and ETPs, primarily ETFs, in order to
implement the model asset allocation strategy.
The amount allocated to an asset class or type of
investment varies by Portfolio, and some
Portfolios may have little or no allocation to one
or more asset classes or types of investments
described above.
Investment Manager Search Report. DDK
provides to a client an Investment Manager
Search Report that lists investment managers
with investment philosophies and investment
strategies believed to be consistent with the
client’s
policies,
constraints, and risk profile, as specified by the
client to DDK. DDK does not assume responsibility
for the client’s choice of any investment manager
or for any investment manager’s performance
when providing this service to the client, nor is
DDK responsible for an unassociated investment
manager’s compliance with applicable law or for
matters beyond DDK’s reasonable control.
in
Investment Manager Search Interviews. DDK
coordinates client interviews with a select number
of investment managers listed on the Investment
Manager Search Report. The interviews enable
the client to gain additional information regarding
such investment managers’ respective investment
philosophies, policies and business operations.
Baird constructs each ALIGN Strategic Portfolio
and adjusts the asset allocation of each ALIGN
Strategic Portfolio from time to time. Baird also
determines the mutual funds and ETPs that are
available
the ALIGN Strategic Portfolios
Program, including the percentage each mutual
fund or ETP comprises in each asset class within
an ALIGN Strategic Portfolio. Baird may make
changes to an ALIGN Strategic Portfolio from time
to time as it deems appropriate and without
providing prior notice to, or obtaining the consent
of, a client.
compares
various
aspects
of
Past Performance Reviews. DDK provides to a
client a Past Performance Review which, based on
information supplied by the client, includes the
historical performance of the client’s portfolios
and
such
performance to one or more benchmark indices.
Account data will be derived from information
provided by the client or its agent(s) for the
agreed upon time period. DDK is not responsible
for verifying information supplied by the client or
its agent(s).
Portfolios
are
The ALIGN Strategic Portfolios include certain
element portfolios (“ALIGN Elements Portfolios”)
that are designed for certain specific client
investment preferences, such as clients preferring
passive investment management or tax efficiency,
and clients with smaller accounts. ALIGN
Elements Portfolios do not invest in as many
mutual funds or ETFs compared to other ALIGN
therefore
and
Strategic
comparatively less diversified.
provide
a
specific
information about
Performance Monitoring Reports. DDK will
periodically
client written
to
Performance Monitoring Reports which include
calculations of the performance of the client’s
time periods and
Account(s) over various
compare various aspects of such performance to
one or more benchmark indices.
Discretionary Services
ALIGN Strategic Portfolios Program
For more
the
investment options made available through the
Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those investment options,
if any, see “Portfolio Manager Selection and
Investment
Evaluation—Methods of Analysis,
Strategies and Risk of Loss—Program Portfolio
Strategies—ALIGN Strategic Portfolios Programs”
below.
strategic
asset
allocation
Some of the services provided under this Program
may be provided to a client by a DDK Consultant
assigned to the client’s Account. Typically, a client
selects the ALIGN Strategic Portfolio appropriate
Under the ALIGN Strategic Portfolios Program,
Baird manages a client’s Account with
full
discretionary authority according to a proprietary
strategy
model
developed by Baird (each such model an “ALIGN
Strategic Portfolio”) that is selected by the client.
The ALIGN Strategic Portfolios Program offers
that have
model asset allocation portfolios
different investment objectives and use different
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Robert W. Baird & Co. Incorporated
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
for the client’s Account with the assistance of the
client’s DDK Consultant.
from time to time as it deems appropriate and
without providing prior notice to, or obtaining the
consent of, a client.
in
certain
Service
The BairdNext Portfolios Program is designed for
clients with smaller accounts and as such does
not invest in as many mutual funds or ETFs
compared to other Programs. Clients that are able
to satisfy applicable account minimums for other
Programs are encouraged to discuss with their
DDK Consultant whether another Program may be
a more appropriate choice for them.
Baird may replace investments in a client’s
Account, rebalance a client’s Account assets to be
consistent with
the client’s chosen ALIGN
Strategic Portfolio strategy, change the client’s
asset allocation, or engage in tax management
circumstances. See
strategies
“Additional
Information—Special
Considerations for the Programs” and “Additional
Service Information—Tax Management” below for
more information.
specific
information about
Important
Information about Affiliated
Funds. Some of the mutual funds offered by
Baird Funds, which is affiliated with Baird, have
been selected by Baird for inclusion in certain
ALIGN Strategic Portfolios. This presents a conflict
of interest. For more information, see “Additional
Information—Other Financial Industry Activities
and Affiliations” below.
For more
the
investment options made available through the
Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those investment options,
if any, see “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Program Portfolio
Strategies—BairdNext Portfolios Program” below.
BairdNext Portfolios Program
Some of the services provided under this Program
may be provided to a client by a DDK Consultant
assigned to the client’s Account. Typically, a client
selects the BairdNext Portfolio appropriate for the
client’s Account with the assistance of the client’s
DDK Consultant.
that have
different
in
in
Service
Baird may replace investments in a client’s
Account, rebalance a client’s Account assets to be
consistent with the client’s chosen BairdNext
Portfolio strategy, change the client’s asset
tax management
allocation, or engage
circumstances. See
certain
strategies
“Additional
Information—Special
Considerations for the Programs” and “Additional
Service Information—Tax Management” below for
more information.
Under the BairdNext Portfolios Program, Baird
manages a client’s Account with full discretionary
authority according
to a proprietary model
strategic asset allocation strategy developed by
Baird (each such model, a “BairdNext Portfolio”)
that is selected by the client. The BairdNext
Portfolios Program offers model asset allocation
portfolios
investment
objectives and use different strategic investment
strategies. Each BairdNext Portfolio provides for
specific levels of investment across different asset
classes, such as equity securities, fixed income
securities, Non-Traditional Assets, Alternative
Investment Products and cash. Each Portfolio
generally uses mutual funds and ETPs, primarily
ETFs, in order to implement the model asset
allocation strategy. The amount allocated to an
asset class or type of investment varies by
Portfolio, and some Portfolios may have little or
no allocation to one or more asset classes or
types of investments described above.
Important
Information about Affiliated
Funds. Some of the mutual funds offered by
Baird Funds, which is affiliated with Baird, have
been selected by Baird for inclusion in certain
BairdNext Portfolios. This presents a conflict of
interest. For more information, see “Additional
Information—Other Financial Industry Activities
and Affiliations” below.
DDK Investment Management Service
Under the DDK Investment Management Service,
a client grants full discretionary authority and
Baird constructs each BairdNext Portfolio and
adjusts the asset allocation of each BairdNext
Portfolio from time to time. Baird also determines
the mutual funds and ETPs that are available in
the BairdNext Portfolios Program, including the
percentage each mutual fund or ETP comprises in
each asset class within a BairdNext Portfolio.
Baird may make changes to a BairdNext Portfolio
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Robert W. Baird & Co. Incorporated
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
management of the client’s Account to Baird and
the client’s DDK Consultant.
providing prior notice to, or obtaining the consent
of, a client.
involve
special,
reviews
the client’s
investing
in
Service
Consultant makes
a
Important Information about DDK Investment
Management Service Accounts. DDK Consultants
may invest client accounts in illiquid securities
and Complex Investment Products. These types of
sometimes
investments
significant, risks and are not appropriate for all
clients. A client should understand those risks
those products. See
before
“Additional
Information—Complex
Strategies and Complex Investment Products”
and “Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks” below for more
information.
In the DDK Investment Management Service, a
client’s DDK Consultant seeks to meet the client’s
particular investment needs by developing a
customized
investment strategy based upon
guidelines that are jointly established by the client
and
the
the client’s DDK Consultant. At
commencement of services, the client’s DDK
Consultant
investment
objectives and risk tolerance using the Consulting
Services described above. Based upon that review
and other information provided by the client, the
DDK
subsequent
recommendation to the client as to which
investment style the DDK Consultant believes is
best suited for the client. A client makes the final
decision as to which investment style is chosen
for the client’s Account. More specific information
as to how the client’s DDK Consultant will manage
the client’s Account is provided to the client in
connection with the opening of the Account.
Associated Investment Products are available to
clients under the DDK Investment Management
Service. This presents a conflict of interest. For
more information, see “Additional Information—
Other Financial Industry Activities and Affiliations”
below.
Russell Model Strategies Program
the heading
and
in various
portfolios
that
have
Service
A DDK Consultant typically recommends or
selects for client accounts investments in mutual
funds and ETFs that pursue the strategies
“Consulting
described under
Services—Asset Allocation
Investment
Strategy Development” above. However, from
time to time, a DDK Consultant may make direct
investments
types of securities,
including, but not limited to, equity securities,
fixed income securities, Non-Traditional Assets
and certain Alternative Investment Products. All
or a portion of the assets in a client’s Account
may be held in cash or cash equivalents, including
securities issued by money market mutual funds,
or may be deposited in interest-bearing bank
accounts. Additional information about the types
of investments a DDK Consultant may use for
client accounts is contained under the heading
“Additional
Information—Permitted
Investments” below. For more information about
the DDK Investment Management Service, see
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Program Portfolio Strategies—DDK
Investment Management Service” below.
Investment Company
(the
Under the Russell Model Strategies Program (the
“Russell Program”), Baird manages a client’s
Account with full discretionary authority according
to a model asset allocation strategy (a “Russell
Strategy”) developed by Russell Investment
Management, LLC (“Russell”) that is selected by a
client. The Russell Program offers model asset
allocation
different
investment objectives and use different strategic
and tactical investment strategies. Each Russell
Strategy provides for specific levels of investment
across different asset classes, such as equity
securities, fixed income securities, Non-Traditional
Assets, Alternative Investment Products and cash.
Each Strategy generally uses mutual funds and
ETFs in order to implement the model asset
allocation strategy. The amount allocated to an
asset class or type of investment varies by
Strategy, and some Strategies may have little or
no allocation to one or more asset classes or
types of investments described above. Each
Russell Strategy will typically invest exclusively or
significantly in mutual funds or ETFs offered by
Russell
“Russell
Funds”), although some non-Russell Funds may
be used.
Baird may remove any DDK Consultant or
strategy from the Service at any time and
transfer day-to-day management responsibility of
a client’s Account to another DDK Consultant or
Baird Financial Advisor at any time without
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Some of the services provided under this Program
may be provided to a client by a DDK Consultant
assigned to the client’s Account.
Russell constructs each Russell Strategy and
adjusts the asset allocation of each Strategy from
time to time. Russell also determines the mutual
funds and ETFs, including the Russell Funds, that
are available in each Russell Strategy, including
the percentage each mutual
fund and ETF
comprises in each Strategy. From time to time,
Russell may remove mutual funds and ETFs and
replace them with other mutual funds and ETFs.
Some DDK Consultants may recommend that a
client implement a model portfolio in the client’s
Advisory Choice Account. A client implementing a
model portfolio in the client’s Advisory Choice
Account may have the option to have Baird and
the client’s DDK Consultant rebalance the client’s
Advisory Choice Account to the target asset
allocations specified by the model portfolio at
predetermined intervals. Currently, Baird offers
the following rebalance options to applicable
Advisory Choice Accounts: annual, semi-annual
and quarterly.
the client’s
investments
Baird anticipates that it generally will implement a
Russell Strategy as proposed by Russell.
However, Baird has sole discretionary authority
over a client’s Account invested in a Russell
Strategy, and Baird may implement a Russell
Strategy differently than proposed by Russell or
may sell
if Baird
determines such action to be necessary and in the
client’s best interest.
specific
information about
including purchases and sales
the Account, without
For more
the
investment options made available through the
Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those investment options,
if any, see “Portfolio Manager Selection and
Investment
Evaluation—Methods of Analysis,
Strategies and Risk of Loss—Program Portfolio
Strategies—Russell Model Strategies Program”
below.
portfolio,
the model
DDK and Baird do not have discretionary
authority over the assets in a client’s Baird
Advisory Choice Account, and DDK and Baird
cannot purchase or sell any securities or other
investments in the client’s Baird Advisory Choice
Account,
to
rebalance
the client’s
authorization. Ultimately, the client makes the
final decision as to selection of investments for
the client’s Baird Advisory Choice Account.
Furthermore, if a client selects a model portfolio
for the client’s Baird Advisory Choice Account, a
client should understand that the client
is
ultimately responsible for: the selection of the
model
portfolio’s
implementation, and the selection of a rebalance
option, if any.
Some of the services provided under this Program
may be provided to a client by a DDK Consultant
assigned to the client’s Account. Typically, a client
selects the Russell Strategy appropriate for the
client’s Account with the assistance of the client’s
DDK Consultant.
in
regarding:
financial
in
Service
for
Baird may rebalance a client’s Account assets to
be consistent with the client’s chosen asset
allocation strategy, change the client’s asset
tax management
allocation, or engage
circumstances. See
strategies
certain
“Additional
Information—Special
Considerations for the Programs” and “Additional
Service Information—Tax Management” below for
more information.
Non-Discretionary Services
Baird Advisory Choice Program
The Baird Advisory Choice Program is a Non-
Discretionary Service whereby DDK and Baird
provide advice to a client in connection with the
client’s own management of the client’s Account.
A client should understand that DDK and Baird
only provide a client with certain consulting
services and,
for eligible Accounts, Account
rebalancing services under the Baird Advisory
Choice Program. The consulting services that may
be available in the Program from the client’s DDK
Consultant include research, analysis, advice and
recommendations
and
investment goals and needs; asset allocation
strategies, investment strategies and investment
restrictions; methods
implementing
investment strategies; trends and expectations
regarding securities and other
investments,
securities markets, and economic sectors and
industries; and the purchase, holding and sale of
securities and other investments. The specific
consulting services to be provided to a client will
be determined by mutual agreement between the
client and the client’s DDK Consultant. DDK and
Baird do not undertake to provide any other
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
consulting or investment advisory services under
this Program unless DDK and Baird agree to do so
in writing.
in various
bank
is contained under
Service
Portfolio
Baird or the client’s DDK Consultant will provide
investment recommendations
for the client’s
Account and may recommend the amount, type
and timing with respect to buying, holding,
exchanging, converting and selling securities and
other assets for the client’s Account. Baird or the
recommend
client’s DDK Consultant may
investments
types of securities,
including, but not limited to, equity securities,
fixed income securities, Non-Traditional Assets,
certain Alternative Investment Products and
mutual funds and ETPs that in turn invest in those
investments. All or a portion of the assets in a
client’s Account may be held in cash or cash
equivalents, including securities issued by money
market mutual funds, or may be deposited in
interest-bearing
accounts. Additional
information about the types of investments Baird
or a DDK Consultant may recommend for client
accounts
the heading
“Additional
Information—Permitted
Investments” below. For more information about
the Baird Advisory Choice Program, see “Portfolio
Manager Selection and Evaluation—Methods of
Analysis, Investment Strategies and Risk of
Loss—Program
Strategies—Baird
Advisory Choice Program” below.
about
the
investment
A client should ask the client’s DDK Consultant
questions
styles,
philosophies, strategies, analyses and techniques
the client’s DDK Consultant will use in order to
meet the client’s objectives.
Permitted Investments to be held in the Account,
anticipated use of other Baird products and
services, and the costs and benefits of the
Account. The costs of a Baird Advisory Choice
Account may be more or less than in an account
where the client is charged on a per-transaction
basis. A Baird Advisory Choice Account may not
be appropriate for a client who anticipates little or
no trading activity, a client who prefers to direct
the client’s own
investment strategies and
security selection independent of the advice of
DDK or Baird or a client who does not receive or
request investment advisory or other non-trading
services from DDK or Baird. A Baird Advisory
Choice Account is also not for day trading or other
extreme trading activity,
including excessive
options trading or trading in mutual funds based
on market timing. If a client’s Baird Advisory
Choice Account engages in “excessive trading
activity” (herein defined as activity that would be
considered “excessive” by industry professionals
in a non-discretionary, fee-based program, as
determined by Baird in its sole discretion), DDK or
Baird may, to the extent permitted by applicable
law, immediately, upon sending notice to the
client, restrict the activity occurring in the client’s
Account, terminate the Account, convert the
Account to a commission-based account, or
charge a higher fee at such rate as DDK or Baird,
in their sole discretion, may elect. A client is
responsible for monitoring the client’s Account
and determining the desirability of maintaining
the Account as opposed
to maintaining a
traditional, commission-based brokerage account.
In addition to Baird Advisory Choice Accounts and
brokerage
commission-based
traditional,
accounts, DDK offers various other advisory
programs in which it has investment discretion. A
client should periodically reevaluate whether the
ongoing use of this Non-Discretionary Advisory
Program is desired and request a DDK Consultant
to explain the benefits and disadvantages of
maintaining a Baird Advisory Choice Account and
the availability of alternative arrangements.
is
appropriate.
In making
Additional information regarding the differences
between brokerage and advisory relationships can
be found in the “Understanding Brokerage and
Investment Advisory Relationships” document
is available on Baird’s website at
that
bairdwealth.com/retailinvestor.
relevant
factors,
including
it
into a
A client may terminate a Baird Advisory Choice
traditional,
Account and convert
commission-based brokerage account at any time
Important Information about Baird Advisory
Choice Accounts. A Baird Advisory Choice
Account provides a fee-based alternative to a
traditional, commission-based brokerage account.
Unlike a traditional brokerage account where a
client is paying for traditional brokerage services,
an Advisory Choice client is also paying for
investment advice and other investment advisory
services above and beyond those available in a
traditional brokerage account. Each client should
determine whether a Baird Advisory Choice
Account
this
determination, a client should carefully consider
all
the client’s
investment objectives, risk tolerance, past and
anticipated trading practices, current assets,
current investments, the value and type of
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
upon on other SMA Strategies and SMA Managers
offered through other SMA Programs.
by contacting DDK. DDK and Baird also have the
right, at any time upon notice to a client, to
terminate a client’s Baird Advisory Choice Account
and convert it into commission-based brokerage
account.
and
For more specific information about eligibility
standards imposed upon the managers and SMA
Strategies made available through the BAM
Program, see “Portfolio Manager Selection and
Evaluation—Baird
Evaluation—Selection
Affiliated Managers Program” below.
trading.
A client should only participate in the BAM
Program if the client wishes to select Baird or a
manager affiliated with Baird to manage the
client’s Account and the client understands the
potential conflicts of interest presented by the
arrangement and the risks of doing so.
have
varying
Service
BAM Managers
investment
objectives, styles and strategies, and they may
invest a client’s Account in various types of
securities, which will be chosen by the BAM
Manager and which may include mutual funds,
ETFs or other investment products associated with
the manager or Baird.
A client should note that the client’s Baird
Advisory Choice Account may be engaged in
strategies that involve concentrated and less
diversified portfolios of securities, leverage or
margin, options, and
In
frequent
addition,
the client’s Baird Advisory Choice
Account may be invested in illiquid securities and
Complex Investment Products. These types of
strategies and
involve special,
investments
significant,
sometimes
risks and are not
appropriate
for all clients. A client should
understand those risks before engaging in those
strategies or investing in those products. See
“Additional
Information—Complex
Strategies and Complex Investment Products”
and “Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks” below for more
information.
The PWM-Managed Portfolios and BAM Strategies
that are offered through the BAM Program are
discussed below.
PWM-Managed Portfolios
Associated Investment Products are available to
clients under the Advisory Choice Program. This
presents a conflict of
interest. For more
information, see “Additional Information—Other
Financial Industry Activities and Affiliations”
below.
SMA Services
Baird Affiliated Managers Program
of
Analysis—Certain
Under the BAM Program, Baird makes available to
clients the following PWM-Managed Portfolios
managed by Baird PWM’s Research team: the
Baird Recommended Portfolio, the Baird Rising
Dividend Portfolio, and the AQA Portfolios, which
are described under
the heading “Portfolio
Manager Selection and Evaluation—Methods of
Analysis, Investment Strategies and Risk of
Loss—Methods
PWM-
Managed Portfolios” below.
BAM SMA Strategies
Baird Equity Asset Management
The BAM Program is a program whereby a client
independently selects Baird or an investment
manager affiliated with Baird to manage the
client’s Account with full discretionary authority
according to a strategy selected by the client. The
BAM Program is designed to accommodate a
client who wishes to select Baird or an investment
manager affiliated with Baird to manage the
assets in the client’s Account instead of an
unaffiliated manager made available in other SMA
Programs.
Management
Growth
(“BAM Strategies”)
eligible
Under the BAM Program, Baird determines the
investment managers (“BAM Managers”) and their
strategies
to
participate in the Program. The BAM Strategies
and BAM Managers are not subject to the same
evaluation process or eligibility standards imposed
Under the BAM Program, Baird makes available to
clients certain SMA Strategies offered by Baird
Equity Asset Management, an
investment
management department of Baird, including:
growth investment strategies (the “Baird Equity
Asset
Strategies”);
Specialized Asset Management (“SAM”) portfolio
strategies (the “SAM Strategies”), consisting of
SAM Strategic Portfolio strategies and SAM
certain
Custom
Portfolio
strategies;
and
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Robert W. Baird & Co. Incorporated
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird Trust
International Growth and Global Growth SMA
Strategies offered by Chautauqua Capital
Management (“CCM”), part of Baird Equity Asset
Management (the “CCM Portfolios”).
Baird Equity Asset Management also manages
client portfolios according to other strategies
selected by clients (“Other Baird Equity Asset
Management Strategies”, and with the Baird
Equity Asset Management Growth Strategies and
the SAM Strategies, the “Baird Equity Asset
Management Strategies”).
Under the BAM Program, Baird makes available to
clients five (5) portfolio strategies developed and
maintained by Baird Trust Company (“Baird
Trust”), a trust company that is affiliated with
Baird (the “Baird Trust Strategies”) described
under the heading “Portfolio Manager Selection
and Evaluation—Methods of Analysis, Investment
Strategies and Risk of Loss—Methods of
Analysis—Baird Trust Strategies” below. The Baird
Trust Strategies invest in a mix of equity
securities and ETFs.
portfolios
that
have
The SAM Strategic Strategies are model asset
allocation
different
investment objectives. Each SAM Strategy
provides for specific levels of investment across
different asset classes, such as equity securities,
fixed income securities, Non-Traditional Assets,
Alternative Investment Products and cash. Each
Strategy generally uses
individual securities,
mutual funds and ETFs in order to implement the
model asset allocation strategy. The amount
allocated to an asset class or type of investment
varies by Strategy, and some Strategies may
have little or no allocation to one or more asset
classes or types of investments described above.
In addition, Baird makes available to clients Baird
Trust Custom Portfolio Management℠, which
offers clients a customized approach to investing
and the ability to work directly with an in-house
Baird Trust Portfolio Manager. A client’s Baird
Trust Portfolio Manager and DDK Consultant will
work closely with a client to develop a diversified,
customized investment portfolio, managed to fit a
client’s specific needs. The Baird Trust Portfolio
Manager will determine the investments for a
client’s Account based on a comprehensive
assessment process that includes the client’s
financial
investment objective, time horizon,
situation, and special circumstances. Once the
assessment
is complete, a client’s portfolio
construction begins. Baird Trust Custom Portfolio
Management accounts typically invest in a mix of
equity securities, fixed income securities, mutual
funds and ETFs, depending upon the needs of a
particular client.
A SAM Custom Portfolio provides a client with a
customized level of investment across one or
more of the asset classes described above. The
custom model asset allocation strategy
is
determined by the client with the assistance of
Baird Equity Asset Management.
GAMMA
(“GAMMA”), an
receipts
for specific
deemed
appropriate,
The CCM Portfolios invest in equity securities of
companies located in different regions around the
world, primarily in developed markets but also in
emerging and less developed markets. Each
Portfolio generally uses common or ordinary
shares, depositary
representing an
ownership interest in ordinary shares, preferred
stocks, in order to implement the strategy. The
CCM Portfolios generally invest in a limited
number of securities, but seek to be diversified in
terms of currencies, regions and economic
sectors.
Under the BAM Program, Baird makes available to
clients certain SMA Strategies offered by GAMMA
Investing, LLC
investment
manager that is affiliated with Baird (the “GAMMA
Portfolios”). GAMMA offers Custom Indexing
strategies providing
levels of
investment across different asset classes, such as
equity securities, fixed income securities, and
cash. Each Portfolio generally uses stocks and
ETFs, in order to implement the target strategy.
When
GAMMA’s
management may also
involve the use of
Alternative Investment Products. The amount
allocated to an asset class or type of investment
varies by Portfolio, and some Portfolios may have
little or no allocation to one or more asset classes
or types of investments described above.
include mutual
Baird Equity Asset Management may invest a
client’s Baird Equity Asset Management Strategies
Account in various types of securities, which will
be chosen by Baird Equity Asset Management and
which may
funds or other
investment products associated with Baird.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
The Riverfront Portfolio strategies that Riverfront
offers under
the Baird Affiliated Managers
Program
include Riverfront Asset Allocation
Portfolios (also known as “Advantage Portfolios”);
Riverfront ETF Portfolios (also known as “ETF
Advantage Portfolios”); Riverfront Income ETF
Portfolios (also known as “Income ETF Advantage
Portfolios”); RiverShares Model Portfolios; and
Riverfront Custom Portfolios.
Strategas
to
The GAMMA Custom Indexing strategies that
GAMMA offers under the Baird Affiliated Managers
Program include managed portfolios of individual
securities that seek to deliver similar return and
risk characteristics as an index strategy (“target
strategy”) selected by the client. Custom Indexing
strategies can be benchmarked to any standard
or customized index, or combination of standard
or customized benchmarks. Custom Indexing
strategies typically invest directly in a subset of
the securities which make up the target strategy.
The
investment objective of each Custom
Indexing strategy is to provide exposure to a
client selected market segment or combination of
market segments into an overall asset allocation
while seeking
improve after-tax returns
through tax loss harvesting techniques.
include
thematic
strategies
Reinhart
(the
securities using
themes,
ideas or
that
Under the BAM Program, Baird makes available to
clients certain SMA Strategies offered by Reinhart
investment
(“Reinhart”), an
Partners, LLC
manager
is affiliated with Baird (the
that
“Reinhart Portfolios”). The Reinhart Portfolio
strategies include: (1) a Genisis Private Market
Value strategy that focuses investment on small-
and small/mid-cap value companies; (2) Mid Cap
Private Market Value strategy
focuses
investment on mid-cap value companies; and (3)
a Focused Private Market Value strategy that
concentrates investment in a limited number mid-
cap value companies.
investments that
Riverfront
invest
Under the BAM Program, Baird makes available to
clients certain SMA Strategies offered by
Strategas Asset Management, LLC (“Strategas”),
an investment manager that is affiliated with
Baird (the “Strategas Portfolios”). The Strategas
(the
Portfolios
“Strategas Thematic Portfolios”), asset allocation
strategies
“Strategas Asset Allocation
Portfolios”) and fixed income strategies (the
“Strategas Fixed
Income Portfolios”). The
Strategas Thematic Strategies invest principally in
certain proprietary
equity
investment
trends. The
Strategas Asset Allocation Portfolios primarily
invest in ETFs that focus investment in equity and
fixed income securities in a manner that aligns
with client goals and risk preferences over a
medium-term
time horizon. Each Portfolio
combines Strategas’s strategic asset allocation
outlook with tactical tilts towards those sectors
and
it believes are most
favorable for investment. The Strategas Fixed
Income Strategies are actively managed,
multisector, enhanced total return bond strategies
that seek to maximize return, while seeking to
minimize total return volatility. The Strategas
Fixed Income Strategies primarily
in
sector-focused ETFs.
that have
different
Additional Information about the BAM
Program
Clients are urged to review the BAM Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the BAM
Manager, including information about the BAM
Manager’s strategies, the types of investments
the BAM Manager may use for a client’s Account,
and the risks associated with investing in a BAM
Strategy. Such brochures are available upon
request.
Under the BAM Program, Baird makes available to
clients certain SMA Strategies offered by
Riverfront Investment Group, LLC (“Riverfront”),
an investment manager that is affiliated with
Baird (the “Riverfront Portfolios”). The Riverfront
Portfolio strategies are model asset allocation
portfolios
investment
objectives and use different strategic and tactical
investment strategies. Each Riverfront Portfolio
provides for specific levels of investment across
different asset classes, such as equity securities,
fixed income securities, Non-Traditional Assets,
Alternative Investment Products and cash. Each
Portfolio generally uses mutual funds and ETPs,
primarily ETFs and ETNs, in order to implement
the model asset allocation strategy. The amount
allocated to an asset class or type of investment
varies by Portfolio, and some Portfolios may have
little or no allocation to one or more asset classes
or types of investments described above.
Some of the services provided under the BAM
Program may be provided to a client by a DDK
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
discuss the Account’s performance with the
client’s DDK Consultant.
Consultant assigned to the client’s Account, and
the client’s DDK Consultant may provide his or
her own advice and recommendations about BAM
Managers.
If a client participates in the BAM Program, the
client authorizes and directs DDK and Baird to
appoint the BAM Manager selected by the client to
serve as sub-adviser to the client’s Account. The
client also authorizes and directs the BAM
Manager to manage client’s Account with full
discretionary authority in accordance with the
BAM Strategy selected by the client.
Information—Trading
Certain managers of Model-Traded Strategies
offered
through the Overlay Manager have
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a Baird client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by those Model Providers. See
“Additional Service
for
Client Accounts—Trading Practices of Investment
Managers” below for more information.
the
reviewing
the
Certain BAM Strategies are only made available
through the Overlay Manager. The BAM Strategies
offered through the Overlay Manager consist of
Manager-Traded Strategies and Model-Traded
Strategies. If a client selects a BAM Strategy
offered through the Overlay Manager for the
client’s Account, the client authorizes and directs
DDK and Baird to appoint the Overlay Manager to
serve as sub-adviser to the client’s Account. If a
client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to manage the client’s Account
with full discretionary authority in accordance
with the BAM Strategy selected by the client. If a
client selects a Manager-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to appoint the applicable BAM
Manager as sub-adviser, and the client also
authorizes and directs such BAM Manager to
manage the client’s Account with full discretionary
authority in accordance with the BAM Strategy
selected by the client.
If a client’s Account is managed by an Other
Manager under the BAM Program, the client
should understand that: Baird does not manage
the Account and does not otherwise have any
influence over the Other Manager’s investment
decisions or securities selections, and therefore,
Baird is not responsible for the decisions made by
the Other Manager; Baird does not provide any
recommendation or investment advice regarding
the purchase or sale of investment products made
for the client’s Account; and Baird and the client’s
DDK Consultant only provide the client with
certain consulting services, which may include the
assistance with
client’s DDK Consultant’s
determining
needs,
financial
client’s
investment goals and investment restrictions and
periodically
manager’s
performance. Baird does not undertake to provide
any other consulting or investment advisory
services under the BAM Program unless Baird
agrees to do so in writing.
is
If a client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the Overlay Manager will typically
implement the Model Portfolio as proposed by the
Model Provider. However, since the Overlay
Manager has discretionary authority over the
client’s Account, the Overlay Manager may
implement the Model Portfolio differently than
proposed by the Model Provider if the Overlay
Manager determines such action to be necessary
and in the client’s best interest. A client should
note that Baird does not monitor or ascertain
whether the Overlay Manager
fully and
faithfully implementing the Model Portfolio on a
continuous basis. The client should periodically
regarding
A client that participates in the BAM Program is
strongly encouraged to contact the client’s Baird
DDK Consultant or BAM Manager on a periodic
basis to discuss: the Account and its investment
performance; the BAM Manager’s investment
philosophy and style (to determine if the BAM
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
the BAM Manager,
information
described on the manager’s Form ADV, which is
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
available on the SEC's website at www.adviser
info.sec.gov.
Manager will only be removed from managing the
client’s Account upon the BAM Manager’s removal
from the Program by Baird, the BAM Manager’s
withdrawal or the client’s direction to do so.
DDK Recommended Managers Service
the
The DDK Recommended Managers Service is a
program whereby a client provides Baird and the
client’s DDK Consultant with discretionary
authority to appoint investment managers to
manage the client’s Account with full discretionary
authority and to terminate or replace investment
managers for the client’s Account. The DDK
Recommended Managers Service is designed for a
client who wishes to have the client’s Account
managed by
investment managers that are
monitored by DDK and Baird on an ongoing basis.
the
Program, Baird
cannot
appoint
Under the DDK Recommended Managers Service,
DDK and Baird determine
investment
managers (“DDK Recommended Managers”) and
their strategies (“DDK RM Strategies”) eligible to
participate in the Service through an initial and
ongoing evaluation process.
and
Evaluation—Baird
The BAM Strategies and BAM Managers made
available under the BAM Program are subject to
change or removal at any time in Baird’s sole
discretion. A client’s appointment and continued
retention of a BAM Manager to manage the
client’s Account are based upon the client’s review
of the BAM Manager and its services. In selecting
the BAM Strategy,
client ultimately
determines that the strategy to be used in
managing the client’s Account is consistent with
the client’s stated investment objectives and
financial needs and risk tolerance. Once retained
by the client, a BAM Manager will only be
removed from managing the client’s Account upon
the BAM Manager’s removal from the Program by
Baird, the BAM Manager’s withdrawal or the
client’s direction to do so. Under the terms of the
BAM
a
replacement manager without client consent.
Given the terms of the BAM Program, upon the
withdrawal or removal of an investment manager
from the BAM Program, a client’s BAM Program
Account will be automatically removed from the
BAM Program and the Account will become an
unmanaged brokerage account, unless the client
provides contrary
instructions to Baird. See
“Portfolio Manager Selection and Evaluation—
Affiliated
Selection
Managers Program” below for further information.
For more specific information about the managers
and SMA Strategies made available through the
DDK Recommended Managers Service and the
level of initial and ongoing research, evaluation,
monitoring and review performed by Baird on
those managers and SMA Strategies, see
“Portfolio Manager Selection and Evaluation—
Selection and Evaluation—DDK Recommended
Managers Service” below.
DDK Recommended Managers have varying
investment objectives, styles and strategies, and
they may invest a client’s Account in various
types of securities, which will be chosen by the
DDK Recommended Manager and which may
include mutual funds, ETFs or other investment
products associated with the manager or Baird.
are urged
review
Important
Information about Affiliated
Managers All of the BAM Strategies made
available under the BAM Program are offered by
Baird or a manager affiliated with Baird. PWM-
Managed Portfolios are Managed by Baird PWM.
Baird Equity Asset Management and CCM are part
of Baird. Baird Trust, GAMMA, Reinhart, Riverfront
and Strategas are affiliated with Baird. This
presents a conflict of
interest.. For more
information, see “Additional Information—Other
Financial Industry Activities and Affiliations”
below.
information
about
the DDK
to
Clients
Recommended Manager’s Form ADV Part 2A
contain additional
Brochure, which
should
important
DDK
the
Recommended Manager, including information
the DDK Recommended Manager’s
about
strategies, the types of investments the DDK
Recommended Manager may use for a client’s
Account, and the risks associated with investing in
a DDK RM Strategy. Such brochures are available
upon request.
A client’s appointment and continued retention of
a BAM Manager to manage the client’s Account
are based upon the client’s review of the BAM
Manager and its services. In selecting the BAM
Strategy, the client ultimately determines that the
strategy to be used in managing the client’s
Account is consistent with the client’s stated
investment objectives and financial needs and risk
tolerance. Once retained by the client, a BAM
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
implement
the
client’s Account,
initially selects
RM
Strategy with
faithfully
Some of the services provided under the DDK
Recommended Managers Service will be provided
to a client by a DDK Consultant assigned to the
client’s Account. A client, typically working with a
DDK Consultant,
the DDK
Recommended Manager and DDK RM Strategy for
the client’s Account. Thereafter, whenever Baird
or
it
the client’s DDK Consultant deems
necessary, Baird or the client’s DDK Consultant
will replace a DDK Recommended Manager or
DDK
another DDK
Recommended Manager or DDK RM Strategy for
the client’s Account.
typically
the Model Portfolio as
proposed by the Model Provider. However, since
the Implementation Manager has discretionary
the
authority over
Implementation Manager may implement the
Model Portfolio differently than proposed by the
Model Provider if the Implementation Manager
determines such action to be necessary and in the
client’s best interest. A client should note that
DDK and Baird do not monitor or ascertain
whether a third party Implementation Manager is
fully and
implementing the Model
Portfolio on a continuous basis. The client should
periodically discuss the Account’s performance
with the client’s DDK Consultant.
full discretionary authority
If a client participates in the DDK Recommended
Managers Service, the client authorizes and
directs DDK and Baird
to appoint DDK
Recommended Managers to serve as sub-adviser
to the client’s Account and to otherwise manage
the client’s Account in accordance with the terms
of the DDK Recommended Managers Service. The
client also authorizes and directs the DDK
Recommended Managers to manage the client’s
Account with
in
accordance with the DDK RM Strategy selected.
RM
Strategies
offered
below
Certain managers of Model-Traded Strategies
through the Overlay Manager have
offered
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a DDK client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of other
client accounts managed by
those Model
Providers. See “Additional Service Information—
Trading for Client Accounts—Trading Practices of
Investment Managers”
for more
information.
the client should understand
the discretionary
full discretionary authority
recommendation or
full discretionary authority
If a client’s Account is managed by an Other
Manager under the DDK Recommended Managers
that,
Service,
notwithstanding
authority
granted to Baird and the client’s DDK Consultant
under the Service: Baird and the client’s DDK
Consultant do not manage the Account and do not
otherwise have any influence over the Other
Manager’s
investment decisions or securities
selections, and therefore, Baird and the client’s
DDK Consultant are not responsible for the
decisions made by the Other Manager; and Baird
and the client’s DDK Consultant do not provide
any
investment advice
regarding the purchase or sale of investment
products made for the client’s Account.
Certain DDK RM Strategies are only made
available through Implementation Managers. The
DDK
through
Implementation Managers consist of Manager-
Traded Strategies and Model-Traded Strategies. If
a DDK RM Strategy offered
through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs DDK
and Baird to appoint the Implementation Manager
to serve as sub-adviser to the client’s Account. If
a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to manage the client’s
Account with
in
accordance with the selected DDK RM Strategy. If
a Manager-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, the client authorizes and directs the
Implementation Manager to appoint the applicable
DDK Recommended Manager as sub-adviser, and
the client also authorizes and directs such DDK
Recommended Manager to manage the client’s
Account with
in
accordance with the selected DDK RM Strategy.
from
the
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Implementation Manager will
Account,
the
From time to time, DDK or Baird may remove
investment managers
DDK
Recommended Managers Service, and DDK or
Baird may select a replacement manager to
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the direction of
to clients that select ALIGN 55ip Tax Managed
Solutions.
the prior manager and
manage the client’s Account. In such event, DDK
or Baird, at
the client’s
replacement manager, or the client’s replacement
manager may sell all or a portion of the securities
or other investments in the Account that were
managed by
the
replacement manager will reinvest the cash
proceeds of those sales. Sales of securities or
other investments could result in adverse tax
consequences for the client.
strategy
together with
its
in
If a client selects an ALIGN 55ip Tax Managed
Solution for the client’s Account, the client
authorizes and directs Baird to appoint 55ip to
serve as sub-adviser to the client’s Account. The
client also authorizes and directs 55ip to manage
the client’s Account with
full discretionary
authority: (1) to transition the Account holdings
to reflect the target portfolio holdings of the
Target ALIGN Strategy selected by the client
using its tax management strategies; and (2) in
accordance with the selected ALIGN Strategic
Portfolio
tax
management strategies on an ongoing basis, as
applicable.
If DDK or Baird terminates an
investment
manager from the DDK Recommended Managers
Service, a client authorizes DDK and Baird to
invest, with full discretionary authority, the assets
in the client’s Account previously managed by the
terminated
other
investment manager
securities, including, but not limited to, mutual
funds and ETPs. DDK’s and Baird’s discretionary
authority to make such other investments will
continue until a replacement investment manager
is selected or alternative arrangements are made
for the management of the client’s assets.
Additional information about the ALIGN Strategic
Portfolio strategies is contained under the heading
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Program Portfolio Strategies—ALIGN
Strategic Portfolios Program” below.
investment strategies, there
is no
Like all
guarantee that 55ip’s implementation of tax
management strategies will be successful, and
when such strategies are used, a client’s Account
may not be successful in pursuing its primary
investment strategies, objectives or goals.
A client who prefers to continue using an
investment manager that has been removed from
the DDK Recommended Managers Service, or who
directs or otherwise requests that a particular
investment manager not recommended by DDK
be selected to manage the client’s Account, will
need to move to another Service, such as the
BSN Program. See “Baird SMA Network Program”
below for more information. Clients who elect to
do so will no longer receive the same level of
rigorous ongoing monitoring, evaluation, or
review of that investment manager from DDK or
Baird.
ALIGN 55ip Tax Managed Solutions
Clients are urged to review 55ip’s Form ADV Part
2A Brochure, which should contain additional
important
including
information about 55ip,
information about 55ip’s strategies, the types of
investments 55ip may use for a client’s Account,
and the risks associated with 55ip’s strategies.
Such brochure is available upon request.
A client should note that the time it takes to
transition an Account to a Target ALIGN Strategy
could be significant and involve a period of five
(5) years or more. The actual time can vary
greatly by Account and will depend on a number
of factors, including, but not limited to, the
differences between the holdings of the Account
and the Target ALIGN Portfolio, the tax basis of
the Account holdings, and additions to and
withdrawals from the Account.
The DDK Recommended Managers Service makes
available ALIGN 55ip Tax Managed Solutions that
are designed for a client that: (1) desires to have
the strategy for the client’s Account transitioned
to an ALIGN Strategic Portfolio strategy selected
by the client (the “Target ALIGN Strategy”) using
tax management strategies that are intended to
reduce the negative impact of U.S. federal income
taxes on an Account resulting from the transition;
(2) seeks investment in an ALIGN Strategic
Portfolio strategy together with enhanced tax
management strategies on an ongoing basis; or
(3) a combination of both services. Baird has
engaged 55I, LLC (d/b/a 55ip, “55ip”) to provide
tax management services on a subadvisory basis
Important
Information about Affiliated
Managers. The DDK Recommended Managers
Service makes available to clients investment
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the
client
client’s particular needs, and
understands the risks of doing so.
have
varying
services
services that are offered by Baird Advisors and
Baird Equity Asset Management,
investment
management departments of Baird. This presents
a conflict of interest. For more information, see
“Additional Information—Other Financial Industry
Activities and Affiliations” below. Baird receives a
portion of the Portfolio Fee paid by clients
pursuing ALIGN 55ip Tax Managed Solutions for
that Baird
portfolio management
provides in connection with those Solutions. Such
compensation provides Baird a financial incentive
to recommend those Solutions.
investment
BSN Managers
objectives, styles and strategies, and they may
invest a client’s Account in various types of
securities, which will be chosen by the BSN
Manager and which may include mutual funds,
ETFs or other investment products associated with
the manager or Baird. Certain managers offer
strategies that exclusively invest in Funds (“Fund
Strategist Portfolios”).
Baird SMA Network Program
a
is designed
client who wishes
Clients are urged to review the BSN Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the BSN
Manager, including information about the BSN
Manager’s strategies, the types of investments
the BSN Manager may use for a client’s Account,
and the risks associated with investing in a BSN
Strategy. Such brochures are available upon
request.
The BSN Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
to
client. The BSN Program
accommodate
to
independently select an investment manager not
available in the DDK Recommended Managers
Program to manage the assets in the client’s
Account.
(“BSN
Strategies”)
eligible
Some of the services provided under the BSN
Program may be provided to a client by a DDK
Consultant assigned to the client’s Account, and
the client’s DDK Consultant may provide his or
her own advice and recommendations about BSN
Managers.
Under the BSN Program, Baird determines the
investment managers (“BSN Managers”) and their
strategies
to
participate in the Program through a significantly
less rigorous evaluation process compared to the
DDK Recommended Managers Service. However,
a client should note that DDK and Baird do not
make any recommendation to clients regarding
any BSN Strategy or any
representations
regarding a BSN Manager’s qualifications as an
investment adviser or abilities to manage client
assets.
If a client participates in the BSN Program, the
client authorizes and directs DDK and Baird to
appoint the BSN Manager selected by the client to
serve as sub-adviser to the client’s Account. The
client also authorizes and directs the BSN
Manager to manage client’s Account with full
discretionary authority in accordance with the
BSN Strategy selected by the client.
if any, see
and
Evaluation—Selection
For more specific information about the managers
and SMA Strategies made available through the
BSN Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those managers and SMA
“Portfolio Manager
Strategies,
Selection
and
Evaluation—Baird SMA Network and Dual Contract
Programs” below.
A client should only participate in the BSN
Program if the client wishes to take more
responsibility for monitoring the client’s Account,
the DDK Recommended Managers Program does
not contain an SMA Strategy that meets the
Certain BSN Strategies are only made available
through the Overlay Manager. The BSN Strategies
offered through the Overlay Manager consist of
Manager-Traded Strategies and Model-Traded
Strategies. If a client selects a BSN Strategy
offered through the Overlay Manager for the
client’s Account, the client authorizes and directs
DDK and Baird to appoint the Overlay Manager to
serve as sub-adviser to the client’s Account. If a
client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to manage the client’s Account
with full discretionary authority in accordance
with the BSN Strategy selected by the client. If a
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
reviewing
the
client selects a Manager-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the client authorizes and directs the
Overlay Manager to appoint the applicable BSN
Manager as sub-adviser, and the client also
authorizes and directs such BSN Manager to
manage the client’s Account with full discretionary
authority in accordance with the BSN Strategy
selected by the client.
of investment products made for the client’s
Account; and DDK and Baird only provide the
client with certain consulting services, which may
include the client’s DDK Consultant’s assistance
with determining the client’s financial needs,
investment goals and investment restrictions and
periodically
manager’s
performance. DDK and Baird do not undertake to
investment
provide any other consulting or
advisory services under the BSN Program unless
DDK and Baird agree to do so in writing.
the Account and
its
regarding
If a client selects a Model-Traded Strategy offered
through the Overlay Manager for the client’s
Account, the Overlay Manager will typically
implement the Model Portfolio as proposed by the
Model Provider. However, since the Overlay
Manager has discretionary authority over the
client’s Account, the Overlay Manager may
implement the Model Portfolio differently than
proposed by the Model Provider if the Overlay
Manager determines such action to be necessary
and in the client’s best interest. A client should
note that DDK and Baird do not monitor or
ascertain whether the Overlay Manager is fully
and faithfully implementing the Model Portfolio on
a continuous basis. The client should periodically
discuss the Account’s performance with the
client’s DDK Consultant.
A client that participates in the BSN Program is
strongly encouraged to contact the client’s DDK
Consultant or BSN Manager on a periodic basis to
discuss:
investment
performance; the BSN Manager’s investment
philosophy and style (to determine if the BSN
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information
the BSN Manager,
described on the manager’s Form ADV, which is
available on the SEC's website at www.adviser
info.sec.gov.
Information—Trading
Certain managers of Model-Traded Strategies
offered
through the Overlay Manager have
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a DDK client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by those Model Providers. See
“Additional Service
for
Client Accounts—Trading Practices of Investment
Managers” below for more information.
for
The BSN Strategies and BSN Managers made
available under the BSN Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the BSN Program,
DDK and Baird cannot appoint a replacement
manager or otherwise manage a client’s Account
assets. Given the terms of the BSN Program,
upon the withdrawal or removal of an investment
manager from the BSN Program, a client’s BSN
Program Account will be automatically removed
from the BSN Program and the Account will
become an unmanaged brokerage account, unless
the client provides contrary instructions to DDK.
See “Portfolio Manager Selection and Evaluation—
Selection and Evaluation—Baird SMA Network and
Dual Contract Programs” below
further
information.
influence over
If a client’s Account is managed by an Other
Manager under the BSN Program, the client
should understand that: DDK and Baird do not
manage the Account and do not otherwise have
any
the Other Manager’s
investment decisions or securities selections, and
therefore, DDK and Baird are not responsible for
the decisions made by the Other Manager; DDK
and Baird do not provide any recommendation or
investment advice regarding the purchase or sale
Important Information about
the BSN
Program. Portfolios managed by 55I, LLC (d/b/a
55ip, “55ip”) are made available under the BSN
Program. 55ip uses research and other services
from Riverfront, an affiliate of Baird, in the
development of certain of those portfolios, and
Riverfront receives compensation from 55ip with
respect to those portfolios. This presents a conflict
of interest. For more information, see “Additional
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Information—Other Financial Industry Activities
and Affiliations” below.
a DC Manager’s qualifications as an investment
adviser or abilities to manage client assets.
if any, see
and
Evaluation—Selection
appointment
For more specific information about the managers
and SMA Strategies made available through the
DC Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those managers and SMA
“Portfolio Manager
Strategies,
Selection
and
Evaluation—Baird SMA Network and Dual Contract
Programs” below.
in managing
the client’s Account
A client should only participate in the DC Program
if the client wishes to take more responsibility for
monitoring
the DDK
the client’s Account,
Recommended Managers Program does not
contain an SMA Strategy that meets the client’s
particular needs, and the client understands the
risks of doing so.
the
foregoing when deciding
DC Managers have varying investment objectives,
styles and strategies, and they may invest a
client’s Account in various types of securities,
which will be chosen by the DC Manager and
which may include mutual funds, ETFs or other
investment products associated with the manager
or Baird.
The BSN Program is designed to accommodate a
client who wishes to independently select an
investment manager that is not available in the
DDK Recommended Managers Service to manage
the client’s Account. The client assumes ultimate
responsibility for monitoring the client’s BSN
the BSN Manager’s
Program Account and
performance. A
and
client’s
continued retention of a BSN Manager to manage
the client’s Account are based ultimately upon the
client’s independent review of the BSN Manager
and the BSN Manager’s services. The client
ultimately determines that the BSN Strategy to be
used
is
consistent with the client’s stated investment
objectives and financial needs and risk tolerance.
Once retained by the client, a BSN Manager will
only be removed from managing the client’s BSN
Program Account upon the manager’s withdrawal,
removal from the BSN Program, or the client’s
direction to do so. A client should carefully
consider
to
participate in the BSN Program and also consider
whether another Service, such as the DDK
Recommended Managers Service, may be more
appropriate for the client.
Dual Contract Program
a
is designed
client who wishes
Clients are urged to review the DC Manager’s
Form ADV Part 2A Brochure, which should contain
additional important information about the DC
Manager, including information about the DC
Manager’s strategies, the types of investments
the DC Manager may use for a client’s Account,
and the risks associated with investing in a DC
Strategy. Such brochures are available upon
request.
The DC Program is a program whereby a client
independently selects an investment manager to
manage the client’s Account with full discretionary
authority according to a strategy selected by the
to
client. The DC Program
accommodate
to
independently select an investment manager not
available in the DDK Recommended Managers
Service or BSN Program to manage the assets in
the client’s Account. The Program is also designed
for a client that wants to independently select a
manager and negotiate the manager’s Portfolio
Fee rate directly with the manager.
Some of the services provided under the DC
Program may be provided to a client by a DDK
Consultant assigned to the client’s Account, and
the client’s DDK Consultant may provide his or
her own advice and recommendations about DC
Managers.
Under the DC Program, Baird determines the
investment managers (“DC Managers”) and their
strategies (“DC Strategies”) eligible to participate
in the Program through a significantly less
rigorous evaluation process compared to the DDK
Recommended Managers Service. However, a
client should note that DDK and Baird do not
make any recommendation to clients regarding
any DC Strategy or any representations regarding
Under the DC Program, DC Managers are offered
to clients through a dual contract arrangement,
and a client will need to enter into a separate
agreement with the DC Manager in addition to the
advisory agreement the client enters into with
DDK and Baird. A client participating in the DC
Program is solely responsible for negotiating the
client’s agreement with the client’s DC Manager,
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DDK Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and neither DDK nor Baird will participate or
advise a client regarding the terms of such an
agreement, the advisability of entering into such
an agreement, or the retention of the client’s DC
Manager unless DDK and Baird agree to do so in
writing.
become an unmanaged brokerage account, unless
the client provides contrary instructions to DDK.
See “Portfolio Manager Selection and Evaluation—
Selection and Evaluation—Baird SMA Network and
Dual Contract Programs” below
for more
information.
Information about
the DC
Important
Program. Other
investment management
departments of Baird and Associated Managers
are available to clients under the DC Program.
This presents a conflict of interest. For more
information, see “Additional Information—Other
Financial Industry Activities and Affiliations”
below.
appointment
reviewing
the
If a client’s Account is managed by an Other
Manager under the DC Program, the client should
understand that: DDK and Baird do not manage
the Account and do not otherwise have any
influence over the Other Manager’s investment
decisions or securities selections, and therefore,
DDK and Baird are not responsible for the
decisions made by the Other Manager; DDK and
Baird do not provide any recommendation or
investment advice regarding the purchase or sale
of investment products made for the client’s
Account; and DDK and Baird only provide the
client with certain consulting services, which may
include the client’s DDK Consultant’s assistance
with determining the client’s financial needs,
investment goals and investment restrictions and
periodically
manager’s
performance. DDK and Baird do not undertake to
provide any other consulting or
investment
advisory services under the DC Program unless
DDK and Baird agree to do so in writing.
in managing
the client’s Account
the Account and
its
the DC Manager’s
the
foregoing when deciding
The DC Program is designed to accommodate a
client who wishes to independently select an
investment manager. The client assumes ultimate
for monitoring the client’s DC
responsibility
the DC Manager’s
Program Account and
and
client’s
performance. A
continued retention of a DC Manager to manage
the client’s Account are based ultimately upon the
client’s independent review of the DC Manager
and the DC Manager’s services. The client
ultimately determines that the DC Strategy to be
used
is
consistent with the client’s stated investment
objectives and financial needs and risk tolerance.
Once retained by the client, a DC Manager will
only be removed from managing the client’s DC
Program Account upon the manager’s withdrawal,
removal from the DC Program, or the client’s
direction to do so. A client should carefully
to
consider
participate in the DC Program and also consider
whether another Service, such as the DDK
Recommended Managers Service, may be more
appropriate for the client.
Other SMA Strategy Information
A client that participates in the DC Program is
strongly encouraged to contact the client’s DDK
Consultant or DC Manager on a periodic basis to
investment
discuss:
performance;
investment
philosophy and style (to determine if the DC
Strategy remains appropriate for the client); any
potential conflicts of interest; and any investment
restrictions the client may wish to impose or
change. A client should also periodically check the
registration status, disciplinary events and other
information regarding the DC Manager, described
on the manager’s Form ADV, which is available on
the SEC's website at www.adviserinfo.sec.gov.
Certain SMA Strategies are available through
multiple Services. The overall cost of an SMA
Strategy and the types and levels of service
provided to a client in connection with an SMA
Strategy will vary depending upon the particular
Service selected by the client. Certain managers
offer lower Portfolio Fee rates to clients through
the DC Program compared to the BAM, DDK
Recommended Managers or BSN Programs. A
client considering an SMA Strategy should discuss
with client’s DDK Consultant SMA Strategy
availability and the different Portfolio Fee rates,
The DC Strategies and DC Managers made
available under the DC Program are subject to
change or removal at any time in Baird’s sole
discretion. Under the terms of the DC Program,
DDK and Baird cannot appoint a replacement
manager or otherwise manage a client’s Account
assets. Given the terms of the DC Program, upon
the withdrawal or removal of an investment
manager from the DC Program, a client’s DC
Program Account will be automatically removed
from the DC Program and the Account will
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
make changes to an ALIGN UMA Select Portfolio
from time to time as it deems appropriate and
without providing prior notice to, or obtaining the
consent of, a client.
costs, and the types and levels of service
provided in connection with the different Services.
A client is solely responsible for selecting the SMA
Strategy and the Service in which the client’s
Account will participate.
invested
in concentrated and
through an
(“BRM Strategies”)
information about
A client should note that certain SMA Strategies
less
may be
diversified portfolios of securities and may involve
the use of leverage, margin, and options. A client
should discuss with the client’s DDK Consultant
the specific strategies and investments used by a
the
manager. Additional
strategies and investments used by a manager
are available in a manager’s Form ADV Part 2A
Brochure.
The ALIGN UMA Select Portfolios Program makes
available: (1) certain mutual funds and ETPs that
for the UMA
Baird determines are eligible
Programs
initial and ongoing
evaluation process (“UMA Recommended Funds”),
which may include Associated Funds; (2) certain
strategies
that Baird
determines are eligible for the UMA Programs
through an initial and ongoing evaluation process
(“UMA Recommended SMA Strategies”), which
may include Associated SMA Strategies; and (3)
PWM-Managed Portfolios.
specific
information about
UMA Programs
ALIGN UMA Select Portfolios Program
and
For more
the
investment options made available through the
Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those investment options,
if any, see “Portfolio Manager Selection and
Evaluation—Selection
Evaluation—UMA
Programs” and “Portfolio Manager Selection and
Investment
Evaluation—Methods of Analysis,
Strategies and Risk of Loss—Program Portfolio
Strategies—UMA Programs” below.
Investment managers participating in the ALIGN
UMA Select Portfolios Program have varying
investment objectives, styles and strategies, and
they may invest a client’s Account in various
types of securities, which will be chosen by the
investment manager and which may include
mutual funds, ETFs or other investment products
associated with the manager or Baird.
Under the ALIGN UMA Select Portfolios Program,
Baird and the Overlay Manager manage a client’s
Account with full discretionary authority according
to a proprietary model asset allocation strategy
developed by Baird (each such model, an “ALIGN
UMA Select Portfolio”) that is selected by the
client. The ALIGN UMA Select Portfolios Program
offers model asset allocation portfolios that have
different investment objectives and use different
investment strategies. Each ALIGN UMA Select
Portfolio provides for specific levels of investment
across different asset classes, such as equity
securities, fixed income securities, Non-Traditional
Assets, Alternative Investment Products and cash.
Each Portfolio generally uses mutual funds, ETPs,
primarily ETFs, and SMA Strategies in order to
implement the model asset allocation strategy.
The amount allocated to an asset class or type of
investment varies by Portfolio, and some
Portfolios may have little or no allocation to one
or more asset classes or types of investments
described above.
the
investment manager,
the
Portfolios
Program,
including
Clients are urged to review the investment
manager’s Form ADV Part 2A Brochure, which
should contain additional important information
about
including
investment manager’s
information about the
the
investments
types of
strategies,
investment manager may use for a client’s
Account, and the risks associated with investing in
the investment manager’s SMA Strategies. Such
brochures are available upon request.
in
Some of the services provided under this Program
may be provided to a client by a DDK Consultant
assigned to the client’s Account. Typically, a client
the ALIGN UMA Select Portfolio
selects
Baird constructs each ALIGN UMA Select Portfolio
and adjusts the asset allocation of each ALIGN
UMA Select Portfolio from time to time. Baird also
determines the mutual funds, ETPs, or SMA
Strategies that are available in the ALIGN UMA
Select
the
percentage each investment comprises in each
asset class within an ALIGN UMA Select Portfolio.
Baird may remove mutual funds, ETPs, or SMA
Strategies used
the ALIGN UMA Select
Portfolios Program from time to time and replace
them with other investment options. Baird may
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
appropriate for the client’s Account with the
assistance of the client’s DDK Consultant.
Information—Trading
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a DDK client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by those Model Providers. See
“Additional Service
for
Client Accounts—Trading Practices of Investment
Managers” below for more information.
If a portion of client’s ALIGN UMA Select Portfolios
Account is managed by an Other Manager, the
client should understand that: DDK and Baird do
not manage such portion of the Account and do
not otherwise have any influence over the Other
Manager’s
investment decisions or securities
selections, and therefore, DDK and Baird are not
responsible for the decisions made by the Other
Manager; and DDK and Baird do not provide any
recommendation or investment advice regarding
the purchase or sale of investment products made
for such portion of the client’s Account.
Baird has engaged the Overlay Manager to
provide certain subadvisory services in connection
with the ALIGN UMA Select Portfolios Program.
The ALIGN UMA Select Portfolios Program makes
both Manager-Traded Strategies and Model-
Traded Strategies available to clients. If a client
selects an ALIGN UMA Select Portfolio, the client
authorizes and directs Baird to manage the
client’s Account with full discretionary authority in
accordance with the ALIGN UMA Select Portfolio
selected by the client. The client also authorizes
and directs Baird to appoint the Overlay Manager
to serve as sub-adviser to the client’s Account
and directs the Overlay Manager to manage the
client’s Account in accordance with the ALIGN
UMA Select Portfolio selected by the client and the
terms of the ALIGN UMA Select Program. If an
ALIGN UMA Select Portfolio contains a Model-
Traded Strategy, the client authorizes and directs
the Overlay Manager to manage such SMA
Strategy within the client’s Account with full
discretionary authority in accordance with the
SMA Strategy. If an ALIGN UMA Select Portfolio
contains a Manager-Traded Strategy, the client
authorizes and directs the Overlay Manager to
appoint the applicable investment manager as
sub-adviser, and the client also authorizes and
directs such investment manager to manage such
SMA Strategy within the client’s Account with full
discretionary authority in accordance with the
SMA Strategy.
for
A client participating in the ALIGN UMA Select
Program gives the Overlay Manager and Baird the
authority to replace investments in a client’s
Account, rebalance a client’s Account assets to be
consistent with the client’s chosen asset allocation
strategy, or engage in tax management strategies
in certain circumstances. See “Additional Service
Information—Special Considerations
the
Programs” and “Additional Service Information—
Tax Management” below for more information.
implement
inclusion
Important
Information about Affiliated
Products. Some of the investment services and
products offered by Riverfront, and mutual funds
offered by the Baird Funds, both of which are
affiliated with Baird, have been selected by Baird
for
in certain ALIGN UMA Select
Portfolios. This presents a conflict of interest. For
more information, see “Additional Information—
Other Financial Industry Activities and Affiliations”
below.
periodically
discuss
Unified Advisory Select Portfolios Program
If an ALIGN UMA Select Portfolio contains a
Model-Traded Strategy, the Overlay Manager will
typically
the Model Portfolio as
proposed by the Model Provider. However, since
the Overlay Manager has discretionary authority
over the applicable portion of the client’s Account,
the Overlay Manager may implement the Model
Portfolio differently than proposed by the Model
Provider if the Overlay Manager determines such
action to be necessary and in the client’s best
interest. A client should note that DDK and Baird
do not monitor or ascertain whether the Overlay
Manager is fully and faithfully implementing the
Model Portfolio on a continuous basis. The client
should
the Account’s
performance with the client’s DDK Consultant.
Under the UAS Portfolios Program, Baird and the
Overlay Manager generally manage a client’s
Account on a non-discretionary basis according to
a custom model asset allocation strategy (each
Certain managers of Model-Traded Strategies
through the Overlay Manager have
offered
adopted trade rotation policies that allow them to
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
to
available under the UAS Program through a
less rigorous evaluation process
significantly
compared
the UMA Recommended SMA
Strategies (“UAS Available SMA Strategies”),
which may include Associated SMA Strategies.
Assets,
Alternative
strategy,
client
selects
such model, a “UAS Portfolio”) that is selected by
the client. UAS Portfolios involve the use of
various different investment strategies because
they are customized for each client. A UAS
Portfolio provides a client with a customized level
of investment across different asset classes, such
as equity securities, fixed income securities, Non-
Traditional
Investment
Products and cash. To implement the asset
allocation
the
a
investments for the Account from among those
mutual funds, ETPs, SMA Strategies and PWM-
Managed Portfolios that Baird has determined are
eligible for use in the Program.
If a client has not selected the discretionary
management option of the UAS Program, the
client should note that: (1) the UAS Available
Funds and UAS Available SMA Strategies are
made available to accommodate a client who
wishes to independently select investments that
are not on a Baird recommended list for the
client’s Account; (2) DDK and Baird do not make
any recommendation to clients regarding any UAS
Available Fund or UAS Available SMA Strategy and
DDK and Baird do not select any investments for
the client’s UAS Program Account; and (3) DDK
and Baird do not make any representation to
clients regarding any UAS Available Manager’s
qualifications as an investment adviser or abilities
to manage client assets.
that option, a
client grants
The UAS Portfolios Program also makes available
a discretionary management option, whereby a
client grants discretionary investment authority
over the client’s UAS Program Account to Baird
and a DDK Consultant who has been approved by
Baird to manage client accounts in the UAS
Portfolios Program (a “UAS Manager”). If a client
selects
full
discretionary authority and management of the
client’s Account to Baird and the client’s UAS
Manager. A client’s UAS Manager will manage the
client’s Account on a discretionary basis according
to the UAS Portfolio strategy selected by the client
by investing Account assets in various mutual
funds, ETPs, SMA Strategies and PWM-Managed
Portfolios that Baird has determined are eligible
for use in the Program.
Funds, which may
such
If a client has selected the discretionary option of
the UAS Program, the client should note that
Baird or the client’s DDK Consultant may use their
discretionary authority to invest the client’s UAS
Account in Associated Funds or Associated SMA
Strategies, or to the extent required by applicable
law or regulation, they may recommend, and
request the client’s consent to, such investment.
The client’s DDK Consultant may also use the
DDK Consultant’s discretionary authority to invest
the client’s UAS Account in UAS Available Funds
and UAS Available SMA Strategies if the DDK
investments are
Consultant believes
consistent with the client’s investment objectives,
risk tolerance and in the client’s best interest.
The UAS Portfolios Program makes available two
categories of mutual funds and ETPs: (1) UMA
include
Recommended
Associated Funds, that Baird determines are
eligible for the UMA Programs through an initial
and ongoing evaluation process; and (2) certain
other mutual funds and ETPs that Baird makes
available under the UAS Program through a
significantly
less rigorous evaluation process
compared to the UMA Recommended Funds (“UAS
Available Funds”), which may include Associated
Funds.
Similarly, the UAS Portfolios Program makes
available two categories of SMA Strategies: (1)
UMA Recommended SMA Strategies, which may
include Associated SMA Strategies, that Baird
determines are eligible for the UMA Programs
through an initial and ongoing evaluation process;
and (2) certain SMA Strategies made available by
certain managers (“UAS Available Managers”)
through the Overlay Manager that Baird makes
When Associated Funds are included in the UMA
Recommended Funds lineup, and when Associated
in
SMA Strategies are
the UMA
included
Recommended SMA Strategies
lineup, those
Associated Funds and Associated SMA Strategies
are subject to the same eligibility standards that
are imposed upon mutual funds, ETFs and SMA
Strategies that are not associated with Baird.
However, when Associated Funds are included in
the UAS Available Funds lineup, and when
Associated SMA Strategies are included in the
UAS Available SMA Strategies
lineup, those
Associated Funds and Associated SMA Strategies
are not subject to the same eligibility standards
that are imposed upon mutual funds, ETFs and
SMA Strategies that are not associated with Baird.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and
selects
the UAS
Some of the services provided under this Program
may be provided to a client by a DDK Consultant
assigned to the client’s Account. Typically, a client
Portfolio
develops
appropriate for the client’s Account with the
assistance of the client’s DDK Consultant. If the
client has selected the discretionary management
option of the Program, Baird and the DDK
Consultant, acting as UAS Manager, will manage
the client’s Account.
and
To be included in the UAS Available Fund lineup or
the UAS Available SMA Strategy lineup, an
Associated Fund or Associated SMA Strategy,
respectively, only needs to meet certain limited
criteria. For more specific information about the
investment options made available through the
Program and the level of initial and ongoing
research, evaluation, monitoring and review
performed by Baird on those investment options,
if any, see “Portfolio Manager Selection and
Evaluation—Selection
Evaluation—UMA
Programs” and “Portfolio Manager Selection and
Investment
Evaluation—Methods of Analysis,
Strategies and Risk of Loss—Program Portfolio
Strategies—UMA Programs” below.
A client retaining discretion over the client’s UAS
Program Account should only select UAS Available
Funds or UAS Available SMA Strategies if the
client wishes to take more responsibility for
managing and monitoring
the client’s UAS
Program Account, the UMA Recommended Funds
and UMA Recommended SMA Strategies do not
meet the client’s particular needs, and the client
understands the risks of doing so.
Baird may allow a client to transfer to a UAS
Account from another account a Fund that is not a
UMA Recommended Fund or UAS Available Fund
in certain circumstances, such as when the client
has significant unrealized capital gains related to
the client’s investment in the Fund. Additional
purchases of such Fund while held in a UAS
Account will not be permitted.
Investment managers participating in the UAS
Portfolios Program have varying
investment
objectives, styles and strategies, and they may
invest a client’s Account in various types of
securities, which will be chosen by the investment
manager and which may include mutual funds,
ETFs or other investment products associated with
the manager or Baird.
Baird has engaged the Overlay Manager to
provide certain subadvisory services in connection
with the UAS Select Portfolios Program. The UAS
Portfolios Program makes both Manager-Traded
Strategies and Model-Traded Strategies available
to clients. If a client selects a UAS Portfolio, the
client authorizes and directs Baird to manage the
client’s Account in accordance with the UAS
Portfolio selected by the client and the terms of
the UAS Program. The client also authorizes and
directs Baird to appoint the Overlay Manager to
serve as sub-adviser to the client’s Account and
directs the Overlay Manager to manage the
client’s Account in accordance with the UAS
Portfolio selected by the client and the terms of
the UAS Program. If a UAS Portfolio contains a
Model-Traded Strategy, the client authorizes and
directs the Overlay Manager to manage such SMA
Strategy within the client’s Account with full
discretionary authority in accordance with the
SMA Strategy. If a UAS Portfolio contains a
Manager-Traded Strategy, the client authorizes
and directs the Overlay Manager to appoint the
applicable investment manager as sub-adviser,
and the client also authorizes and directs such
investment manager
to manage such SMA
Strategy within the client’s Account with full
discretionary authority in accordance with the
SMA Strategy. If a UAS Portfolio contains a PWM-
Managed Portfolio, the client authorizes and
directs Baird to manage such PWM-Managed
Portfolio within the client’s Account with full
discretionary authority in accordance with the
PWM-Managed Portfolio.
the
investment manager,
the
Clients are urged to review the investment
manager’s Form ADV Part 2A Brochure, which
should contain additional important information
about
including
investment manager’s
information about the
strategies,
the
investments
types of
investment manager may use for a client’s
Account, and the risks associated with investing in
the investment manager’s SMA Strategies. Such
brochures are available upon request.
If a UAS Portfolio contains a Model-Traded
Strategy, the Overlay Manager will typically
implement the Model Portfolio as proposed by the
Model Provider. However, since the Overlay
Manager has discretionary authority over the
applicable portion of the client’s Account, the
Overlay Manager may implement the Model
Portfolio differently than proposed by the Model
Provider if the Overlay Manager determines such
25
DDK Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
periodically
discuss
action to be necessary and in the client’s best
interest. A client should note that DDK and Baird
do not monitor or ascertain whether the Overlay
Manager is fully and faithfully implementing the
Model Portfolio on a continuous basis. The client
should
the Account’s
performance with the client’s DDK Consultant.
the UAS Available SMA remains appropriate for
the client); any potential conflicts of interest; and
any investment restrictions the client may wish to
impose or change. A client should also periodically
check the registration status, disciplinary events
and other information regarding the investment
manager, described on the manager’s Form ADV,
which is available on the SEC's website at
www.adviserinfo.sec.gov.
Baird constructs each PWM-Managed Portfolio and
may make changes to a PWM-Managed Portfolio
from time to time as it deems appropriate and
without providing prior notice to, or obtaining the
consent of, a client.
Information—Trading
Certain managers of Model-Traded Strategies
offered
through the Overlay Manager have
adopted trade rotation policies that allow them to
send Model Portfolio updates to the Overlay
Manager after they have implemented the Model
Portfolio updates for client accounts managed by
them or after they have otherwise completed
trading for those accounts. As a result, the
performance of a DDK client Account pursuing a
Model Portfolio strategy offered by those Model
Providers will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by those Model Providers. See
for
“Additional Service
Client Accounts—Trading Practices of Investment
Managers” below for more information.
for
in the UAS Portfolios
A client participating
Program gives the Overlay Manager and Baird the
authority to replace investments in a client’s
Account, rebalance a client’s Account assets to be
consistent with the client’s chosen asset allocation
strategy or engage in tax management strategies
in certain circumstances. See “Additional Service
Information—Special Considerations
the
Programs” and “Additional Service Information—
Tax Management” below for more information.
and Baird
not
provide
full discretionary authority
If a client has not selected the discretionary
management option of the Program, the client
retains discretionary authority over the selection
of mutual funds, ETFs, SMA Strategies and PWM-
Managed Portfolios for the Account. However, by
selecting an SMA Strategy or PWM-Managed
Portfolio, the client authorizes and directs Baird,
the Overlay Manager and the client’s investment
manager, as applicable, to manage each SMA
Strategy or PWM-Managed Portfolio portion of the
Account with
in
accordance with the SMA Strategy or PWM-
Managed Portfolio selected by the client.
If a portion of client’s UAS Program Account is
managed by an Other Manager, the client should
understand that: DDK and Baird do not manage
such portion of the Account and do not otherwise
have any influence over the Other Manager’s
investment decisions or securities selections, and
therefore, DDK and Baird are not responsible for
the decisions made by the Other Manager; and
DDK
any
do
recommendation or investment advice regarding
the purchase or sale of investment products made
for such portion of the client’s Account; and if the
client has not
the discretionary
selected
management option of the Program, DDK and
the client with certain
Baird only provide
consulting services, which may include the client’s
DDK Consultant’s assistance with determining the
client’s financial needs, investment goals and
investment restrictions and periodically reviewing
the manager’s performance. DDK and Baird do
not undertake to provide any other consulting or
investment advisory services under this Program
unless DDK and Baird agree to do so in writing.
the discretionary
If a client has selected
management option of
the UAS Portfolios
Program, the client should note that Baird may
remove any UAS Manager or strategy from the
UAS Portfolios Program at any time and transfer
day-to-day management
responsibility of a
client’s Account to another UAS Manager or
another DDK Consultant or Baird Financial Advisor
at any time without providing prior notice to, or
obtaining the consent of, a client.
the
Important Information about
Portfolios Program. Associated
the UAS
Investment
A client that selects a UAS Available SMA is
strongly encouraged to contact the client’s DDK
Consultant or investment manager on a periodic
basis to discuss: the Account and its investment
investment manager’s
performance;
investment philosophy and style (to determine if
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
invested
in concentrated and
Products and Services are available to clients
under the UAS Portfolios Program. This presents a
conflict of interest. For more information, see
“Additional Information—Other Financial Industry
Activities and Affiliations” below.
information about
A client should note that certain SMA Strategies
may be
less
diversified portfolios of securities and may involve
the use of leverage, margin, and options. A client
should discuss with the client’s DDK Consultant
the specific strategies and investments used by a
manager. Additional
the
strategies and investments used by a manager
are available in a manager’s Form ADV Part 2A
Brochure.
Additional Service Information
Investment Discretion
Investment Selection and Trading
Authorizations
client’s
independent
review of
A client
retains complete discretion over
investment selection and trading decisions with
respect to assets in a client’s Non-Discretionary
Service Accounts, and DDK and Baird will only
execute transactions for such Accounts pursuant
to the client’s instruction or authorization.
If a client’s Account participates in a Discretionary
Service, the client’s advisory agreement provides
Baird and the client’s DDK Consultant, as
applicable, discretionary authority to manage the
assets in the client’s Account in accordance with
the terms of the Service selected by the client.
If a client has not selected the discretionary
management option of the UAS Program, it is
important to note that: the UAS Available Funds
and UAS Available SMA Strategies are made
available to accommodate a client who wishes to
independently select investments that are not on
a Baird recommended list for the client’s Account;
the client assumes ultimate responsibility for
monitoring each UAS Available Fund and UAS
Available SMA Strategy and
the manager’s
performance; the client’s selection and continued
holding of a UAS Available Fund or a UAS
Available SMA Strategy are based ultimately upon
the
such
investment; the client ultimately determines that
each UAS Available Fund and UAS Available SMA
Strategy in the client’s Account is consistent with
the client’s stated investment objectives and
financial needs and risk tolerance; and once an
investment is made by the client, the investment
will only be removed from the client’s Account
upon the manager’s withdrawal, removal of the
investment from the Program, or the client’s
direction to do so. A client should carefully
consider the foregoing when deciding to select a
UAS Available Fund or UAS Available SMA
Strategy or when deciding to participate in the
UAS Program and also consider whether another
mutual fund, ETF, SMA Strategy or Service may
be more appropriate for the client.
SMA Strategy Information
a
If a client’s Account participates in the DDK
Recommended Managers Service, the client’s
advisory agreement provides Baird and the
client’s DDK Consultant discretionary authority to
appoint investment managers to manage the
client’s Account and to terminate or replace
investment managers for the client’s Account for
any reason without prior notice to the client. If
DDK or Baird terminates an investment manager
client’s DDK
of
from management
Recommended Managers Service Account, the
client’s advisory agreement provides DDK and
Baird discretionary authority to manage the
assets in the client’s Account until a replacement
investment manager is selected or alternative
arrangements are made for the management of
the client’s assets.
include
Certain SMA Strategies are available through
multiple Services. The overall cost of an SMA
Strategy and the types and levels of service
provided to a client in connection with an SMA
Strategy will vary depending upon the particular
Service selected by the client. A client considering
an SMA Strategy should discuss with client’s DDK
Consultant SMA Strategy availability and the
different Portfolio Fee rates, costs, and the types
and levels of service provided in connection with
is solely
the different Services. A client
responsible for selecting the SMA Strategy and
the Service in which the client’s Account will
participate.
If a client’s Account participates in an SMA
Service, the client’s advisory agreement provides
the investment manager selected to manage the
client’s Account, which may
an
Implementation Manager, discretionary authority
to manage the assets in the client’s Account in
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
accordance with the terms of the SMA Service
selected by the client.
If a client’s Account participates in a UMA
Program, the client provides Baird, the client’s
UAS Manager, the Overlay Manager and the
client’s
investment manager, as applicable,
discretionary authority to manage the assets in
the client’s Account in accordance with the terms
of the UMA Program selected by the client.
execution otherwise requires or unless the client
has provided other instructions to Baird in writing.
DDK and Baird do not have discretionary
authority over the assets in a client’s SMAs or
UMAs that are managed by an Other Manager and
cannot purchase or sell such assets without the
consent of the client or such Other Manager. The
investment manager for a client’s SMAs or UMAs
may initiate securities transactions through Baird,
in its capacity as broker-dealer, as further
described under the heading “Trading for Client
Accounts” below, subject to the manager’s duty to
seek to obtain best execution, or unless a client
has provided other instructions in writing. Baird,
as broker-dealer, will rely upon any such
instructions of any investment managers selected
to manage the client’s Account.
for
buying,
holding,
and
any Other Manager
If a client participates in an SMA Service or UMA
Program, the client authorizes DDK and Baird to
the Overlay
share client’s
information with
or
Manager
Implementation Manager managing the client’s
Account. The client also authorizes and directs
DDK and Baird to transmit to the Overlay
Manager and any such Other Manager or
Implementation Manager any instructions that the
client may provide to DDK or Baird to the extent
necessary to carry out the client’s instructions.
Client Investment Restrictions
the client. Pursuant
investment
restrictions on
including
The Discretionary and the SMA Services and the
UMA Programs offer a client the ability to impose
the
reasonable
the
management of an Account,
designation of particular securities or types of
securities that should not be purchased for the
client’s Account, but a client may not require that
particular funds or securities (or
types) be
purchased for the client’s Account. Reasonable
investment restrictions requested by a client will
apply only to those assets over which DDK, Baird
or a client’s investment manager has discretion.
investments
to
those
If a client grants discretionary authority over the
client’s Account to DDK, Baird, the client’s DDK
Consultant or the client’s investment manager,
the client’s advisory agreement authorizes DDK,
Baird, the client’s DDK Consultant and the client’s
investment manager, as applicable, to manage
the client’s Account and to make investment
decisions for the client’s Account, with the
authority to determine the amount, type and
timing
exchanging,
converting and selling securities and other assets
for the client’s Account, subject to the terms of
the Service selected by the client. The client’s
advisory agreement also grants to DDK, Baird,
the client’s DDK Consultant and the client’s
investment manager, as applicable, complete and
unlimited trading authorization and appoints them
as the client’s agents and attorneys-in-fact to
manage the assets in the client’s Account on the
client’s behalf, subject to the terms of the Service
selected by
to such
authorization and powers of attorney, DDK, Baird,
the client’s DDK Consultant and the client’s
investment manager may, in their sole discretion
and at the client’s risk, purchase, sell, exchange,
convert and otherwise trade the securities and
other assets in the client’s Account, as well as
arrange for delivery and payment in connection
with the above, and act on the client’s behalf in
all matters necessary or incidental to the handling
of the client’s Account without prior notice to the
client. Such trading authorizations and powers of
attorney, whether granted to DDK, Baird, the
client’s DDK Consultant or the client’s investment
manager, shall remain in full force and effect until
terminated by the client, the client’s investment
manager, DDK or Baird.
DDK may also offer clients a socially responsible
investing (“SRI”) service, which assists a client in
restricting
that are
consistent with the client’s social investment
guidelines or objectives. Clients electing the SRI
service generally bear the cost of the SRI service
as it is generally included in the Advisory Fee.
In the event that a client’s Account is restricted
from investing in certain securities, DDK, Baird or
Orders for the purchase and sale of securities in a
client’s Discretionary Service Accounts will
generally be executed by Baird, in its capacity as
broker-dealer, as further described under the
heading “Trading for Client Accounts” below,
unless Baird’s duty to seek to obtain best
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
accounts without
restrictions
to invest a client’s assets in investment products
unassociated with Baird. For more information
about the criteria used by DDK and Baird, clients
should review the section of the Brochure entitled
“Portfolio Manager Selection and Evaluation”
below. A client’s consent may be revoked at any
time.
The Services allow Other Managers, including
Associated Managers, to use the discretionary
authority granted to them by a client to invest the
client’s Account in investment products managed
or sponsored by the Other Manager or any of its
associated firms, which may include Baird. The
Other Manager or its associated firms receive
investment management or advisory fees or other
compensation from such products for the services
they provide, the amount of which generally
increases when clients invest in such products.
the client’s investment manager, as applicable,
will select such other replacement securities, if
any, as they deem appropriate. Accounts with
investment restrictions may perform differently
from
and
performance may be poorer. In addition, in the
event there is a change in the classification or
credit rating of a security held in the client’s
Account, a client’s investment restrictions may
force DDK, Baird or the client’s investment
manager to sell such security at an inopportune
time, possibly negatively
impacting Account
performance and causing the client’s Account to
realize taxable gains or losses, which could be
significant. A client should also be aware that, if
the client’s Account holds any investment vehicle
(such as a mutual fund or ETF), any investment
restrictions the client places on the client’s
Account may not flow through to the securities
owned by that investment vehicle.
Should a client wish to impose or modify existing
restrictions, or the client’s financial condition or
investment objectives have changed, the client
should contact the client’s DDK Consultant.
Associated Investment Products
other
from
the services
By signing an advisory agreement with Baird or
participating in a Service, a client consents to
each Other Manager, including each Associated
Manager, managing client’s Account investing all
or a portion of the client’s Account in investment
products managed or sponsored by the Other
Manager or any of its associated firms, which may
include Baird. Each Other Manager is responsible
for providing to the client information about the
amount of fees received by the Other Manager
and its associated firms and the criteria used by
the Other Manager in deciding to invest in
products managed or sponsored by the Other
Manager or any of its associated firms. A client
should contact the Other Manager and review the
Other Manager’s Form ADV Part 2A Brochure for
more information. A client’s consent may be
revoked at any time.
Investment Policy Statements
The Services allow DDK and Baird to use the
discretionary authority granted to them by a
client to invest the client’s Account in Associated
Investment Products. Baird and Associated Parties
receive investment management or advisory fees
Associated
compensation
or
Investment Products
they
for
provide, the amount of which generally increases
when clients invest in such products. The amount
of fees or other compensation received by Baird
and Associated Parties is generally described in
the prospectus or other offering or disclosure
documents for the investment product. Additional
information is also available on Baird’s website at
bairdwealth.com/retailinvestor.
in Associated
DDK and Baird will not review, monitor, accept or
adhere to an investment policy statement or
similar document that was not prepared by DDK
or Baird, unless they otherwise specifically agree
to do so in writing. Adherence to any such
investment policy statement or similar document
is solely a client’s responsibility.
Conversion, Exchange or Sale of Certain
Investments
By signing an advisory agreement with Baird or
participating in a Service, a client consents to
DDK and Baird investing all or a portion of the
Investment
client’s Account
Products. DDK and Baird will use
their
discretionary authority to invest the client’s
Account in Associated Investment Products when
they determine it to be in the client’s best interest
to do so. Generally, the criteria used by them in
deciding to invest in Associated Investment
Products are the same as those used in deciding
By participating in a Service, a client authorizes
DDK and Baird to convert or exchange any shares
of Funds, such as mutual funds, ETFs, closed-end
funds, UITs, Complex Investment Products, and
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
provide clients with the best qualitative execution
under the circumstances.
other similar investment pools, held in the client’s
Account to a class of shares of the same fund,
such as advisory class shares, institutional class
shares, financial intermediary class shares, or
another class of shares primarily designed for use
in advisory programs (collectively, “Advisory Class
Shares”), to the extent made available by the
mutual fund or other Fund in accordance with
policies established by Baird from time to time,
including, without limitation the Mutual Fund
Share Class Policy that is described below.
transactions. For
Because a client does not pay commissions to
Baird when Baird, acting as broker-dealer,
executes a client’s trade orders, and because a
client may incur commission costs in addition to
the Advisory Fee if trade orders were to be
executed by another broker-dealer firm, clients
generally receive a cost advantage whenever
Baird executes client
this
reason, and given Baird’s execution capabilities as
that Baird will
broker-dealer, DDK expects
generally execute trade orders, as broker-dealer,
for Non-Discretionary Accounts and the client’s
Accounts that are directly managed by DDK or
Baird.
that may require DDK or Baird,
A client should understand that, the client may
not hold Advisory Class Shares in a non-Advisory
Account and that the client may not be able to
hold certain Advisory Class Shares in an account
held at another firm. Upon the termination of a
Service for an Account or the closure of an
Account for any reason, DDK and Baird may
convert or exchange the Advisory Class Shares
held in the Account to an appropriate non-
Advisory Class Shares issued by the same fund,
or, if an appropriate non-Advisory Class Shares is
not available, DDK and Baird may redeem or sell
such Advisory Class Shares.
Trading for Client Accounts
DDK’s and Baird’s Trading Practices
However, in some instances, circumstances may
arise
in
compliance with their best execution obligations
to a client, to place a client’s trade order with a
firm other than Baird. If they place trade orders
for the client’s Account for execution by a firm
other than Baird, and the other firm imposes a
commission or equivalent fee on the trade
(including a commission imbedded in the price of
the investment), the client will incur trading costs
in addition to the Advisory Fee.
Placement of Client Trade Orders
Trade Aggregation, Allocation and Rotation
Practices
DDK and Baird may aggregate contemporaneous
buy and sell orders for the accounts over which
they have discretionary authority (a practice also
known as bunching trades or block transactions).
This practice may enable them to obtain more
favorable execution, including better pricing and
enhanced investment opportunities, than would
if orders were not
otherwise be available
aggregated. Using block transactions may also
assist them in potentially avoiding an adverse
effect on the price of a security that could result
from simultaneously placing a number of
separate, successive or competing, client orders.
under
their
direct
DDK and Baird will select the broker-dealers that
will execute trade orders for Non-Discretionary
Accounts and with respect to Accounts that are
managed directly by DDK or Baird unless the
client has provided instructions to DDK to the
contrary. As investment adviser, DDK and Baird
have an obligation to seek “best execution” of
client trade orders. “Best execution” means that
they must place client trade orders with those
broker-dealers that they believe are capable of
providing the best qualitative execution of client
trade orders under the circumstances, taking into
account the full range and quality of the services
offered by the broker-dealer, including the value
of the research provided (if any), the broker-
dealer’s execution capabilities, the cost of the
trade, the broker-dealer’s financial responsibility,
and its responsiveness to DDK and Baird. It is
important to note that DDK’s and Baird’s best
execution obligation does not require them to
solicit competitive bids for each transaction or to
seek the lowest available cost of trade orders, so
long as they reasonably believe that the broker-
dealer selected can be reasonably expected to
DDK and Baird generally aggregate buy and sell
orders when executing trades for client account
discretionary
assets
management when they have the opportunity to
do so. When utilizing block transactions, DDK and
Baird generally aggregate a client’s trade orders
with trade orders for clients who are participating
in the same Service and pursuing the same model
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
favorable net price
client’s Account that occurs near or at the end of
the rotation and, in such event, client’s trade
orders will significantly bear the market price
impact, if any, of those trades executed earlier in
the rotation, and, as a result, the client may
receive a
for the
less
applicable trade.
into
consideration
account
portfolio or strategy. In some cases, DDK or Baird
may aggregate a client’s trade orders with trade
orders for other advisory clients who are not
participants in the Services described in this
Brochure. However, DDK and Baird determine
whether or not to utilize block transactions for a
client in their sole discretion and DDK’s and
Baird’s decision is subject to their duty to seek
best execution. In determining the amount to be
allocated to an account, if any, DDK and Baird
take
specific
investment restrictions, undesirable position size,
account portfolio weightings, client tax status,
client cash positions and client preferences.
income securities
All advisory clients participating
in a block
transaction will receive the same execution price
for the security bought or sold. Average prices
may be used when allocating purchases and sales
to a client’s Account because such securities may
be purchased and sold at different prices in a
series of block transactions. As a result, the
average price received by a client may be higher
or lower than the price the client may have
received had the transaction been effected for the
client independently from the block transaction.
Notwithstanding the foregoing, if an aggregated
trade order involves fixed income securities, DDK
and Baird may allocate the securities based on
the needs of client accounts. In addition, DDK and
Baird will at times place aggregated trade orders
for fixed income securities prior to determining
how the aggregated trade order will be allocated
to client accounts. In those instances when an
aggregated trade order for fixed income securities
is placed prior to determining client allocations or
when such trade order is only partially filled, DDK
or Baird will seek to allocate trades in manner
intended to be fair and equitable to applicable
clients over time. Furthermore, when a trade
order for fixed income securities is only partially
filled, DDK and Baird may place orders for other
fixed
that have similar
characteristics, such as issuer name, structure,
credit rating, or market sector.
in
treatment over
Because DDK and Baird are unable to buy or sell
any security for a client’s Non-Discretionary
Accounts without the client’s authorization, DDK
and Baird generally do not aggregate or bunch
trades for those Accounts with the same or similar
trades for other client accounts. Because similar
orders for the client and DDK’s or Baird’s other
clients may be placed and filled at different times,
the client may buy or sell securities at prices that
are different from the prices obtained by other
clients who received the same or similar advice
from DDK or Baird.
Directed Brokerage Arrangements
The amount of securities available
the
marketplace, at a particular price at a particular
time, may not satisfy the needs of all clients
participating in a block transaction and may be
insufficient to provide full allocation across all
client accounts. To address this possibility, Baird
has adopted
trade allocation policies and
procedures that are designed to make securities
allocations to discretionary client accounts in a
manner such that all such clients receive fair and
equitable
time. If a block
transaction cannot be executed in full at the same
price or time, the securities actually purchased or
sold by the close of each business day will
generally be allocated pro rata among the clients
participating in the block transaction. However,
DDK may also make random allocations to client
accounts in certain circumstances, such as when
Baird deems a partial fill for the total block order
to be low. Adjustments may also be made to
avoid a nominal allocation to client accounts.
In some cases, a client may direct DDK to use a
particular broker-dealer for execution of the
client’s trade orders (a “directed brokerage
arrangement”), and DDK may agree to the
arrangement. This may occur when a client’s
Account is held at another broker-dealer firm and
a client directs DDK to execute trades through
such firm, or when a client’s Retirement Account
or other account is maintained on a platform
operated and managed by a third party and
trades must be executed through that platform. A
client should understand that DDK and Baird
When DDK is not able to aggregate trades, DDK
generally uses a trade rotation process that is
designed to be fair and equitable to its advisory
clients over time. However, a client should be
aware that DDK’s trade rotation practices may at
times result in a transaction being effected for the
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the purchase of
except in limited instances such as when clients
buy or sell variable rate demand obligations which
are also known as “put bonds”. When DDK
believes that the transaction is consistent with
each client’s best
interest, DDK, acting as
investment manager, may cause (or in the case
of Non-Discretionary accounts, recommend) the
sale of securities from the account of an advisory
client while at or about the same time causing
(or, in the case of Non-Discretionary accounts,
recommending)
the same
securities for the account of another DDK advisory
client. Such transactions may have the benefit of
reducing transaction and market impact costs.
In such cases, because Baird is acting as
investment adviser for both buyer and seller,
Baird is subject to potentially conflicting interests
in causing (or recommending) the transactions.
Also, because Baird is acting as investment
adviser for both buyer and seller, transaction
prices may be determined more by reference to
market information or dealer indications for the
securities involved, and less through the type of
independent arms-length negotiation that might
otherwise occur. Baird has adopted internal
policies and procedures that require DDK and
Baird to obtain approval of Baird’s Compliance
Department before affecting a cross trade.
consider such arrangements to be directed
brokerage arrangements. A client should also
understand that if the client has a directed
brokerage arrangement, DDK and Baird may be
unable to achieve best execution for the client’s
transactions. A client should note that any costs
related to the directed brokerage arrangement
are not included in the Advisory Fee and that the
client will be solely responsible for monitoring,
evaluating and reviewing the arrangement with
the directed broker-dealer and paying any
commissions or markups or markdowns or other
costs imposed by the directed broker-dealer. A
client should also note that DDK generally will not
aggregate the client’s directed brokerage trade
orders with orders for other DDK clients. As a
result, a client’s transaction costs may be higher
because the client will not benefit from any
volume discounts or other reduced transaction
costs that DDK may obtain for its other clients. A
client should further note that DDK generally will
not include such client trade orders in its trade
rotation process and that DDK will generally place
the client’s trade orders with the directed broker-
dealer after DDK completes its trading for other
DDK client accounts. The client’s trade orders will
significantly bear the market price impact, if any,
of those trades executed earlier in DDK’s rotation.
As a result, the client may receive a less favorable
net price for the trade.
Trade Error Correction
interest
If a client directs DDK to use a particular broker-
dealer, and if the particular broker-dealer referred
the client to DDK or if the particular broker-dealer
refers other clients to DDK or Baird in the future,
DDK and Baird may benefit from the client’s
directed brokerage arrangement. Because of
these potential benefits, DDK and Baird may have
an economic interest in having the client continue
the directed brokerage arrangement. The benefits
that DDK and Baird receive conflict with the
client’s
in having DDK or Baird
recommend that the client utilize another broker-
dealer to execute some or all transactions for the
client’s Account.
Before directing DDK to use a particular broker-
dealer, a client should carefully consider the
possible costs or disadvantages of directed
brokerage arrangements.
It is Baird’s policy that if there is a trade error for
which DDK or Baird is responsible, DDK or Baird
will take actions, based on the
facts and
circumstances surrounding the error, to put the
client’s Account in the position that it would have
been in as if the error had not occurred, including
by adjusting or reversing the transaction, entering
an offsetting transaction, or other methods that
may be deemed appropriate by Baird. Errors
caused by DDK or Baird will be corrected at no
cost to client’s Account, with the client’s Account
not recognizing any loss from the error. DDK and
Baird may net gains and losses from a single error
event involving more than one transaction in a
security or transactions in multiple securities. The
client’s Account will be fully compensated for any
losses incurred as a result of an error event. If
the trade error results in a gain, the gain may be
retained by Baird but such gain is not given to or
shared with any DDK or Baird associate.
Cross Trading Involving Advisory Accounts
DDK generally does not in engage in cross
transactions, including agency cross transactions,
DDK and Baird offer many services and, from
time to time, may have other clients in other
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
programs trading in opposition to a client. To
avoid favoring one client over another client,
Baird attempts to use objective market data in
the correction of any trading errors.
in
the
information
end of the investment manager’s rotation and, in
such event, client’s trade orders will significantly
bear the market price impact, if any, of those
investment
trades executed earlier
manager’s rotation, and, as a result, the client
may receive a less favorable net price for the
trade. Additional
regarding an
investment manager’s trade rotation policies, if
any, is available in the investment manager’s
Form ADV Part 2A Brochure.
If a client’s Account is managed by an Other
Manager, the client should review the Other
the Other
Manager’s Brochure and contact
Manager for information about how the Other
Manager corrects trade errors.
Trading Practices of Investment Managers
If a client’s Account or a portion thereof is
managed by an investment manager, the client
should note that, like Baird, such investment
manager has a duty to seek best execution for
the client’s Account.
on
website
the
investment manager,
Investment managers may participate in other
wrap fee programs sponsored by firms other than
Baird. In addition, investment managers may
manage institutional and other accounts not part
of a wrap
fee program. In the event an
investment manager purchases or sells a security
for all accounts using a particular SMA Strategy
the
offered by
investment manager may have to potentially
effect similar transactions through a number of
different broker-dealers. In some cases, to
address this situation, investment managers may
decide to aggregate all such client transactions
into a block trade that is executed through one
broker-dealer. This practice may enable the
investment manager to obtain more favorable
execution, including better pricing and enhanced
investment opportunities, than would otherwise
be available if orders were not aggregated. Using
block transactions may also assist the investment
manager in potentially avoiding an adverse effect
on the price of a security that could result from
simultaneously placing a number of separate,
successive or competing client orders. However,
as it pertains to DDK clients, this practice may
result in “trading away” from Baird, which is more
fully described below.
in
Alternatively, an investment manager may utilize
a trade rotation process where one group of
clients may have a transaction effected before or
after another group of the investment manager’s
clients. A client should be aware that an
investment manager’s trade rotation practices
may at times result in a transaction being effected
for the client’s Account that occurs near or at the
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after
they have
implemented the Model Portfolio
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. The Overlay Manager has
provided to Baird a list of Model Providers that
have such trade rotation policies, which list is
available
at
Baird’s
bairdwealth.com/retailinvestor. A DDK client
should understand that an Account pursuing a
Model Portfolio strategy offered by those Model
Providers will have trades executed for the client’s
Account at the end of the Model Provider’s trade
rotation on a regular and consistent basis. As a
result, trade orders for such an Account will
significantly bear the market price impact, if any,
of those trades executed earlier in the Model
Provider’s rotation and the performance of the
Account will differ, perhaps in a materially
negative manner, from the performance of client
accounts managed by the Model Provider. In
addition and for the same reasons described
above, the performance of a Model Portfolio, as
reported by the Model Provider, will differ,
perhaps in a materially negative manner, from
the actual performance realized by DDK client
Accounts pursuing the Model Portfolio strategy.
DDK and Baird do not make or control any
investment manager’s trade rotation policies, and
they do not monitor, evaluate or review any
investment manager’s compliance with
the
manager’s trade rotation policies or whether such
trade rotation policies result
inequitable
performance of client Accounts. A client selecting
a Model Portfolio offered by such a Model Provider
is urged to obtain a copy of the Model Provider’s
Form ADV Part 2A Brochure and review the
description of the Model Provider’s trade rotation
policy contained in that document. A copy of a
Model Provider’s Brochure can be obtained by
contacting a DDK Consultant. A client should also
monitor the performance of an Account pursuing
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the Model Provider’s
(which is embedded in the price of the security)
for executing the trade. As a result, these types of
managers and their strategies could be more
costly to a client than managers that primarily
place client trade orders with Baird for execution.
such a Model Portfolio strategy and compare that
performance with the performance reported for
the Model Portfolio by the Model Provider. A client
about Account
questions
discuss
should
performance or
trade
rotation policy with the client’s DDK Consultant.
is based solely upon
independently verified
as
broker-dealer,
A list of managers that have informed Baird that
they have traded away from Baird during 2024 -
2025 and general information about the additional
cost of those trades (if any) is available on Baird’s
website at bairdwealth.com/retailinvestor. The
information about each manager provided on
the
Baird’s website
information provided to Baird by such manager.
Baird has not
the
information, and as a result, none of Baird or any
of its Associated Parties or associates makes any
representation as to the accuracy of any such
information.
incurred
A client should contact
the client’s DDK
Consultant or investment manager if the client
would like to obtain specific information about
trade aways and the amount of commissions or
other costs,
in
if any, the client
connection with step out trades.
Because a client does not pay commissions to
Baird when Baird, acting as broker-dealer,
executes a client’s trade orders, and because a
client generally would incur trading costs in
addition to the Advisory Fee if trade orders were
to be executed by another broker-dealer firm,
clients generally
receive a cost advantage
whenever Baird executes DDK client transactions.
For this reason, and given Baird’s execution
capabilities
investment
managers may determine that placing trade
orders for the client’s Account with Baird is the
most favorable option for the client. However,
investment managers may place a client’s trade
orders with a broker-dealer firm other than Baird
if the manager determines that it must do so to
comply with its best execution obligations. This
practice is frequently referred to as “trading
away” and these types of trades are frequently
called “step out trades”. A client’s trade order so
executed is then cleared and settled through
Baird in what is frequently referred to as a “step
in”.
the other
A client should note that each
investment
manager is solely responsible for ensuring that it
complies with its best execution obligations to the
client. A client should review the manager’s
trading for the client’s Account because DDK and
Baird do not monitor, review or evaluate whether
the manager is complying with its best execution
obligations to the client. A client should review
the manager’s Form ADV Part 2A Brochure,
inquire about the manager’s trading practices,
and consider that information carefully, before
selecting a manager. In particular, the client
should carefully consider any additional trading
costs the client may incur before selecting a
manager to manage the client’s Account.
In some instances, step out trades are executed
by
firm without any additional
commission or markup or markdown, but in other
instances, the executing firm may impose a
commission or a markup or markdown on the
trade. If a client’s investment manager places
trade orders for the client’s Account with a firm
other than Baird, and the other firm imposes a
commission or equivalent fee on the trade
(including a commission imbedded in the price of
the investment), the client will incur trading costs
in addition to the Advisory Fee.
A client should note that the client’s advisory
agreement permits DDK and Baird to trade as
principal on orders received from Other Managers.
See “Trade Execution Services Performed by
Baird—Principal Transactions” below for more
information.
Trade Execution Services Performed by Baird
If Baird provides trade execution services for a
client’s Account, Baird will generally act as agent
when routing client trade orders for execution.
Some managers have historically placed nearly all
client trades with broker-dealer firms other than
Baird for execution. Some managers have placed
nearly all or all client trades resulting from
changes to their model portfolios or strategies
with firms other than Baird. Similarly, some
managers have frequently placed client trade
orders for fixed income, foreign and small cap
securities with firms other than Baird. In some
cases, the other executing broker-dealer firm
imposes a commission or markup or markdown
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
sole discretion by notifying the client’s DDK
Consultant in writing.
Principal Transactions
However, Baird may cross trades between client
accounts or may act as principal for its own
account in certain circumstances to the extent
permitted by applicable law as is more fully
described below.
transactions.
Riskless
A client should understand that certain securities,
such as securities traded over-the-counter and
fixed income securities, are primarily traded in
dealer markets. When Baird purchases or sells
these types of securities for client accounts, it
generally does so through broker-dealer firms
acting as a dealer or principal. Dealers executing
principal trades typically
include a markup,
markdown or spread in the net price at which
transactions are executed. A client bears such
costs in addition to the Advisory Fee.
Agency Cross Transactions
except
in
limited
Subject to the requirements of applicable law,
Baird and DDK Consultants may execute
transactions for a client’s Account while acting as
principal for Baird’s own account. Baird and DDK
Consultants act as principal when they sell a
security from Baird’s inventory to a client or they
purchase a security from a client for Baird’s
inventory. Baird and DDK Consultants also act as
principal when they sell new issue securities to
clients in securities offerings underwritten by
Baird. Baird also acts as principal in riskless
principal
principal
transactions refer to transactions in which Baird,
after having received a client’s order, executes an
identical order in the marketplace to fill the
client’s order while acting as principal. Baird and
DDK Consultants commonly engage in principal
trades with clients in the Baird Advisory Choice
Program.
realize profits
in accordance with
DDK generally does not in engage in agency cross
transactions,
instances.
However, in certain circumstances and to the
extent permitted by applicable law and regulation,
Baird and DDK Consultants may effect “agency
cross” transactions with respect to a client’s
Account. An “agency cross” transaction is a
transaction in which Baird or its affiliates act as
broker for the party or parties on both sides of
the transaction. As compensation for brokerage
services, Baird may receive compensation from
parties on both sides of an agency cross
transaction, the amount of which may vary. DDK
Consultants may receive compensation from Baird
related to agency cross transactions. Therefore,
Baird and DDK Consultants may have a conflicting
division of loyalties and responsibilities. However,
in all cases, Baird and DDK Consultants will seek
to obtain the best execution for each respective
advisory client and will effect agency cross
the
transactions only
requirements of Rule 206(3)-2 under the Advisers
Act. Furthermore, Baird will comply with
additional regulations applicable to Retirement
Accounts.
interests of
incentive
to
agency
transactions
“agency
Baird may
from principal
transactions with a client based on the difference
between the price Baird paid for the security and
the price at which Baird sold the security, which
may include a markup, markdown or spread from
the prevailing market price, an underwriting fee,
selling dealer concession, or other incentive to
execute the transaction. DDK Consultants may
receive compensation
from Baird related to
principal trades of securities underwritten by
Baird. Any compensation received by Baird or a
DDK Consultant in a principal transaction is in
addition to the Advisory Fee paid by the client.
Principal trades also allow Baird to sell securities
from its account that it deems undesirable and to
buy securities for its account that it deem
desirable. Thus, in trading as principal with a
client, Baird and DDK Consultants will have
potentially conflicting division of loyalties and
responsibilities regarding their own interests and
the client. This potential
the
compensation may give Baird and DDK
Consultants an
recommend a
transaction in which Baird and DDK Consultants
transactions.
act as principal over other
Nonetheless, Baird and DDK Consultants have a
fiduciary duty to act in the client’s best interest
and to seek best execution for advisory clients.
Baird addresses this conflict through disclosure in
this Brochure. Furthermore, Baird has adopted
Where applicable, a client’s advisory agreement
discusses
and
cross
authorizes Baird and DDK Consultants to effect
agency cross transactions for a client’s Account. A
client’s authorization to Baird and DDK
to effect
Consultants
cross”
transactions
is given pursuant to Rule
206(3)-2 under the Advisers Act and may be
revoked at any time by the client in client’s
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and
venture
capital
and
internal procedures that require Baird and DDK
Consultants, when acting in a principal capacity,
to disclose all material information regarding
Baird’s interest in the transaction, and obtain the
client’s approval of the transaction prior to
settlement.
such
as
options,
is contained under
A client’s advisory agreement discloses, where
applicable, the possibility of Baird’s role in
potential principal
transactions, and each
transaction confirmation sent to DDK clients
discloses the capacity in which Baird served in the
transaction and whether Baird is a market maker
in each security the client bought or sold.
of
or
if
other
the Account
agricultural products), currencies, movements in
securities indices, credit spreads and interest
rates,
buyout
investments in private companies. Some Complex
Strategies engage in the use of margin or
leverage or selling securities short (“short sales”).
Some Complex Strategies invest in derivative
instruments
convertible
securities, futures, swaps, or forward contracts.
Complex Investment Products generally engage in
one or more Complex Strategies. Additional
information about Alternative Strategies and
the
Complex Strategies
“Portfolio Manager Selection and
heading
Evaluation—Methods of Analysis,
Investment
Strategies
Loss—Investment
and Risk
Strategies—Alternative Strategies and Complex
Strategies” below. Additional information about
Complex Strategies and Complex Investment
Products, generally, is provided below.
Non-Traditional Assets
currencies,
securities
tokens
investment
To the extent permitted by applicable law and
regulation, if a client’s Account participates in a
non-
Non-Discretionary Service
discretionary service, or
is
managed by an Other Manager, the client’s
advisory agreement provides Baird and DDK
Consultants with a blanket authorization to act as
principal for Baird’s own account in selling any
security to, or purchasing any security from, the
client’s Account. With this authorization, Baird
and DDK Consultants may effect any and all
principal transactions with the client’s Account
without having
to provide specific written
disclosures or obtain written client consent prior
to completion of each proposed principal trade,
subject to the requirements of an exemptive
order issued by the SEC to Baird (Rel. No. IA-
4596) and other applicable law and regulation.
This authorization to enable Baird and DDK
Consultants to trade as principal with a
client’s Account may be revoked at any time
by the client in client’s sole discretion by
notifying the client’s DDK Consultant in
writing.
Complex Strategies and Complex Investment
Products
Non-Traditional Assets, such as investments in
commodities,
indices,
interest rates, credit spreads, private companies,
and digital assets, such as cryptocurrencies, non-
stablecoins, and
fungible
(“NFTs”),
tokenized
products (collectively,
“Digital Assets”) may be used for diversification
purposes. They may also be used to try to reduce
market and inflation risk. The performance of
Non-Traditional Assets may not correspond to the
performance of the stock markets generally, and
investments
in Non-Traditional Assets will
generally impact an account’s returns differently
than more traditional investments like stocks or
bonds. Non-Traditional Assets are subject to risks
that are different from, and in some instances,
greater than, other assets like stocks and bonds.
Non-Traditional Assets are generally more difficult
to value, less liquid, and subject to greater
volatility compared to stocks and bonds.
Margin and Leverage
or
Margin
including by
investing
Some Services offer clients the ability to pursue
other Complex
Alternative Strategies
Strategies that involve special risks not apparent
in more traditional investments like stocks and
bonds. Complex Strategies may be pursued in
multiple ways,
in
alternative mutual funds, ETFs, hedge funds,
managed futures, private equity funds and SMAs
third party managers. Some
managed by
Complex Strategies
in Non-Traditional
invest
Assets, such as real estate, commodities (which
include metals, mining, energy and
may
Margin involves borrowing money from a firm,
such as Baird, to buy securities or other property.
If a client wishes to pay for securities by
borrowing part of the purchase price from Baird, a
client must open a margin account with Baird, and
Baird may provide the client with a margin loan.
Securities held in a client’s margin account are
used as Baird’s collateral for the margin loan. The
value of the collateral in the margin account must
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Options and Other Derivative Instruments
Derivative Instruments
instruments,
securities,
futures,
be maintained at a certain level relative to the
margin loan for the duration of the loan. If the
securities in the margin account decline in value,
so does the value of the collateral supporting the
margin loan, and as a result, Baird may take
action, such as issue a margin call and sell
securities in the account.
Leverage
instruments. While
returns,
than,
the
traditional
investments.
Investing
Leverage generally attempts to obtain investment
exposure in excess of available assets through the
use of borrowings, short sales and other
leverage can
derivative
potentially enhance
can also
it
exacerbate losses if changes in the markets, or
the values of the investments subject to the
leverage, are adverse to the strategy being
pursued. The use of leverage may also increase
an Account’s volatility.
involves
Short Sales
such as options,
Derivatives
convertible
swaps, and
forward contracts are financial contracts that
derive value based upon the value of an
underlying asset, such as a security, commodity,
currency, or index. Derivative instruments may be
used as a substitute for taking a position in the
underlying asset. Derivative instruments may also
be used to try to hedge or reduce exposure to
other risks. They may also be used to make
speculative investments on the movement of the
value of an underlying asset. The use of
derivative instruments involves risks different
from, or possibly greater
risks
associated with investing directly in securities and
other
in
derivatives also generally
leverage.
Derivatives are also generally less liquid, and
subject to greater volatility compared to stocks
and bonds.
to benefit
Options
Options transactions may involve the buying or
writing of puts or calls on securities. In some
cases, Baird may require clients to open a margin
account to engage in options trading.
security or
Short selling attempts
from an
anticipated decline in the market value of a
security. To affect a short sale, a client sells a
security the client does not own. When a client
sells a security short, Baird borrows the security
from a lender and makes delivery to the buyer on
the client’s behalf. Because short sales involve an
extension of credit from Baird to the client, a
client must use a margin account. A client must
also eventually purchase the same shares sold
short and return them back to the lender. It is
possible that the prices of securities that a client
sells short may increase in value, in which case
the client may lose money on the short position.
Short selling thus runs the risk of loss if the price
of the securities sold short does not decline below
the price at which they were originally sold. This
risk of loss is theoretically unlimited, as there is
no cap on the amount that the price of a security
may appreciate.
With a call option, the purchaser has the right to
buy, and the seller (writer) the obligation to sell,
the underlying
index at a
predetermined price (i.e., the exercise or strike
price) prior to expiration of the option. The
premium paid to the seller (writer) for the option
is in consideration for the underlying obligations
imposed on the seller should the option be
exercised. With a put option, the purchaser has
the right to sell, and the seller has the obligation
to buy, the underlying security or index at the
exercise price prior to expiration of the option.
Clients should note that investment managers
investment
managing a client’s Account or
products in the client’s Account may also engage
in short sales. Thus, a client’s Account will be
subject to short sales risks if the investment
manager managing the client’s Account or an
the client’s Account
in
investment product
engages in short sales.
In buying a call option, the purchaser expects
that the market value of the underlying security
or index will appreciate, which would enable the
purchaser of a call to buy the underlying security
or index at a strike price lower than the prevailing
market price. The purchaser of the call option
makes a profit if the prevailing market price is
greater than the sum of the strike price plus the
premium paid for the option. The seller of a call
option earns income in the form of the premium
received from the purchaser for the option and
expects that the market value of the underlying
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
futures, but also
security or index will depreciate such that the
option will expire without being exercised. The
seller of a call option makes a profit if the
prevailing market price of the underlying security
or index is less than the sum of the strike price
plus the premium received.
ETNs,
business
Investment Products, such as hedge funds, funds
of hedge funds, private equity funds, funds of
private equity funds, private debt funds, and
include other
managed
investments
pursuing Complex Strategies,
including but not limited to, exchange or swap
funds, leveraged funds, inverse funds, and other
special situation funds, structured certificates of
(“structured
structured notes
deposit and
products”),
development
companies (“BDCs”), real estate investment trusts
(“REITs”), and master
limited partnerships
(“MLPs”).
thereby making
website
In buying a put option, the purchaser expects that
the market value of the underlying security or
index will depreciate, which would enable the
purchaser of a put to sell the underlying security
or index at a strike price higher than the
prevailing market price. The purchaser of the put
option makes a profit if the prevailing market
price is less than the sum of the strike price and
the premium paid for the option. The seller of a
put option earns income in the form of the
premium received from the purchaser for the
option and expects that the market value of the
underlying security or index will appreciate such
that
the option will expire without being
exercised. The seller of a put option makes a
profit if the prevailing market price of the
underlying security or index is greater than the
difference between the strike price and the
premium.
In addition, a client should be aware that more
traditional investments, such as mutual funds,
ETFs, UITs and variable annuities may also pursue
them
Complex Strategies,
Complex Investment Products. A client should
carefully review the prospectus or other offering
document for each investment and understand
the strategy being pursued before deciding to
invest. More detailed information about mutual
funds, ETFs, UITs and variable annuities is
available
at
Baird’s
on
bairdwealth.com/retailinvestor.
Additional Important Information
losses
in
In purchasing a put or call option, the purchaser
faces the risk of loss of the premium paid for the
option if the market price moves in a direction
opposite to what the purchaser had expected. In
selling or writing an option, the seller faces
significantly more risk. A seller of a call option
faces the risk of significant loss if the prevailing
market price of the underlying security or index
increases above the strike price, and a seller of a
put option faces the risk of significant loss if the
prevailing market price of the underlying security
or index decreased below the strike price.
and
any
Clients should note that investment managers
managing a client’s Account or
investment
products in the client’s Account may also engage
in options transactions. Thus, a client’s Account
will be subject to options risks if the investment
manager managing the client’s Account or an
investment product
the client’s Account
in
engages in options transactions.
Complex Investment Products
The use of Complex Strategies or Complex
Investment Products is not appropriate for some
clients because they involve special risks. A client
should not engage in those strategies or invest in
those products unless the client is prepared to
experience significant
the client’s
Account. This is especially true for short selling,
which can result in unlimited losses as there is no
limit to the amount borrowed securities can rise in
value. See “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Principal Risks”
below for more information. Before using those
types of strategies or products, a client is strongly
urged to discuss them with the client’s DDK
Consultant
investment manager
managing the client’s Account. A client should
also carefully review the client’s agreements with
Baird and related disclosure documents, which the
client should have received when opening the
Account. Additional information about Complex
Strategies and Complex Investment Products is
provided under the heading “Portfolio Manager
Selection and Evaluation—Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment Strategies—Alternative Strategies and
Complex Investment Products typically invest
primarily in Non-Traditional Assets or engage in
one or more Complex Strategies. Complex
Alternative
Investment
Products
include
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Complex Strategies” below and on Baird’s website
at bairdwealth.com/retailinvestor.
Analysis, Investment Strategies and Risk of
Loss—Program Portfolio Strategies” below.
DDK or Baird may add Permitted Investments or
restrict client access to a Permitted Investment at
any time in their sole discretion.
for notifying
and
any
of
an
Account.
See
Some Permitted Investments contain restrictions
that limit their use, and clients will not be
permitted to purchase or hold such investments
outside
“Account
Requirements and Types of Clients” below for
more information.
A client assumes responsibility for engaging in
Complex Strategies and investing in Complex
Investment Products. If a client determines that
the client no longer wants to engage in those
strategies or invest in those products, the client is
responsible
the client’s DDK
Consultant
investment manager
managing the client’s Account. DDK and Baird are
not responsible for any losses resulting from any
Other Manager’s failure or delay in implementing
any such instructions.
In certain limited instances, Baird may allow a
client to hold an investment in an Account that is
an Unpermitted Investment.
“Advisory
Complex
Strategies
or
Interest
ALIGN, BairdNext Portfolios and UMA
Programs. The ALIGN, BairdNext Portfolios and
UMA Programs generally only permit investments
in certain mutual funds and ETPs, and with
respect to UMA Portfolios, SMA Strategies and
PWM-Managed Portfolios, that Baird has selected
for use in those Programs. For more information,
see the descriptions of each Program under
“Services, Fees and Compensation” above.
The use of Complex Strategies or Complex
Investment Products has a unique impact upon
the calculation of a client’s asset-based Advisory
Fee. See
Fees—Calculation and
Payment of Advisory Fees” below for more
information. A client should also understand that
Baird and the client’s DDK Consultant have a
financial incentive to use, select or recommend
certain
Complex
Investment Products, including margin and short
Information—Code of
sales. See “Additional
in Client
Ethics, Participation or
Transactions and Personal Trading” below.
for
Baird Advisory Choice Program. Permitted
Investments
the Baird Advisory Choice
Program generally include, but are not limited to,
the following types of investments:
As a creditor, Baird may have interests that are
adverse to a client. Neither DDK nor Baird will act
as investment adviser to a client with respect to
the liquidation of securities held in an Account to
meet a call on a margin loan. Any such sale of
assets will be executed in Baird’s capacity as
broker-dealer and creditor and may, as permitted
by law, result in executions on a principal basis.
• equity securities, including, but not limited to,
common stocks, American Depositary Receipts
(“ADRs”), and ordinary shares,
including
whether exchange-traded, or over-the-counter
traded;
Permitted Investments
stocks,
• fixed income securities, including but not limited
to, debt securities issued by domestic and
corporations and other entities;
foreign
preferred
securities
asset-backed
(including mortgage-backed securities and
collateralized mortgage obligations (“CMOs”));
convertible debt securities; obligations issued
by U.S., state, or foreign governments or their
agencies, instrumentalities, or authorities, such
as securities issued by the U.S. Treasury,
federal
federal government agencies or
government-sponsored enterprises
(“Agency
securities”), or foreign governments; municipal
funds;
securities; money market mutual
Under the Discretionary and Non-Discretionary
Services and UMA Programs, Baird determines the
asset categories and investment products that
clients may access for investment (“Permitted
Investments”) and those that are not permitted in
Program Accounts (“Unpermitted Investments”).
Permitted Investments vary by Service. Although
Baird determines the Permitted Investments
under those Services, the level of initial and
ongoing evaluation, monitoring and review that
DDK and Baird perform on Permitted Investments
varies. For more information, see the descriptions
of each Service under “Services, Fees and
Compensation” above and under
“Portfolio
Manager Selection and Evaluation—Methods of
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
certificates of deposit (“CDs”) (primary or
secondary); commercial paper;
The Unpermitted Investments
for the Baird
Advisory Choice Program generally include, but
are not limited to:
• rights or warrants on equity securities, and
written covered call and written cash secured
put equity options;
• Class B or Class C shares offered by mutual
funds or any other class of mutual fund shares
that impose a contingent deferred or level sales
charge (back-end or level load);
• inverse funds;
• UITs that impose an initial or deferred sales
load-waived, or
for purchase; shares
charge (load);
in
fee-based
• all annuities and insurance products, except for
variable annuities that have cost structures
investment
for use
designed
advisory programs;
or
options
on
• commodities,
futures
commodities, and commodity pools; and
investment
funds
• private
• open-end mutual funds shares that Baird has
selected for use in the Program, which generally
includes only those funds with which Baird has a
selling agreement and only those funds that are
institutional are
no-load,
that were
allowed
originally purchased
in a Baird brokerage
account and not sold when transitioned to an
advisory account will held in the account as
non-billable assets when the original purchase
was subject to a
front-end sales charge
(typically 36 months) or until the Contingent
Deferred Sales Charge (CDSC) expires (typically
13 months) if subject to a back-end sales
charge after which time they will be converted
to the appropriate advisory share class and
become billable assets;
and Complex
Investment Products that Baird has not selected
for use in the Program.
for use
in
for
and
DDK
• closed-end funds, ETFs, and UITs that have cost
structures designed
fee-based
investment advisory programs; UITs originally
purchased in a brokerage account and not sold
when transitioned to an advisory account will be
held as non-billable assets until the UIT
termination date at which time they will be
liquidated and the proceeds are billable;
Investment Management Service.
DDK
Unpermitted
Investments
Permitted
Investments
Investment
the
Management Service are generally the same as
the Baird Advisory Choice Program, except the
following types of investments are generally not
permitted
for DDK Investment Management
Service Accounts:
• put options; and
• BDCs, publicly-traded REITs, certain non
publicly-traded (or private) REITs, and MLPs
(which may be organized as limited liability
companies (“LLCs”));
• variable annuities.
• ETNs, opportunity zone funds, and other special
situation mutual funds, and exchange or swap
funds;
• certain hedge funds, funds of hedge funds,
private equity funds, funds of private equity
funds, funds of real estate, structured products,
private debt funds and managed futures that
Baird has selected for use in the Program;
SMA Services. Investment products under the
SMA Services are selected solely by
the
investment manager providing services to the
client. The investment products used by an
investment manager may include products that
Baird does not permit to be used in connection
with the other Programs and Services described
above. A client should review the investment
manager’s Form ADV Part 2A Brochure for more
information.
for use
fee-based
• variable annuities that have cost structures
designed
investment
in
advisory programs; and
Russell Program. The Russell Program generally
only permits investments in mutual funds and
ETFs selected by Russell, which will exclusively or
• cash and cash equivalents.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
substantially consist of Russell Funds, although
non-Russell Funds may be used.
negative Account performance. A client should
consult the client’s DDK Consultant for further
information.
Special Considerations for the Services
ALIGN, BairdNext Portfolios, Russell, SMA
and UMA Clients
Selection of Investment Options
Consulting Services. From time to time, DDK
may advise clients with respect to, or may
manage, certain Held-Away Assets such as
private REITs, real estate
investments, and
insurance products held by custodians other than
Baird even though those assets may not be
eligible for Accounts held at Baird. Any such
arrangement will be set forth in the client’s
advisory agreement.
Unsupervised Assets
or
supervised
by
them
Baird solely determines the investment options
made available to a client under the ALIGN,
BairdNext Portfolios, Russell and UMA Programs.
ALIGN, BairdNext Portfolios, Russell and UMA
Program Accounts will generally be invested in
mutual funds or ETPs, and, with respect to UMA
Portfolios, SMA Strategies or PWM-Managed
Portfolios. If Baird has discretion over a client’s
Account (or a portion thereof), Baird may invest
such Account (or such portion of an Account over
which Baird has discretion) in any investment
product it deems appropriate for the client’s
Accounts participating in those Programs.
Replacement of Investment Options
If a
If
a
client
holds
From time to time, Baird may remove mutual
funds, ETPs, SMA Strategies and PWM-Managed
Portfolios, from the ALIGN, BairdNext Portfolios,
Russell or UMA Programs, and Baird may replace
them with other mutual funds, ETPs, or SMA
Strategies or PWM-Managed Portfolios, as it
client’s Account
deems appropriate.
participates in those Programs, Baird may replace
any such investments in the client’s Account
whenever Baird removes the investment option
from those Programs. Baird may make such
in the client’s Account without
replacement
providing prior notice to, or obtaining the consent
of, the client.
Timing of Investment
to minimize potential negative
scheduled mutual
In certain instances, Baird may delay investing
client assets when Baird determines it is in the
client’s best interest to do so. For example, in
tax
order
consequences on a client, Baird may delay
investing assets
in a new ALIGN Strategic
Program Account when the Account is opened
shortly before a
fund
distribution date.
Asset Allocation Changes and Rebalancing
Under certain circumstances, Baird, in its sole
discretion, may accept a client request to hold an
asset in an Account that is not included in the
investment advisory services provided by Baird or
a DDK Consultant or otherwise monitored,
overseen
(an
“Unsupervised Asset”). For example, if Baird
to hold an Unpermitted
permits a client
Investment in an Account, the asset is typically
also considered an Unsupervised Asset. Baird, in
its sole discretion, may also designate an asset
that is otherwise a Permitted Investment as an
Unsupervised Asset under certain circumstances,
such as when a client acquires the asset in an
unsolicited transaction, transfers the asset from
an account held at another
firm or Baird
brokerage account, or continues to hold the asset
against Baird’s or the client’s DDK Consultant’s
recommendation.
an
Unsupervised Asset in an Account, the client
should understand that the Unsupervised Asset
may not be included in performance reports
provided to the client and that Baird and DDK
Consultants do not manage, provide investment
advice, or otherwise act as an investment adviser
with respect to the Unsupervised Asset, even if
the Unsupervised Asset is included in account
statements or performance reports provided to
the client. Because Baird and DDK Consultants do
not manage or provide investment advisory
services regarding Unsupervised Assets, no asset-
based Advisory Fee is charged on Unsupervised
Assets. While Unsupervised Assets are not subject
to the asset-based Advisory Fee, Baird may
impose additional fees upon Accounts holding
Unsupervised Assets. See “Other Fees and
Expenses” below for more information. A client
should also understand
that holding an
Unsupervised Asset in an Account may increase
the risk of trade errors, overinvestment, and
If a client’s Account participates in an ALIGN
Program, the BairdNext Portfolios Program, the
Russell Program, or a UMA Program, the client
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
target asset allocation strategy
asset allocations of its model portfolio strategies
or changes in market conditions, Baird’s opinion
on the future performance of particular asset
classes or the client’s financial circumstances.
Any rebalance of a client’s Account or other
change in asset allocation may result in taxable
gains or losses.
Overlay Manager
authorizes DDK and Baird to rebalance the client’s
Account assets to be consistent with the client’s
chosen
in
accordance with the rebalance option selected by
the client. When Baird rebalances a client’s
Account, all or only a portion of, the Account may
be traded. The rebalance options made available
under a Service may change at any time in DDK’s
and Baird’s discretion and may be different from
the rebalance options made available in another
Service.
for
Under the ALIGN or UMA Programs, the asset
allocation changes,
rebalancing, and other
changes described above may be performed or
implemented by the Overlay Manager.
Third Party Information
the ALIGN
Current rebalancing options
Program, the BairdNext Portfolios Program, the
Russell Program, and the UMA Program include:
(1) annually on the Account’s anniversary date;
or (2) quarterly whenever the Account’s allocation
to an asset class drifts by 3% or more from the
target allocation.
inconsistent with
and
When providing services to a client, DDK and
Baird rely on information provided by third parties
and other external sources believed to be reliable,
including, but not limited to, information provided
by investment managers. DDK and Baird assume
that all such information is accurate, complete
and current. DDK and Baird do not conduct an in-
depth review of, or verify, such information, and
they do not guarantee the accuracy of the
“Portfolio Manager
information used. See
Selection
Evaluation—Performance
Calculation” and “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Methods of Analysis”
below for more information.
DDK and Baird, at times, may adjust their typical
rebalancing of a client Account based on certain
tax considerations. For example, Baird will
generally not rebalance an Account, particularly
during the fourth calendar quarter, to the extent
doing so would be
its
implementation of tax management services for
the Account as described above. For more
specific, current information about the frequency
and conditions under which a particular Account
will be rebalanced, a client should contact the
client’s DDK Consultant.
Goal Management
service
impacted
by market
DDK and Baird reserve the right to delay or stop
the rebalancing of a client's Account if DDK or
Baird believes it is in the client’s best interest to
do so. For example, DDK and Baird oftentimes
delay rebalancing when doing so would cause the
client’s Account to recognize taxable gains in the
fourth quarter or have other negative tax
consequences on
the client’s Account. The
rebalancing of a client Account may be delayed or
negatively
events,
operational limitations or other conditions beyond
DDK’s or Baird’s control.
With respect to the ALIGN Strategic Portfolios
Program, the BairdNext Portfolios Program, the
ALIGN UMA Select Portfolios Program, and the
Russell Program, and with respect to Baird-
Managed Models in the UAS Portfolios Program,
Baird may also change a client’s asset allocation
for any reason, which may include, but shall not
be limited to, updates made by Baird to the target
DDK and Baird make available to clients an
(“Goal
optional goal management
Management”). Goal Management provides clients
the ability to set a single, overall investment
objective for all or a portion of assets selected by
the client with the flexibility of using multiple,
eligible Advisory Accounts that may have different
investment strategies or objectives. If a client
elects to have Baird implement a plan of Goal
Management (a “Goal Management Plan”) using
two or more eligible Advisory Accounts (“Goal
Management Accounts”), the Goal Management
Accounts, taken together, will be managed or
advised by Baird and client’s DDK Consultant in
such a way so as to seek to achieve a single,
overall goal or
investment objective (“Goal
Management Objective”) chosen by the client.
Each individual Account included in a Goal
Management Plan will also be managed or advised
in
by Baird and client’s DDK Consultant
accordance with the terms of the applicable
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
or
for
Advisory Program or Service and any investment
strategy or objective applicable to the Account.
However, to the extent consistent with the terms
applicable to an Account included in a Goal
Management Plan, each
individual Account
included in the Goal Management Plan may be
managed or advised in any manner believed by
Baird or the client’s DDK Consultant to be
the Goal
appropriate
necessary
Management Accounts, taken together, to seek to
achieve the Goal Management Objective.
risks,
and
would be able to achieve the Goal Management
Objective. It is likely that one or more Accounts
included in a Goal Management Plan, taken alone,
will be managed or advised differently and will be
subject to greater or enhanced risks than would
be the case if the Account alone had the same
objective as the Goal Management Objective.
Such enhanced risks include, without limitation,
market risks, investment objective and asset
allocation risks, capitalization risks, investment
style risks, illiquid securities and liquidity risks,
concentration risks, frequent trading and portfolio
risks, Non-Traditional Assets and
turnover
Complex
Complex
Strategies
Investment Product risks.
is contained under
The Goal Management Objectives that Baird
makes available to clients as part of Goal
Management include: (1) All Growth; (2) Capital
Growth; (3) Growth with Income; (4) Income
with Growth; (5) Conservative Income; and (6)
Capital Preservation. A description of those
objectives
the heading
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Loss—Investment Strategies—Asset
Risk of
Allocation Strategies” below.
included
in
A client should note, particularly if the client
elects to include eligible Advisory Accounts in a
Household Goal Management Plan, that: if an
Account is removed from a Goal Management
Plan for any reason, including if the client ceases
to be a member of the same household, the
Service and strategy for the Account removed
from the Goal Management Plan will remain
unchanged unless a change is requested by the
client; further, the Account removed from the
Goal Management Plan will not be allocated assets
from other Accounts
the Goal
Management Plan unless the client and all other
applicable clients, if any, consent and direct Baird
to do so and then only to the extent permitted by
applicable law; and DDK and Baird will have no
liability for implementing a Goal Management Plan
as requested by the client.
In certain circumstances, clients that are part of
the same household may include their eligible
Advisory Accounts in the same Goal Management
Plan (a “Household Goal Management Plan”). It is
the client’s sole responsibility to notify DDK that
the client is part of a household so that DDK is
aware of the client’s eligibility for a Household
Goal Management Plan. It is also the client’s sole
responsibility to notify DDK whenever the client
ceases to be part of a household if an Account is
part of a Household Goal Management Plan.
Failure to do so could have a materially negative
impact on applicable Accounts.
Tax Management and Values Overlay
Services
Many Services and managers make available tax
management strategies and services that are
intended to reduce the negative impact of U.S.
federal income taxes on an Account and enhance
Account performance by selectively
trading
investments in the Account to recognize or avoid
investment gains and losses.
An Account will be removed
from a Goal
Management Plan: (1) upon request or consent of
the client, (2) if the Account ceases to be an
eligible Advisory Account, (3) in the event the
Account is part of a Household Goal Management
Plan, if the client notifies DDK that the client
ceases to be a member of the applicable
household, or (4) upon written notice from Baird
that it is no longer able to manage the Account
according to the Goal Management Plan.
Certain Services and managers
include tax
management services as a default feature of the
Services or the manager’s services. A client that
wishes to opt an Account out of participation in a
tax management service should contact the
client’s DDK Consultant.
Given the nature of Goal Management, a client
enrolling Accounts in a Goal Management Plan
should understand that each Account enrolled in a
Goal Management Plan may not be invested in a
manner such that the individual Account alone
Tax management services are provided solely
information
the direction and
based upon
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Services unless the client opts out by contacting
the client’s DDK Consultant.
also offer
provided by a
client. The offering and
performance of tax management services to a
client’s Account does not constitute tax advice. A
client is ultimately responsible for all tax-related
consequences resulting from the client’s decision
to enroll in a Service or select a manager that
utilizes tax management services.
implementation of
tax
Certain DDK Consultants
management investment strategies (“DDK TM
Strategies”), described below, to non-Retirement
Accounts enrolled in DDK Consultant-directed
Services, including the Advisory Choice, DDK
Investment Management, and UAS Programs. A
client is encouraged to ask the client’s DDK
Consultant if DDK TM Strategies will be used if the
Account is enrolled in a Service. DDK Consultants
who offer DDK TM Strategies will generally
implement such strategies for Accounts they
manage on a discretionary basis unless a client
opts out by contacting
the client’s DDK
Consultant. The Baird PWM Home Office will assist
the DDK TM
the
with
Strategies.
investment strategy designed
for
tax
purposes
in
Information—Legal
and
and Risk
of
Each Baird TM Strategy and DDK TM Strategy is a
to
secondary
achieve a secondary objective of an Account to
reduce the negative impact of U.S. federal income
taxes and each such strategy is implemented
together with the other primary investment
strategies for the Account that are designed to
achieve the client’s primary investment objectives
or goals.
Tax management strategies are not intended to,
and likely will not, eliminate a client’s U.S. federal
income tax obligations relating to investments in
an Account. Like all investment strategies, there
is no guarantee that the implementation of a tax
management strategy will be successful. A client’s
use of a tax management strategy may not
actually
lower a client’s tax obligations or
otherwise achieve a client’s tax goals. The
effectiveness of tax managed strategies and
services may be negatively
impacted by
applicable tax rules, such as the IRS wash sales
rules and straddle rules, which will disallow, limit
or defer a client’s ability to recognize losses in an
Account
specified
circumstances. Tax management strategies and
services also involve special risks. See “Additional
Service
Tax
Considerations” and “Portfolio Manager Selection
and Evaluation—Methods of Analysis, Investment
Strategies
Loss—Investment
Strategies—Tax Management Strategies” below
for more information.
The Baird TM Strategies and DDK TM Strategies
features are not available to Retirement Accounts.
Tax Harvesting Strategy
A client should understand the terms of the tax
management services that will be implemented,
including the associated limitations, risks and
additional costs, if any, before enrolling an
Account in a Service or selecting a manager for
that Account. A client is strongly urged to consult
with the client’s tax advisor about potential tax
implications before enrolling an Account in a
Service or selecting a manager for that Account. A
client is also encouraged to discuss the client’s tax
management needs with
the client’s DDK
Consultant.
Baird and DDK Tax Management Strategies
As a default feature of the ALIGN Strategic
Portfolios, the BairdNext Portfolios, the Russell
Model Strategies and the UMA Programs, the
Baird PWM Home Office implements certain tax
management
investment strategies described
below (“Baird TM Strategies”) for each non-
Retirement Account enrolled in one of those
A tax harvesting strategy seeks to improve the
value of an Account, on a post U.S. federal
income tax basis, by offsetting capital losses in
the Account with capital gains. This strategy is
oftentimes referred to a “tax harvesting” or “tax
implementing a tax
loss harvesting”. When
harvesting strategy, the Baird PWM Home Office
or the DDK Consultant, as applicable, periodically,
but at least annually, conducts an assessment of
the Account to identify capital losses for tax
harvesting opportunities. When an opportunity is
identified, the Baird PWM Home Office or the DDK
Consultant, as applicable, sells (or recommends
the sale of) certain securities in the client’s
Account in order for the Account to recognize the
unrealized capital losses identified as part of the
assessment process. The Baird PWM Home Office
or the DDK Consultant will then reinvest (or
recommend the reinvestment of) the proceeds of
such sale in one or more replacement securities
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
included in the implementation of the strategy
only if the potential net U.S. federal income tax
benefit to the Account related to such position is
estimated by Baird to be $1,000 or more. For
purposes of calculating the $1,000 threshold, the
Account’s current unrealized gain or loss in each
mutual fund position is analyzed in light of the
applicable amount of capital gains distribution
announced by the mutual fund company.
Baird’s capital gains avoidance strategies are
generally not available to UMA Accounts and are
not an automatic feature of those Accounts.
that the Baird PWM Home Office or the DDK
Consultant, as applicable, believes are not
“substantially identical” for purposes of the IRS
wash sales rules. Replacement securities may
include, without limitation, ETFs, cash, cash
equivalents or other securities. Unless the client
instructs otherwise, investment in replacement
securities will be made on a temporary basis and
generally only for the duration of any applicable
IRS wash sale rule period, currently 30 days after
the sale, and within a reasonable time thereafter,
the proceeds will be reinvested in a manner
consistent with the way the Account was invested
prior to the employment of the tax harvesting
strategy.
Additional Important Information about Baird’s
and DDK’s Tax Management Strategies.
the
implementation of
the
implementation of a
Generally,
tax
harvesting strategy is limited to open end mutual
fund and ETF positions with unrealized capital
losses over $1,000 for U.S. federal income tax
purposes, unless Baird and the client otherwise
agree.
Capital Gains Avoidance Strategy
tax management
The
strategy is based upon Baird’s or the DDK
Consultant’s, as applicable, estimates of capital
gains and losses associated with investments in
client’s Account and information provided to them
by third parties, such as issuers of securities.
Capital losses will remain in an Account following
the implementation of a tax harvesting strategy,
and the Account will realize capital gains following
the implementation of a capital gains avoidance
strategy,
the extent such estimates or
to
information are incorrect.
identified as part of
The implementation of the tax harvesting strategy
and capital gains avoidance strategy (or the
recommendation to implement a strategy) is done
in the sole discretion of the Baird PWM Home
Office or DDK Consultant, as applicable, and
securities may be excluded from implementation
of such strategies for a number of reasons,
including without limitation, the length of time the
security has been in the Account, the lack of a
replacement security acceptable to Baird or the
DDK Consultant, withdrawal and deposit activity
in
the Account, market conditions deemed
unfavorable by Baird or the DDK Consultant, or if
doing so would, in Baird’s or the DDK Consultant’s
judgment, negatively impact management of the
Account.
A capital gains avoidance strategy seeks to avoid
capital gains attributable to an investment in the
Account for U.S. federal income tax purposes by
selling the investment before the capital gain is
distributed by the issuer. When implementing a
capital gains avoidance strategy, the Baird PWM
Home Office or the DDK Consultant, as applicable,
periodically, but at least annually, monitors the
issuers of investments held in the Account for
capital gains distributions announcements and
capital gains avoidance opportunities. When an
opportunity is identified, the Baird PWM Home
Office or the DDK Consultant, as applicable, sells
(or recommends the sale of) such securities in the
client’s Account
the
monitoring process in order for the Account to
avoid a capital gain distribution made by the
issuer. The Baird PWM Home Office or the DDK
Consultant will then reinvest (or recommend the
reinvestment of) the proceeds of such sale in cash
until the capital gain distribution has been paid by
the issuer, and then the securities will be
purchased again. If the securities are sold at a
loss, then Baird PWM or the DDK Consultant may
employ (or recommend the employment of) the
tax harvesting strategy described above.
Generally, the capital gains avoidance strategy is
limited to open end mutual fund positions in a
client Account, and a mutual fund position will be
The tax harvesting and capital gains avoidance
strategies are provided by Baird and DDK
Consultants on an Account-by-Account basis.
When employing such strategies for a client
Account, Baird does not monitor or consider the
trading activity in any other client account,
including any Account held at Baird or another
firm.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
A client should also note that when normal
trading activity
for the client’s
is resumed
Account, such activity could generate taxable
gains or losses.
Envestnet
about the Overlay Manager’s tax overlay services,
including the risks associated with those services,
is contained in a document entitled “Important
Information About Tax Overlay
Additional
Services
Asset
by
Provided
Management, Inc.” and is available upon request.
Third Party Manager Tax Management
Services
Some investment managers participating in the
SMA and UMA Programs offer tax management
services and others do not. A client should consult
the client’s DDK Consultant or review the
investment manager’s Form ADV Part 2A
Brochure for specific information.
Client-Directed Tax Management Strategies
If a client selects tax overlay or values overlay
services, the client should understand that DDK
and Baird do not determine the strategies used in
connection with such services, implement any
such strategies, or otherwise have any influence
over the Overlay Manager’s investment decisions,
and therefore, DDK and Baird are not responsible
for the tax overlay or values overlay services
provided by the Overlay Manager.
Investment Objectives
for an Account based upon
A client may direct DDK and Baird, and DDK and
Baird may agree, to implement an investment
strategy designed by the client or client’s tax
advisors for the client’s specific tax purposes (a
“client-designed strategy”). DDK and Baird do not
undertake any responsibility for the development,
evaluation or efficacy of any client-designed
strategy.
responsible
for
selecting
for
Overlay Manager Tax Overlay and Values
Overlay Services (UMA Programs Only)
Generally, every Account will have one of the
investment objectives described below. Although
a DDK Consultant may recommend an investment
the
objective
information provided by a client, the client is
ultimately
the
investment objective
the Account. The
investment objective will determine, in part, and
limit the Services, investment products and
services that will be made available to the
Account.
All Growth. An All Growth investment objective
typically seeks to provide growth of capital.
Typically, an Account pursuing an All Growth
investment objective will experience high
fluctuations in annual returns and overall market
value. Under normal market conditions, such an
Account generally invests nearly all of its assets in
equity securities. Such an Account may also hold
other types of investments.
the
individual
securities
that
Capital Growth. A Capital Growth investment
objective typically seeks to provide growth of
capital. Typically, an Account pursuing a Capital
investment objective will experience
Growth
moderately high fluctuations in annual returns
and overall market value. Generally, under
normal market conditions, such an Account will
primarily invest in a mix of equity securities and
fixed income securities, with a significantly higher
allocation to equity securities. Such an Account
may also hold other types of investments.
Growth with Income. A Growth with Income
investment objective typically seeks to provide
The Overlay Manager offers an optional tax
overlay service and a values overlay service in
connection with the UMA Programs. The Overlay
Manager’s tax overlay service seeks to consider
tax implications that may detract from the client’s
after-tax returns. The Overlay Manager’s values
overlay service provides a client the opportunity
to restrict investments in companies that derive
revenues from certain business areas or that are
involved in certain business activities that the
client may find objectionable. A client that wishes
to enroll in one or more of those services can do
so by contacting the client’s DDK Consultant.
These services provided by the Overlay Manager
may involve direct indexing strategies (also
known as direct index investing), whereby a client
are
owns
index
constituents of a selected benchmark
instead of a pooled investment vehicle, such as a
mutual fund or ETF, which presents certain risks
and may not be appropriate for certain clients.
The Overlay Manager charges an additional fee
for tax and values overlay services. The cost of
tax and values overlay services are generally the
same whether the client enrolls in one or both
services. The amount of the tax or values overlay
fee will be disclosed to a client prior to enrolling
an Account in the service. Additional information
46
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
for
a
client’s
specific
moderate growth of capital and some current
income. Typically, an Account pursuing a Growth
with Income investment objective will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of equity securities and fixed
income securities, with a bias towards equity
securities. Such an Account may also hold other
types of investments.
investment
objective
various investment categories to take advantage
of the manager’s perception of market pricing
anomalies, market sectors deemed favorable for
investment by the manager, the current interest
rate environment or other macro-economic trends
identified by the manager to achieve growth while
accounting
short,
intermediate and long term investment and/or
cash flow needs. Depending upon the investment
strategy used, an Account pursuing an
Opportunistic
could
experience high fluctuations in annual returns and
overall market value. The types of investments in
which such an Account may invest will also vary
widely, depending upon the particular investment
strategy used.
long-term growth by
investments based upon
Income with Growth. An Income with Growth
investment objective typically seeks to provide
current income and some growth of capital.
Typically, an Account pursuing an Income with
Growth
investment objective will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, such an Account will primarily
invest in a mix of fixed income securities and
equity securities, with a bias towards fixed income
securities. Such an Account may also hold other
types of investments.
in
to
implement a
typically
objective
and
overweighting
index or
Tactical. A tactical investment objective seeks to
provide
tactically and
actively adjusting account allocations to different
categories of
the
manager’s perception of how those investment
the short-term.
categories will perform
tactical
Strategies used
involve
investment
underweighting
account
allocations to certain asset classes, geographic
locations or market sectors relative to an
applicable long-term strategic asset allocation,
benchmark
the market generally.
Accounts with a tactical investment objective may
have investments focused or concentrated in
certain asset classes, geographic locations or
market sectors and they often experience higher
levels of trading and portfolio turnover relative to
accounts with other investment objectives.
Conservative Income. A Conservative Income
investment objective typically seeks to provide
current income. Typically, an Account pursuing a
Conservative Income investment objective will
experience relatively small fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, such an Account
will primarily invest in a mix of fixed income
securities, cash and equity securities, with a
significantly higher allocation to fixed income
securities. Such an Account may also hold other
types of investments.
A
Tax-Managed
indicates
that
the
account
investment
Tax-Managed.
objective
is
transitioning from one investment strategy to
another using one or more tax management
strategies or tax management considerations. The
primary investment strategy or consideration for
Accounts with a Tax-Managed
investment
objective will involve tax management, and such
accounts may not be successful in pursuing any
other investment strategies, objectives or goals.
Capital Preservation. A Capital Preservation
investment objective typically seeks to preserve
capital while generating current income. Typically,
an Account pursuing a Capital Preservation
investment objective will experience relatively
small fluctuations in annual returns and overall
market value. Under normal market conditions,
such an Account generally invests nearly all of its
assets in a mix of fixed income securities and
cash. Such an Account may also hold other types
of investments.
Goal. A Goal investment objective indicates that
the Account is a Goal Management Account that is
part of a Goal Management Plan and the Account
will be managed or advised in accordance with
the applicable Goal Management Objective.
Opportunistic. An Opportunistic
investment
objective typically seeks to provide long term
growth
through capital appreciation and/or
income by utilizing an active management style
that shifts the percentage of assets held in
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
of
Investment Objectives
For information about the risks associated with
the investment objectives described above, see
the section of the Brochure entitled “Portfolio
Manager Selection and Evaluation—Methods of
Analysis, Investment Strategies and Risk of
Loss—Principal Risks—Risks Associated with
Certain
and Asset
Allocation Strategies” below.
Mutual Fund Share Class Policy
including
based Advisory Fee (sometimes referred to as
“unbillable assets”) for such period of time that
Baird collects and retains the distribution (12b-1)
fee as further described under the heading
“Additional
Ethics,
Information—Code
Participation or Interest in Client Transactions and
Personal Trading—Participation or Interest
in
Client Transactions—Investment Product Selling
or Servicing—Mutual Funds” below. Clients should
note that the Approved Share Class for a mutual
fund family is based upon the average expense
ratio for the class across all mutual funds in the
fund family and not on a fund-by-fund basis.
Further, the expenses of every mutual fund can
and will vary over time. Therefore, while Baird
has endeavored to select the lowest cost share
classes as described above, in some instances,
the Approved Share Class is not the least
expensive share class for a particular mutual
fund. Clients may be able to obtain a less
expensive share class in other Programs or at
another firm.
payments,
revenue
sharing
the applicable mutual
Interest
Baird receives certain compensation from mutual
fund families in the form of distribution (12b-1)
fees, shareholder servicing fees, transfer agency
fees, networking fees, accounting fees, marketing
support
and
administration fees. The amount of compensation
paid to Baird generally varies based upon the
fund
share class of
purchased by clients. Because the compensation
that Baird receives from certain mutual funds is
based upon share class purchased by clients,
Baird has a financial incentive to make available
to clients those share classes that provide Baird
greater compensation, which, in many instances,
would cause clients investing in those share
classes to incur higher ongoing costs relative to
other share classes made available by the fund
families. This presents a conflict of interest. Baird
addresses this conflict through the Share Class
Policy described above and through disclosure in
this Brochure. For more information about the
compensation that Baird receives from mutual
funds, see “Additional Information—Code of
Ethics, Participation or
in Client
Transactions and Personal Trading—Participation
or Interest in Client Transactions—Investment
Product Selling and Servicing—Mutual Funds”
below.
Most mutual funds offer different share classes.
While each share class of a given mutual fund has
the same underlying investments, those share
classes have different fees, costs and investment
minimums, and they provide different levels of
compensation to Baird. In an effort to provide
clients with appropriate low cost mutual fund
investment options for their fee-based investment
advisory accounts, Baird has established a mutual
fund share class policy (“Share Class Policy”) for
certain DDK-directed Services,
the
Advisory Choice, DDK Investment Management,
and UAS Services (the “Share Class Policy
Services”). Typically, only one share class of a
given mutual fund family will be made available
for purchase by clients in the Share Class Policy
Services pursuant to the Share Class Policy (the
“Approved Share Class”). When selecting the
Approved Share Class for a mutual fund family,
Baird endeavors to select the share class with the
lowest expense ratio, based upon the average
expense ratio of the class across all mutual funds
in the mutual fund family, that are widely
available for trading on the mutual fund trading
platform of Charles Schwab & Co.,
Inc.
(“Schwab”). In selecting the share class for a
mutual fund family to be made available for
purchase by clients in the Share Class Policy
Services, Baird considers a number of factors,
including the number of funds within the fund
family that offer the share class, client positions
in and demand
funds, and the
for those
availability of the share classes and funds for
purchase on the Schwab mutual fund trading
platform. Generally, share classes designed for
retirement plans and those that pay a distribution
(12b-1) fee to Baird will not be permitted in those
Services, or, if such share classes are permitted
and the client’s Account is subject to an asset-
based fee arrangement, Baird will either: (1)
rebate the distribution (12b-1) fees to a client if
the client is paying an asset-based Advisory Fee
on such investment; or (2) exclude such fund
shares from the calculation of the client’s asset-
Shares of mutual funds held in client Accounts
that do not meet the requirements of the Share
Class Policy will generally be converted to the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
applicable Approved Share Class subject to
certain restrictions. The Share Class Policy is
subject to change at Baird’s discretion without
notice to clients. Additional information about the
Share Class Policy is available on Baird’s website
at bairdwealth.com/retailinvestor.
to client Accounts on
The Share Class Policy does not apply to the
portion of a UAS Account managed by third party
managers. Third party managers are responsible
for establishing their own criteria for selecting
investments, including mutual funds, if any.
Custody Services
from
Certain Services may require clients to custody
their Account assets at Baird. If Baird is the
custodian of a client’s assets, Baird will provide
certain custody services, including holding the
client’s Account assets, crediting contributions
and interest and dividends received on securities
held in a client’s Account, and making or
the Account.
“debiting” distributions
Information about account statements and
performance reports, if any, that DDK and Baird
provide to clients is contained under the heading
“Services, Fees and Compensation–Consulting
Services” above and “Additional Information—
Review of Accounts” below.
The client should also understand that the client
will pay a custody fee to the third party custodian
in addition to the Advisory Fee. Baird may also
impose additional fees on Accounts with assets
held by a third party custodian due to the
increase in resources needed to administer those
Accounts. Further, such third party custody
arrangements may
limit the Services made
available to the client. In addition, a client should
understand that: (a) each third party custodian
has exclusive control over the investment options
made available
the
custodian’s platform; (b) DDK and Baird have no
authority or ability to add to, or remove from, a
custodian’s platform any investment option; (c)
any advice given by DDK or Baird with respect to
the Account is inherently limited by the options
available through a custodian’s platform; (d) DDK
or Baird may have provided different investment
advice with respect to the Account had they not
been limited to the investment options made
available through the custodian’s platform; and
(e) certain investments, such as mutual fund
shares, could be more or less expensive than if
the investment was obtained from Baird or
another firm. A client should further note that
DDK and Baird may not provide performance
review or reporting for Held-Away Assets. In
addition, a client who uses a third party custodian
is not eligible for cash sweep services offered by
Baird. Clients using a third party custodian are
encouraged to establish appropriate cash sweep
arrangements.
As custodian, Baird may hold a client’s Account
assets in nominee or “street” name, a practice
that refers
to securities and assets being
registered in Baird’s name or in a name that Baird
designates, rather than in a client’s name directly.
Baird will be the holder of record in those
instances.
Baird may utilize one or more subcustodians to
provide for the custody of a client’s assets in
certain circumstances. For instance, Baird utilizes
subcustodians to maintain custody of certain
client assets participating in the Cash Sweep
Program (described below) and securities that are
traded on foreign exchanges.
(e.g.,
A client who uses a third party custodian
authorizes DDK and Baird to give instructions to
the client’s custodian for all actions necessary or
incidental to the purchase, sale, exchange, and
delivery of securities held in the client’s Account.
Also, the client will receive account statements
directly from the client’s selected custodian. A
client should carefully review those account
statements and
them with any
compare
statements provided by DDK or Baird. A client
should note that the prices shown on a client’s
Account statements provided by the custodian
could be different from the prices shown on
statements and reports provided by DDK or Baird
due to a variety of factors, including the use of
different valuation sources and accounting
methods
settlement date
trade or
accounting) by the custodian and Baird.
DDK and Baird in their sole discretion may accept
into a client’s Account,
Held-Away Assets
including assets
that are held by another
custodian (a “third party custodian”). A client who
uses a third party custodian to hold Account
assets does so at the client’s risk. A client should
understand that DDK and Baird do not monitor,
evaluate or review any third party custodian
unless they otherwise agree to do so in writing.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Cash Sweep Program
the program. More information about the Money
Market Fund Feature of Baird’s Cash Sweep
Program is available at rwbaird.com/cashsweeps.
to provide FDIC
The Bank Sweep Feature seeks to provide FDIC
insurance protection for a client’s cash balances
up to an aggregate deposit limit determined
under the program. Any deposits, including CDs,
that a client maintains, directly or indirectly
through an intermediary (such as us or another
broker), with a bank participating in the Cash
Sweep Program in the same capacity with the
bank will be aggregated with the client’s cash
balances deposited with the bank under the Cash
Sweep Program for purposes of calculating the
$250,000 FDIC insurance limit. Total deposits
exceeding $250,000 at a bank may not be fully
insured by the FDIC. A client is responsible for
monitoring the total amount of other deposits that
the client has with a bank outside the Cash Sweep
Program in order to determine the extent of
deposit insurance coverage available. Baird is not
responsible for any insured or uninsured portion
of a client’s deposits at a bank. Cash invested in a
money market mutual fund under the Money
Market Fund Feature is not FDIC insured, but is
Investor Protection
protected by Securities
Corporation (“SIPC”) coverage up to applicable
limits.
receives
compensation
for
is
available
Baird maintains a Cash Sweep Program that is
intended for clients who want to earn interest and
receive FDIC insurance protection on their cash
over short periods of
time while awaiting
investment. If a client participates in Baird’s Cash
Sweep Program, uninvested cash in the client’s
accounts will be automatically deposited or swept,
on a daily basis, into one or more FDIC-insured
deposit accounts at participating banks (the “Bank
Sweep Feature”) or, under certain conditions, will
be automatically invested in shares of a money
market mutual fund that Baird makes available in
the program (the “Money Market Fund Feature”),
subject to the terms and conditions of the
program. By using multiple participating banks as
opposed to a single bank, the Bank Sweep
Feature seeks
insurance
protection for a client’s cash balances of up to an
aggregate deposit limit determined under the
program (currently, $2,500,000 for most account
types and $5,000,000 for joint accounts). A client
receives interest on cash balances in deposit
accounts under the Bank Sweep Feature at tiered
rates that are based on the aggregate value of
the accounts within the client’s household. The
applicable client household tier values are: less
than $1 million; at least $1 million but less than
$2 million; at least $2 million but less than $5
million; and $5 million are more. Current rate
at
information
rwbaird.com/cashsweeps. Each deposit account at
a bank constitutes a direct obligation of the bank
and is not directly or indirectly Baird’s obligation.
account
values
of
less. For
Any aggregate cash balances held by a client in
excess of the applicable aggregate deposit limit
are automatically invested in shares of a money
market mutual fund that Baird makes available in
the Money Market Fund feature of the program.
Cash held in employee benefit plan accounts,
employee health and welfare plan accounts, donor
advised fund accounts, and SEP and SIMPLE IRAs
will be automatically invested or swept into a
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the program. In addition, clients with aggregate
cash balances of $5 million or more across all of
their accounts with Baird within the same
household may opt out of the Bank Sweep
Feature and instead have all of their cash
balances automatically swept into an institutional
money market mutual fund that Baird makes
available under the Money Market Fund Feature of
the
Baird
administrative, accounting and other services that
Baird provides under the program, which is paid
out of the aggregate interest that is paid by the
participating banks on the aggregate client
balances in the deposit accounts participating in
the Bank Sweep Feature. Baird’s annual rate of
compensation may be up to 3.60% of the
for clients with
aggregate client balances
than
less
household
$1,000,000, 2.45% for clients with household
account values of $1,000,000 but less than
$2,000,000, 2.00% for clients with household
account values of $2,000,000 but less than
$5,000,000, and 1.75% for clients with household
account values of $5,000,000 or more. In a lower
interest rate environment Baird’s annual rate of
compensation will be
fee-based
investment advisory IRA accounts participating in
the Bank Sweep Feature, Baird’s compensation is
a monthly per account fee (which is the same
regardless of client balances in bank deposit
accounts). The per account fee for these advisory
IRA accounts is generally paid out of the interest
that the banks pay on aggregate client balances
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
on
website
More detailed information about the Cash Sweep
Program and the compensation Baird receives is
available
at
Baird’s
client also
www.rwbaird.com/cashsweeps. A
receives information about the compensation
Baird receives from the Cash Sweep Program
through a client’s account statements.
Trust Services Arrangements
trust administration
trust administration, custody,
its
related
to
those assets, and
in the deposit accounts, and the per account fee
varies based on the applicable Fed Funds Target
Rate but in no event will it exceed $19.00 per
month. Baird also receives an annual rate of
compensation of up to 0.50% of the aggregate
client balances automatically invested into money
market mutual funds under the Money Market
Fund Feature. A client should note that the client
will be charged the asset-based Advisory Fee on
the value of all of the assets in the client’s
Accounts, including cash that is swept into a bank
deposit account or invested into a money market
mutual fund under the Cash Sweep Program. As a
result, Baird receives two layers of fees on a
client’s assets swept or invested in the Cash
Sweep Program:
the Advisory Fee, which
compensates Baird for the investment advice,
trading and custody services provided to the
client
the
compensation paid by the banks or money market
funds related to those assets, which compensates
Baird for the services Baird provides to the banks
and funds and for Baird’s efforts in maintaining
the Cash Sweep Program. The compensation that
Baird receives from the Cash Sweep Program
gives Baird a financial incentive to recommend
that a client participate in the Cash Sweep
Program and maintain high levels of uninvested
cash balances in the client’s accounts.
any
trust
financial
incentive
to
As an alternative to the Cash Sweep Program,
Baird makes available other money market
mutual funds and other cash alternatives in which
a client may invest, often at a higher yield,
although these investments do not have an
automatic sweep feature. In addition, instead of
maintaining cash balances in an advisory Account,
a client has the option to maintain such cash
balances in a brokerage account that is not
subject to an asset-based Advisory Fee.
it
Baird maintains an alliance with
certain
institutions, both non-affiliated and affiliated,
including Baird Trust Company (“Baird Trust”),
services,
that provide
including
tax
reporting and recordkeeping. DDK Consultants at
times refer clients seeking trust services to
institutions that are members of the alliance.
Subject to
fiduciary duties, the trustee
oftentimes retains Baird to provide investment
advisory services to the client trust. A client
should understand that any such referral for trust
services under the Trust Alliance Program made
by Baird and its DDK Consultants is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
oversee
services
such
arrangement. Baird has a financial incentive to
recommend that clients use Baird Trust, an
affiliate, over other non-affiliated trust companies.
As a result of this affiliation, Baird Trust also has
a financial incentive to retain Baird to provide
investment advisory or other services on behalf of
the client. In addition, Baird and DDK Consultants
have a
recommend
arrangements that involve Baird and the DDK
Consultant providing investment advisory services
to the client and the trust company only providing
trust administration services compared to an
arrangement whereby a trust company would
investment advisory and trust
provide both
administration services because
is more
profitable to Baird and the DDK Consultant.
in connection with
A client should understand that the Cash Sweep
Program is an ancillary account service and it is
not nor is it part of any advisory program or
investment advisory service. DDK and Baird do
not act as investment adviser or a fiduciary to a
client
the Cash Sweep
Program. However, a client should note that the
amount of the client’s advisory Account dedicated
to cash and cash equivalents is part of the overall
investment allocation advice provided to the client
and thus the amount of such cash and cash
equivalents included in the calculation of the
Advisory Fee for the client’s advisory Account.
In addition, outside of the Trust Alliance Program,
DDK Consultants may refer a client to Baird Trust
to provide investment management and trust
administration services to the client. If a client
enters into such a relationship with Baird Trust,
Baird and the client’s DDK Consultant typically
relationship management
provide
provides
services.
ongoing
Baird
Trust
generally
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
a cash need. Because the interest Baird receives
and fees Baird earns on a client’s Accounts
increase as the amount of the client’s margin loan
increases, Baird and DDK Consultants also have
an
incentive to recommend that the client
continue to maintain a margin loan balance with
Baird at high levels. Baird has the right to lend
the securities a client pledges as collateral for the
client’s margin loan, and Baird receives additional
compensation for lending those securities, which
provides Baird a further incentive to recommend
margin to a client.
compensation to Baird and the client’s DDK
Consultant for the referral and providing ongoing
services, which may be up to 50% of the ongoing
fees that a client pays to Baird Trust, and which is
credited to the client’s DDK Consultant for
purposes of determining the DDK Consultant’s
compensation. The compensation paid to Baird
and a client’s DDK Consultant does not increase
the fees that the client pays to Baird Trust. Due to
Baird’s affiliation with Baird Trust and the
compensation paid to Baird and DDK Consultants,
Baird and DDK Consultants have a financial
incentive to favor Baird Trust over other trust
companies.
Margin Loans
A client should note that Baird’s margin loan
program is generally intended to be used to fund
additional purchases of securities. or short-term
liquidity needs. If a client wishes to obtain a loan
for some other purpose, a client should instead
consider whether the client is eligible for Baird’s
Securities-Based Lending Program, which involves
clients obtaining loans from third-party lenders for
general use purposes. Baird and DDK Consultants
have a conflict to the extent they would
recommend that a client use the Baird margin
loan program instead of the Securities-Based
Lending Program because a client pays interest
and other fees to Baird instead of a third-party
lender.
visit
website
contact
Additional important information about margin,
including the risks and margin interest rates that
apply, is set forth in the “Margin” section of
Baird’s website at bairdwealth.com/retailinvestor.
Securities-Based Lending Program
loan, Baird has an
incentive
that any margin balance
(i.e.,
the
loan or
Margin involves borrowing money from Baird
using eligible securities as collateral, including for
the purpose of buying securities. If a client uses
margin, the client will pay Baird interest on the
amount the client borrows. The rate of interest
that a client pays on a margin loan will be at a
base rate determined by Baird plus or minus a
specified percentage that varies based on the
outstanding debit balance of the margin loan and
the client’s household account value. Interest
rates are lower for larger debit balances and
those with higher household account balances. As
a result, rates will vary. To determine the actual
interest rate that may apply to a client’s margin
at
Baird’s
loan,
rwbaird.com/loanrates
a DDK
or
Consultant. Because a client will pay interest to
Baird on the outstanding balance of the client’s
margin
to
recommend to the client investment products and
services that involve the use of margin. Baird and
DDK Consultants also have an incentive to
recommend investment products and services
that involve the use of margin, because a margin
loan allows a client to make larger securities
purchases and retain assets
in the client’s
Accounts
that pay an ongoing asset-based
Advisory Fee instead of liquidating them to fund a
cash need, which increases the asset-based fees
Baird earns on a client’s Accounts. A client should
note
the
outstanding amounts of the margin loan the client
owes to Baird) in the client’s advisory Accounts
will not be applied to reduce the client’s billable
account value in calculating the client’s asset-
based Advisory Fee, which gives Baird and DDK
Consultants further incentive to recommend client
use of margin instead of liquidating assets to fund
Baird offers clients an opportunity to borrow
money from a third party lender under Baird’s
Securities-Based Lending Program. These loans, if
made, can be used for any personal or business
purpose other than to purchase, carry or trade
securities, or to repay margin debt. These loans
are secured by the investments and other assets
in the client’s accounts with Baird. A client will
pay interest on the outstanding balance of the
client’s loan. The rates of interest charged by the
bank depends on many factors, such as the
prevailing interest rate environment, the amount
of
line of credit, a client’s
creditworthiness, and the aggregate assets in a
client’s Baird accounts in the client’s household
(“relationship size”). The interest rates are based
on a benchmark
rate, plus an applicable
percentage that varies based on the approved
loan amount and the relationship size. Rates are
52
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Other Non-Advisory Services
Certain Baird associates from time to time may
provide clients with tax return preparation, bill
pay or related services. In some instances, the
fee for those services may be bundled with the
Advisory Fee. A client should understand that the
provision of such services is separate from, and
not related to, the Services offered under this
Brochure and will be governed by an agreement
separate from the client’s advisory agreement
with Baird. A client should understand that Baird
and its associates do not act as investment
advisor or fiduciary to the client when providing
tax return preparation, bill pay or related non-
advisory services to the client.
Client Responsibilities
informing
the
financial
incentive
of
website
generally higher for smaller loans and relationship
sizes and lower for larger loans and relationship
sizes. The interest rate that will apply to a client’s
loan will be set forth in the loan agreement the
client enters into with the bank. Baird receives an
ongoing administrative fee from the bank, at an
annual rate of up to 2.50% of the outstanding
balance under a client’s loan, which is paid by the
bank out of the interest the client pays to the
bank. A client’s DDK Consultant typically receives
an ongoing referral fee at an annual rate of up to
0.25% of the outstanding balance of the client’s
loan, which is paid out of Baird’s administrative
fee. A client should note that Baird and DDK
Consultants will continue to receive compensation
on assets held in the client’s accounts that serve
as collateral for the client’s loans, including
receives an
Advisory Fees. Because Baird
administrative fee and DDK Consultants receive a
referral fee if a client obtains a loan from a third
party
lender under Baird’s Securities-Based
Lending Program, Baird and DDK Consultants
have an incentive to recommend that a client
obtain loans under that program. Baird and DDK
Consultants will continue to receive compensation
on assets held in a client’s accounts that are
collateral for such loans, including Advisory Fees
on such assets if those assets are in the client’s
advisory Account. As a result, Baird and DDK
Consultants have a
to
recommend that a client obtain a loan under the
program to provide for the client’s needs instead
of liquidating assets in the client’s accounts with
Baird because a decline in the amounts the client
has in the client’s accounts will result in lower
revenues to Baird and compensation paid to the
client’s DDK Consultant. Additional important
information about securities-based lending is set
forth in the “Securities-Based Lending Program”
at
Baird’s
section
bairdwealth.com/retailinvestor.
A client is responsible for providing information to
Baird and the client’s DDK Consultant reasonably
requested by them in order to provide the
services selected by the client. Baird, the client’s
DDK Consultant and investment managers, if any,
will rely on this information when providing
services to the client. A client is also responsible
for promptly
client’s DDK
Consultant of any significant life changes (e.g.,
change in marital status, significant health issue,
or change in employment) or if there is any
change to the client’s investment objectives, risk
tolerance,
investment
financial circumstances,
needs, or other circumstances that may affect the
manner in which the client’s assets are invested.
None of Baird, the client’s DDK Consultant or any
investment manager managing a client’s Account
for any adverse consequence
is responsible
arising out of the client’s failure to promptly
inform the client’s DDK Consultant of any such
changes. Since investment goals and financial
circumstances change over time, a client should
review the client’s participation in a Service with
the client’s DDK Consultant at least annually.
Retirement Accounts
A client should understand that any referral made
by Baird and DDK Consultants under
the
Securities-Based Lending Program is an ancillary
account service and it is not an, nor is it part of
any, Advisory Program or investment advisory
service. They do not act as investment adviser or
a fiduciary to the client when making such a
referral and they will not provide advice on or
oversee any such lending arrangement.
Additional laws, regulations and other conditions
apply to Retirement Accounts. Each owner,
trustee, plan
sponsor, adopting employer,
responsible plan fiduciary, named fiduciary, or
other fiduciary acting on behalf of a Retirement
Account (“Retirement Account Fiduciary”) should
understand that DDK and Baird do not provide
legal advice regarding Retirement Accounts. A
Retirement Account Fiduciary is urged to consult
with his or her own legal advisor about the laws
and regulations that may apply to Retirement
53
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Accounts. ERISA and the IRC prohibit DDK and
Baird from offering certain types of investment
products and services to Retirement Accounts.
the Services,
Legal and Tax Considerations
the
tax
implications of
A client’s investment activities may have legal
and tax consequences to the client.
purchases,
sales,
The investment strategies used for a client’s
Account and transactions in a client’s Account,
including
liquidations,
redemptions, and rebalancing transactions, may
cause the client to realize gains or losses for
income
tax purposes. Funds often make
distributions of income and capital gains to
investors, which may cause the client to realize
income for tax purposes.
DDK and Baird do not offer legal or tax advice to
clients. The information, recommendations, and
services provided by DDK and Baird to clients
including, without
through
limitation, tax management strategies, do not
constitute tax advice. A client is responsible for
understanding
the
investment activities in the client’s accounts
(whether held at Baird or another firm) and
complying with applicable tax rules. A client is
strongly urged to consult with the client’s tax
advisor about potential tax implications before
making investment or trading decisions. DDK and
Baird do not undertake any responsibility to
monitor or verify a client’s compliance with
applicable tax rules, and they are not responsible
for any tax‑related effects or obligations resulting
from the investments or transactions in a client’s
Account.
Advisory Fees
Fee Options and Fee Schedule
Certain investment products, such as Alternative
Investments and Complex Investments, are
classified as partnerships. Clients invested in such
investment products will be treated as partners
for U.S. federal income tax purposes, which has
tax implications different from other types of
investments, including Schedule K-1 reporting.
A client’s advisory agreement will set forth the
actual compensation the client will pay to Baird.
In most instances, a client pays an ongoing
Advisory Fee based upon the value of assets in
the client’s Account (an “asset-based
fee”),
although other options, such as a flat fee, are
available.
Asset-Based Fee Arrangement
taxable
fee
DDK generally offers one asset-based
arrangement: a tiered fee schedule.
Clients with tax-exempt Accounts, such as certain
Retirement Accounts or charitable or religious
organization Accounts, should be aware that some
investments, such as some Non-Traditional
Assets, Alternative Investments and Complex
Investments, may produce
income,
referred to as unrelated business taxable income
(“UBTI”). In such circumstances, such clients will
be required to pay tax on the UBTI produced by
the tax-exempt Accounts.
Under a tiered fee schedule, the asset-based fee
will vary for different segments of client assets,
gradually decreasing as the Account balance
increases. For example, a client with an Account
value of $50 million may pay one rate on the first
$10 million of assets in the Account, a lower rate
on the next $15 million of assets in the Account
and a still lower rate on the remaining $25 million
of assets. Use of a tiered fee schedule will result
in a blended asset-based fee rate.
The typical asset-based fee varies depending
upon the Service and the fee option selected by
the client. Fee options and rates may also differ
among different Accounts held by the same client,
depending on the services selected
for an
Account.
A client’s ability to recognize losses in an Account
for tax purposes may be disallowed, limited or
deferred by applicable tax rules. For example, IRS
wash sales rules will disallow a client’s tax
deductions for a loss in an Account related to the
sale of an investment if the client purchases
(whether through Baird or another firm) a
“substantially identical” investment within the
wash sale period (currently 30 days before or 30
days after the date of the sale). Similarly, IRS
straddle rules limit and defer a client’s ability to
claim tax deductions related to the loss on a sale
of an investment in an Account if the client holds
an offsetting position in any account held at Baird
or another firm.
All new client Accounts paying an asset-based fee
are generally subject to a unified advice fee
54
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Portfolio Fee Schedule
arrangement (“Unified Advice Fee Arrangement”),
which is described below.
Service
Annual Fee Rate
or Range of Rates
Unified Advice Fee Arrangement
0.00%
ALIGN Elements Portfolios
0.00%
ALIGN Strategic Portfolios
ALIGN UMA Select Portfolios1
0.25% - 0.52%
Equity SMA Strategies
0.16% - 0.40%
Fixed Income SMA Strategies
0.25% - 0.60%
Global and International SMA
Strategies
0.00%
Mutual Funds
0.00%
ETFs
0.00%
ALIGN Strategic Sleeve or
Portfolio
Under a Unified Advice Fee Arrangement, the
asset-based Advisory Fee is comprised of an
advice fee (“Advice Fee”) and, for some Services,
an additional portfolio fee (“Portfolio Fee”). The
Advice Fee covers certain investment advisory,
brokerage and custody services provided by DDK
and Baird. The Portfolio Fee covers portfolio
management and other services provided by
Baird and the manager to the client’s Account,
which may include departments or affiliates of
Baird. If a client has a Unified Advice Fee
Arrangement, the client’s Advisory Fee rate will be
equal to the sum of the applicable Advice Fee rate
and the applicable Portfolio Fee rate, if any.
0.00%
Baird Advisory Choice
0.00%
BairdNext Portfolios
Clients with a Unified Advice Fee Arrangement
generally choose a tiered fee schedule for the
Advice Fee portion of the Advisory Fee.
Baird Affiliated Managers
Portfolios
Tiered Advice Fee Schedule
PWM-Managed Portfolios
following
fee schedule sets
0.00%
AQA Portfolios
tiered Advice Fee rates
forth
for
the
the
0.00%
Baird Recommended Portfolio
The
maximum
Services.
0.00%
Baird Rising Dividend Portfolio
Tiered Advice Fee Schedule
Baird Equity Asset Management
Value of Assets
Annual Fee Rate
0.35% - 0.50%
SAM Strategic Portfolios
0.32% - 0.50%
On the first $10 million
Negotiable
Other Portfolios
0.32% - 0.50%
Riverfront Managed Portfolios
On next $15 million
0.60%
0.35% - 0.45%
Baird Trust Strategies
On next $25 million
0.45%
0.37%
CCM Portfolios
On next $25 million
0.30%
0.15% - 0.25%
GAMMA Portfolios
On next $25 million
0.15%
0.02% - 0.37%
Strategas Portfolios
Above $100 million
Negotiable
DDK Investment Management
0.00%
DDK Recommended Managers
Portfolio Fee Schedule
0.18% - 0.75%
Equity SMA Strategies
0.20% - 0.52%
Balanced SMA Strategies
0.20% - 0.32%
Fixed Income SMA Strategies
following
fee schedule sets
forth
0.32% - 0.47%
Global and International SMA
Strategies
rate varies by Service,
The Portfolio Fee
investment vehicle, and the type of investment
strategy or style being pursued by the Account.
The
the
maximum Portfolio Fee rates or range of rates for
the Services.
0.35% - 0.60%
Other SMA Strategies
0.10%
ALIGN 55ip Tax Managed
Solutions
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Portfolio Fee Schedule
Service
Annual Fee Rate
or Range of Rates
Baird SMA Network (BSN)
2 Fees charged by managers under the DC Program are
negotiated by each client pursuant to a separate
agreement that does not include Baird. Baird, therefore,
does not have the necessary information to provide a
definitive range of fees paid to managers under the DC
Program.
0.22% - 0.77%
Equity SMA Strategies
0.22% - 0.52%
Balanced SMA Strategies
0.10% - 0.27%
Fixed Income SMA Strategies
0.27% - 0.52%
Global and International SMA
Strategies
0.37% - 0.77%
Alternative SMA Strategies
The Portfolio Fee rates are current as of the date
of this Brochure. A client’s actual Portfolio Fees
could be higher or lower than the amounts shown
above if Baird adds new investment managers to
the Services with higher or lower fees or if Baird
and a manager renegotiate the amount of the
subadvisory fee.
0.02% - 0.50%
Fund Strategist Portfolios
—2
Dual Contract (DC)
0.00%
Russell Model Strategies
Unified Advisory Select (UAS)
Portfolios1
The Advice Fee and Portfolio Fee rates do not
reflect the internal fees and expenses of any
Funds or other investment products used in
connection with a strategy, the costs of which are
borne by a client in addition to the Advisory Fee.
See “Other Fees and Expenses” below.
0.25% - 0.52%
Equity SMA Strategies
0.25% - 0.52%
Balanced SMA Strategies
0.16% - 0.40%
Fixed Income SMA Strategies
0.25% - 0.60%
Global and International SMA
Strategies
0.32% - 0.50%
Riverfront SMA Strategies
0.02% - 0.50%
Fund Strategist Portfolios
0.00%
Mutual Funds
0.00%
ETFs
Baird provides operational and administrative
services to 55ip
in connection with 55ip’s
management of client Accounts using an ALIGN
55ip Tax Managed Solution. As compensation for
those services, Baird receives a portion of the
Portfolio Fee at an annual rate of up to 0.02% of
the value of the Account. Additional information is
contained in the document titled “Administrative
Servicing, Revenue Sharing, and Other Third
Party Payments” available on Baird’s website at
bairdwealth.com/retailinvestor.
0.00%
ALIGN Elements Portfolios
0.00%
ALIGN Strategic Sleeve or
Portfolio
0.00%
AQA Portfolios
0.00%
Baird Recommended Portfolio
The Portfolio Fee rates set forth above do not
include the overlay fees charged by the Overlay
Manager
for tax overlay or values overlay
services, which are generally 0.10% of the value
of the Account annually.
0.00%
Baird Rising Dividend Portfolio
0.32% -0.40%
Baird Equity Asset Management
Portfolios
compared
to
the
0.35%
Baird Trust Strategies
0.35% - 0.37%
CCM Portfolios
0.02% - 0.37%
Strategas Portfolios
1 Reflects the range of fees charged by managers or
products that are not affiliated with Baird. The range of
fees charged by Baird or by managers or products
affiliated with Baird are shown elsewhere in the Portfolio
Fee Schedule.
Certain managers offer lower Portfolio Fee rates
for SMA Strategies to clients through the DC
Program
BAM, DDK
Recommended Managers or BSN Programs. If a
client has decided to participate in the DC
Program, upon the client’s request, the client’s
DDK Consultant may assist the client with the
client’s negotiation with the manager of the
Portfolio Fee rate for the applicable SMA Strategy.
The Portfolio Fee negotiated by the client could be
higher or lower than the Portfolio Fee that applies
to the same SMA Strategy that is available
through other Services. The client is ultimately
responsible for understanding the differences
to
between
the SMA Programs, deciding
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Account Minimum
Service
Asset Level
participate in the DC Program, selecting the SMA
Strategy, and negotiating and agreeing to the
Portfolio Fee rate.
Consulting Services
Negotiable
$5,000
investments
ALIGN Elements
Portfolios
$25,000
ALIGN Strategic
Portfolios
$100,000(1)
ALIGN UMA Select
Portfolios
Baird Advisory Choice
$10,000
BairdNext Portfolios
$5,000
Baird Affiliated Managers
$250,000
Baird Equity Asset
Management Growth
Portfolios
$250,000(2)
Baird Equity Asset
Management SAM
Portfolios
Baird Trust
$60,000
$100,000(3)
Important Information about UMAs and Blended
Rates. UMAs offer
in different
investment vehicles (such as mutual funds, ETFs,
SMAs and PWM-Managed Portfolios) and asset
classes (such as equity securities and fixed
income securities). Each investment vehicle and
asset class may have a different Portfolio Fee
rate, which is shown in the table above. For
purposes of calculating the Portfolio Fee for a
UMA, the Portfolio Fee rate applicable to each
investment vehicle or asset class will be applied
to the value of assets invested in each such
investment vehicle or asset class in the Account.
In other words, the overall Portfolio Fee rate for
the UMA as a whole will be a blended rate. The
blended Portfolio Fee rate, and the actual Portfolio
Fee paid by a client, will vary over time due to
many factors, including market appreciation or
depreciation of the assets in the Account and
changes in allocations to different investment
vehicles or asset classes in the Account.
Riverfront Managed
Portfolios
$50,000
Riverfront Managed
ETF Portfolios
Overlay Manager Tax and Value Overlay
Services
CCM Portfolios
$100,000
GAMMA Portfolios
$250,000
Strategas Portfolios
$100,000(4)
The Overlay Manager charges an additional fee
for tax and value overlay services, which will be
included in the Advisory Fee. The amount of the
fee will be disclosed to a client prior to enrolling
an Account in the service.
$100,000(5)
DDK Recommended
Managers
Flat or Hourly Fee Arrangement
Baird SMA Network
$100,000(5)
Dual Contract
$100,000(5)
$50,000
DDK Investment
Management
Russell Model Strategies
$10,000
$5,000(6)
Unified Advisory Select
(UAS) Portfolios
(1) Account minimums
for ALIGN UMA Select
Portfolios range from $100,000 to $400,000,
depending upon the particular Portfolio.
Under a flat fee or hourly fee arrangement, the
applicable fee may be determined according to a
fixed asset-based or hourly fee rate or may be a
fixed dollar amount. Specific services may each
have their own, separately-stated, flat fee, or
several services may be grouped together under a
single flat fee. Some services may entail a flat fee
per usage. Flat fees are negotiable and vary by
client. The details of flat fee arrangements,
including fee amounts, the billing schedule, and
the services covered, will be included in the
client’s advisory agreement.
Service Account Minimums
(2) Baird Equity Asset Management’s SAM Strategic
Portfolios have a minimum account requirement of
$250,000 and its SAM Custom Portfolios have a
minimum account requirement of $1,000,000.
The minimum asset value to open an Account in a
Service is set forth in the table below.
(3) Riverfront Managed Portfolios have an account
minimum ranging from $50,000 to $100,000.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
(4) Strategas Managed Portfolios that use strategies
that primarily invest in mutual funds or ETFs may
have an account minimum as low as $25,000.
result, some
including the aggregate value of assets in certain
other Advisory accounts held by a client and
certain members of the client’s household or
family (a “household fee arrangement”). A client
should note that Retirement Accounts may not be
included in a household fee arrangement to the
extent a prohibited transaction under ERISA or
the IRC may result. The terms of any such
household fee arrangement will be set forth in the
client’s advisory agreement.
(5) BSN Fund Strategist Portfolios have a minimum
account requirement of $10,000. Other SMA
Strategies typically have an account minimum of
$100,000. However, each investment manager
sets its own minimum account size requirements,
which can range from $25,000 to more than
$1,000,000. As a
investment
managers may not be available to clients with
smaller accounts.
(6) Account minimums vary depending upon the
investments that are selected for UAS Program
Account and will be significantly higher if, for
example, an SMA Strategy is selected.
A client’s Account may also be subject to a
minimum quarterly Advisory Fee that will be set
forth in the client’s advisory agreement regardless
of the value of the assets in the client’s Account.
In addition, if a third party custodian has custody
of the client’s Account assets, Baird may impose
Account requirements different than those set
forth above, including but not limited to higher
minimums, and it may impose additional fees due
to the increase in resources needed to administer
the Account.
While DDK and Baird may perform an analysis as
to whether any client Accounts may be eligible for
a household fee arrangement, a client should note
that it is client’s sole responsibility to inform the
client’s DDK Consultant that client’s household or
family has two or more Advisory accounts that
are eligible for a household fee arrangement. DDK
and Baird do not undertake any obligation to
ensure client Accounts are eligible for a household
fee arrangement. By agreeing to a household fee
to such
arrangement, each client subject
household fee arrangement consents to DDK and
Baird providing to each other client subject to
such household fee arrangement, in DDK’s or
Baird’s sole discretion, information about the
aggregate level, or range, of household assets
used for fee calculation purposes. As a result,
each such client should understand that the other
clients included in the household fee arrangement
may be able to ascertain the amount of the
client’s assets at Baird.
A client is encouraged to periodically review with
the client’s DDK Consultant the client’s Advisory
Fee and the services provided to determine if the
services and fees continue to meet the client’s
needs.
Calculation and Payment of Advisory Fees
Baird will calculate a client’s Advisory Fee by
applying the applicable fee rate to the value of all
of the assets in the client’s Accounts, including
cash and its equivalent and including all Held-
Away Assets, unless otherwise agreed to in
writing. Liabilities held in a client's Accounts,
including the value of margin debit balances, open
short sale positions and open options positions
with a negative market value will be excluded
from the calculation of a client's Advisory Fee. The
value of cash balances held in a client’s Account
will be excluded from the calculation of a client's
Advisory Fees in an amount equal to the value of
any open short sale positions and options
positions with a negative market value held in the
margin account.
For purposes of calculating a client’s asset-based
Advisory Fee, the value of a client’s assets is
generally determined by Baird. Baird generally
relies upon third party sources, such as third
party pricing services when valuing Account
assets. In some instances, such as when Baird is
unable to obtain a price for an asset from a
pricing service, Baird may obtain a price from its
trading desk or it may elect to not price the asset.
Obtaining a price from its trading desk may
present a conflict of interest. In some cases, Baird
obtains prices from the issuers or sponsors of
investment products in the client’s Account when
prices are not otherwise readily available. This
frequently occurs with respect to the valuation of
annuities and Complex Investment Products. If
the assets in the client’s Account are held by a
custodian other than Baird, Baird may also use
valuation information provided by the client’s
third party custodian in determining the value of
the assets in the client’s Account.
If requested by a client and approved by Baird, a
client’s Advisory Fee may be determined by also
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
is unreliable. Valuation data
client’s Account statement or performance report
due to a variety of factors, including the client’s
use of margin, options, short sales, and other
considerations. If a client has assets held by a
third party custodian, the prices shown on a
client’s Account statements provided by the
custodian could be different from the prices
shown on statements and reports provided by
Baird. See “Services, Fees and Compensation—
Additional Service Information—Custody Services”
above for more information.
third party pricing services,
Neither DDK nor Baird conducts a review of
valuation information provided by third party
pricing services, issuers, sponsors, or custodians,
and they do not verify or guarantee the accuracy
of such information. DDK and Baird do not accept
responsibility for valuations provided by third
parties that are inaccurate unless they have a
reason to believe that the source of such
for
valuations
investments, particularly annuities and Complex
Investment Products, may not be provided to
Baird in a timely manner, resulting in valuations
that are not current. The prices obtained by Baird
from
issuers,
sponsors and custodians may differ from prices
that could be obtained from other sources.
the
Values used for fee-calculation purposes may vary
from prices received in actual transactions and
are not firm bids, offers or guarantees of any type
with respect to the value of assets in an Account,
and the Advisory Fee for some securities may be
calculated based on values that are greater than
the amount a client would receive if the securities
were actually sold from the client’s Account.
A client’s Advisory Fees are payable in accordance
with the terms of the client’s advisory agreement.
Typically, Advisory Fees are payable on a calendar
quarterly basis, in advance. The initial billing
period begins when
client’s advisory
agreement is accepted by Baird and the Account
is opened by Baird (the “Opening Date”). The
initial Advisory Fee payment will be adjusted for
the number of days remaining in the then current
quarter. The initial Advisory Fee will be based on
the value of assets in the client’s Account on the
Opening Date. The period which such payment
covers shall run from the Opening Date through
the last business day of the then current calendar
quarterly billing period. Thereafter, the quarterly
Advisory Fees shall be calculated based upon the
Account’s asset value on the last business day of
the prior calendar quarter and shall become
payable on the first business day of the then
current calendar quarter.
As mentioned above, Baird will include cash and
cash equivalent balances in a client’s Account
when calculating a client’s asset-based Advisory
Fee. Baird has adopted internal policies that
monitor the percentage of an Account swept into
cash under the Cash Sweep Program. These
internal policies are designed to inform DDK
Consultants and their clients who hold large cash
sweep balances in their Accounts for sustained
periods that those Accounts are holding large
cash sweep balances and that there may be other
investment or account options for their cash and
that Baird receives direct compensation
in
addition to the Advisory Fee from client balances
in the Cash Sweep Program.
the
client’s Account may
A client’s Advisory Fees and other charges will be
automatically deducted from the client’s Account,
unless the client requests, and DDK and Baird
agree, to an alternate arrangement, such as
having Baird issue the client an invoice for the
Advisory Fees (“direct billing”). A client should
understand that the client’s Advisory Fees and
other charges relating to the client’s Account may
be satisfied from free credit balances and other
assets in the client’s Account. If free credit
balances in a client’s Account are insufficient to
pay the Advisory Fees or other charges when due,
investment manager
DDK, Baird and any
managing
sell
investments from the client’s Account to the
extent they deem necessary and appropriate, in
their sole discretion, to pay the client’s Advisory
Fees and other charges.
If a client maintains a debit balance in the client’s
margin account with Baird, such balance has no
bearing on the asset-based Advisory Fees charged
on client’s Account. In other words, the margin
balance (i.e., the outstanding amounts of the
margin loan a client owes to Baird) in client’s
Account will not be applied to reduce the client’s
billable Account value in calculating the Advisory
Fee.
The Account value used for the Advisory Fee
calculation may differ from that shown on a
If a client’s Account is subject to direct billing, the
client is required to pay each bill within 30 days of
the date of the invoice. DDK and Baird may
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
schedule above. The fees paid by a client may
differ from the fees paid by other clients based on
a number of factors, including but not limited to
the factors identified above.
automatically deduct a client’s Advisory Fees and
other charges from the client’s Account as
described above in the event that Baird does not
receive payment from the client within 30 days of
the date of the invoice. DDK or Baird may rescind
a direct billing arrangement with a client at any
time. Direct billing may not be available for
Retirement Accounts.
To the extent permitted by applicable law, DDK or
Baird may modify a client’s existing fees and
other charges or add additional fees or charges by
providing the client with 30 days’ prior written
notice.
The fee schedule set forth above is the current
fee schedule for the Services. Each Service has
had other fee schedules in effect, which may
reflect fees that are lower or higher, as the case
may be, than those shown above. As new fee
schedules are put into effect, they are made
applicable only to new clients, and fee schedules
applicable to existing clients may not be affected.
Therefore, some clients may pay different fees
than those shown above.
Obtaining Services Separately: Brokerage or
Advisory? Factors to Consider
DDK generally does not offer the Services to
clients on an unbundled basis. In other words, the
Services do not permit clients to pay for services,
such as investment advice, trade execution, and
custody
separately. However, Baird offers
brokerage accounts and other services to clients,
and certain services provided to a client in
connection with a particular Service may be
available to a client outside of the Service
separately. Thus, a client’s participation in a
Service could cost the client more or less than if
the client purchased each service separately. A
number of factors bear upon the relative cost of
each Service. In comparing the Services to
brokerage accounts or other services, a client
should consider a number of factors, including,
but not limited to:
If DDK, Baird or the client terminates the client’s
advisory agreement or the client’s participation in
a Service, a pro-rated refund from the date of
termination through the end of the applicable
billing period will generally be made to the client
in the client’s affected Accounts. DDK and Baird
will not implement a decrease in the client’s fee
rate during a billing period or otherwise reimburse
or adjust Advisory Fees during any such period for
asset value appreciation or depreciation in a
client’s Account during such period. For example,
if a client’s Account is subject to a tiered or
breakpoint fee schedule and the asset levels of
the Account move into a new tier or cross a
breakpoint during such period, no rebate or fee
adjustment will be made. However, DDK and
Baird, in their sole discretion, may make fee
adjustments in response to asset fluctuations in a
client’s Account occurring during a billing period
that result from contributions to, or withdrawals
from, the client’s Account.
• whether a client prefers to have ongoing
monitoring, investment advice or professional
management of the client’s investments, which
are provided to Service Accounts, or whether
the client does not want or need such services;
The minimum asset value in order to retain the
services of DDK is $10 million, and a minimum
annual Advisory Fee of $60,000 may be assessed
to a client regardless of the level of assets
advised by DDK. DDK may waive the minimum
asset value or minimum Advisory Fee at its
discretion. The minimum Advisory Fee is subject
to change upon notice to the client.
• whether the types of investment strategies,
products and solutions the client seeks are
available;
• whether there are limitations on the types of
securities and other investments available for
purchase and whether those limitations are
significant to the client;
• whether the nature and level of transaction
services, account performance reporting, or
The Advisory Fee and minimum account value are
negotiable in certain instances and may vary
based upon a number of factors, including but not
limited to the size and nature of the assets in the
client’s Account, the client’s particular investment
strategy or objective, and any particular services
requested by the client. In some instances, clients
may pay a higher fee than indicated in the fee
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
other ancillary services the client wants are
available;
and
Managers, Baird pays Other Managers (including
Associated Managers
Implementation
Managers, if any) a Portfolio Fee or subadvisory
fee as compensation for the manager’s services
as further described below.
• whether the client prefers to pay an ongoing
Advisory Fee for continuous advice or pay
commissions and other fees on a transaction-
by-transaction basis;
• the relative costs and expenses of a Service
Account and a brokerage account, which will
vary depending upon:
fee or commission rate
the client
o the
negotiates;
o the size of the client’s account;
o the level of trading activity and size of trade
orders;
Client Accounts are generally subject to a Unified
Advice Fee Arrangement in which the Advisory
Fee consists of an Advice Fee and a separate
Portfolio Fee. Baird pays the manager out of the
Portfolio Fee paid by the client. The Portfolio Fee
rates are set forth under “Fee Options and Fee
Schedules—Unified Advice Fee Arrangement—
Portfolio Fee” above. However, Baird, in many
instances, retains a portion of the Portfolio Fee
when a client’s Account is managed by an Other
Manager. The maximum portion of the Portfolio
Fee retained by Baird in those instances is equal
to an annual rate of 0.10% of the value of a
client’s Account. Such amounts are retained by
Baird for the services it provides.
o applicable account fees and charges;
o the client’s use of third party managers who
charge their own fees for managing accounts
in addition to DDK’s Advice Fee; and
As the portion of the Advisory Fee or Portfolio Fee
paid to an Other Manager increases, the portion
of the Advisory Fee or Portfolio Fee that is
retained by Baird decreases. Thus, Baird (but not
DDK) has an incentive to recommend or favor
investment managers that are paid less, because
Baird will receive a higher portion of the Advisory
Fee or Portfolio Fee.
o the amount of the client’s account invested in
investment products that have additional
internal ongoing operating fees and expenses
(e.g., Funds).
Additional important information about brokerage
accounts and facts to consider when making
account type decisions is contained in the Client
Relationship Details document, which should have
been delivered to the client and is available on
Baird’s website at bairdwealth.com/retailinvestor.
In addition, Baird has an incentive to favor
Associated SMA Strategies over other SMA
Strategies because the entire Advisory Fee is
retained by Baird and Associated Managers and
because Baird benefits from its receipt of Advisory
Fees and the overall success of Associated
Managers. For more information, see “Additional
Information—Other Financial Industry Activities
and Affiliations” below.
A client should review other account types and
programs with the client’s DDK Consultant to
determine whether they are more appropriate or
should be used in addition to a Service.
incentive
Advisory Fee Payments to Baird, DDK
Consultants and Investment Managers
DDK and Baird and Associated Managers benefit
from the Advisory Fees and charges that clients
pay for the services described in this Brochure.
Given the nature of the Advisory Fee, Baird also
has an
to select or recommend
investment managers that trade less frequently
with or that trade away from Baird because Baird
will incur lower trading costs with respect to such
managers and such relationships will be more
profitable to Baird. With respect to UMAs, Baird
retains a portion of the Portfolio Fee paid to
certain managers as described above. Thus, Baird
has an incentive to favor SMA Strategies provided
by those managers over other SMA Strategies,
mutual funds, ETPs and PWM-Managed Portfolios
because it will be more profitable for Baird.
Baird retains the entire Advisory Fee paid by
clients, except as further described below. With
respect to SMA Strategies available under the
SMA and UMA Programs managed by Other
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Interest
to
Trading—Participation or
in Client
Transactions” below. They also generally receive
non-cash compensation and other benefits from
Baird and from sponsors of investment products
with which Baird does business. Such non-cash
compensation and other benefits may include
invitations to attend conferences or educational
seminars, payment of related travel, lodging and
meal expenses, reimbursement for branch and
client events, and
receipt of gifts and
entertainment. Receipt of such compensation and
benefits provides DDK Consultants an incentive to
favor investment products and their sponsors that
provide the greatest levels of compensation and
benefits.
recognition
trips
for
achievement
of
A DDK Consultant is primarily compensated on a
monthly basis based upon a percentage of the
DDK Consultant’s total production each month,
which primarily consists of the total advisory fees
and transaction-based fees paid to Baird by the
DDK Consultant’s clients and any other fees Baird
earns on advisory and brokerage accounts held by
those clients, including trail fees paid by third
parties. The percentage of the DDK Consultant’s
total production actually paid
the DDK
Consultant will increase as the total amount of the
DDK Consultant’s production increases, meaning
that, as the total amount of the DDK Consultant’s
production increases, the rate and amount of
compensation that Baird pays to the DDK
Consultant also
increase. DDK Consultants
generally also receive deferred compensation or
bonuses based on various criteria, including net
new assets they gather, performing certain wealth
management activities, such as financial planning,
and their total production levels. DDK Consultants
who achieve certain production thresholds are
eligible for professional development conferences,
business development coaching, reimbursements,
awards and
to attractive
destinations. DDK Consultants are also eligible for
professional
bonuses
designations depending on a DDK Consultant’s
total production level. Thus, DDK Consultants
have a general incentive to generate financial and
other plans and charge higher fees for advisory
accounts and recommend larger investments in
advisory accounts.
Given the structure of their compensation, they
also have an incentive to recommend that a client
transfer the client’s accounts to Baird, establish
new accounts with Baird (including IRA rollovers)
and add more money into the client’s accounts. In
addition, most DDK Consultants are shareholders
of Baird Financial Group, Inc. (“BFG”), Baird’s
ultimate parent company, and thus benefit
financially from the overall success of Baird and
its Associated Parties. The number of shares of
BFG stock that a DDK Consultant may purchase is
based in part on the DDK Consultant’s total
production
level. DDK Consultants generally
receive compensation for referrals to certain
affiliated managers and products and for referrals
to a limited number of other firms. More specific
information
is provided under the headings
“Additional Information—Other Financial Industry
Activities and Affiliations” and
“Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
DDK Consultants generally receive recruitment
bonuses and/or special compensation from Baird
when they join Baird from another firm. The
amount of such special compensation is typically
based on the DDK Consultant’s production at the
prior firm for the 1-year period prior to joining
Baird or on the level of the DDK Consultant’s
client assets at the prior firm. All or a substantial
portion of the special compensation is paid in the
form of an upfront bonus when the DDK
Consultant joins Baird, and the remaining portion,
if any, is paid in the form of back end bonuses
generally in equal installments on an annual basis
thereafter
for a certain number of years
(generally from one to three years). Installment
payments are generally contingent upon the DDK
Consultant achieving annual production or client
asset levels that exceed a significant percentage
of the DDK Consultant’s annual production for the
1-year period prior to joining Baird or the client
assets that the DDK Consultant had prior to
joining Baird. The special compensation
is
intended to compensate DDK Consultants for the
significant effort involved in transitioning their
business from the prior firm. This compensation
provides DDK Consultants who have left another
firm additional incentive to recommend that
clients of the prior firm become Baird clients and
to recommend investment products and services
that increase their production, and thus presents
a conflict of interest. The special compensation is
generally structured in the form of a forgivable
loan from Baird to the DDK Consultant. Under the
terms of the forgivable loan, Baird makes the
upfront or installment payment to the DDK
Consultant in the form of a loan, and Baird
forgives a portion of the loan made to the DDK
Consultant each month for so long as the DDK
Consultant remains Baird’s employee. Should the
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in
the
to DDK Consultants
under
the
heading
important
Interest
DDK Consultant cease to be Baird’s employee
prior to the maturity date of the loan, the DDK
Consultant is required to repay Baird the amount
of the loan outstanding and not forgiven by Baird.
In other words, upon leaving Baird, the DDK
Consultant would be required to repay to Baird a
portion of the special compensation that the DDK
Consultant had received and that had not been
forgiven. The amount of such repayment declines
over time in proportion to the time the DDK
Consultant remains Baird’s employee. Structuring
this special compensation
form of
forgivable loans provides the DDK Consultant
added incentive to remain Baird’s employee and
to recommend that persons become and remain a
Baird client. Additional information about referral
and non-cash compensation and other financial
is
incentives provided
provided
“Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
in Client
Trading—Participation or
Transactions” below.
expenses that are deducted from the assets of the
product (or income or gains generated by the
product on its investments) and thus reduce the
value or return of the client’s investment in the
product. These fees and expenses may include
investment management fees, distribution (12b-
1) fees, shareholder servicing fees, transfer
agency fees, networking fees, accounting fees,
marketing support payments, administration fees,
custody
fees, expense reimbursements, and
expenses associated with executing securities
transactions for the investment product’s portfolio
(“ongoing operating expenses”). These ongoing
operating expenses are separate from, and in
addition to, the Advisory Fees. As a result of
making investments in these types of products, a
client should be aware that the client is paying
multiple layers of fees and expenses on the
amount of the client’s assets so invested—the
ongoing operating expenses and the Advisory
Fee. Additional
information about
ongoing fees and expenses that apply to those
types of investments is provided in Baird’s Client
Relationship Details document and Baird’s website
at bairdwealth.com/retailinvestor. A client can
find the actual ongoing fees and expenses of an
investment product that the client will pay or bear
in the product’s prospectus or offering document.
than
Additional Account Fees and Charges
website
Due to the manner in which Baird compensates
DDK Consultants, a DDK Consultant generally will
have a financial incentive to trade less for Baird
Advisory Choice Accounts
traditional
brokerage accounts and to reduce trading or
increase a client’s Advisory Fees if trading for a
client’s Advisory Choice Account exceeds certain
levels established by Baird. From time to time,
Baird DDK Consultants outside of DDK may refer
their clients to DDK Consultants. In those
instances, the DDK Consultant generally shares a
portion of his or her compensation with the
referring Baird Financial Advisor.
If the client’s Account is custodied at Baird, the
client is also responsible for all applicable account
fees and service charges Baird may impose in
connection with the client’s agreements with
Baird. A schedule of fees and service charges is
at
Baird’s
on
available
bairdwealth.com/retailinvestor.
Other Fees and Charges
In addition to the Advisory Fee described above, a
client of DDK will incur other fees and expenses.
A client is responsible for bearing or paying, in
addition to the Advisory Fee, the costs of all:
Baird addresses the conflicts described above
through disclosure in this Brochure and by
adopting internal policies and procedures for DDK
and Baird and their associates that require them
to provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients).
Other Fees and Expenses
Cost and Expense Information for Certain
Investment Products
• markups, markdowns, and spreads charged by
Baird in a principal transaction with a client or
charged by other broker-dealers that buy
securities from, or sell securities to, the client’s
Account (such costs are inherently reflected in
the price the client pays or receives for such
securities);
• front-end or deferred sales charges, redemption
fees, or other commissions or charges
A client should be aware that certain investment
products in which the client invests, such as
mutual funds and other Funds, annuities and
their own ongoing
other products, have
fees and
management and other operating
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associated with securities transferred into or
from an Account;
• redemption fees, surrender charges or similar
fees that an investment product or its sponsor
may impose;
each investment manager selected by the client
under the Dual Contract Program. If a client
directs DDK or Baird to pay the client’s DC
Manager’s fee out of the client’s Account, and
DDK or Baird agree to do so, DDK and Baird will
not be responsible for verifying the calculation or
accuracy of such fee.
• underwriting discounts, dealer concessions or
similar fees related to the public offering of
investment products;
through another
• extra or special fees or expenses that may
result from the execution of odd lot trade orders
(i.e., “odd-lot differential”);
A client may also be assessed other trading costs
in addition to the Advisory Fee if client trades are
executed
firm. Please see
“Services, Fee and Compensation—Additional
Service Information—Trading for Client Accounts”
above for more information.
• electronic fund fees, wire transfer fees, fees for
transferring an investment between firms, and
similar fees or expenses related to account
transfers (including any such fees imposed by
Baird);
• currency conversions and transactions;
To the extent mutually agreed by a client and
DDK, the client may also incur additional costs to
reimburse DDK for extraordinary travel expenses
it incurs to attend meetings at the request of the
client.
conversions,
• securities
including, without
limitation, the conversion of ADRs to or from
foreign ordinary shares;
• interest, fees and other costs related to margin
accounts, short sales and options trades;
related
to
the
• fees
establishment,
administration or termination of Retirement
Accounts, retirement or profit sharing plans,
trusts or any other legal entity, including,
without limitation, the calculation and payment
of unrelated business income tax (“UBIT”);
• fees imposed by the SEC or securities markets,
including transaction fees imposed by electronic
trading platforms, which fees may be imbedded
in the price the client receives for the security;
and
imposed upon or
resulting
• taxes
If a client holds an Unsupervised Asset in the
client’s Account, the client may be charged a
commission, markup or markdown in connection
with its purchase or sale. The cash proceeds from
the sale of an Unsupervised Asset that remain in
a client’s Account are considered Permitted
Investments subject to the asset-based Advisory
Fee. If an asset becomes an Unsupervised Asset
during a quarterly billing period, that asset will be
excluded for purposes of determining the asset-
based Advisory Fee beginning at the start of the
next quarterly billing period, and no portion of the
asset-based Advisory Fee paid by a client in
advance for the quarter will be refunded or
rebated to the client. Additionally, Unsupervised
Assets in an Account are subject to any applicable
set-up, maintenance and administrative
fees
established by Baird. Baird may waive such fees
in its discretion.
from
transactions effected for a client’s Account, such
as income, transfer or transaction taxes, foreign
stamp duties, or any other costs or fees
mandated by law or regulation.
Clients who have Accounts managed by DDK may
also have other accounts with Baird that are not
managed by DDK. Those accounts may be subject
to fees, commissions or other expenses that are
entirely separate from the payment of fees and
expenses for the services provided by DDK.
Clients who use a custodian other than, or in
addition to, Baird will pay the other custodian’s
fees and expenses in addition to the Advisory Fee.
In addition, if a third party custodian has custody
of the client’s Account assets, the Account is
subject to any applicable set-up, maintenance and
administrative fees established by Baird. Baird
may waive such fees in its discretion.
Compensation Received by DDK and Baird
The individual who recommends a Service to a
client, including a DDK Consultant, receives
compensation from Baird that is based upon the
amount of the Advisory Fee paid by the client.
The amount of the compensation may be more
In addition to the Advisory Fee, a client will also
be responsible for paying the fees charged by
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird generally requires that assets in a client’s
Account be held in a Baird account, for which
Baird acts as custodian. However, in certain
limited circumstances when requested by a client,
Baird may permit a client to include Held-Away
Assets in the client’s Account.
specific
about
to
Compensation—Additional
and
“Services,
Fees
Fees—Advisory
than what the individual would receive if the client
participated in other Baird investment advisory
services or paid separately for investment advice,
brokerage, and other services. Accordingly, the
individual may have a financial incentive to
recommend a Service over other programs or
services offered by Baird. However, when
providing investment advisory services to clients,
DDK and Baird are fiduciaries and are required to
act solely in the best interest of clients. Baird
addresses this conflict through disclosure in this
Brochure and by adopting internal policies and
procedures for DDK and Baird and their associates
that require them to provide investment advice
that is suitable for advisory clients (based upon
the information provided by such clients). For
more
Baird’s
information
compensation and other benefit arrangements
and how Baird addresses the potential conflicts of
interest, please see the sections “Services, Fees
Service
and
and
Information”
Compensation—Advisory
Fee
Payments
to Baird, DDK Consultants and
Investment Managers” above, and “Additional
Information—Other Financial Industry Activities
and Affiliations” and “Additional Information—
Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading” below.
After a client has signed and delivered an
advisory agreement to Baird, the agreement is
subject to review and acceptance by the client’s
DDK Consultant, his or her Market Director or
PWM Supervision department supervisor (or his or
her respective designee), and Baird PWM’s Home
Office. The agreement and Baird’s advisory
relationship with a client will become effective
when the client’s paperwork is accepted by Baird
PWM’s Home Office and following such acceptance
the client written
Baird has delivered
confirmation of the Account’s enrollment in the
applicable Service. A client should understand
that the advisory agreement will not become
effective, and Baird will not provide any advisory
services to the client, until such time that Baird
has accepted the advisory agreement. Baird may
delay acceptance of the advisory agreement and
the provision of advisory services to the client for
various reasons, including deficiencies in the
client’s paperwork. Once it has become effective,
the agreement shall continue until it is terminated
in accordance with the terms described in the
advisory agreement.
Account Requirements and Types of
Clients
Opening an Account
A client that wishes to engage DDK will enter into
an advisory agreement with DDK and Baird. The
client’s advisory agreement will contain the
specific terms applicable to the services selected
by the client, Advisory Fees payable by the client,
and other terms applicable to the client’s advisory
relationship with DDK and Baird.
retain
those documents
for
The terms of a client’s agreements and this
Brochure apply to all Accounts that a client
establishes with DDK, including any Accounts that
a client may open with Baird in the future. Some
of the information in those documents may not
apply to a client now, but may apply in the future
if a client changes services or establishes other
Accounts with DDK. DDK will generally not
provide a client another copy of the agreements
or this Brochure when a client changes services or
establishes new Accounts unless
the client
requests a copy from DDK. Therefore, a client
future
should
reference as they contain important information if
a client changes services or establishes other
Accounts with DDK.
Certain Account Requirements
Minimum Account Size
In addition to the investment advisory services
that DDK and Baird provide in connection with
each Service, Baird, in its capacity as broker-
dealer, also provides clients with trade execution,
custody and other standard brokerage services.
For this reason, a client will also enter into a client
account agreement with Baird if the client has not
already done so. The client account agreement is
a brokerage agreement that authorizes Baird to
execute trades for, and perform related brokerage
and custody services to, the client’s Account.
Each Service has a minimum account size and
may have a minimum Advisory Fee, which are
described in the section entitled “Services, Fees
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
immediately
terminate
the
and Compensation—Advisory Fees” above. DDK
or Baird may remove an Account from a Service
and
advisory
agreement with respect to an Account upon
written notice to the client if the client fails to
maintain the required minimum asset levels in an
Account or if the client fails to otherwise abide by
the terms of a Service as determined by DDK or
Baird in their sole discretion.
that
Account Contributions and Withdrawals
in
sale
could
in adverse
A client may fund an Account with cash and with
securities that DDK, Baird and the client’s
if any, deem
investment manager,
to be
acceptable
their sole discretion. Funds
deposited or transferred to a client’s SMAs or
UMAs from another Baird account and funds
deposited or transferred to a client’s SMAs or
UMAs from outside of Baird will not be available
for investment by the client’s investment manager
until the next business day and therefore the
investment of such funds, at the discretion of the
manager, will occur no earlier than the next
business day.
certain
When a client funds an Account with securities,
including when a client changes Services for an
Account or changes investment managers for an
Account within the same Service, the client should
understand that DDK’s, Baird’s or the client’s
investment manager’s review of securities used to
fund the Account may delay
investing. In
addition, DDK, Baird or the client’s investment
the
if any, may determine
manager,
securities contributed to the Account may not be
appropriate for the client’s strategy, and DDK,
Baird or the investment manager, if any, may
sell, or recommend the sale of, such securities.
Further, an investment manager may be removed
from the management of a client’s Account and a
replacement
investment manager may be
appointed. In such event, Baird, at the direction
of the client’s replacement manager, or the
client’s replacement manager may sell all or a
portion of the securities or other investments in
the Account that were managed by the prior
manager and the replacement manager will
reinvest the cash proceeds of those sales. Any
such
tax
result
consequences for the client. A client should note
that securities transferred into an Account may be
subject to the Advisory Fee immediately upon its
transfer into the Account, even if the client paid a
commission or front-end sales charge on the
security prior to its transfer into the Account. In
addition, if the securities are subject to deferred
sales charges or redemption fees, the client will
be responsible for paying those charges and fees.
To the extent permitted by applicable law, certain
funding transactions may be handled by Baird on
a principal basis, and such transactions are not
considered investment advisory services of DDK,
Baird or the client’s investment manager.
If an asset transferred to an Account is an
Unpermitted Investment under the terms of the
applicable Service, DDK, Baird or the client’s
investment manager may sell the asset or
transfer it into a separate brokerage account.
Alternatively, they may designate such asset as
an Unsupervised Asset as further described under
“Services, Fees and Compensation—Additional
Service
Assets”
Information—Unsupervised
above.
Some DDK Consultants will invest, or recommend
investing, cash contributions made to an Account
over a period of time. This method of investment
is sometimes referred to dollar cost averaging
(“DCA”). The goal of this method of investment is
to reduce the risk of making large purchases of
securities at an inopportune time or price. The
Overlay Manager
investment
and
managers also offer an optional DCA service for
Accounts they manage. Additional information will
be provided to a client if the client enrolls in a
DCA service. A client should note that, if dollar
cost averaging is used to invest cash in the
client’s Account, the returns for the Account
could, depending upon market and other
conditions, be lower than the returns that could
have been obtained had all the cash in the
Account been fully invested upon contribution to
the Account. In addition, a client should note that,
when dollar cost averaging is used, the amount of
cash in the client’s Account will be included in the
value of the Account for fee calculation purposes.
Whenever assets are contributed to an Account, a
client should discuss with the client’s DDK
Consultant the timing of when the assets will be
invested. If DCA will be used to invest the assets,
a client should ask for more specific information
about how the assets will be invested and the
associated timing for investing.
A client is responsible for notifying DDK and any
investment manager managing
the client’s
Account of any contributions made into the
Account and instructing DDK and any investment
manager to liquidate positions in the event the
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assets pledged as collateral for the loan to meet a
collateral call, which may occur without prior
notice to the client. A collateral call could have
adverse tax consequences, disrupt a client’s
investment strategy, and have an adverse impact
on the Account’s performance. A client should be
aware of these and other potential adverse effects
of securities-based lending and collateralizing
Accounts before deciding to do so.
client wishes to withdraw assets
from the
Account. DDK and Baird have no responsibility to
invest cash deposits (other than complying with a
client’s cash sweep instructions) or liquidate
positions with respect to an Account managed by
an Other Manager, and they are not responsible
for any losses that may result from a client’s
failure to notify DDK and any investment manager
managing the client’s Account regarding deposits
or withdrawals.
A client may also incur additional expenses and
liabilities, including tax related liabilities, when
transferring assets out of an Account or Baird’s
custody. See “Termination of Accounts” below.
A client is required to disclose the terms of the
client’s agreements with Baird to any lender
seeking to use Account assets as collateral. A
client must promptly notify DDK and Baird of any
default or similar event under the client’s
collateral arrangements.
Liens and Use of Account Assets as Collateral
A client should understand that neither DDK nor
Baird will provide advice on or oversee a
securities-based lending or collateral arrangement
and they will not act as investment adviser or a
fiduciary to the client with respect to the
liquidation of securities held in the client’s
Account to meet a collateral call. Any such
liquidation will be executed in Baird’s capacity as
broker-dealer and may, as permitted by law,
result in executions on a principal basis.
“Services,
Fees
In some instances, Baird and DDK Consultants
may refer a client to a third party lender under
Baird’s Securities-Based Lending Program that
certain
pays Baird and DDK Consultants
compensation.
and
See
Compensation—Additional Service Information—
Securities-Based Lending Program” above for
more information.
As security for the full and complete payment
when due of any debts and other obligations that
a client owes to DDK and Baird, and to the extent
permitted by applicable law or regulation, all
assets in a client’s Account held at Baird will be
subject to a first priority security interest, lien and
right of setoff in favor of Baird. Baird may sell
assets in an Account to satisfy the lien. As a
secured party, Baird may have interests that are
adverse to a client. Neither DDK nor Baird will act
as investment adviser to a client with respect to
such sale of assets held in an Account. Any such
sale of assets will be executed in Baird’s capacity
as broker-dealer and creditor and may, as
permitted by law, result in executions on a
principal basis. Such sales could have adverse tax
consequences, disrupt a client’s
investment
strategy, and have an adverse impact on the
Account’s performance. A client should review the
client’s agreements for more information.
Investment Products” above
Securities purchased on margin are used as
Baird’s collateral for the margin loan. Clients that
have a margin account should review the section
“Services, Fees and Compensation—Additional
Service Information—Complex Strategies and
Complex
for
additional information.
Electronic Delivery of Documents
All of the assets in a client’s Account must be free
and clear from any security interest, lien, charge
or other encumbrance (other than a security
interest, lien, charge or other encumbrance in
favor of Baird) and must remain so for the
duration of the client’s relationship with Baird,
unless Baird otherwise specifically agrees in
writing.
By signing an advisory agreement, a client
consents to the electronic delivery of documents
that DDK or Baird may deliver to the client. The
term of the consent to electronic delivery is
indefinite but a client may revoke the consent at
any time by notifying DDK.
If a client wishes to obtain loans secured by
assets in the client’s Account (commonly referred
to as “securities-based lending”) and DDK and
Baird agree to the arrangement, the client should
understand that the lender may exercise certain
rights and powers over the assets in the Account,
including the disposition and sale of any and all
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
transaction-based fee schedule for the particular
investment then in effect. Additional information
about the compensation that a client pays to
Baird for effecting brokerage transactions is
contained in Baird’s Client Relationship Details
document, available on Baird’s website at
bairdwealth.com/retailinvestor.
A client may incur significant expenses and
liabilities, including tax-related liabilities for which
the client will be solely liable, if the client closes
an Account, terminates an advisory agreement, or
transfers assets out of Baird’s custody. DDK and
Baird will not be liable to a client in any way with
respect to the termination, closure, transfer or
liquidation of the client’s Accounts.
Termination of Accounts
The client’s advisory agreement will survive any
event that causes the client’s DDK Consultant to
be unable to provide services to the client (either
on a temporary or permanent basis), including if
the client’s DDK Consultant ceases
to be
employed by Baird. In any such event, Baird will
endeavor to continue to provide services to the
client and will as promptly as practicable assign
another DDK Consultant or Baird Financial Advisor
to the client’s Accounts (either on a temporary or
permanent basis) and the client will be notified of
any such change or, if Baird determines that it is
unable to continue to provide advisory services to
the client, Baird may remove the applicable
Account from a Service or Program and convert
the Account to a brokerage account upon notice
to the client.
DDK or Baird may remove an Account from a
Service and immediately close an Account upon
written notice to a client if the client fails to abide
by the terms of the Service. DDK or Baird may
also remove an Account from a Service at any
time upon written notice to a client if the client
fails to maintain the required minimum asset
levels in such Account.
Some of the investments offered in connection
with the Services contain restrictions that limit
their use, and such
investments may be
unavailable for purchase or holding outside of an
Account. For example, certain mutual funds, ETFs
or other Funds held in an Account may only be
available to a client through a DDK Service or
may not be held at another firm. If such
restrictions apply and the client terminates a
Service or closes an Account, the Client will be
required to sell or redeem such Funds or
exchange them for other Funds that may be more
costly to the client or have poorer performance. A
client should consider restrictions applicable to
investments carefully before participating in a
Service. A client should contact the client’s DDK
Consultant for specific information as to how
Account closure, termination of an agreement, or
asset transfers might impact the assets in the
client’s Accounts.
individuals and
their
exclusive
responsibility
to
in
writing,
Upon the termination of an Account’s enrollment
in a Service, DDK, Baird and, if relevant, any
investment manager managing such
other
Account, shall have no obligation to act as
investment adviser to such Account. If such
Account is custodied at Baird, the Account shall
be converted to and designated as a brokerage
account. DDK, Baird, and, if relevant, any other
investment manager managing such Account,
shall be under no obligation to recommend any
action with regard to, or to liquidate the securities
or other investments in, such Account. After an
Account is removed from a Service, it is the
issue
client’s
instructions,
the
regarding
management of any assets in such Account.
Types of Clients
DDK offers the Services primarily to: high net
worth
families and
businesses. DDK also provides services to other
types of current or prospective clients, including,
but not limited to: pension and profit sharing
plans; trusts; estates; charitable organizations;
and corporations or other business entities.
Portfolio Manager Selection and
Evaluation
The persons providing portfolio management
services to clients vary by Service. Information
about how Baird may select and evaluate portfolio
managers is further described below.
If a client directs Baird to liquidate assets in
connection with a closure of an Account, the client
should understand that Baird acts as broker-
investment adviser, when
dealer, and not
processing such a liquidation request and that the
client will generally be charged commissions,
sales charges, sales “loads”, or other applicable
transaction-based fees in accordance with the
applicable Baird fee schedule or other third-party
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Selection and Evaluation
Baird Affiliated Managers Program
presentation of performance information, and
delivery of the manager’s Form ADV Part 2
brochure documents to clients.
DDK Recommended Managers Service
or
Affiliated Managers
Program
the heading
selecting
other
When
recommending
investment managers
to manage a client’s
Account in the DDK Recommended Managers
Service, DDK typically utilizes managers included
on Baird’s Recommended Managers List described
under
“Methods of Analysis,
Investment Strategies and Risk of Loss—Methods
of Analysis—Certain Recommended Lists—Baird’s
Recommended Managers List” below. Although in
some circumstances, DDK may select a manager
to manage a client’s Account that is not included
on Baird’s Recommended Managers List.
The process and standards that Baird uses for
determining whether to make PWM-Managed
Portfolios and SMA Strategies available under the
Baird
are
significantly less rigorous than those used in
connection with other SMA Programs offered by
Baird. Baird generally makes available all SMA
Strategies offered by Baird Equity Asset
Management, Baird Trust, GAMMA, Reinhart,
Riverfront and Strategas under the Program, and
Baird generally does not remove any of those
SMA Strategies from the Program unless Baird
Equity Asset Management, Baird Trust, GAMMA,
Reinhart, Riverfront or Strategas ceases to offer
the SMA Strategy or otherwise requests that Baird
remove the SMA Strategy from the Program.
PWM-Managed Portfolios and Baird Equity
Asset Management
the manager,
focusing on
include
from
sustained
underperformance
In order for Baird PWM and Baird Equity Asset
Management to provide portfolio management
services under the Program, Baird requires that
Baird PWM and Baird Equity Asset Management
associates meet all applicable requirements set
forth by self-regulatory organizations. Baird
Equity Asset Management also requires Baird
Equity Asset Management portfolio managers to
have an undergraduate degree. Furthermore,
Baird Equity Asset Management
strongly
encourages all Baird Equity Asset Management
portfolio managers to pursue and work towards
the attainment of the CFA designation or a
relevant graduate level degree. Baird may remove
a PWM or Baird Equity Asset Management
portfolio manager from providing services under
the Program
if Baird deems circumstances
warrant removal. Potential causes for removal
stated
significant drift
may
objectives,
in
relation to peers, or other adverse changes
affecting the manager.
DDK will select or replace, or recommend the
selection or replacement of, a particular manager
based upon the client’s particular goals and
circumstances and the client’s selected asset
allocation and
investment strategy. Before
selecting or recommending a manager to a client,
DDK performs its own quantitative and qualitative
the
analysis of
manager’s performance and factors DDK believes
will help a manager repeat historical performance
such as the investment process and personnel,
organizational and investment structure. DDK also
focuses on the risk and investment style relative
to other investment strategies already in a client’s
portfolio. DDK generally relies upon Baird’s
Advisory Research group to provide periodic
review and evaluation of managers on Baird’s
Recommended Managers List. To the extent a
manager
is not on Baird’s Recommended
Managers List, DDK will perform periodic review
and evaluation of the manager using its own
quantitative and qualitative analysis described
above. DDK will remove a manager
from
management of a client’s Account when the
manager is removed from Baird’s Recommended
Managers List or if DDK determines that removal
is in the client’s best interest.
Baird Trust, GAMMA, Reinhart, Riverfront
and Strategas
Clients should note that an investment manager
managing the client’s Account under the DDK
Recommended Managers Service may not be on
Baird’s Recommended Managers List. A client
should understand that DDK and Baird do not
perform any due diligence or ongoing monitoring,
evaluation or reviews of investment managers
legal and
Baird conducts a very limited review of Baird
Trust, GAMMA, Reinhart, Riverfront and Strategas
consisting solely of an annual compliance
questionnaire that asks the manager to confirm
certain matters or provide certain information
about the manager’s compliance policies and
regulatory
procedures, material
matters, management of the firm, the manager’s
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
except to the extent DDK otherwise specifically
agrees to do so in writing.
regarding any BSN Strategy or DC Strategy or
any representations regarding a BSN Manager’s or
DC Manager’s qualifications as an investment
adviser or abilities to manage client assets.
If a Model-Traded Strategy offered through an
Implementation Manager is selected for a client’s
Account, a client should note that DDK and Baird
do not monitor or ascertain whether a third party
Implementation Manager is fully and faithfully
implementing the Model Portfolio on a continuous
basis.
The Overlay Manager may provide review and
ongoing evaluations of certain BSN Managers that
it makes available through the BSN Program.
Clients should review Overlay Manager’s Form
ADV Part 2A Brochure for more information, which
is available upon request, or contact their DDK
Consultant for more information.
is
DDK and Baird do not monitor or ascertain
whether the Overlay Manager
fully and
faithfully implementing Model Portfolios under the
BSN Program on a continuous basis.
A client assumes ultimate responsibility
for
client’s selection of an Other Manager under the
DDK Recommended Managers Program (including
any third party Implementation Manager). DDK
and Baird assume no responsibility for the client’s
termination of an Other Manager (including any
third party Implementation Manager), the Other
Manager’s investment decisions, performance,
compliance with applicable laws or regulations, or
for any other matters involving or affecting the
Other Manager.
of
Loss—Principal
Baird SMA Network and Dual Contract
Programs
SMA Strategies offered under the BSN and DC
Programs are subject to certain risks. See
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risks—Available
Risk
Investment Product Risks” below
for more
information.
the
A client should only participate in the BSN or DC
Programs if the client wishes to take more
responsibility for monitoring the client’s Account,
the DDK Recommended Managers Program does
not contain an SMA Strategy that meets the
client’s particular needs, and
client
understands the risks of doing so.
Clients participating in the BSN Program or the
DC Program should note that the level of initial
and ongoing review performed by DDK and Baird
on the managers and their SMA Strategies made
available under those Programs, including any
Associated SMA Strategies, is significantly less
than that performed by DDK and Baird with
respect to managers and their strategies eligible
for the DDK Recommended Managers Service.
retention of an
A client should note that the client’s appointment
and continued
investment
manager to manage the client’s Account in
connection with the BSN or DC Programs are
based ultimately upon the client’s independent
review of the investment manager and the
investment manager’s services. Once retained by
the client, an investment manager will only be
removed from managing the client’s Account upon
the investment manager’s withdrawal, removal
from the Program, or the client’s direction to do
so.
BSN and DC Managers are subject to an initial
review by Baird that considers the manager’s
assets under management,
regulatory and
compliance history, and certain other limited
factors deemed
qualitative and quantitative
relevant by Baird. The ongoing review is generally
performed on an annual basis and is generally
limited to significant changes in the managers’
assets under management in the SMA Strategy
and a review of the SMA strategy in comparison
to a relevant peer group or benchmark.
a
client who wishes
(including any
A client assumes ultimate responsibility
for
client’s selection of a manager under the BSN or
DC Programs
third party
Implementation Manager). DDK and Baird assume
no responsibility for the client’s termination of a
the BSN or DC Programs
manager under
Implementation
third party
(including any
The BSN and DC Programs are designed to
to
accommodate
independently select an investment manager not
available in the DDK Recommended Managers
Service to manage the assets in the client’s
Account. A client should note that DDK and Baird
do not make any recommendation to clients
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performance,
compliance
Manager). DDK and Baird also assume no
responsibility for any Other Manager’s investment
decisions,
with
applicable laws or regulations, or for any other
matters involving or affecting the Other Manager.
“ALIGN
Programs—ALIGN
Portfolio management services under the DC
Program may be provided by an investment
management department of Baird if the client
selects such an SMA Strategy. In order to provide
portfolio management services under the DC
Program, Baird requires that Baird associates
meet all applicable requirements set forth by
applicable law and regulations of self-regulatory
organizations, such as the Financial Industry
Regulatory Authority,
Inc., exchanges, and
governmental agencies.
The UMA Programs make available UMA
Recommended Funds and UMA Recommended
SMA Strategies. The process Baird uses for
selecting and removing UMA Recommended Funds
for the UMA Programs is substantially similar to
the process Baird uses to select and remove
mutual funds and ETPs in connection with the
ALIGN Strategic Portfolios Program described
Strategic
under
Portfolios” below. The process Baird uses for
selecting and removing UMA Recommended SMA
Strategies for the UMA Programs is the same
process used for selecting and removing BRM
Strategies, which is described under the heading
“Methods of Analysis, Investment Strategies and
Risk of Loss—Methods of Analysis—Certain
Recommended
Recommended
Lists—Baird’s
Managers List” below.
ALIGN, BairdNext Portfolios, DDK
Investment Management and Russell
Programs
Portfolios,
DDK
In addition to the UMA Recommended Funds and
the UMA Recommended SMA Strategies, the UAS
Program also makes available UAS Available
Funds and UAS Available SMA Strategies. Clients
participating in the UAS Program should note that
the level of initial and ongoing review performed
by Baird on UAS Available Funds and UAS
Available SMA Strategies, including Associated
Funds and Associated SMA Strategies,
is
significantly less than that performed by Baird
with respect to UMA Recommended Funds and
UMA Recommended SMA Strategies.
Portfolio management services under the ALIGN,
BairdNext
Investment
Management Service and Russell Programs are
provided by Baird PWM, Baird PWM’s home office
investment professionals, and DDK. In order to
provide portfolio management services, Baird
requires that DDK Consultants and other Baird
associates meet all applicable requirements set
forth by applicable law and regulations of self-
regulatory organizations, such as the Financial
Industry Regulatory Authority, Inc., exchanges,
and governmental agencies.
considers
the
fund’s
UMA Programs
certain other
in
to a
Portfolio management services under the UMA
Programs are provided by Baird PWM, Baird
PWM’s home office investment professionals,
investment management departments of Baird
and DDK Consultants. In order to provide portfolio
management services under the Programs, Baird
requires that Baird associates meet all applicable
requirements set forth by applicable law and
regulations of self-regulatory organizations, such
as the Financial Industry Regulatory Authority,
Inc., exchanges, and governmental agencies.
UAS Available Funds, other than Associated
Funds, are subject to an initial review by Baird
that
assets under
management, regulatory and compliance history,
and
limited qualitative and
quantitative factors deemed relevant by Baird.
The ongoing review is generally performed on an
annual basis and is generally limited to significant
changes
the managers’ assets under
management and a review of the fund strategy in
comparison
relevant peer group or
benchmark. The process Baird uses for selecting
and removing UAS Available SMA Strategies,
other than Associated SMA Strategies, from the
UAS Program is the same process used for
selecting and removing BSN Strategies from the
BSN Program, which is described under the
heading
“Portfolio Manager Selection and
Evaluation—Selection and Evaluation—Baird SMA
Network and Dual Contract Programs” above.
Under the UMA Programs, portfolio management
services are also provided by managers of mutual
funds and ETPs, if those investments are part of a
UMA Portfolio, and by Other Managers and the
Overlay Manager, if an SMA Strategy is part of
the UMA Portfolio.
To be included the UAS Available Funds lineup or
lineup,
the UAS Available SMA Strategies
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to
less
faithfully implementing Model Portfolios under the
UMA Programs on a continuous basis.
of
Loss—Principal
and
UAS Available Funds and UAS Available SMA
Strategies are subject to certain risks. See
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risks—Available
Risk
Investment Product Risks” below
for more
information.
Associated Funds and Associated SMA Strategies,
respectively, are subject
rigorous
standards than the standards imposed upon funds
and SMAs that are not associated with Baird. The
standards used by Baird are substantially similar
to those it uses when including Associated SMA
Strategies
in the BAM Program. For more
information see the information contain under the
“Portfolio Manager Selection and
heading
Evaluation—Selection
Evaluation—Baird
Affiliated Managers Program” above.
A client retaining discretion over the client’s UAS
Program Account should only select UAS Available
Funds or UAS Available SMA Strategies if the
client wishes to take more responsibility for
managing and monitoring
the client’s UAS
Program Account, the UMA Recommended Funds
and UMA Recommended SMA Strategies do not
meet the client’s particular needs, and the client
understands the risks of doing so.
and
Likewise, the PWM-Managed Portfolios made
available under the UAS Program are not subject
to the same processes and standards used by
Baird in determining whether to make non-
affiliated investment options available under other
Programs. The process Baird uses for selecting
and removing PWM-Managed Portfolios from the
UAS Program is the same process used for
selecting and removing PWM-Managed Portfolios
from the BAM Program, which is described under
the heading “Portfolio Manager Selection and
Evaluation—Selection
Evaluation—Baird
Affiliated Managers Program” above.
client’s
independent
review of
any UAS
If a client has not selected the discretionary
management option of the UAS Program, it is
important to note that: the UAS Available Funds
and UAS Available SMA Strategies are made
available to accommodate a client who wishes to
independently select investments that are not on
a Baird recommended list for the client’s Account;
the client assumes ultimate responsibility for
monitoring each UAS Available Fund and UAS
Available SMA Strategy and the manager’s
performance; the client’s selection and continued
holding of a UAS Available Fund or a UAS
Available SMA Strategy are based ultimately upon
the
such
investment; and once an investment is made by
the client, the investment will only be removed
from the client’s Account upon the manager’s
withdrawal, removal of the investment from the
Program, or the client’s direction to do so.
If a client has not selected the discretionary
management option of the UAS Program, the
client should note that: (1) the UAS Available
Funds and UAS Available SMA Strategies are
made available to accommodate a client who
wishes to independently select investments that
are not on a Baird recommended list for the
client’s Account: (2) DDK and Baird do not make
any recommendation to clients regarding any UAS
Available Fund or UAS Available SMA Strategy and
DDK and Baird do not select any investments for
the client’s UAS Program Account: (3) DDK and
Baird do not make any representation to clients
Available Manager’s
regarding
qualifications as an investment adviser or abilities
to manage client assets.
(including any
(including any
The Overlay Manager may provide review and
ongoing evaluations of certain UAS Available
Managers that it makes available through the UAS
Program. Clients should review Overlay Manager’s
Form ADV Part 2A Brochure for more information,
which is available upon request, or contact their
DDK Consultant for more information.
A client assumes ultimate responsibility
for
client’s selection of an Other Manager under the
UAS Program
third party
Implementation Manager). DDK and Baird assume
no responsibility for the client’s termination of an
Other Manager
third party
Implementation Manager), the Other Manager’s
investment decisions, performance, compliance
with applicable laws or regulations, or for any
other matters involving or affecting the Other
Manager.
DDK and Baird do not monitor or ascertain
fully and
whether the Overlay Manager
is
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
• DDK and Baird associates acting as portfolio
managers under the ALIGN, BairdNext, DDK
Investment Management, BAM, ALIGN UMA
Select Services and PWM-Managed Portfolios;
and
and
regulations
of
• Other Managers participating in the BAM, DDK
Recommended Managers, BSN and DC
Programs that directly manage client accounts
under a Manager-Traded Strategy.
Portfolio management services under the UMA
Programs may be provided by Baird PWM’s home
office investment professionals or an investment
management department of Baird if the client
selects a model portfolio or an SMA Strategy
offered by them. In order to provide portfolio
management services under the UMA Programs,
Baird requires that Baird associates meet all
applicable requirements set forth by applicable
law
self-regulatory
organizations, such as the Financial Industry
Regulatory Authority,
Inc., exchanges, and
governmental agencies.
Oversight of the Services
Asset Management,
PWM
Departments,
oversees
Fixed
When Baird calculates a manager’s investment
performance, Baird generally uses composites of
the manager’s client accounts to calculate the
manager’s performance. A composite
is an
aggregation of client accounts managed by the
manager that are representative of a particular
investment strategy, style, or objective. Examples
of composites include large cap growth, all cap
value, balanced (which includes equity and fixed
income securities), and fixed income. Composites
may be further broken down to separate taxable
and non-taxable portfolios.
income
composites may be categorized by portfolio
duration.
The Investment Advisory Oversight Committee
(“IAOC”) of Baird, which includes members of
Baird’s
Sales
Management,
Investment Solutions, Asset
Manager Research, Compliance, Legal, and Risk
Management
the
standards and implementation of the Services. In
addition, Baird Equity Asset Management’s
Director also oversees the Baird Equity Asset
Management portfolio managers.
Investment
recommendations. Baird
When calculating composite performance, Baird
seeks to utilize calculation methods that adhere to
Performance Standards
Global
calculates
(GIPS®)
the
composite performance generally using
following principles:
• A total return calculation is used in reporting.
• Current market value including accrued income
is used.
• Trade date accounting is used in deriving
valuations.
the
• Monthly returns are calculated using
Modified Dietz calculation.
Baird’s
Investment
along with
• Returns for periods greater than a month are
calculated by geometrically linking the monthly
returns. Returns for periods greater than one
year are annualized.
The IAOC delegates its day-to-day oversight
responsibilities to certain subcommittees of the
IAOC, the applicable Market Director and Baird’s
PWM Supervision, Investment Solutions and
Compliance Departments to monitor the Services
and the performance of Baird associates providing
portfolio management services under the ALIGN,
BairdNext, DDK Investment Management, Russell
and ALIGN UMA Select Programs, and the
discretionary management of UAS Program
Accounts by UAS Managers. The applicable Market
Director, along with Baird’s PWM Supervision and
Compliance Departments and other designees,
provide periodic review of the performance of
DDK Consultants providing portfolio management
services.
Solutions
Department,
the Compliance
Department and other designees, provide periodic
the performance of other Baird
review of
portfolio management
associates
providing
services under
those Services. Performance
information
is provided to the IAOC or a
subcommittee or delegate thereof.
• Reporting is net of fees at the total portfolio,
but gross of fees for individual investment
categories (e.g., equity or fixed income).
calculates
its
or
Performance Calculation
As part of Baird’s selection and evaluation of
the
portfolio managers, Baird
investment performance of:
No independent third party reviews the composite
performance information calculated by Baird to
compliance with
accuracy
verify
presentation standards.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
departments,
is described under
independent
third party
reviews
investment management
or
investment managers that are affiliated with
Baird: ALIGN, BairdNext
Portfolios, DDK
Investment Management, Russell and Baird
Affiliated Managers Programs (“Affiliates-Only
Programs”). The processes, if any, used by Baird
those portfolio
for selecting and reviewing
managers
the headings
“Portfolio Manager Selection and Evaluation—
Selection and Evaluation” above and “Portfolio
Manager Selection and Evaluation—Methods of
Analysis, Investment Strategies and Risk of
Loss—Program Portfolio Strategies” below.
To the extent Baird selects or reviews other
portfolio managers participating in the Programs,
Baird does not calculate investment performance
information for such managers. Baird obtains
investment performance information for those
managers directly from the managers (including
the Overlay Manager) or from other external
sources that Baird believes to be reliable. A client
that: Baird does not
should understand
recalculate the performance provided by such
managers or external sources; neither Baird nor
any
the
information provided by such
performance
managers to verify its accuracy or compliance
with presentation standards unless otherwise
stated in writing; those managers may not
calculate performance on a uniform or consistent
basis; and Baird does not guarantee the accuracy
of information provided by such managers or any
external source.
thereby
and periodically discuss
A client should note that Baird does not generally
present its investment performance calculations
to clients. The information that DDK or Baird
provides to clients about portfolio managers from
time to time may not be calculated by DDK or
Baird but may be calculated by the managers
themselves or derived from external sources. DDK
and Baird do not audit or verify that investment
performance information presented to clients that
is calculated by managers or external sources is
accurate. In addition, a client should note that
such investment performance information may
not be calculated on a uniform or consistent basis
or reviewed by any independent third party. A
client should ask the client’s DDK Consultant for
more information.
A client should note that the processes and
standards used by Baird in determining whether
to make affiliated investment options available
under Affiliates-Only Programs differ from those
processes and standards used by Baird
in
determining whether
to make non-affiliated
investment options available under other
Services. Baird approves, and continues to make
available, affiliated investment options under
Affiliates-Only Programs
that would not be
approved for, or would have been removed from,
such other Services. For the Affiliates-Only
Programs, this practice presents a conflict of
interest because Baird has a financial incentive to
maximize the number of affiliated investment
options it makes available under Affiliates-Only
Programs due to the fact that, by increasing
investment options, Baird will likely attract more
client assets and
increase Baird’s
revenues. A client participating in an Affiliates-
Only Program should monitor the client’s Account
the
performance
performance of such Account with the client’s
DDK Consultant.
Portfolios,
DDK
professionals,
an
or
for
the
Portfolio Management by DDK, Baird and
Associated Managers
Portfolio management services under the ALIGN,
BairdNext
Investment
Management, Russell, BAM, Baird Recommended
Managers, DC and UMA Programs may be
provided by Baird and Associated Managers. Such
arrangements create a potential conflict of
interest because Baird and Associated Managers
may receive higher aggregate compensation if
clients retain Baird and Associated Managers
instead of retaining unassociated managers.
The following Services exclusively offer portfolio
management by Baird, its DDK Consultants, its
PWM home office investment professionals, its
Portfolio management services under the DDK
Recommended Managers Service or DC Program
could be provided by Baird PWM home office
investment
investment
management department of Baird or an
Associated Manager should a client select an
Associated SMA Strategy. When Baird selects SMA
Strategies, or otherwise determines manager
availability
Baird
eligibility,
Recommended Managers List or the DC Program,
Associated SMA Strategies and Associated
Managers are subject to the same selection and
review processes, if any, that Baird applies to
unassociated SMA Strategies and investment
managers participating in each respective Service.
The processes, if any, used by Baird for selecting
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
and
Evaluation—Selection
and reviewing SMA Strategies and Associated
SMA Strategies for those Services are further
described under the heading “Portfolio Manager
and
Selection
Evaluation” above.
how Baird addresses them, please see the
sections “Additional Information—Other Financial
Industry Activities and Affiliations” and “Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” below.
Advisory Business
Baird is privately-held, employee-owned global
investment and wealth management firm formed
in the State of Wisconsin in 1919.
Baird is owned indirectly by its associates through
several holding companies. Baird
is owned
directly by Baird Financial Corporation (“BFC”).
BFC is, in turn, owned by Baird Financial Group,
is the ultimate parent
Inc. (“BFG”), which
company of Baird. Associates of Baird own
substantially all of the outstanding stock of BFG.
analysis
and
research,
analysis
planning;
investment
and
account
transactions
and
Baird offers various investment advisory services
to clients, including services not described in this
Brochure. The investment advisory services Baird
include: portfolio management and
offers
recommendations
analysis;
investment
regarding asset allocation and
strategies;
and
recommendations regarding investment managers
and individual securities; investment consulting;
financial
policy
performance
development;
monitoring. Baird also offers clients execution of
brokerage
administrative
services, including maintaining custody of account
assets. Clients may also negotiate other services
with Baird. Baird offers its services separately or
in combination with other services. DDK and Baird
tailor advisory services to the individual needs of
clients. For more information about the services
offered by DDK and Baird, please see “Services,
Fees and Compensation” above.
Portfolio management services under the UMA
Programs could be provided by Baird PWM home
office investment professionals, an investment
management department of Baird or an
Associated Manager. The PWM-Managed Portfolios
made available under
the UAS Program
exclusively offer portfolio management by Baird.
If a client selects the discretionary management
option of the UAS Program, portfolio management
is also provided by the client’s UAS Manager.
When Baird selects SMA Strategies, or otherwise
determines manager availability or eligibility, for
the UMA Recommended SMA Strategies lineup for
the UMA Programs, Associated SMA Strategies
and Associated Managers are subject to the same
selection and review processes that Baird applies
to unassociated SMA Strategies and managers.
However, when Baird selects SMA Strategies, or
otherwise determines manager availability or
eligibility, for the UAS Available SMA Strategies
lineup for the UAS Program, Associated SMA
Strategies and Associated Managers are subject
to a less rigorous selection and review processes
than Baird applies to unassociated SMA Strategies
the PWM-Managed
and managers. Likewise,
Portfolios made available under the UAS Program
are not subject to the same processes and
standards used by Baird in determining whether
to make unassociated
investment options
available under other Programs. The processes, if
any, used by Baird for selecting and reviewing
those portfolio managers is described under the
headings
“Portfolio Manager Selection and
Evaluation—Selection and Evaluation” above and
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Program Portfolio Strategies” below.
see
above
Subject to the agreement of DDK, a client may
impose reasonable restrictions on the securities or
types of securities to be held in the client’s
Account. Please
“Services, Fees and
Compensation—Additional Service Information—
Investment Discretion”
for more
information.
Baird participates in wrap fee programs not
described in this Brochure and it provides portfolio
management services in connection with those
programs. Baird receives a portion of the wrap fee
When providing investment advisory services to
clients, DDK and Baird are fiduciaries and are
required to act solely in the best interest of
clients. Baird addresses the conflicts described
above through disclosure in this Brochure and by
adopting internal policies and procedures for DDK
and Baird and their associates that require them
to provide investment advice that is suitable for
advisory clients (based upon the information
provided by such clients). For more specific
information about these potential conflicts and
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
by
clients
providing
paid
portfolio
for
management services under those wrap fee
programs.
Methods of Analysis, Investment
Strategies and Risk of Loss
Investment Strategies
under management,
As of December 31, 2025, Baird had
approximately $394.0688 billion in regulatory
assets
approximately
$289.4898 billion of which was managed on a
discretionary basis and approximately $104.5790
billion of which was managed on a non-
discretionary basis.
The investment styles, philosophies, strategies,
techniques and methods of analysis that DDK,
investment
Baird, Baird PWM’s home office
professionals, and Other Managers use
in
formulating investment advice for clients vary
widely by Service and the person providing the
advice. A brief description of commonly used
strategies is provided below.
Equity Strategies
Performance-Based Fees and Side-By-Side
Management
DDK does not advise any client accounts that are
subject to performance-based fee arrangements.
Act.
Performance-based
focused,
Equity strategies generally have an objective to
provide growth of capital and primarily invest in
equity securities, such as common stocks.
However, these strategies may also invest in
other types of investments, such as fixed income
securities and cash. Equity strategies may invest
in companies of all market capitalization ranges or
focus on any combination of specific
may
capitalization ranges, such as large cap, mid cap
or small cap companies. Equity strategies may be
combined with other strategies described below,
such as growth, value, income, economic industry
international, global, or
or sector
geographic region or country focused strategies.
Fixed Income or Bond Strategies
Baird advises client accounts not participating in
services described in this Brochure that are
subject to performance-based fee arrangements.
Performance-based fee arrangements involve the
payment of fees based upon the capital gains or
capital appreciation of a client’s account. Any such
fee arrangements are made in compliance with
applicable provisions of Rule 205-3 under the
fee
Advisers
arrangements present a potential conflict of
interest for Baird (but not DDK) with respect to
other client accounts that are not subject to
performance-based fee arrangements because
such arrangements give Baird an incentive to
favor client accounts subject to performance-
based fees over client accounts that are not
subject to performance-based fees.
interest
the
arrangements
holdings
inequitable
region or
country
Fixed income or bond strategies generally have
one or more of the following objectives: (1)
provide current income; or (2) preservation of
capital. These strategies primarily invest in fixed
income securities, such as corporate bonds,
municipal securities, mortgage-backed or asset-
backed securities, or government or agency debt
obligations. However, these strategies may also
invest in other types of investments, such as
equity securities or cash. Fixed income strategies
may invest in debt obligations having any credit
rating, maturity or duration, or they may focus on
specific credit ratings, maturities or durations,
such as investment grade, non-rated, or high
yield (“junk”) bonds, or bonds having short-term,
intermediate-term or long-term maturities. Fixed
income strategies may be combined with other
strategies described below, such as economic
industry or sector focused, international, global,
or geographic
focused
strategies.
In addition to complying with its fiduciary duties
by disclosing this conflict of interest to clients
through this Brochure, Baird generally addresses
posed by
potential
conflicts
of
by
fee
performance-based
periodically monitoring
and
performance of performance-based fee accounts
and comparing them to accounts not subject to a
performance fee that are also managed using a
similar strategy in an attempt to detect any
possible
treatment. Baird also
attempts to minimize potential conflicts of interest
posed by performance-based fee arrangements
through internal trade allocation procedures that
are designed to make securities allocations to
discretionary client accounts in a manner such
that all such clients receive fair and equitable
treatment over time.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Balanced Strategies
client’s entire portfolio diversification needs.
These strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
International Strategies
include companies
ranges,
regions, credit
region or market
Generally, international strategies primarily invest
in securities issued by foreign companies, which
may
in developed and
emerging markets. International strategies may
invest in companies of all market capitalization
ranges and in investments having any credit
rating, maturity or duration, or they may focus on
industries or
specific capitalization
sectors, geographic
ratings,
maturities or durations.
Balanced strategies generally have one or more of
the following objectives: (1) provide current
income; (2) growth of capital/principal or income;
or (3) preservation of capital. These strategies
primarily invest in a mix of equity, fixed income
securities and cash. Balanced strategies may
invest in companies of all market capitalization
ranges and in investments having any credit
rating, maturity or duration, or they may focus on
specific capitalization ranges, credit ratings,
maturities or durations as described above.
Balanced strategies may be combined with other
strategies described below, such as economic
industry or sector focused, international, global,
or geographic
focused
strategies.
Global Strategies
Value Strategies
A value strategy typically invests primarily in
equity securities of value companies, which are
those that the investment manager believes are
out of favor with investors, appear underpriced by
the market relative to their earnings or intrinsic
value, or have high dividend yields. This strategy
is subject to investment style risks.
ranges,
regions, credit
Growth Strategies
Generally, global strategies invest in a mix of
securities issued by U.S. and foreign companies,
which may include companies in developed and
emerging markets. Global strategies may invest
in companies of all market capitalization ranges
and in investments having any credit rating,
maturity or duration, or they may focus on
industries or
specific capitalization
sectors, geographic
ratings,
maturities or durations.
Geographic Region or Country Focused Strategies
A growth strategy typically invests primarily in
equity securities of growth companies, which are
those that the investment manager believes
exhibit signs of above-average growth relative to
peers or the market, even if the share price is
high relative to earnings or intrinsic value. This
strategy is subject to investment style risks.
Income Strategies
Geographic region or country focused strategies
primarily invest in companies located a particular
part of the world, such as Latin America, Europe
or Asia, in a group of similarly-situated countries,
such as developed or emerging markets, or one
or more specific countries. These strategies alone
generally are not intended to satisfy a client’s
entire portfolio diversification needs. These
strategies are subject to concentration risks
because they generally are not diversified or they
may invest in a limited number of securities.
fixed
invest
Tactical and Rotation Strategies
An income strategy typically invests primarily in
income-producing securities, such as dividend-
income
paying equity securities and
securities. This strategy may
in a
combination of investment grade and high yield
bonds. This type of strategy may also invest in
income-producing, Non-Traditional
yield- or
Assets.
Economic Industry or Sector Focused Strategies
technology,
Tactical strategies typically tactically and actively
adjust account allocations to different categories
of investments, such as asset classes, geographic
locations or market sectors, based upon the
manager’s perception of how those investments
will perform in the short-term. Similarly, rotation
strategies
typically actively adjust account
allocations to different market sectors based upon
the manager’s perception of how those market
sectors will perform in the short-term. Tactical
Economic industry or sector focused strategies
primarily invest in companies in one or more
economic industries or sectors, such as the
telecommunications,
industrial,
materials, or financial sectors. These strategies
alone generally are not intended to satisfy a
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Tax Management Strategies
underweighting
and
taxable
Tax management strategies involve buying and
selling investments in a manner intended to
reduce the negative impact of U.S. federal income
taxes. They often involve buying or selling
investments to limit taxable investment gains or
to offset
investment gains with
investment losses or selling investments to avoid
recognition of taxable investment gains.
tax management strategy
is
strategies are often
subject
these
strategies
and rotation strategies are often driven by
technical analysis or methodologies and typically
involve
overweighting
account allocations to certain asset classes,
geographic locations or market sectors relative to
an applicable long-term strategic asset allocation,
benchmark index or the market generally. These
strategies often will be focused or concentrated in
one or more asset classes, geographic locations or
market sectors from time to time, and it is likely
that they will have limited or no exposure to one
or more asset classes, geographic locations or
market sectors. For that reason, tactical and
rotation
to
concentration risk. Because the decision-making
for tactical and rotation strategies is based upon
the manager’s short-term market outlook,
often
accounts pursuing
experience higher levels of trading and portfolio
turnover relative to other strategies.
Opportunity or Opportunistic Strategies
A
typically a
secondary strategy used to achieve a secondary
tax management objective and it is typically
together with other primary
implemented
investment
to achieve
strategies designed
primary investment objectives or goals. However,
managers in certain situations may use a tax
management strategy as the primary investment
strategy or tax management may be their primary
consideration when managing client Accounts,
such as when the manager is transitioning an
Account from one investment strategy to another.
the
strategy, particularly
utilizes
strategy
Accounts pursuing a tax management strategy in
some instances will be subject to additional or
different risks of loss, which may be material. The
holdings of Accounts pursuing tax management
strategies will often differ from the holdings of
similarly-managed accounts that do not utilize
if
such a
tax
replacement
management
securities. Therefore,
the performance of
Accounts utilizing a tax management strategy will
vary from similarly-managed accounts that do not
utilize such a strategy, possibly in a materially
negative manner, and such Accounts may not be
successful in pursuing any other investment
strategies, objectives or goals.
investment strategies, there
than other strategies. The
to
Tax management strategies are not intended to,
and likely will not, eliminate a client’s tax
obligations relating to investments in an Account.
Like all
is no
guarantee that the implementation of a tax
management strategy will be successful. A client’s
use of a tax management strategy may not
actually
lower a client’s tax obligations or
otherwise achieve a client’s tax goals.
Opportunity strategies will generally be invested
in a manner that seeks to provide long term
growth
through capital appreciation and/or
income by utilizing an active management style
that shifts the amount of investment made in
different asset classes and market sectors to take
advantage of the manager’s perception of market
pricing anomalies, those market or industry
sectors deemed favorable for investment by the
manager, the current interest rate environment
and/or other macro-economic trends identified by
the manager. Opportunity strategies often involve
the use of other strategies, particularly tactical or
rotation strategies, and will have the risks
associated with those strategies. Opportunity
Strategies may also involve investment in a more-
limited number of companies compared to other
strategies. As a result, a decline in value of one or
a few investments will more adversely impact
performance than if assets were more evenly
invested in a larger number of companies.
Opportunity strategies often experience higher
fluctuations in annual returns and overall market
value
types of
investments used
implement opportunity
strategies vary widely by manager and could
include equity securities, fixed income securities,
Non-Traditional Assets, Alternative Investment
Products and cash.
The effectiveness of tax management strategies
will be reduced if a client’s ability to recognize
losses for tax purposes is disallowed, limited or
deferred under applicable tax rules, such as the
IRS wash sales rules, which disallow losses if
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Direct Indexing Strategies
that
involve
the
substantially identical securities are purchased by
a client (whether through Baird or another firm)
within 30 days before or after a sale, and IRS
straddle rules, which limit and defer a client’s
ability to claim tax deductions related to the loss
on a sale of an investment in an Account if the
client holds an offsetting position in any account
held at Baird or another
firm. Some tax
the sale of
management strategies
securities at a loss and the reinvestment of the
proceeds into a replacement security that the
manager believes
to not be “substantially
identical” for purposes of the IRS wash sales rule.
A manager’s belief may be incorrect, resulting in
a disallowance of the loss and reducing the
intended benefits of
tax management
strategy.
limitations of
the wash sales
resulting
Direct indexing strategies involve investing in a
basket of individual securities, such as stocks,
that seeks to track a selected benchmark index.
Direct indexing strategies may be more costly
than other
track
investment options
benchmark indices, such as mutual funds and
ETFs. Direct indexing strategies also generally
include the use of tax management strategies in
an attempt to enhance Account performance. The
use of tax management strategies will cause an
Account to deviate from the benchmark index,
which will cause the Account’s returns to vary
from that of the benchmark index. The use of tax
management strategies may not be successful
and the performance of Accounts pursuing a
direct index strategy could be materially lower
than the benchmark index. See “Tax Management
Strategies” above for more information about the
risks and
tax management
strategies.
losses. The
rules,
risk of
Alternative Strategies and Complex Strategies
involved
invest
Trading activity in a client’s accounts (whether at
Baird or another firm) may also inadvertently
violate
in
inadvertent
disallowed
violations increases as the number of client
accounts and managers
increases
because there is a higher chance of uncoordinated
or conflicting trading activity in those accounts.
Automatic purchases in client accounts, such as
dividend
reinvestment programs, may also
inadvertently violate wash sales rules. A client’s
investments held in other accounts at Baird or
another firm may be deemed to be offsetting
positions for purposes of the IRS straddle rules,
which will also negatively impact the client’s
ability to deduct losses and will reduce the
intended benefit of the tax management strategy.
Alternative Strategies and other Complex
Strategies may
in a wide range of
investments, which may include equity securities,
fixed income securities, Non-Traditional Assets,
Alternative
Investment Products and cash.
Alternative Strategies and other Complex
Strategies generally involve the use of margin,
leverage, short sales and derivative instruments.
Many Alternative Strategies and other Complex
Strategies have no substantive restrictions on the
types of investments that may be used. Examples
of Alternative Strategies and other Complex
Strategies include the following.
resulting
from
• Relative Value Strategies. Relative value
strategies generally involve the purchase of
traditional assets, such as stocks and bonds,
and Non-Traditional Assets and the use of short
sales and derivative instruments in an attempt
to exploit price differences among securities
financial
that share similar economic or
characteristics.
Managers do not consider the holdings or
transactions in other client accounts (whether
held at Baird or another firm) when implementing
tax management strategies. Managers do not
undertake any responsibility to monitor or verify a
client’s compliance with applicable tax rules, and
they are not responsible for any tax‑related
effects or obligations
the
investments or transactions in a client’s Account.
A client is responsible for ensuring that the
holdings and transactions in the client’s other
accounts at Baird or another firm do not violate
appliable tax rules and bears the risk of such
violations. A client is strongly urged to consult the
client’s tax advisor prior to pursuing a tax
management strategy.
• Long/Short Strategies. Long/short strategies
generally involve the purchase of securities
believed to be undervalued and selling short
securities believed to be overvalued. They may
also involve the use of Non-Traditional Assets,
leverage and derivative instruments.
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complete market cycle. They may also involve
the use of derivative instruments.
• Event-Driven
• Market Neutral Strategies. Market neutral
strategies generally involve the purchase of
securities and selling securities short in similar
dollar amounts in an attempt to produce returns
that are
independent of general market
performance. They may also involve the use of
Non-Traditional Assets, leverage and derivative
instruments.
events
(such
and
liquidations).
Event-driven
Strategies.
strategies generally involve the use of Non-
Traditional Assets, short sales and derivative
instruments in an attempt to seek arbitrage
opportunities, particularly those triggered by
as mergers,
corporate
restructurings,
These
strategies typically involve the assessment of if,
how and when an announced transaction will be
completed.
• Statistical Arbitrage Strategies. Statistical
Arbitrage is based on the theory that stocks
have a tendency to return to a short-term trend
line. This type of strategy typically involves the
“systematic” or automated trading of securities
based upon where a security is relative to its
trend line.
arbitrage
strategies
involve
in corporate
is
buy-outs,
restructurings
short
securities believed
• Merger Arbitrage/Special Situations Strategies.
Merger
the
purchase and sale of securities of companies
involved
reorganizations and
business combinations, such as mergers,
exchange offers, cash tender offers, spin-offs,
and
leveraged
involve
liquidations. These strategies often
short selling, options trading, and the use of
other derivative instruments.
• Convertible Arbitrage Strategies. Convertible
arbitrage involves the purchase and short sale
of multiple securities of the same company. The
strategy
implemented by purchasing
securities believed to be undervalued and
selling
to be
overvalued. Often, the strategy involves the
purchase of a convertible bond issued by a
company and selling short that company’s
common stock. This strategy may involve the
use of a wide range of derivative instruments.
• Fixed
• Distressed Strategies. Distressed strategies
generally involve the purchase of securities in
companies that are in financial distress, or
companies that are entering into or are already
in bankruptcy. They may also involve the use of
short sales and derivative instruments.
Income Arbitrage Strategies. Fixed
income arbitrage strategies generally seek to
profit from interest rate, credit spread and other
arbitrage opportunities by investing in fixed
income securities, interest rate instruments and
derivative instruments.
• Macro Strategies. Macro strategies generally
involve the purchase of traditional assets, such
as stocks and bonds, and Non-Traditional Assets
and the use of short sales and derivative
instruments in an attempt to profit from
anticipated changes
in securities markets,
commodities markets, currency values, and/or
interest rates.
and
Systematic
• Discretionary
• Capital Structure Arbitrage Strategies. Capital
structure arbitrage generally involves investing
in multiple levels of a single company’s capital
structure, often taking long and short positions
in a company’s debt or equity in order to
capitalize on perceived mispricings resulting
from market inefficiencies or different pricing
assumptions. This type of strategy typically
involves the use of derivatives and structured
products.
strategies
generally
rely
Trading
Strategies. Discretionary
trading strategies
generally attempt to identify and capitalize on
patterns or trends in the markets. Systematic
trading
on
computerized trading systems or models to
identify and capitalize on those patterns or
trends. These strategies often involve the use of
Non-Traditional Assets, short sales, derivative
instruments and significant leverage.
• Absolute Return, Total Return and Real Return
Strategies. Absolute return, total return and
real return strategies generally involve the
purchase of traditional assets, such as stocks
and bonds, and Non-Traditional Assets in an
attempt to generate performance that has low
correlation to the major equity markets over a
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• Private Investment Strategies.
property damage, or environmental hazards.
Leverage is often used in private real estate
investments, which can increase potential
returns but also amplifies potential losses.
generally
in
companies
involve
in
o Private
invest
types. Examples of
include,
These
among
utilities,
investments
o Private Equity Strategies. Private equity
equity
strategies
investments
private
transactions. These investments are typically
made through participation in private equity
funds or funds of private equity funds. Private
equity strategies may invest in companies of
all market capitalization ranges or may focus
on any combination of specific capitalization
ranges. They may also focus on companies in
one or more economic industries or sectors or
geographic regions. Some private equity
strategies focus on companies that are newly
formed, in financial distress or already in
bankruptcy. The securities purchased are
typically unregistered and illiquid. Private
equity strategies may also involve the use of
leverage.
Infrastructure Strategies. Private
infrastructure
in
strategies
infrastructure projects and assets and may
involve exposure to a range of economic or
market sectors, geographic locations and
infrastructure
asset
others,
investments
and
telecommunication,
transportation.
are
typically made through participation in private
infrastructure funds. Investments in private
infrastructure strategies are often illiquid.
They may focus on certain sectors, industries,
geographic regions, size ranges or stages of
development or operations, or on certain
types and sizes of investments and may,
therefore, also lack diversification.
typically unrated or
• Leveraged Strategies. Leveraged strategies
generally involve the use of Non-Traditional
Assets, leverage, short sales and derivative
instruments in an attempt to amplify returns or
produce returns that are a multiple of a
benchmark index.
types of
referred
to as
floating
• Inverse Strategies. Inverse strategies generally
involve the use of Non-Traditional Assets,
leverage, short sales and derivative instruments
in an attempt to produce returns that are the
opposite of a benchmark index.
in
smaller
o Private Debt or Private Credit Strategies.
Private debt (also known as private credit)
strategies invest in loans or debt instruments
issued by companies in private transactions.
These investments are typically made through
participation in private debt funds or funds of
private debt funds. The investments involved
are
rated below
investment grade and are illiquid. Oftentimes,
the interest rate paid by the companies is
determined by a reference interest rate, such
as the federal funds rate, which is periodically
investments are
reset. These
sometimes
rate
corporate debt, floating rate loans or floating
rate bank loans. Private debt strategies often
involve the use of leverage and may involve
investment
capitalization,
distressed or bankrupt companies.
industrial
typically made
Alternative Strategies and other Complex
Strategies are not appropriate for some clients
because they are subject to special risks. See
“Services, Fees and Compensation—Additional
Service Information—Complex Strategies and
Complex
Investment Products” above and
“Portfolio Manager Selection and Evaluation—
Methods of Analysis, Investment Strategies and
Risk of Loss—Principal Risks—Non-Traditional
Assets and Complex Strategies Risks” below for
more information.
Asset Allocation Strategies
Certain Services, including the ALIGN, BairdNext
Portfolios, DDK Investment Management, Russell,
Baird Affiliated Managers and UMA Programs,
make available asset allocation strategies. Asset
o Private Real Estate Strategies. Private real
estate strategies invest in physical properties,
such as office buildings, apartments, retail
facilities. These
centers, and
investments are
through
participation in private REITs. Private real
focus on specific
estate strategies may
types, or
regions, property
geographic
economic sectors. Investments in private real
estate can be illiquid, meaning they may take
time to sell or refinance. Property values can
fluctuate due to market conditions, supply
and demand, and other factors. There are
tenant vacancies,
to
also
risks
related
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allocation strategies involve investing in one or
more of the following categories of assets:
tactical
allocation strategies involve the use of both
strategic and
investment strategies,
sometimes referred to as dynamic strategies.
Asset allocation strategies may be implemented
using a variety of investment types, such as
individual securities, mutual funds and ETPs. The
amount allocated to an asset class or investment
type varies by strategy, and some strategies may
have little or no allocation to one or more asset
classes or types of investments described above.
companies; U.S.
cap
located
• the equity securities asset category, which is
comprised of certain asset classes, such as,
equity securities issued by: U.S. large cap
growth companies; U.S.
large cap value
companies; U.S. large cap core companies; U.S.
mid cap growth companies; U.S. mid cap value
companies; U.S. mid cap core companies; U.S.
small cap growth companies; U.S. small cap
core
small
value
in
foreign companies
companies;
developed markets; foreign companies located
in emerging markets; U.S. REITs; and foreign
REITs;
as:
short-term
taxable
That
analysis
involves
• the fixed income securities asset category,
which is comprised of certain asset classes,
such
bonds;
intermediate term taxable bonds; long-term
taxable bonds; short-term tax-exempt bonds;
intermediate term tax-exempt bonds; long-term
tax-exempt bonds; high yield fixed income
securities; foreign fixed income securities; and
broad fixed income securities;
Baird uses its Capital Market Assumptions in
developing its proprietary model asset allocation
strategies, including those used in the ALIGN,
BairdNext Portfolios and UMA Programs, and
those used by some DDK Consultants. In
determining its Capital Market Assumptions, Baird
conducts an analysis of different asset classes and
the different levels of risk associated with those
investments.
the
consideration of past performance and the use of
forward-looking projections that are based upon
certain assumptions made by Baird about how
markets will perform in the future. There is no
assurance that asset classes or markets will
perform in accordance with Baird’s projections or
assumptions. For more information about Baird’s
Capital Market Assumptions, a client should
contact the client’s DDK Consultant.
and
• the Non-Traditional Assets category, which is
comprised of certain asset classes, such as:
commodities
commodity-linked
instruments; and currencies and currency-
linked instruments, and Digital Assets;
Baird’s most common asset allocation strategies
are described below. A client should note that the
specific investments in an Account following a
particular asset allocation strategy could vary
from the description below for a number of
reasons, including market conditions.
• the Alternative Investment Products category
which is comprised of certain asset classes,
such as: hedge funds, private equity funds and
managed futures; and
• cash.
allocation
strategies
have
also
have
varying
invest
All Growth Portfolio. An All Growth Portfolio
typically seeks to provide growth of capital.
Typically, an All Growth Portfolio will experience
high fluctuations in annual returns and overall
market value. Under normal market conditions,
this strategy generally invests nearly all of its
assets in equity securities. This strategy may also
invest in other asset classes, such as fixed income
securities, Non-Traditional Assets and cash. This
strategy may also
in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
investing, which
and
actively
typically
adjusting
Capital Growth Portfolio. A Capital Growth
Portfolio typically seeks to provide growth of
capital. Typically, a Capital Growth Portfolio will
Asset
varying
investment objectives, ranging from growth of
capital to preservation of capital. Asset allocation
investment
strategies
strategies. Some asset allocation strategies use
strategic investment strategies, which involve
investing accounts
in accordance with a
predetermined target allocation to different asset
classes. Some asset allocation strategies use
involves
tactical
tactically
account
allocations to different asset classes based upon
the manager’s perception of how those asset
classes will perform in the short-term. Some asset
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
fluctuations in annual returns and overall market
value. Generally, under normal market conditions,
this strategy will primarily invest in a mix of fixed
income securities, cash and equity securities, with
a significantly higher allocation to fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets.
Generally, under normal market conditions, this
strategy will have a significantly higher allocation
to fixed income securities and cash than equity
securities.
Preservation
A
Portfolio.
experience moderately high fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, this strategy will
primarily invest in a mix of equity securities and
fixed income securities, with a significantly higher
allocation to equity securities. This strategy may
also invest in other asset classes, such as Non-
Traditional Assets and cash. This strategy may
also invest in Alternative Investment Products or
may involve the use of leverage, short sales and
derivative instruments. Generally, under normal
market conditions, this strategy will have a
significantly higher allocation to equity securities
than fixed income securities.
typically seeks
Capital
Capital
Preservation Portfolio typically seeks to preserve
capital while generating current income. Typically,
a Capital Preservation Portfolio will experience
relatively small fluctuations in annual returns and
overall market value. Under normal market
conditions, this strategy generally invests nearly
all of its assets in a mix of fixed income securities
and cash. This strategy may also invest in other
asset classes, such as equity securities and Non-
Traditional Assets.
Growth with Income Portfolio. A Growth with
Income Portfolio
to provide
moderate growth of capital and some current
income. Typically, a Growth with Income Portfolio
will experience moderate fluctuations in annual
returns and overall market value. Generally,
under normal market conditions, this strategy will
primarily invest in a mix of equity securities and
fixed income securities, with a bias towards equity
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
equity securities than fixed income securities.
Objectives
and
Some ALIGN Programs, UMA Programs, DDK
Consultants and investment managers use asset
allocation strategies that include target asset
allocation percentages for equity and/or fixed
income investments in the names or descriptions
of the strategies (e.g., 80-20, 60-40, 40-60, 20-
80, etc.). A client should note that those
percentages are intended to be asset allocation
targets only. There is no guarantee that Accounts
following asset allocation strategies will be
invested strictly in accordance with target asset
allocations. It is likely that the actual investments
in Accounts following those strategies will vary,
sometimes significantly, from the target asset
allocations and may include other asset classes
due to market conditions and Baird’s, the DDK
Consultant’s or investment manager’s assessment
of how to best invest a client’s Accounts. See
“Important Information about Implementation of
Investment
Investment
Strategies” below for more information.
Income with Growth Portfolio. An Income with
Growth Portfolio typically seeks to provide current
income and some growth of capital. Typically, an
Income with Growth Portfolio will experience
moderate fluctuations in annual returns and
overall market value. Generally, under normal
market conditions, this strategy will primarily
invest in a mix of fixed income securities and
equity securities, with a bias towards fixed income
securities. This strategy may also invest in other
asset classes, such as Non-Traditional Assets and
cash. This strategy may also invest in Alternative
Investment Products or may involve the use of
leverage, short sales and derivative instruments.
Generally, under normal market conditions, this
strategy will have a slightly higher allocation to
fixed income securities than equity securities.
For information about the risks associated with
the asset allocation strategies described above,
see the section of the Brochure entitled “Principal
Risks—Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies” below.
Conservative Income Portfolio. A Conservative
Income Portfolio typically seeks to provide current
Income
income. Typically, a Conservative
small
Portfolio will
experience
relatively
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Important Information about Implementation of
Investment Objectives and Investment Strategies
basis how the Account is being managed or
advised and whether any such conditions exist.
Methods of Analysis
Baird, its home office investment professionals,
and DDK Consultants may use various forms of
investment analyses, including the following:
A client should note that, to implement an
investment strategy, a client’s DDK Consultant or
investment manager may use or recommend
mutual funds, ETPs or other Funds that primarily
invest in particular types of securities instead of
direct investment in those types of securities. A
client should also note that the client’s DDK
Consultant or investment manager may use a
strategy not described above or they may use a
strategy with the same or similar name that is
implemented differently. A client should ask the
client’s DDK Consultant or investment manager
for more specific information about the strategy
being used for the client’s Account.
• Fundamental Analysis. Fundamental analysis
involves an approach to investing through a
detailed analysis of specific companies, such as
their financial statements and financial ratios,
management, competitive advantages and
markets, in an attempt to determine the value
of an investment. Fundamental analysis may
include qualitative and quantitative analyses.
Analysis. Qualitative
• Qualitative
A client’s Account
is subject to the risks
associated with the Account’s particular strategies
and investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
analysis
involves the use of subjective judgment to
analyze factors that may be difficult to quantify
or measure objectively. As it pertains to
managers and investment products, qualitative
analysis may include review of the background
and experience of a manager or a mutual fund
company.
in an attempt
• Quantitative Analysis. Quantitative analysis is a
method of evaluating securities by analyzing a
large amount of data through the use of
algorithms or models
to
understand behavior, predict market events,
market prices, etc., and generate an investment
decision. As it pertains to managers and
investment products, quantitative analysis may
review of manager performance,
include
investment style, style consistency, risk, and
risk-adjusted performance.
• Technical Analysis. Technical analysis is a
method of analyzing past price and volume
patterns and trends in the trading markets to
attempt to predict the direction of both the
overall market and specific investments.
investment
restrictions,
• Top-Down Analysis. Top-down analysis involves
a consideration of certain macroeconomic
trends, such as general economic conditions,
geographic or market sector performance, fiscal
and monetary policy, taxes, or interest rates, to
make investment decisions.
Analysis. Bottom-up
• Bottom-Up
From time to time, the client’s DDK Consultant or
invest the client’s
investment manager will
Account, or recommend that the client invest the
Account, in a manner that is inconsistent with the
investment strategy or
investment objective
selected by the client for the Account when the
client’s DDK Consultant or investment manager
determines that it is appropriate to do so, such as
using defensive strategies in response to adverse
market or other conditions or engaging in tax
management. Similarly, a client’s Account may be
invested in a manner inconsistent with the
investment strategy or
investment objective
selected by the client for the Account in certain
other circumstances, such as when the client’s
is transitioning to a new Service,
Account
investment objective or investment strategy, or
due to other factors, such as market appreciation
or depreciation of the assets in the client’s
Account, deposits and withdrawals made by the
if any,
client, and
imposed by the client. A client’s Account may not
be able to achieve its investment objectives
during any such period of time and the Account
may be subject to different or enhanced risks
than would be the case had the Account been
invested in a manner wholly consistent with the
investment objective or
investment strategy
selected by the client. Clients are encouraged to
discuss with their DDK Consultant on a regular
analysis
involves consideration of factors particular to a
such as business
particular
investment,
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Consultants. All AI Tool-assisted outputs used in
formulating investment advice are subject to
human
inform
review before such outputs
recommendations or investment decisions.
financials (e.g., balance sheet strength and
cash flows), financial ratios (e.g., price-to-
earnings ratio), and business fundamentals
(e.g., management and product or services
performance) to make investment decisions.
could negatively
influence
When providing investment advice to clients, DDK
Consultants utilize research reports and other
research material created by Baird PWM Research
Groups, such as PWM Equity Research, PWM Fixed
Income Research, and Asset Manager Research.
DDK Consultants may also utilize research reports
Institutional Equities &
created by Baird’s
Research Department. It should be noted that
DDK Consultants are not obligated to act in a
manner consistent with those research reports
and they may act in a manner that is contrary to
those reports if they deem it to be in the client’s
best interest.
AI Tools are highly-useful but complex and fallible
systems that can exhibit bias, hallucinations,
deceptive behaviors and other flaws due to the
construction of their underlying models and the
composition of their training data, which can
result in outputs that seem plausible but are in
fact inaccurate, incomplete, or misleading. The
use of AI Tools creates a risk that erroneous
information
the
investment-advice process. Baird has established
policies and procedures designed to address the
risks posed by AI Tools, which
include
requirements that AI Tools pass a firm-level due
diligence process and that Baird associates obtain
training and independently verify AI Tool outputs.
However, such measures cannot eliminate the
risks posed by AI Tools.
their
sponsors
(which may
Baird PWM Research Groups and DDK Consultants
use various third party information and tools
when formulating investment advice. The sources
of information and tools may include, among
others, information provided or created by issuers
and
include
information that is reported publicly, provided
directly to Baird, or reported through third party
platforms) and information and tools provided by
third party research firms, which may include
firms affiliated with Baird. Although Baird has
deemed the information and tools provided by
third party research firms to be generally reliable,
Baird does not independently verify or guarantee
the accuracy of the information or tools used.
(“AI”)
When providing investment advice to clients, DDK
Consultants may also use the model portfolios or
recommended or eligible product lists (described
below) made available by Baird’s PWM Research
Groups, or they may use investment products
that Baird has generally deemed to be “available”
for use in its advisory programs (“Available
Investment Products”). The level of initial and
ongoing evaluation, monitoring and review that
DDK and Baird perform on managers and on
investment products varies. Available Investment
Products generally do not receive the same level
of initial or ongoing evaluation, monitoring or
review by Baird as those managers or products
that are included in a model portfolio or on a
recommended or eligible product list. As a result,
Available Investment Products are subject to
certain risks. See “Portfolio Manager Selection
and Evaluation—Methods of Analysis, Investment
Strategies and Risk of Loss—Principal Risks—
Available Investment Product Risks” below for
more information.
in
formulating
Baird PWM home office investment professionals
and DDK Consultants may use artificial
intelligence
tools, such as machine
learning, predictive analytics and probabilistic
modeling tools, data processing and automation
tools, generative AI tools, visual, speech and
audio tools, specialized domain tools, and other
similar technologies and tools (collectively, “AI
investment advice.
Tools”),
Generally, the use of AI Tools is limited to certain
aspects of Baird’s investment-advice process,
such as assisting with drafting of materials,
automation of workflow processes, and the
compilation,
organization,
reproduction,
summarization, analysis and interpretation of
information. The use of AI Tools is only supportive
of Baird’s investment-advice process and does not
replace the professional judgment of Baird PWM
home office investment professionals or DDK
More specific information about Baird PWM model
portfolios, recommended lists and eligible product
lists is provided below. A client should note that
investment products recommended to the client
or selected for the client’s Account, including
investment managers or products included on a
Baird PWM recommended or eligible product list,
are those which, in Baird’s professional judgment,
may be appropriate to help the client pursue the
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird Rising Dividend Portfolio
client’s financial goals. DDK and Baird do not
represent or guarantee that such investment
managers or products are or will be the best
investment managers or products available.
Under certain circumstances when requested by a
client, DDK and Baird may allow a client to
transfer from another firm or select an investment
product that is not on a Baird recommended or
eligible product list or that does not qualify as an
Available Investment Product. A client should note
that, unless DDK and Baird otherwise agree in
writing, DDK and Baird do not provide any initial
or ongoing evaluation, monitoring or review of
any such investment product and that the client’s
decision to transfer or select such investment
product is based solely upon the client’s review of
the investment product.
Certain PWM-Managed Portfolios
Baird Recommended Portfolio
The Baird Rising Dividend Portfolio, which is
managed by Baird’s PWM Equity Research team,
seeks to provide a core equity strategy with a
portfolio yield above that of the S&P 500 Index.
The team’s top–down investment approach begins
with macroeconomic and market outlooks from
Baird’s Investment Strategy team. The 30–50
stocks in the portfolio are primarily large cap
stocks—as defined by a market capitalization of
$10 billion or greater at the time of investment—
and all are above $5 billion at the time of
investment. The team looks for quality companies
with strong
fundamental characteristics and
management, attractive dividend yields, and the
ability to increase their dividends. Companies are
screened for dividend history and consistency,
earnings growth expectations, and balance sheet
quality. Each stock selected
is assigned a
weighting as a percentage of the portfolio. No
single company stock will comprise more than the
greater of 5% of the portfolio or 1.5 times the
stock’s market weight in the S&P 500 index;
provided that a stock will not be removed due to
capital appreciation. A position can be reduced or
removed due to changes in valuation, company
fundamentals or the perceived ability to continue
to raise its dividend in the future—among a
variety of other potential reasons for portfolio
changes including a change in industry sector
weighting. The Portfolio is intended as a long-
term investment strategy.
investment
approach
AQA Portfolios
to
clients
Analysis
performance.
The
analysis
The Baird Recommended Portfolio, which
is
managed by Baird’s PWM Equity Research team,
seeks to outperform the S&P 500 Index by
investing in a diversified core portfolio of 35–50
stocks. The portfolio invests primarily in stocks
with market capitalization greater than or equal to
$10 billion (large cap). The portfolio may also
contain stocks with market caps below $10 billion
but these stocks generally will not represent more
than 35% of the total portfolio. The team’s top–
down
begins with
macroeconomic and market outlooks from Baird’s
Investment Strategy team. This information is
used to underweight or overweight particular
industry sectors compared to the S&P 500 Index.
Individual stocks are selected with an emphasis
on higher quality companies that the team
believes have strong fundamental characteristics
teams, attractive growth
and management
prospects, and
reasonable price-appreciation
expectations. Each stock selected is assigned a
weighting as a percentage of the portfolio. No
single company stock will comprise more than the
greater of 5% of the portfolio or 1.5 times the
stock’s market weight in the S&P 500 index;
provided that a stock will not be removed due to
capital appreciation. Stocks can be sold or
positions reduced for a variety of reasons such as
valuation, a change in company or industry
fundamentals, or a change in industry sector
weighting. The Portfolio is intended as a long-
term investment strategy.
certain
Baird makes available
Automated Quantitative
(“AQA”)
Portfolios, which are managed by Baird’s PWM
Equity Research team. AQA is an analytical tool
that seeks to identify stocks of companies that
are undervalued by calculating the intrinsic values
for the stocks and comparing the calculated
values to current market prices. Focusing on a
company’s past
financial performance, AQA
analyzes fundamental ratios and trends of the
most recent eight-year history of a company and
each company in its peer group, excluding
estimates of future balance sheet and income
statement
is
ignores certain qualitative
quantitative and
information such as company-specific material
news and events. Stocks are ranked from the
most undervalued to the most overvalued based
on the difference between the values calculated
by AQA and current market prices. The stocks
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• reliability and consistency of their investment
process
• competitiveness of their investment
performance
Baird’s Asset Manager Research Department may
also employ the use of computers and third party
software to more readily display information and
assist with the evaluation and analysis.
identified by AQA as being the most undervalued
are then selected for investment. Baird offers the
following four (4) AQA Portfolio strategies, each of
which invest in undervalued stocks identified
using AQA, excluding securities issued by banks,
REITS and insurance companies: (1) the AQA All
Cap Strategy, which primarily invests in stocks
across market capitalizations, generally those
included in the S&P 500®, S&P MidCap 400® or
S&P SmallCap 600® Indices; (2) the AQA Large
Cap Strategy, which primarily invests in large cap
stocks, generally those included in the S&P 500®
Index; (3) the AQA Mid Cap Strategy, which
primarily invests in mid cap stocks, generally
those included in the S&P MidCap 400® Index;
and (4) the AQA Small Cap Strategy, which
primarily invests in small cap stocks, generally
those included in the S&P SmallCap 600® Index.
Certain Recommended Lists
Baird’s Recommended Managers List
Baird’s initial screening process begins with a
proprietary, multi-factor model that evaluates
managers on different factors including risk-
adjusted performance, consistency of returns and
downside protection. These factors are scored
over various time periods and relative to a
specific peer group universe, narrowing the pool
of managers for further evaluation. Baird’s Asset
Manager Research Department then performs a
more in-depth evaluation of managers that are
identified through the initial screening process,
which generally includes a review of the following
factors: stability of the firm/team, the robustness
and repeatability of the investment process, the
portfolio’s past returns pattern and tax-efficiency,
and how the manager adds value. The final
determination of Baird’s Recommended Managers
List
is subject to the approval of Baird’s
Investment Committee.
conference
calls,
for
removal
When selecting managers and BRM Strategies for
Baird’s Recommended Managers List, Baird often
seeks registered investment advisory firms having
portfolio managers with academic credentials
such as a master’s degree or participation or
completion of the Chartered Financial Analyst
(“CFA”) program. Baird also typically looks for a
portfolio manager with greater than three (3)
years of investment experience focusing on the
particular investment style that is offered by the
portfolio manager. Baird generally looks for
portfolio managers
that have demonstrated
success, that have performance histories showing
sufficient ability to achieve returns in excess of
their respective benchmarks, and that have
investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird
also considers other qualitative and quantitative
factors.
change
Ongoing manager evaluation generally includes
quarterly
performance
attribution and periodic onsite visits. Material
adverse changes affecting a manager may result
in the manager being placed on “watch” status.
Managers on “watch” status are scrutinized to see
if improvement or degradation is taking place.
Potential causes
from Baird’s
Recommended Managers List include fundamental
changes in the operations of the manager,
turnover in key personnel, substantial changes in
management or ownership, a
in
investment philosophy or style, significant drift
from stated objectives, major legal, regulatory or
compliance difficulties, impairment of financial
condition, sustained underperformance in relation
to its peers, or other adverse changes affecting
the manager that in Baird’s opinion warrants the
manager’s removal.
Baird’s Asset Manager Research Department is
primarily responsible for selecting and evaluating
included on Baird’s
investment managers
Recommended Managers List.
selecting
In
investment managers, Baird’s Asset Manager
Research Department utilizes quantitative and
qualitative measures to evaluate managers based
on the:
• quality and stability of their organization
• soundness and clarity of their investment
philosophy
If a Model-Traded BRM Strategy is selected for a
client’s Account, it is important to note that
Baird’s selection and ongoing evaluation of a BRM
Strategy is based upon an assumption that the
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Investment Committee
its discretion, decides
inclusion
Recommended Manager’s Model Portfolio will be
fully and faithfully implemented by the Overlay
Manager or Implementation Manager on a
continuous basis. A client should understand that
the Overlay Manager or Implementation Manager
has discretion over the client’s Account and may
invest the client’s Account in a manner that differs
from the Model Portfolio. Baird does not monitor
the Account’s performance nor does it ascertain
whether the Overlay Manager or Implementation
Manager is implementing the Model Portfolio as
provided by the Recommended Manager. If the
Overlay Manager or Implementation Manager, in
the exercise of
to
implement the Model Portfolio differently, the
performance of a client’s Account could be
negatively impacted. Baird is not monitoring,
evaluating or reviewing the Overlay Manager or
Implementation Manager or the performance of a
client’s Account under those circumstances.
Department utilizes a quantitative and qualitative
evaluation process of the investment managers of
such funds. The process Baird uses for selecting
and removing funds for the Baird Recommended
Fund List is similar to the process Baird uses to
select and remove BRM Strategies described
under “Baird’s Recommended Managers List”
above. Baird’s
is
ultimately responsible for selecting funds included
on the List. The Baird Ultra Short Bond Fund,
Baird Short-Term Bond Fund, Baird Aggregate
Bond Fund, Baird Quality Intermediate Municipal
Bond Fund, Baird Core Intermediate Municipal
Bond Fund, and Baird Mid Cap Growth Fund,
mutual funds affiliated with Baird, have been
selected by Baird
in Baird’s
for
Recommended Mutual Fund List. This presents a
conflict of interest. However, the criteria used by
Baird in deciding to select Associated Funds for
Baird’s Recommended Mutual Fund List are the
same as those used for unassociated funds.
Baird’s Recommended Funds of Hedge Fund List
SMA
Strategies
for
Certain SMA Strategies offered by Baird Equity
Asset Management have been selected by Baird
for inclusion on Baird’s Recommended Managers
List. This presents a conflict of interest. However,
the criteria used by Baird in deciding to select
Baird’s
Associated
Recommended Managers List are the same as
those used for unassociated SMA Strategies.
Baird’s Recommended Mutual Fund List
Baird’s Recommended Funds of Hedge Fund List
may contain several types of funds of hedge
funds (“FOHFs”) that pursue various Alternative
Strategies or other Complex Strategies. Some
FOHFs primarily use credit-oriented investment
strategies, which Baird classifies as fixed income
diversifiers. Some FOHFs primarily use equity-
oriented investment strategies and are classified
as equity diversifiers. Other FOHFs use a
combination of credit- and equity-oriented
strategies, which Baird views as balanced
diversifiers. In certain circumstances, FOHFs may
be an appropriate substitute for part of a client’s
allocation to traditional high yield fixed income or
equity investments.
that
to
the
for
the
fund; and
Baird’s Recommended Mutual Fund List
is
designed to include mutual funds and ETFs across
numerous asset classes. When selecting funds for
inclusion on the List, Baird generally seeks funds
that have investment managers with tenure of at
least three (3) years and have underlying
investments
fund’s
adhere
market capitalization policy and are consistent
with the manager’s stated investment process
and philosophy. Baird generally looks for funds
that are among the top-performing funds in a
style category in terms of risk-adjusted returns or
that are managed by individuals or firms that
have demonstrated success in other, related asset
classes; that have performance histories showing
sufficient ability to achieve returns in excess of
their respective style index; and that have
investment processes, infrastructure, personnel
and other resources satisfactory to Baird. Baird’s
Asset Manager Research Department is primarily
responsible
for assisting with selecting and
evaluating funds included on the List. In selecting
Research
funds,
Baird’s
Asset Manager
To be added to Baird’s Recommended FOHF List,
a FOHF must generally meet the
following
requirements: the investment advisor to the FOHF
is registered as an Investment Adviser under the
Advisers Act; the fund has stable to growing
assets under management as determined by
Baird, principals of the fund have an appropriate
level of hedge fund management experience and
a sufficient network of contacts in the industry as
determined by to Baird; in Baird’s opinion, the
fund has adequate diversification by number of
hedge funds and type of hedge fund strategy;
effective risk management programs have been
established
the service
providers to the fund (e.g., auditor, administrator,
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and legal counsel) are deemed to be reputable in
the judgment of Baird. Baird also seeks FOHFs
that it believes possess one or more unique
attributes that may lead to favorable performance
relative to their peers going forward.
legal documents
notable change in the investment or compliance
teams, weakening performance, or regulatory
problems. Any firm that is placed on “watch”
status is evaluated more closely to determine if
the problem is likely to be temporary or long-
term, and whether it can be remedied. Baird will
remove a FOHF from “watch” status and return it
to active status if, in Baird’s opinion, the problem
has been or is in process of being adequately
addressed. However, Baird will terminate a FOHF
from the List if it believes the issue is likely to be
long-term and adversely affect the FOHF’s future
performance.
offering memorandum,
Baird’s Recommended Private Funds Lists
Baird maintains lists of recommended private
Funds (“Recommended Private Funds”), including
a Recommended Funds of Private Equity Funds
List, a Recommended Private Debt Fund List, and
a Recommended Private Real Assets Fund List.
In making
that determination,
funds,
funds
or
Before adding a prospective FOHF to the List,
Baird’s Asset Manager Research Department
conducts an in-depth due diligence process. The
process begins with a review of the FOHF’s
responses to a due diligence questionnaire and of
marketing and
(such as,
subscription documentation, investor agreements,
and
organizational
documents, and the investment advisor’s Form
ADV Part 2A Brochures). This is followed by an
onsite review, where Baird meets with one or
more principals and analysts to assess how the
FOHF identifies, hires, monitors, and terminates
individual hedge funds. Baird also evaluates how
the FOHF constructs its hedge fund portfolio and
manages risk. At the conclusion of the onsite
review, an investment thesis is presented to and
discussed with a Baird Investment Committee.
The Committee votes on whether to add the FOHF
to Baird’s Recommended Funds of Hedge Fund
the
List.
Committee considers the information presented,
taking into account the merits of the individual
FOHF, how that FOHF compares to other FOHFs
that Baird offers, and the level of expected
demand for the particular FOHF.
client’s allocation
to
and
onsite
Baird’s Recommended Funds of Private Equity
Funds List contains funds of private equity funds
that pursue certain Alternative Strategies or other
Complex Strategies. These strategies can include
buyout, growth equity, venture capital, special
situations or distressed
investments. The
investments are typically structured in the form of
primary
co-
secondary
investments. Most will be to “middle market”
companies, many of which have above average to
high levels of leverage, or debt relative to equity.
In certain circumstances, funds of private equity
funds may be an appropriate substitute for part of
traditional equity
a
investments.
changes
that pursue
or
After a FOHF is added to Baird’s Recommended
Funds of Hedge Fund List, it is monitored each
reviews
subsequent
quarter,
periodically take place. As part of its quarterly
monitoring, Baird evaluates a FOHF’s assets under
(subscriptions and
management and
flows
(e.g.,
redemptions), organizational
personnel changes or new offerings), recent
changes made to the FOHF portfolio (e.g., hedge
funds added or removed), and reasons for
performance differences between the FOHF and
its benchmark. Subsequent onsite reviews are
similar in nature and scope to the initial on-site
review.
Baird’s Recommended Private Debt Fund List
contains private debt funds (also known as
certain
funds)
credit
private
Alternative Strategies
other Complex
Strategies. The private debt funds on Baird’s
Private Debt Funds List generally make first lien,
second lien and unsecured loans, primarily to
middle market companies sponsored by private
equity firms. In certain circumstances, private
debt funds may be an appropriate substitute for
part of a client’s allocation to traditional high yield
fixed income or equity investments.
funds
Baird’s Recommended Private Real Assets Fund
List contains private real estate and private
pursue
infrastructure
certain
other Complex
Alternative Strategies
that
or
Baird may place a FOHF on “watch” status if it has
experienced a material event that, in Baird’s
opinion, may negatively affect
the FOHF’s
performance going forward or possibly lead to the
departure of an important member(s) of the
FOHF. Examples include a large decline in assets
under management, high rate of redemptions,
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the
the Committee
information
considers
presented, taking into account the merits of the
individual fund, how that fund compares to other
similar funds that Baird offers, and the level of
expected demand for that particular fund.
utilities,
telecommunication,
The
investments may
with
companies
that
Strategies. These strategies invest in different
real assets and may involve exposure to a range
of economic or market sectors, geographic
types. Examples of
locations and asset
investments may include, among others, real
and
estate,
transportation.
be
structured in the form of asset ownership or
leasing or include direct investment in or joint
ventures
control
infrastructure assets. In certain circumstances,
private real assets funds may be an appropriate
substitute for part of a client’s allocation to
traditional fixed income or equity investments.
After a fund is added to a Baird Recommended
Private Fund List, it is monitored each quarter,
and subsequent onsite reviews periodically take
place. As part of its quarterly monitoring, Baird
evaluates a fund’s assets under management and
fund
flows (subscriptions and redemptions),
organizational changes (e.g., personnel changes
or new offerings), recent changes made to the
portfolio, and reasons for performance differences
between the fund and its benchmark. Subsequent
onsite reviews are similar in nature and scope to
the initial on-site review.
To be added to a Baird Recommended Private
Fund List, a fund must generally meet the
following requirements: the investment advisor to
the fund is registered under the Advisers Act ; the
fund has stable
to growing assets under
management as determined by Baird; principals
of the fund have an appropriate level of applicable
experience and a sufficient network of contacts in
the industry as determined by Baird; effective risk
management programs have been established for
the fund; and the service providers to the fund
(e.g., auditor, administrator, and legal counsel)
are deemed to be reputable in the judgment of
Baird. Baird also seeks funds that it believes
possess one or more unique attributes that may
lead to favorable performance relative to their
peers going forward.
fund
Baird may place a Recommended Private Fund on
“watch” status if it has experienced a material
event that, in Baird’s opinion, may negatively
affect the fund’s performance going forward or
possibly lead to the departure of an important
member(s) of the
investment team.
fund’s
Examples include a large decline in assets under
management, high rate of redemptions, notable
change in the investment or compliance teams,
weakening performance, or regulatory problems.
Any fund that is placed on “watch” status is
evaluated more closely to determine if the
problem is likely to be temporary or long-term,
and whether it can be remedied. Baird will
remove a fund from “watch” status and return it
to active status if, in Baird’s opinion, the problem
has been or is in process of being adequately
addressed. However, Baird will remove a fund
from a Recommended Private Fund List if it
believes the issue is likely to be long-term and
adversely affect the fund’s future performance.
Certain Eligible Product Lists
Annuities
the
strength
ratings
When determining whether to make an annuity
product available to Baird clients, Baird reviews
the offering documents for the product and
considers: the size of the insurer and the insurer’s
credit rating,
insurer’s distribution and
support model, and product specifications and
features of the product. Baird favors highly-rated
insurers and evaluates them by using credit rating
agencies
and
financial
independent third-party research.
Before adding a prospective
to a
Recommended Private Fund List, Baird’s Asset
Manager Research Department conducts an in-
depth due diligence process. The process begins
with a review of the fund’s responses to a due
diligence questionnaire (known as a DDQ or RFI)
and of marketing and legal documents (such as,
subscription documentation, investor agreements,
offering memorandum, organizational documents,
and the investment advisor’s Form ADV Part 2A
Brochures). This is followed by an onsite review,
where Baird meets with one or more principals
and analysts to assess how the fund makes
investment decisions. Baird also evaluates how
the fund constructs its portfolio and manages risk.
In addition, Baird may undertake a brief review of
the fund’s third-party service providers. At the
conclusion of the onsite review, an investment
thesis is presented to and discussed with a Baird
Investment Committee. The Committee votes on
whether to add the fund to a Baird Recommended
Private Fund List. In making that determination,
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Baird’s ETF Focus List
indices,
Baird tends to favor larger-sized issuers of
structured products over smaller-sized issuers
and also tends to favor structured products that
have shorter maturities, less complex payout
structures, underlying assets that are more liquid
or transparent, and offer full or partial principal
protection. If a product does not offer full
principal protection, Baird also considers how
much principal is exposed to loss, whether, in
Baird’s judgment, there is reasonable risk/reward
trade-off for that exposure, as well as the events
that could trigger loss of principal and Baird’s
belief as to the likelihood of the occurrence of
such events.
Investment Solutions Department
Baird’s ETF Focus List is designed to encompass
numerous asset classes and varied investment
objectives. Baird generally seeks to include ETPs,
primarily ETFs, with transparent, experienced
sponsors that have stable or growing assets under
management and have demonstrated consistent
strategy performance over time. Baird tends to
favor ETPs that have well-known, diversified
benchmark
fees and tracking
lower
errors, and higher trading liquidity relative to
other ETPs. Inclusion on or exclusion from the
Baird ETF Focus List is not meant to be a buy or
sell recommendation. Rather, the List
is a
collection of ETPs that may be appropriate to
meet particular client investment goals.
PWM Stock Opportunities List
the
Programs.
Baird’s
Compliance,
Legal,
and
Baird’s
is
primarily responsible for selecting and evaluating
structured products made available to clients
under
Alternative
Investment Committee, which includes members
of Baird’s Investment Solutions, Asset Manager
Risk
Research,
Management Departments, ultimately determines
whether to make a structured product available to
Baird clients.
Available Hedge Funds
yield,
The PWM Stock Opportunities List is comprised of
stocks that Baird’s PWM Equity Research team
believes offer timely investment opportunities
fundamental
based on market, sector, and
analysis. Stocks on the list must be covered by
Baird, Evercore ISI, or Morningstar and are
screened to curb near-term fundamental risk. The
List focuses on large cap and mid/small cap
companies,
and
investments with
speculative investment opportunities.
Managed Futures
Effective March 1, 2018, Baird ceased maintaining
an official list of managed futures funds that are
structured as limited partnerships. Therefore,
Baird does not, and will not in the future, provide
any evaluation, monitoring or review of those
funds or their sponsors. A client’s decision to
invest in, or to maintain an investment in, a
managed futures fund is based solely upon the
client’s own review and evaluation of the fund.
Structured Products
Baird makes hedge funds available to clients in
certain Programs sponsored by, affiliated with or
offered by Capital Integration Systems LLC or
CAIS Capital LLC (“CAIS”). An independent third-
party research firm provides research and due
diligence materials to Baird on the hedge funds
available on the CAIS platform (“Available Hedge
Funds”). Clients interested in an Available Hedge
Fund or invested in an Available Hedge Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely
relies upon the independent third-party research
firm to provide an independent analysis of each
Available Hedge Fund, Baird does not conduct its
own research or due diligence on any Available
Hedge Fund, and Baird does not verify the
accuracy of the information contained in the
research and due diligence materials.
Available Private Funds
is calculated,
When determining whether to make a structured
product available to Baird clients, Baird reviews
the offering documents for the structured product
and considers: the size of the issuer and issuer’s
credit rating, the maturity of the product, how
interest
the underlying asset
category (e.g., a basket of securities or currencies
or a market index), applicable caps, barriers, and
participation rate, and whether the structured
product has principal protection.
In addition to Recommended Private Funds, Baird
makes available to clients in certain Programs
other private funds sponsored by, affiliated with,
or offered by CAIS (“Available Private Funds”),
including Available Private Equity Funds, Available
Private Debt Funds, Available Private REITs and
Available Private Infrastructure Funds. When
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third-party
research
firm
target equity allocation. The strategy uses the
Baird Trust Large Cap Equity strategy as the core
allocation of
the portfolio while providing
exposure to satellite asset classes (such as mid
cap and small cap companies) through the use of
ETFs that principally invest in equity securities.
This model does not include fixed income.
determining whether to make a fund an Available
Private Fund, Baird utilizes the services of an
independent
that
provides research and due diligence materials to
Baird on the private funds available on the CAIS
platform. Clients interested in an Available Private
Fund or invested in an Available Private Fund may
obtain additional information from Baird upon
request. Clients should note that Baird solely
relies upon the independent third-party research
firm to provide an independent analysis of each
Available Private Fund, Baird does not conduct its
own research or due diligence on any Available
Private Fund, and Baird does not verify the
accuracy of the information contained in the
research and due diligence materials.
Affiliated Private Equity Funds
(3)
The Baird Trust Core + Satellite 70/30
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation of the portfolio
while providing exposure to satellite asset classes
(such as mid cap and small cap companies) and
fixed income securities through the use of ETFs
that principally invest in equity securities and
fixed income securities. This strategy has a target
allocation of 70% of its assets to equity securities
and 30% of its assets to fixed income securities.
fixed
(4)
The Baird Trust Core + Satellite 50/50
strategy utilizes the Baird Trust Large Cap Equity
strategy as the core allocation portion of the
portfolio while providing exposure to satellite
asset classes (such as mid cap and small cap
companies) and fixed income securities through
the use of ETFs that principally invest in equity
income securities. This
securities and
strategy has a target allocation of 50% of its
assets to equity securities and 50% of its assets
to fixed income securities.
Financial
Industry
Activities
Relationships
In addition to Recommended Funds of Private
Equity Funds and Available Private Equity Funds,
Baird makes available to clients private equity
funds that are affiliated with Baird (“Affiliated
Private Equity Funds”). Baird does not subject
Affiliated Private Equity Funds to the criteria
imposed upon Recommended Funds of Private
Equity Funds or Available Private Equity Funds
described above when making them available to
clients, and Baird does not perform any
evaluation, monitoring or review of Affiliated
Private Equity Funds. This presents a potential
conflict of interest. See “Additional Information—
and
Other
Affiliations—Certain
and
Arrangements—Baird and Associated Parties”
below.
(5)
The Baird Trust Equity Income strategy
primarily invests in dividend paying companies
that Baird Trust believes have the ability to
consistently grow their dividend at attractive rates
over the long‑term.
Baird Trust Strategies
More specific information about the particular
investment strategies and methods of analysis
that Baird uses in connection with each Program
is further described below.
The DDK Investment Process
Under the BAM and UAS Programs, Baird makes
available to clients five (5) portfolio strategies
developed and maintained by Baird Trust (“Baird
Trust Strategies”) described below. The Baird
Trust Strategies invest in a mix of equity
securities and ETFs.
(1)
The Baird Trust Large Cap Equity strategy
invests in a fairly concentrated portfolio of large
cap equity securities. This strategy is intended for
clients seeking investment in large cap companies
as one part of their overall asset allocation. This
strategy is generally not intended to be a
complete investment program.
When providing advice to clients, DDK starts with
a needs analysis developed for a client in
connection with the financial planning process
described above. Using a variety of tools, DDK
then develops and recommends a long-term,
strategic asset allocation and investment strategy
for the client’s portfolio that is customized for the
client’s risk and return objectives. DDK diversifies
the client’s portfolio among different investments
in each asset class with the goal to manage risk.
Investment strategies may involve the use of
The Baird Trust Core + Satellite 100
(2)
strategy is a diversified portfolio with a 100%
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that DDK and Baird use in connection with each
Service is further described below.
Program Portfolio Strategies
ALIGN Strategic Portfolios Program
The ALIGN Strategic Portfolios Program offers
model asset allocation portfolios that have varying
investment objectives and strategies. Each ALIGN
Portfolio provides for specific levels of investment
(or allocation) across the asset classes described
under the heading “Investment Strategies—Asset
Allocation Strategies” above.
different equity styles or strategies, such as: large
cap growth, large cap value, mid cap growth, mid
cap value, small cap growth, small cap value,
international and emerging market equities
strategies; different
income styles or
fixed
strategies, such as short or intermediate, taxable
and tax-exempt bond, international and emerging
market bond, and high yield bond strategies; and
Complex Strategies, such as real estate and real
estate funds (including private real estate funds
and private real estate fund of funds), commodity
strategies, hedge funds, funds of hedge funds,
private equity funds, funds of private equity
funds, private debt funds and managed futures.
time
to
time, and depending on
From
macroeconomic
conditions, DDK may also
recommend or implement a slight, short-term
tactical tilt to the client’s chosen asset allocation
that is above or below the long-term strategic
asset allocation.
Investment
Management
DDK typically recommends or selects mutual
funds and ETFs for Advisory Choice Accounts and
DDK
Accounts.
However, other types of securities may be
recommended or selected for those Accounts.
information
regarding
for
the client. Once
review
Each ALIGN Portfolio generally uses mutual funds
and ETPs, primarily ETFs and ETNs, in order to
implement the model asset allocation strategy.
Depending on the ALIGN Portfolio chosen, the
ALIGN Portfolio may consist of mutual funds and
ETFs that have various investment objectives and
strategies, including but not limited to, the
following: large cap, mid cap and small cap
strategies (which may include value, growth or
core strategies); short-term, intermediate-term
and long-term fixed income strategies (which may
include high yield corporate bond strategies);
international and global
balanced strategies;
equity and fixed income strategies; market sector
focused strategies, geographic area
focused
strategies; real estate strategies; commodities
strategies; currency strategies; managed futures
strategies; and other Alternative Strategies. For
additional
the
characteristics of the mutual funds and ETPs used
in an ALIGN Portfolio, clients should contact their
the applicable
DDK Consultant or
prospectus.
The amount allocated to each asset class and type
of investment varies by Portfolio. However, some
Portfolios may have little or no allocation to one
or more asset classes or types of investments
described above.
and
When recommending or selecting a particular
mutual fund or ETF for client Accounts, DDK
begins by reviewing a client’s asset allocation and
investment strategy needs and identifying the
characteristics of the types of mutual funds or
ETFs appropriate
the
characteristic types of mutual funds or ETFs are
identified, DDK looks for investments that meet
those requirements. DDK looks for funds that
have
lower expense ratios. Once DDK has
identified a potential fund for a client, DDK
conducts a quantitative and qualitative analysis of
the investment manager for the fund similar to
the analysis it performs on investment managers
described under “Portfolio Manager Selection and
Evaluation—Selection
Evaluation—DDK
Recommended Managers Service” above.
its asset allocation strategies
the heading
information about how Baird
is
“Investment
More specific
develops
contained under
Strategies—Asset Allocation Strategies” above.
In order to implement the overall client portfolio
strategy, DDK may utilize one or more of the
combination of different
Services and a
investment vehicles, such as SMAs, mutual funds
and ETFs.
The ALIGN Strategic Portfolios Program offers
model portfolios that have different investment
objectives and use different strategic investment
strategies. The ALIGN Strategic Portfolios
Program generally accommodates both taxable
More specific information about the particular
investment strategies and methods of analysis
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and tax-exempt accounts of clients with differing
investment objectives and risk tolerances.
Product
allocations
intended
to
Portfolio is designed to be global in nature and
attempts to be diversified across countries,
industry sectors and company capitalization sizes,
with an objective to participate in the total return
potential of the global stock markets. The fixed
income allocation is also normally global in nature
and diversified across credit quality and maturity.
The Non-Traditional Asset and Alternative
provide
Investment
diversification and are
reduce
correlation to U.S. stock and bond markets.
The ALIGN Strategic Portfolios include active and
hybrid options. Active ALIGN Strategic Portfolios
primarily consist of actively managed mutual
funds and hybrid ALIGN Strategic Portfolios
primarily consist of both actively managed mutual
funds and passive ETFs. Multiple funds may be
used for a particular asset class (referred to as a
“sleeve”).
The ALIGN Strategic Portfolios are described
below.
invest
Some ALIGN Strategic Portfolios invest a material
portion of assets in mutual funds and ETFs that
pursue Alternative Strategies designed to provide
absolute
return. Those strategies generally
involve the purchase of traditional assets, such as
stocks and bonds, and Non-Traditional Assets and
the use of derivative instruments in an attempt to
generate performance that has low correlation to
the major equity markets over a complete market
cycle.
above,
including
fixed
ALIGN Strategic All Growth Portfolio. The ALIGN
Strategic All Growth Portfolio seeks to provide
aggressive growth of capital. Under normal
market conditions, this Portfolio generally invests
nearly all of its assets in mutual funds that in turn
principally
in equity securities. This
Portfolio may also invest in other asset classes
described
income
securities, Non-Traditional Assets, Alternative
Investment Products and cash. This Portfolio has
the same risk profile as an All Growth Portfolio.
Some ALIGN Strategic Portfolio Strategies invest
a material portion of assets in mutual funds and
ETFs that that focus on investments that provide
diversified yield or sources of income, such as
dividend-paying stocks, preferred stocks, high
yield bonds, foreign (including emerging markets)
fixed income securities, Non-Traditional Assets,
Alternative Investment Products and derivative
instruments.
that
this
Portfolio
also
in passively managed ETFs
ALIGN Strategic All Growth Hybrid Portfolio. The
ALIGN Strategic All Growth Hybrid Portfolio has
the same objective, underlying
investments,
target allocations and risk profile as the ALIGN
Strategic All Growth Portfolio described above,
includes
except
investments
in
addition to actively managed mutual funds.
investing
The ALIGN Strategic Portfolios Program offers
“environmental, social and governance” (“ESG”)
portfolios, which focus investments in mutual
funds and ETFs with investment managers that
evaluate portfolio companies’ performance on
various environmental, social and corporate
governance criteria as part of the managers’
investment process. The particular environmental,
social and governance criteria used by mutual
funds and ETFs vary by mutual fund and ETF and
are determined by the manager for the applicable
mutual fund or ETF and not Baird. How each
company performs with respect to those criteria is
a matter of subjective judgement. It is possible
managers could come to different conclusions
about how a particular company performs with
respect to the same environmental, social and
governance criteria.
above,
including
Non-Traditional
fixed
Assets,
ALIGN Strategic All Growth (Absolute Return)
Portfolio. The ALIGN Strategic All Growth
(Absolute Return) Portfolio seeks to provide
aggressive growth of capital. Under normal
market conditions, this Portfolio primarily invests
its assets in mutual funds that in turn principally
invest in equity securities. A material portion of
this Portfolio will normally seek to provide
in Alternative
absolute return by
Investment Products, primarily mutual funds, that
pursue that strategy. This may involve material
exposure to Non-Traditional Assets, leverage,
short sales, and derivative instruments. This
Portfolio may also invest in other asset classes
income
described
securities,
other
Alternative Investment Products and cash. This
Generally, under normal market conditions, the
equity security allocation of each ALIGN Strategic
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Portfolio has the same risk profile as an All
Growth Portfolio.
passively managed ETFs in addition to actively
managed mutual funds; and (2) primarily invests
its fixed income allocation in actively managed
mutual funds and ETFs that in turn principally
invest in municipal securities.
underlying
investments,
in passively managed ETFs
ALIGN Strategic All Growth Hybrid (Absolute
Return) Portfolio. The ALIGN Strategic All Growth
Hybrid (Absolute Return) Portfolio has the same
objective,
target
allocations and risk profile as the ALIGN Strategic
All Growth (Absolute Return) Portfolio described
above, except that this Portfolio also includes
investments
in
addition to actively managed mutual funds.
in equity securities or
fixed
investing
in equity securities or
fixed
ALIGN Strategic Capital Growth (Absolute Return)
Portfolio. The ALIGN Strategic Capital Growth
(Absolute Return) Portfolio seeks to provide
growth of
capital. Under normal market
conditions, this Portfolio primarily invests its
assets in mutual funds that in turn principally
income
invest
securities. This Portfolio normally will have a
significantly higher underlying asset allocation to
equity securities than fixed income securities. A
material portion of this Portfolio will normally seek
in
to provide absolute return by
Alternative Investment Products, primarily mutual
funds, that pursue that strategy. This may involve
material exposure to Non-Traditional Assets,
leverage, short sales, and derivative instruments.
This Portfolio may also invest in other asset
classes described above, including Non-Traditional
Assets, other Alternative Investment Products and
cash. This Portfolio has the same risk profile as a
Capital Growth Portfolio.
ALIGN Strategic Capital Growth Portfolio. The
ALIGN Strategic Capital Growth Portfolio seeks to
provide growth of capital. Under normal market
conditions, this Portfolio primarily invests its
assets in mutual funds that in turn principally
invest
income
securities. This Portfolio normally will have a
significantly higher underlying asset allocation to
equity securities than fixed income securities. This
Portfolio may also invest in other asset classes
described above, including Non-Traditional Assets,
Alternative Investment Products and cash. This
Portfolio has the same risk profile as a Capital
Growth Portfolio.
ALIGN Strategic Capital Growth Hybrid Portfolio.
The ALIGN Strategic Capital Growth Hybrid
Portfolio has the same objective, underlying
investments, target allocations and risk profile as
the ALIGN Strategic Capital Growth Portfolio
described above, except that this Portfolio also
includes investments in passively managed ETFs
in addition to actively managed mutual funds.
ALIGN Strategic Capital Growth Hybrid (Absolute
Return) Portfolio. The ALIGN Strategic Capital
Growth Hybrid (Absolute Return) Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the ALIGN Strategic
Capital Growth
(Absolute Return) Portfolio
described above, except that this Portfolio also
includes investments in passively managed ETFs
in addition to actively managed mutual funds.
that
that
its
fixed
its
fixed
ALIGN Strategic Capital Growth (Tax Exempt)
Portfolio. The ALIGN Strategic Capital Growth
(Tax Exempt) Portfolio has the same objective,
underlying investments, target allocations and
risk profile as the ALIGN Strategic Capital Growth
this
Portfolio described above, except
Portfolio primarily
income
invests
allocation in actively managed mutual funds that
in turn principally invest in municipal securities.
ALIGN Strategic Capital Growth (Tax Exempt with
Absolute Return) Portfolio. The ALIGN Strategic
Capital Growth (Tax Exempt with Absolute
Return) Portfolio Has the same description as the
ALIGN Strategic Capital Growth (Absolute Return)
Portfolio described above, except
this
income
invests
Portfolio primarily
allocation in actively managed mutual funds that
in turn principally invest in municipal securities.
ALIGN Strategic Capital Growth Hybrid (Tax
Exempt with Absolute Return) Portfolio. The
ALIGN Strategic Capital Growth Hybrid (Tax
Exempt with Absolute Return) Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the ALIGN Strategic
ALIGN Strategic Capital Growth Hybrid (Tax
Exempt) Portfolio. The ALIGN Strategic Capital
Growth Hybrid (Tax Exempt) Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the ALIGN Strategic
Capital Growth Portfolio described above, except
that this Portfolio: (1) includes investments in
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underlying
investments,
Capital Growth
(Absolute Return) Portfolio
described above, except that this Portfolio: (1)
includes investments in passively managed ETFs
in addition to actively managed mutual funds; and
(2) primarily invests its fixed income allocation in
actively managed mutual funds and ETFs that in
turn principally invest in municipal securities.
ALIGN Strategic Growth with
Income (Tax
Exempt) Portfolio. The ALIGN Strategic Growth
with Income (Tax Exempt) Portfolio has the same
target
objective,
allocations and risk profile as the ALIGN Strategic
Growth with Income Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in actively managed mutual
funds that in turn principally invest in municipal
securities.
in equity securities or
fixed
in passively managed ETFs
fixed
ALIGN Strategic Growth with Income Hybrid (Tax
Exempt) Portfolio. The ALIGN Strategic Growth
with Income Hybrid (Tax Exempt) Portfolio has
the same objective, underlying
investments,
target allocations and risk profile as the ALIGN
Strategic Growth with Income Portfolio described
above, except that this Portfolio: (1) includes
investments
in
addition to actively managed mutual funds; and
(2) primarily invests its fixed income allocation in
actively managed mutual funds and ETFs that in
turn principally invest in municipal securities.
ALIGN Strategic Capital Growth (Diversified Yield)
Portfolio. The ALIGN Strategic Capital Growth
(Diversified Yield) Portfolio seeks to provide
growth of
capital. Under normal market
conditions, this Portfolio primarily invests its
assets in mutual funds that in turn principally
invest
income
securities. This Portfolio normally will have a
significantly higher underlying asset allocation to
equity securities than fixed income securities. A
material portion of this Portfolio will normally seek
to provide diversified yield by investing in mutual
funds that pursue that strategy. This may involve
material exposure to high yield bonds, foreign
(including emerging markets)
income
securities, Non-Traditional Assets, REITs, MLPs,
and derivative instruments. This Portfolio may
also invest in other asset classes described above,
including Alternative Investment Products and
cash. This Portfolio has the same risk profile as a
Capital Growth Portfolio.
in equity securities or
fixed
Assets,
Alternative
ALIGN Strategic Growth with Income Portfolio.
The ALIGN Strategic Growth with Income Portfolio
seeks to provide moderate growth of capital and
some current income. Under normal market
conditions, this Portfolio primarily invests its
assets in mutual funds that in turn principally
invest
income
securities. This Portfolio may also invest in other
asset classes described above, including Non-
Investment
Traditional
Products and cash. This Portfolio has the same
risk profile as a Growth with Income Portfolio.
ALIGN Strategic Growth with Income (Absolute
Return) Portfolio. The ALIGN Strategic Growth
with Income (Absolute Return) Portfolio seeks to
provide moderate growth of capital and some
current income. Under normal market conditions,
this Portfolio primarily invests its assets in mutual
funds that in turn principally invest in equity
securities or fixed income securities. A material
portion of this Portfolio will normally seek to
provide absolute return by investing in Alternative
Investment Products, primarily mutual funds, that
pursue that strategy. This may involve material
exposure to Non-Traditional Assets, leverage,
short sales, and derivative instruments. This
Portfolio may also invest in other asset classes
described above, including Non-Traditional Assets,
other Alternative Investment Products and cash.
This Portfolio has the same risk profile as a
Growth with Income Portfolio.
ALIGN Strategic Growth with Income Hybrid
Portfolio. The ALIGN Strategic Growth with
Income Hybrid Portfolio has the same objective,
underlying investments, target allocations and
risk profile as the ALIGN Strategic Growth with
Income Portfolio described above, except that this
Portfolio also includes investments in passively
managed ETFs in addition to actively managed
mutual funds.
that
this
Portfolio
also
in passively managed ETFs
ALIGN Strategic Growth with Income Hybrid
(Absolute Return) Portfolio. The ALIGN Strategic
Growth with Income Hybrid (Absolute Return)
Portfolio has the same objective, underlying
investments, target allocations and risk profile as
the ALIGN Strategic Growth with
Income
(Absolute Return) Portfolio described above,
includes
except
investments
in
addition to actively managed mutual funds.
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including
Non-Traditional
may also invest in other asset classes described
above,
Assets,
Alternative Investment Products and cash. This
Portfolio has the same risk profile as an Income
with Growth Portfolio.
ALIGN Strategic Growth with Income (Tax Exempt
with Absolute Return) Portfolio. The ALIGN
Strategic Growth with Income (Tax Exempt with
the same
Absolute Return) Portfolio Has
description as the ALIGN Strategic Growth with
Income (Absolute Return) Portfolio described
above, except that this Portfolio primarily invests
its fixed income allocation in actively managed
mutual funds that in turn principally invest in
municipal securities.
ALIGN Strategic Income with Growth Hybrid
Portfolio. The ALIGN Strategic Income with
Growth Hybrid Portfolio has the same objective,
underlying investments, target allocations and
risk profile as the ALIGN Strategic Income with
Growth Portfolio described above, except that this
Portfolio also includes investments in passively
managed ETFs in addition to actively managed
mutual funds.
underlying
investments,
ALIGN Strategic Growth with Income Hybrid (Tax
Exempt with Absolute Return) Portfolio. The
ALIGN Strategic Growth with Income Hybrid (Tax
Exempt with Absolute Return) Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the ALIGN Strategic
Growth with Income (Absolute Return) Portfolio
described above, except that this Portfolio: (1)
includes investments in passively managed ETFs
in addition to actively managed mutual funds; and
(2) primarily invests its fixed income allocation in
actively managed mutual funds and ETFs that in
turn principally invest in municipal securities.
Income with Growth (Tax
ALIGN Strategic
Exempt) Portfolio. The ALIGN Strategic Income
with Growth (Tax Exempt) Portfolio has the same
objective,
target
allocations and risk profile as the ALIGN Strategic
Income with Growth Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in actively managed mutual
funds that in turn principally invest in municipal
securities.
in passively managed ETFs
fixed
ALIGN Strategic Income with Growth Hybrid (Tax
Exempt) Portfolio. The ALIGN Strategic Income
with Growth Hybrid (Tax Exempt) Portfolio has
investments,
the same objective, underlying
target allocations and risk profile as the ALIGN
Strategic Income with Growth Portfolio described
above, except that this Portfolio: (1) includes
investments
in
addition to actively managed mutual funds; and
(2) primarily invests its fixed income allocation in
actively managed mutual funds and ETFs that in
turn principally invest in municipal securities.
ALIGN Strategic Growth with Income (Diversified
Yield) Portfolio. The ALIGN Strategic Growth with
Income (Diversified Yield) Portfolio seeks to
provide moderate growth of capital and some
current income. Under normal market conditions,
this Portfolio primarily invests its assets in mutual
funds that in turn principally invest in equity
securities or fixed income securities. A material
portion of this Portfolio will normally seek to
provide diversified yield by investing in mutual
funds that pursue that strategy. This may involve
material exposure to high yield bonds, foreign
(including emerging markets)
income
securities, Non-Traditional Assets, REITs, MLPs,
and derivative instruments. This Portfolio may
also invest in other asset classes described above,
including Alternative Investment Products and
cash. This Portfolio has the same risk profile as a
Growth with Income Portfolio.
in
fixed
ALIGN Strategic Income with Growth (Diversified
Yield) Portfolio. The ALIGN Strategic Income with
Growth (Diversified Yield) Portfolio seeks to
provide high current income and some growth of
capital. Under normal market conditions, this
Portfolio primarily invests its assets in mutual
funds that in turn principally invest in fixed
income securities or equity securities. This
Portfolio normally will have a higher underlying
asset allocation to fixed income securities than
equity securities. A material portion of this
Portfolio will normally seek to provide diversified
yield by investing in mutual funds that pursue
that strategy. This may involve material exposure
ALIGN Strategic Income with Growth Portfolio.
The ALIGN Strategic Income with Growth Portfolio
seeks to provide high current income and some
capital. Under normal market
growth of
conditions, this Portfolio primarily invests its
assets in mutual funds that in turn principally
invest
income securities or equity
securities. This Portfolio normally will have a
higher underlying asset allocation to fixed income
securities than equity securities. This Portfolio
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mutual funds; and (2) primarily invests its fixed
income allocation in actively managed mutual
funds and ETFs that in turn principally invest in
municipal securities.
to high yield bonds, foreign (including emerging
markets) fixed income securities, Non-Traditional
Assets, REITs, MLPs, and derivative instruments.
This Portfolio may also invest in other asset
classes described above, including Alternative
Investment Products and cash. This Portfolio has
the same risk profile as an Income with Growth
Portfolio.
The ALIGN Strategic Portfolios also include certain
ALIGN Elements Portfolios that are designed for
certain specific client investment preferences,
such as clients preferring passive investment
management or tax efficiency, and clients with
smaller accounts. ALIGN Elements Portfolios do
not invest in as many mutual funds or ETFs
compared to other ALIGN Strategic Portfolios and
are therefore comparatively less diversified.
The ALIGN Elements Portfolios are described
below.
ALIGN Strategic Conservative Income Portfolio.
The ALIGN Strategic Conservative
Income
Portfolio seeks to provide high current income.
Under normal market conditions, this Portfolio
primarily invests its assets in mutual funds that in
turn principally invest in fixed income securities
and equity securities. This Portfolio normally will
have a significantly higher underlying asset
allocation to fixed income securities than equity
securities. This Portfolio may also invest in other
asset classes described above, including Non-
Traditional Assets and cash. This Portfolio has the
same risk profile as a Conservative Income
Portfolio.
invest
above,
including
fixed
ALIGN Elements All Growth Portfolio. The ALIGN
Elements All Growth Portfolio seeks to provide
aggressive growth of capital. Under normal
market conditions, this Portfolio generally invests
nearly all of its assets in mutual funds that in turn
principally
in equity securities. This
Portfolio may also invest in other asset classes
income
described
securities, Non-Traditional Assets, Alternative
Investment Products and cash. This Portfolio has
the same risk profile as an All Growth Portfolio.
ALIGN Strategic Conservative Income Hybrid
Portfolio. The ALIGN Strategic Conservative
Income Hybrid Portfolio has the same objective,
underlying investments, target allocations and
risk profile as the ALIGN Strategic Conservative
Income Portfolio described above, except that this
Portfolio also includes investments in passively
managed ETFs in addition to actively managed
mutual funds.
Income
The
ALIGN
ALIGN Elements All Growth ETF Portfolio. The
ALIGN Elements All Growth ETF Portfolio has the
same objective, types of underlying investments,
target allocations and risk profile as the ALIGN
Elements All Growth Portfolio described above,
except that this Portfolio primarily invests in
passively managed ETFs
instead of actively
managed mutual funds.
ALIGN Strategic Conservative
(Tax
Strategic
Portfolio.
Exempt)
Conservative Income (Tax Exempt) Portfolio has
the same objective, underlying
investments,
target allocations and risk profile as the ALIGN
Strategic Conservative Income Portfolio described
above, except that this Portfolio primarily invests
its fixed income allocation in actively managed
mutual funds that in turn principally invest in
municipal securities.
Portfolio.
The
ALIGN
ALIGN Elements ETF All Growth ESG Portfolio. The
ALIGN Elements All Growth ESG Portfolio has the
same objective, types of underlying investments,
target allocations and risk profile as the ALIGN
Elements All Growth Portfolio described above,
except that this Portfolio primarily invests in ETFs
that incorporate ESG criteria into their investment
process.
Income Hybrid
that
ALIGN Strategic Conservative Income Hybrid (Tax
Exempt)
Strategic
Conservative
(Tax Exempt)
Portfolio has the same objective, underlying
investments, target allocations and risk profile as
Income
the ALIGN Strategic Conservative
Portfolio described above, except
this
Portfolio: (1) includes investments in passively
managed ETFs in addition to actively managed
ALIGN Elements Capital Growth Portfolio. The
ALIGN Elements Capital Growth Portfolio seeks to
provide growth of capital. Under normal market
conditions, this Portfolio primarily invests its
assets in mutual funds that in turn principally
income
invest
in equity securities or
fixed
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in equity securities or
fixed
Assets,
Alternative
invest
income
securities. This Portfolio may also invest in other
asset classes described above, including Non-
Investment
Traditional
Products and cash. This Portfolio has the same
risk profile as a Growth with Income Portfolio.
securities. This Portfolio normally will have a
significantly higher underlying asset allocation to
equity securities than fixed income securities. This
Portfolio may also invest in other asset classes
described above, including Non-Traditional Assets,
Alternative Investment Products and cash. This
Portfolio has the same risk profile as a Capital
Growth Portfolio.
underlying
investments,
that
its
fixed
ALIGN Elements Growth with Income (Tax
Exempt) Portfolio. The ALIGN Elements Growth
with Income (Tax Exempt) Portfolio has the same
objective,
target
allocations and risk profile as the ALIGN Strategic
Growth with Income Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in actively managed mutual
funds that in turn principally invest in municipal
securities.
ALIGN Elements Capital Growth (Tax Exempt)
Portfolio. The ALIGN Elements Capital Growth
(Tax Exempt) Portfolio has the same objective,
underlying investments, target allocations and
risk profile as the ALIGN Strategic Capital Growth
this
Portfolio described above, except
Portfolio primarily
income
invests
allocation in actively managed mutual funds that
in turn principally invest in municipal securities.
same objective,
of
underlying
investments,
that
ALIGN Elements Capital Growth ETF Portfolio. The
ALIGN Elements Capital Growth ETF Portfolio has
types of underlying
the
investments, target allocations and risk profile as
the ALIGN Elements Capital Growth Portfolio
described above, except
this Portfolio
primarily invests in passively managed ETFs
instead of actively man
ALIGN Elements Growth with
Income ETF
Portfolio. The ALIGN Elements Growth with
Income ETF Portfolio has the same objective,
target
types
allocations and risk profile as the ALIGN Elements
Growth with Income Portfolio described above,
except that this Portfolio primarily invests in
passively managed ETFs
instead of actively
managed mutual funds.
underlying
investments,
that
its
fixed
ALIGN Elements Growth with Income ETF (Tax
Exempt) Portfolio. The ALIGN Elements Growth
with Income (Tax Exempt) Portfolio has the same
objective,
target
allocations and risk profile as the ALIGN Strategic
Growth with Income Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in passively managed ETFs that
in turn principally invest in municipal securities.
ALIGN Elements Capital Growth ETF (Tax Exempt)
Portfolio. The ALIGN Elements Capital Growth
(Tax Exempt) Portfolio has the same objective,
underlying investments, target allocations and
risk profile as the ALIGN Strategic Capital Growth
this
Portfolio described above, except
Portfolio primarily
income
invests
allocation in passively managed ETFs that in turn
principally invest in municipal securities. aged
mutual funds.
of
underlying
investments,
that
ALIGN Elements ETF Capital Growth ESG Portfolio.
The ALIGN Elements Capital Growth ESG Portfolio
has the same objective, types of underlying
investments, target allocations and risk profile as
the ALIGN Elements Capital Growth Portfolio
this Portfolio
described above, except
primarily invests in ETFs that incorporate ESG
criteria into their investment process.
ALIGN Elements ETF Growth with Income ESG
Portfolio. The ALIGN Elements Growth with
Income ESG Portfolio has the same objective,
types
target
allocations and risk profile as the ALIGN Elements
Growth with Income Portfolio described above,
except that this Portfolio primarily invests in ETFs
that incorporate ESG criteria into their investment
process.
ALIGN Elements Growth with Income Portfolio.
The ALIGN Elements Growth with Income Portfolio
seeks to provide moderate growth of capital and
some current income. Under normal market
conditions, this Portfolio primarily invests its
assets in mutual funds that in turn principally
ALIGN Elements Income with Growth Portfolio.
The ALIGN Elements Income with Growth Portfolio
seeks to provide high current income and some
growth of
capital. Under normal market
conditions, this Portfolio primarily invests its
assets in mutual funds that in turn principally
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in
fixed
same risk profile as a Conservative Income
Portfolio.
Income
ALIGN
including
Non-Traditional
invest
income securities or equity
securities. This Portfolio normally will have a
higher underlying asset allocation to fixed income
securities than equity securities. This Portfolio
may also invest in other asset classes described
above,
Assets,
Alternative Investment Products and cash. This
Portfolio has the same risk profile as an Income
with Growth Portfolio.
(Tax
ALIGN Elements Conservative
Exempt)
Elements
The
Portfolio.
Conservative Income (Tax Exempt) Portfolio has
the same objective, underlying
investments,
target allocations and risk profile as the ALIGN
Strategic Conservative Income Portfolio described
above, except that this Portfolio primarily invests
its fixed income allocation in actively managed
mutual funds that in turn principally invest in
municipal securities.
underlying
investments,
of
underlying
investments,
ALIGN Elements Income with Growth (Tax
Exempt) Portfolio. The ALIGN Elements Income
with Growth (Tax Exempt) Portfolio has the same
objective,
target
allocations and risk profile as the ALIGN Strategic
Income with Growth Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in actively managed mutual
funds that in turn principally invest in municipal
securities.
ALIGN Elements Conservative
Income ETF
Portfolio. The ALIGN Elements Conservative
Income ETF Portfolio has the same objective,
types
target
allocations and risk profile as the ALIGN Elements
Conservative Income Portfolio described above,
except that this Portfolio primarily invests in
instead of actively
passively managed ETFs
managed mutual funds.
of
underlying
investments,
Portfolio.
ALIGN
Income with Growth ETF
ALIGN Elements
Portfolio. The ALIGN Elements Income with
Growth ETF Portfolio has the same objective,
types
target
allocations and risk profile as the ALIGN Elements
Income with Growth Portfolio described above,
except that this Portfolio primarily invests in
passively managed ETFs
instead of actively
managed mutual funds.
ALIGN Elements Conservative Income ETF (Tax
Elements
The
Exempt)
Conservative Income (Tax Exempt) Portfolio has
the same objective, underlying
investments,
target allocations and risk profile as the ALIGN
Strategic Conservative Income Portfolio described
above, except that this Portfolio primarily invests
its fixed income allocation in passively managed
ETFs that in turn principally invest in municipal
securities.
underlying
investments,
ALIGN Elements Income with Growth ETF (Tax
Exempt) Portfolio. The ALIGN Elements Income
with Growth (Tax Exempt) Portfolio has the same
objective,
target
allocations and risk profile as the ALIGN Strategic
Income with Growth Portfolio described above,
except that this Portfolio primarily invests its fixed
income allocation in passively managed ETFs that
in turn principally invest in municipal securities.
The descriptions of the ALIGN Strategic Portfolios
are current as of the date of this Brochure.
However, Baird may change
the objective,
investments, target allocations or risk profile for
any Portfolio at any time. Baird may also offer
other model portfolios under the Program from
time to time.
An ALIGN Strategic Portfolio is subject to the risks
associated with the Portfolio’s particular strategies
and investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
ALIGN Elements Conservative Income Portfolio.
The ALIGN Elements Conservative
Income
Portfolio seeks to provide high current income.
Under normal market conditions, this Portfolio
primarily invests its assets in mutual funds that in
turn principally invest in fixed income securities
and equity securities. This Portfolio normally will
have a significantly higher underlying asset
allocation to fixed income securities than equity
securities. This Portfolio may also invest in other
asset classes described above, including Non-
Traditional Assets and cash. This Portfolio has the
The construction of the ALIGN Strategic Portfolios,
including allocation and strategic decisions, and
the selection of the mutual funds and ETFs for
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each Strategic Portfolio, are made by Baird’s
ALIGN Oversight Committee.
strategies; currency strategies; and Alternative
Strategies. For additional information regarding
the characteristics of the mutual funds and ETFs
used in a BairdNext Portfolio, clients should
contact their DDK Consultant or review the
applicable prospectus.
remove
funds
invest
The amount allocated to each asset class and type
of investment varies by Portfolio. However, some
Portfolios may have little or no allocation to one
or more asset classes or types of investments
described above. While the BairdNext Portfolios
in Non-Traditional Assets and
may
Alternative Investment Products, those Portfolios
tend to have little or no allocation to those asset
classes.
Baird’s Asset Manager Research Department is
primarily responsible for assisting with selecting
and evaluating mutual funds and ETFs available in
the ALIGN Strategic Portfolios Program. The
process Baird uses for selecting and removing
funds for the ALIGN Strategic Portfolios Program
is substantially similar to the process Baird uses
to select and
from Baird’s
Recommended Mutual Fund List described under
the heading “Portfolio Manager Selection and
Evaluation—Methods of Analysis,
Investment
Strategies and Risk of Loss—Methods of
Analysis—Certain Recommended Lists—Baird’s
Recommended Mutual Fund List” above. The
ALIGN Strategic Portfolios Program may include
funds included on Baird’s Recommended Mutual
Fund List and funds associated with Baird.
its asset allocation strategies
the heading
information about how Baird
is
“Investment
More specific
develops
contained under
Strategies—Asset Allocation Strategies” above.
The Portfolio asset allocations and the funds
included in the Program are evaluated on an
ongoing basis, generally at
least quarterly.
Portfolios may be modified or rebalanced and
funds may be removed or added as Baird
determines is appropriate.
The BairdNext Portfolios include mutual fund and
ETF portfolio options. BairdNext mutual fund
portfolios primarily consist of actively managed
funds; and BairdNext ETF portfolios
mutual
primarily consist of passively managed ETFs.
BairdNext Portfolios Program
Program
The BairdNext Portfolios Program offers model
asset allocation portfolios that have different
investment objectives and use different strategic
investment strategies. Each BairdNext Portfolio
provides for specific levels of investment (or
allocation) across the asset classes described
under the heading “Investment Strategies—Asset
Allocation Strategies” above.
The BairdNext
offers
Portfolios
“environmental, social and governance” (“ESG”)
portfolios, which focus investments in mutual
funds and ETFs with investment managers that
evaluate portfolio companies’ performance on
various environmental, social and corporate
governance criteria as part of the managers’
investment process. The particular environmental,
social and governance criteria used by mutual
funds and ETFs vary by mutual fund and ETF and
are determined by the manager for the applicable
mutual fund or ETF and not Baird. How each
company performs with respect to those criteria is
a matter of subjective judgement. It is possible
managers could come to different conclusions
about how a particular company performs with
respect to the same environmental, social and
governance criteria.
Generally, under normal market conditions, the
equity security allocation of each BairdNext
Portfolio is designed to be global in nature and
attempts to be diversified across countries,
industry sectors and company capitalization sizes,
with an objective to participate in the total return
potential of the global stock markets. The fixed
Each BairdNext Portfolio generally uses mutual
funds or ETPs, primarily ETFs, in order to
implement the model asset allocation. Depending
on the BairdNext Portfolio chosen, the BairdNext
Portfolio may consist of mutual funds and ETFs
that have various investment objectives and
strategies, including but not limited to, the
following: large cap, mid cap and small cap
strategies (which may include value, growth or
core strategies); short-term, intermediate-term
and long-term fixed income strategies (which may
include high yield corporate bond strategies);
balanced strategies;
international and global
equity and fixed income strategies; market sector
focused strategies, geographic area
focused
strategies; real estate strategies; commodities
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Portfolio has the same risk profile as a Growth
with Income Portfolio.
Product
allocations
intended
to
income allocation is also normally global in nature
and diversified across credit quality and maturity.
The Non-Traditional Asset and Alternative
provide
Investment
diversification and are
reduce
correlation to U.S. stock and bond markets.
BairdNext ETF All Growth Portfolio. The BairdNext
ETF Growth Portfolio has the same objective,
underlying investments, target allocations and
risk profile as the BairdNext Growth Portfolio
described above, except that this Portfolio invests
in passively managed ETFs instead of actively
managed mutual funds.
underlying
investments,
The BairdNext Portfolios Program is designed for
clients with smaller accounts and as such does
not invest in as many mutual funds or ETFs
compared to other Programs. Clients that are able
to satisfy applicable account minimums for other
Programs are encouraged to discuss with their
DDK Consultant whether another Program may be
a more appropriate choice for them.
The BairdNext Portfolios are described below.
BairdNext ETF All Growth Portfolio ESG. The
BairdNext ESG Growth Portfolio has the same
objective,
target
allocations and risk profile as the BairdNext
Growth Portfolio described above, except that this
Portfolio invests in passively managed ETFs that
incorporate ESG criteria into their investment
process instead of actively managed mutual
funds.
invest
above,
including
fixed
BairdNext ETF Capital Growth Portfolio. The
BairdNext ETF Capital Growth Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the BairdNext
Capital Growth Portfolio described above, except
that this Portfolio invests in passively managed
ETFs instead of actively managed mutual funds.
BairdNext All Growth Portfolio. The BairdNext
Growth Portfolio seeks to provide aggressive
growth of
capital. Under normal market
conditions, this Portfolio generally invests nearly
all of its assets in mutual funds that in turn
principally
in equity securities. This
Portfolio may also invest in other asset classes
income
described
securities, Non-Traditional Assets, Alternative
Investment Products and cash. This Portfolio has
the same risk profile as an All Growth Portfolio.
BairdNext ETF Capital Growth Portfolio ESG. The
BairdNext ETF Capital Growth Portfolio ESG has
the same objective, underlying
investments,
target allocations and risk profile as the BairdNext
Capital Growth Portfolio described above, except
that this Portfolio invests in passively managed
ETFs that incorporate ESG criteria into their
investment process instead of actively managed
mutual funds.
BairdNext Capital Growth Portfolio. The BairdNext
Capital Growth Portfolio seeks to provide growth
of capital. Under normal market conditions, this
Portfolio primarily invests its assets in mutual
funds that in turn principally invest in equity
securities or fixed income securities. This Portfolio
normally will have a
significantly higher
underlying asset allocation to equity securities
than fixed income securities. This Portfolio may
also invest in other asset classes described above,
including Non-Traditional Assets, Alternative
Investment Products and cash. This Portfolio has
the same risk profile as a Capital Growth Portfolio.
BairdNext ETF Growth with Income Portfolio. The
BairdNext ETF Growth with Income Portfolio has
the same objective, underlying
investments,
target allocations and risk profile as the BairdNext
Growth with Income Portfolio described above,
except that this Portfolio invests in passively
managed ETFs
instead of actively managed
mutual funds.
including
Non-Traditional
BairdNext Growth with Income Portfolio. The
BairdNext Growth with Income Portfolio seeks to
provide moderate growth of capital and some
current income. Under normal market conditions,
this Portfolio primarily invests its assets in mutual
funds that in turn principally invest in equity
securities or fixed income securities. This Portfolio
may also invest in other asset classes described
above,
Assets,
Alternative Investment Products and cash. This
BairdNext ETF Growth with Income Portfolio ESG.
The BairdNext ETF Growth with Income ESG
Portfolio has the same objective, underlying
investments, target allocations and risk profile as
the BairdNext Growth with Income Portfolio
described above, except that this Portfolio invests
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
DDK Investment Management Service
in passively managed ETFs that incorporate ESG
criteria into their investment process instead of
actively managed mutual funds.
Under the DDK Investment Management Service,
DDK may use various investment strategies. A
client’s particular investment strategy is typically
determined by DDK in consultation with the client
using the investment process described in the
section “The DDK Investment Process” above.
The descriptions of the BairdNext Portfolios are
current as of the date of this Brochure. However,
Baird may change the objective, investments,
target allocations or risk profile for any Portfolio
at any time. Baird may also offer other model
portfolios under the Program from time to time.
A BairdNext Portfolio is subject to the risks
associated with the Portfolio’s particular strategies
and investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
lists,
see
DDK Consultants, as a group, utilize a variety of
investment styles and strategies, including the
investment strategies described in the sections
“Methods of Analysis, Investment Strategies and
Risk of Loss—Investment Strategies” and “The
DDK Investment Process” above. They may also
use the model portfolios or recommended or
eligible product lists made available by Baird’s
PWM Research Groups, or they may use lists of
investment products that Baird has generally
deemed to be “available” for use in its advisory
programs. For more information about Baird
model portfolios, recommended lists and eligible
“Methods of Analysis,
product
Investment Strategies and Risk of Loss—Methods
of Analysis” above.
The process Baird uses for selecting and removing
funds and ETFs for the BairdNext Portfolios
Program is substantially similar to the process
Baird uses to select and remove mutual funds and
ETFs in connection with the ALIGN Strategic
Portfolio Program described under
“ALIGN
Programs—ALIGN Strategic Portfolios” above. A
BairdNext Portfolio may include funds included on
Baird’s Recommended Mutual Fund List and funds
and ETFs offered by Associated Managers.
included
The Portfolio asset allocations and the investment
in the BairdNext Portfolios
options
Program are evaluated on an ongoing basis,
generally at least quarterly.
investment
strategies,
such
Baird Advisory Choice Program
DDK manages client assets using investment
strategies and investment products based upon a
client’s particular
investment objectives and
financial goals. DDK may use a wide variety of
investment products to implement the client’s
investments are
investment strategy, which
further described under “Services, Fees and
Compensation—Additional Service Information—
Permitted Investments” above. DDK may also use
as
certain
concentrated investment strategies and margin,
and certain types of investments, such as illiquid
securities and Complex Investment Products,
including REITs, private equity funds, funds of
private equity funds, leveraged or inverse funds
and structured products. These
investment
strategies and products involve special risks and
may not be appropriate for all clients. Please see
“Principal Risks” below for more information.
Russell Model Strategies Program
in
that have
different
When recommending investment products to
clients under the Baird Advisory Choice Program,
DDK uses the investment process described in the
section “The DDK Investment Process” above.
DDK may also use the investment strategies
described in the section “Methods of Analysis,
Investment Strategies and Risk of Loss—
Investment Strategies” above or the model
portfolios or recommended or eligible product lists
made available by Baird’s PWM Research Groups,
or they may use lists of investment products that
Baird has generally deemed to be “available” for
use
its advisory programs. For more
information about Baird model portfolios,
recommended lists and eligible product lists, see
“Methods of Analysis, Investment Strategies and
Risk of Loss—Methods of Analysis” above.
The Russell Program offers model asset allocation
portfolios
investment
objectives and use different strategic and tactical
investment strategies. Each Russell Strategy
provides for specific levels of investment (or
allocation) across the asset classes described
under the heading “Investment Strategies—Asset
Allocation Strategies” above.
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funds and ETFs
Each Russell Strategy allocates a portion of the
client’s Account to a short term component,
typically a money market mutual fund. This
allocation is typically for the payment of fees and
other charges. Russell determines the percent
allocated to this short term component; however,
Baird determines which short term investment
product is used. This short term investment
allocation may include investments in money
market mutual funds associated with Baird.
strategies);
balanced
review
The Russell Program offers a number of
investment strategies through four primary asset
allocation models: core models (“Russell Core
Models”), tax-managed models (“Russell Tax-
Managed Models”), hybrid Models (“Russell Hybrid
Models”), and income models (“Russell Income
Models”). Russell Core Model Strategies and
Russell Tax-Managed Model Strategies primarily
consist of actively managed mutual funds; and
Russell Hybrid Model and
Income Model
Strategies primarily consist of both actively
managed mutual funds and passive ETFs.
Each Russell Strategy generally uses mutual funds
and ETFs in order to implement the model asset
allocation. Depending on the Russell Strategy
chosen, the Russell Strategy may consist of
mutual
that have various
investment objectives and strategies, including
but not limited to, the following: large cap, mid
cap and small cap strategies (which may include
value, growth or core strategies); short-term,
intermediate-term and long-term fixed income
strategies (which may include high yield corporate
bond
strategies;
international and global equity and fixed income
strategies; market sector
focused strategies,
geographic area focused strategies; real estate
strategies; commodities strategies; currency
strategies; and Alternative Strategies. Each
Russell Strategy will typically invest exclusively or
significantly in mutual funds offered by Russell
Funds. For additional information regarding the
characteristics of the mutual funds and ETFs used
in a Russell Strategy, clients should contact their
DDK Consultant or
the applicable
prospectus.
Russell Core Model Strategies
that have
different
The Russell Core Model Strategies offer model
portfolios
investment
objectives and use different strategic investment
strategies.
The amount allocated to each asset class and type
of investment varies by Strategy. However, some
Strategies may have little or no allocation to one
or more asset classes or types of investments
described above.
Generally, under normal market conditions, the
Russell Core Model Strategies are designed to be
globally diversified and offer exposure to mix of
asset classes and investment styles.
The Russell Core Model Strategies are described
below.
invest
above,
including
fixed
organization,
Russell Equity Growth Strategy. The Russell
Equity Growth Strategy seeks to provide high
long-term capital appreciation. Under normal
market conditions, this Strategy generally invests
nearly all of its assets in mutual funds that in turn
in equity securities. This
principally
Portfolio will also invest in other asset classes
described
income
securities, Non-Traditional Assets, Alternative
Investment Products and cash.
information management,
Russell performs a quantitative and qualitative
assessment in the selection of money managers
for the mutual funds and ETFs included in the
Russell Strategies. The quantitative
review
generally includes a performance and investment
profile analysis. Russell generally reviews the
performance patterns of the money managers
relative to historic market trends, comparing the
manager’s performance to benchmarks and peer
group performance statistics. Russell also may
review the money manager’s performance in
volatile markets for adherence to the money
manager’s stated investment philosophy and
in such markets. The
relative performance
qualitative review may include a review of the
money manager’s
ownership,
leadership, experience, research and development
investment
efforts,
process, stability of personnel, adherence to
philosophy and risk management. Based on
Russell’s quantitative and qualitative assessment,
Russell establishes an overall opinion of the
money manager.
Russell Growth Strategy. The Russell Growth
Strategy seeks to provide high long-term capital
appreciation and low current income. Under
normal market conditions, this Strategy generally
invests nearly all of its assets in mutual funds that
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Assets,
Alternative
in turn principally invest in equity securities, fixed
income securities. This Strategy normally will
have a significantly higher underlying asset
allocation to equity securities than fixed income
securities. This Portfolio will also invest in other
asset classes described above, including Non-
Traditional
Investment
Products and cash.
The Russell Tax-Managed Model Strategies
generally include: (1) a Tax-Managed Equity
Growth Strategy; (2) a Tax-Managed Growth
Strategy; (3) a Tax-Managed Balanced Strategy;
(4) a Tax-Managed Moderate Strategy; and (5) a
Tax-Managed Conservative Strategy. Each Russell
Tax-Managed Model Strategy generally has the
same objective and target asset allocations as its
counterpart Russell Core Model Strategy
discussed above, except
that Russell Tax-
Managed Models will seek to achieve their
objectives by investing in actively managed
mutual funds that place a higher priority on
managing tax liability as described above.
Russell Hybrid Model Strategies
Russell Balanced Strategy. The Russell Balanced
Strategy seeks to provide above average capital
appreciation and moderate current income. Under
normal market conditions, this Strategy generally
invests nearly all of its assets in mutual funds that
in turn principally invest in equity securities, fixed
income securities. This Portfolio will also invest in
other asset classes described above, including
Non-Traditional Assets, Alternative Investment
Products and cash.
fixed
The Russell Hybrid Model Strategies are designed
to balance an investor’s preference for active
management and the investor’s aversion to the
risk of relative underperformance associated with
active management. The Russell Hybrid Model
Strategies invest in a mix of actively managed
mutual funds, multi-factor mutual funds that
focus on certain investment characteristics (also
factors), such as value, quality,
known as
low volatility, and passively
momentum or
managed ETFs. The Russell Hybrid Model
Strategies will
in short- and
likely engage
intermediate-term tactical trading that will cause
the Strategy’s actual asset allocation to differ
from the Strategy’s long-term strategic target
asset allocation from time to time.
Russell Moderate Strategy. The Russell Moderate
Strategy seeks to provide moderate long-term
capital appreciation and high current income.
Under normal market conditions, this Strategy
generally invests nearly all of its assets in mutual
funds that in turn principally invest in fixed
income securities, equity securities. This Strategy
significantly higher
normally will have a
underlying asset allocation to
income
securities than equity securities. This Portfolio will
also invest in other asset classes described above,
including Non-Traditional Assets, Alternative
Investment Products and cash.
equity
Russell Conservative Strategy. The Russell
Conservative Strategy seeks to provide low long-
term capital appreciation and high current
income. Under normal market conditions, this
Strategy generally invests nearly all of its assets
in mutual funds that in turn principally invest in
fixed income securities. This Portfolio will also
invest in other asset classes described above,
including
securities, Non-Traditional
Assets, Alternative Investment Products and cash.
Russell Tax-Managed Model Strategies
The Russell Hybrid Model Strategies generally
include: (1) a Hybrid Equity Growth Strategy; (2)
a Hybrid Growth Strategy; (3) a Hybrid Balanced
Strategy; (4) a Hybrid Moderate Strategy; and
(5) a Hybrid Conservative Strategy. Each Russell
Hybrid Model Strategy generally has the same
objective and target asset allocations as its
counterpart Russell Core Model Strategy
discussed above, except that Hybrid Model
Strategies will seek to achieve their objectives by
investing in a mix of actively managed mutual
funds, multi-factor mutual funds and passively
managed ETFs as described above.
Russell Income Model Strategies
The Russell Tax-Managed Models also seek to
improve after-tax returns by investing in actively
managed funds that place a higher priority on
managing tax liability, such as funds that consider
shareholder tax consequences when buying and
selling portfolio securities or that invest in tax-
exempt securities.
The Russell Income Models have a dynamic, yield-
oriented
income approach to investing. The
Income Model Strategies invest in a mix of
actively managed mutual funds and passively
managed ETFs.
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strategies);
balanced
Russell Conservative
Income Strategy. The
Russell Conservative Income Strategy is designed
to seek current income over a long-term time
horizon. It is intended to be a core part of an
income-seeking portfolio.
information
regarding
intended to be a complete
review
core strategies); ultra-short term, short-term,
intermediate-term and long-term fixed income
strategies (which may include high yield corporate
strategies;
bond
international and global equity and fixed income
strategies; market sector
focused strategies,
geographic area focused strategies; real estate
strategies; commodities strategies; currency
strategies; and Alternative Strategies. For
additional
the
characteristics of the mutual funds and ETPs used
in a UMA Portfolio, clients should contact their
the applicable
DDK Consultant or
prospectus.
Russell Balanced Income Strategy. The Russell
Balanced Income Strategy is designed to meet
more aggressive current income needs and has a
higher potential for capital depreciation compared
to the Russell Conservative Income Strategy. It is
not
investment
program, but rather it is intended to be a
compliment to other income sources.
The UMA Programs may offer investment in the
following sleeves of mutual funds used in the
ALIGN Strategic Portfolios Program (the “ALIGN
Strategic Sleeves”):
Under normal market conditions, the Russell
Income Models will invest in mutual funds and
ETFs that invest in a mix of equity securities,
fixed income securities, Non-Traditional Assets,
Alternative Investment Products and cash.
consistent
exposure
to
Implementation by Baird
typically
implement
• ALIGN Large Cap Growth Sleeve, which seeks to
larger
provide
companies that have above-market growth
rates;
consistent
exposure
to
• ALIGN Large Cap Value Sleeve, which seeks to
provide
larger
companies that are trading at below-market
valuations, on average;
Baird will
the Russell
Strategies as they are proposed by Russell.
However, since Baird has discretionary authority,
implement a Russell Strategy
Baird may
differently than proposed by Russell or may sell
the client’s investments if Baird determines such
action to be necessary and in the client’s best
interest.
• ALIGN Mid Cap Sleeve, which seeks to provide
to medium-sized
exposure
consistent
companies;
Clients should contact their DDK Consultant with
any questions regarding the Russell Strategies.
UMA Programs
• ALIGN Small Cap Sleeve, which seeks to
provide consistent exposure to smaller-sized
companies;
• ALIGN International Equity Sleeve, which seeks
to provide consistent exposure to non-U.S.
companies;
Strategies—Asset
The UMA Programs offer model asset allocation
portfolios that have varying investment objectives
and strategies. Each UMA Portfolio provides for
specific levels of investment (or allocation) across
the asset classes described under the heading
“Investment
Allocation
Strategies” above.
• ALIGN Absolute Return Sleeve, which seeks to
provide diversification to a traditional stock and
bond allocation by investing in Alternative
Strategies;
• ALIGN Diversified Yield Sleeve, which seeks to
provide exposure to a wide range of income-
producing securities, including various equity
investments such as dividend-paying stocks,
MLPs, and REITs, as well as various fixed
income instruments;
Each UMA Portfolio may use mutual funds, ETPs,
primarily ETFs, and SMA Strategies, and with
respect to the UAS Program, PWM-Managed
Portfolios, in order to implement the model asset
allocation. Depending on the UMA Portfolio
chosen, the UMA Portfolio may consist of mutual
funds, ETFs, SMAs and PWM-Managed Portfolios
that have various investment objectives and
strategies, including but not limited to, the
following: large cap, mid cap and small cap
strategies (which may include value, growth or
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• ALIGN Short-Term Taxable Fixed
and tax-exempt accounts of clients with differing
investment objectives and risk tolerances.
Income
Sleeve, which seeks to provide consistent
exposure to fixed income securities that have
shorter maturities, typically less than five
years;
• ALIGN Short-Term Tax Exempt Fixed Income
Sleeve, which seeks to provide consistent
exposure to municipal or other tax exempt fixed
income securities that have shorter maturities,
typically less than five years;
Product
allocations
intended
to
Generally, under normal market conditions, the
equity security allocation of each ALIGN UMA
Select Portfolio is designed to be global in nature
and attempts to be diversified across countries,
industry sectors and company capitalization sizes,
with an objective to participate in the total return
potential of the global stock markets. The fixed
income allocation is also normally global in nature
and diversified across credit quality and maturity.
The Non-Traditional Asset and Alternative
provide
Investment
diversification and are
reduce
correlation to U.S. stock and bond markets.
intermediate
• ALIGN Intermediate Taxable Fixed Income
Sleeve, which seeks to provide consistent
exposure to a broad range of fixed income
securities that under normal market conditions
term
on average will have
durations and maturities; and
• ALIGN Intermediate Tax Exempt Fixed Income
Sleeve, which seeks to provide consistent
exposure to a broad range of municipal or other
tax exempt fixed income securities that under
normal market conditions on average will have
intermediate term durations and maturities.
The amount allocated to each asset class and type
of investment varies by Portfolio. However, some
Portfolios may have little or no allocation to one
or more asset classes or types of investments
described above.
its asset allocation strategies
the heading
information about how Baird
is
“Investment
Certain strategies offered under the ALIGN UMA
Select Portfolios Program are “environmental,
social and governance” (“ESG”) portfolios, which
focus investments in mutual funds, ETFs and
SMAs with investment managers that evaluate
portfolio companies’ performance on various
environmental, social and corporate governance
criteria as part of the managers’ investment
process. The particular environmental, social and
governance criteria used by mutual funds and
ETFs vary by mutual fund and ETF and are
determined by the manager for the applicable
mutual fund or ETF and not by Baird. How each
company performs with respect to those criteria is
a matter of subjective judgement. It is possible
managers could come to different conclusions
about how a particular company performs with
respect to the same environmental, social and
governance criteria.
More specific
develops
contained under
Strategies—Asset Allocation Strategies” above.
The ALIGN UMA Select Portfolios are described
below.
Some UMA Portfolios have a
risk profile
designation of (1) All Growth Portfolio, (2) Capital
Income
Growth Portfolio, (3) Growth with
Portfolio, (4) Income with Growth Portfolio, (5)
Conservative Income Portfolio, or (6) Capital
Preservation Portfolio, which are described under
“Principal Risks—Risk Information for ALIGN, PIM,
and UMA Program Accounts and Other Accounts
Following Asset Allocation Strategies” below.
ALIGN UMA Select Portfolios
and
use
different
ALIGN UMA Select All Growth Portfolio. The ALIGN
UMA Select All Growth Portfolio seeks to provide
aggressive growth of capital. Under normal
market conditions, this Portfolio generally invests
nearly all of its assets in mutual funds, ETFs and
SMAs that in turn principally invest in equity
securities. This Portfolio may also invest in other
asset classes described above, including fixed
Assets,
securities, Non-Traditional
income
Alternative Investment Products and cash. This
Portfolio has the same risk profile as an All
Growth Portfolio.
The ALIGN UMA Select Portfolios Program offers
model portfolios that have different investment
objectives
investment
strategies. The ALIGN UMA Select Portfolios
Program generally accommodates both taxable
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above,
including
fixed
ALIGN UMA Select ESG Equity. The ALIGN UMA
Select ESG Equity Portfolio seeks to provide
growth of capital, with some consideration for
volatility. Under normal market conditions, this
Portfolio generally invests nearly all of its assets
in mutual funds, ETFs and SMAs that in turn
principally invest in equity securities and that
have investment managers that that incorporate
ESG criteria into their investment process. While
this Portfolio may invest in companies across all
market capitalizations,
the equity securities
portion of this Portfolio tends to emphasize mid
cap and large cap companies. This Portfolio may
also invest in other asset classes described above,
including fixed income securities, Non-Traditional
Assets, Alternative Investment Products and cash.
However, it tends to have little or no allocation to
those asset classes, except for cash. This Portfolio
has the same risk profile as an All Growth
Portfolio.
ALIGN UMA Select Conservative Equity Portfolio.
The ALIGN UMA Select Conservative Equity
Portfolio seeks to provide growth of capital, with
great consideration for volatility. Under normal
market conditions, this Portfolio generally invests
nearly all of its assets in mutual funds, ETFs and
SMAs that in turn principally invest in equity
securities. While this Portfolio may invest in
companies across all market capitalizations and
geographic locations, the equity securities portion
of this Portfolio tends to emphasize mid cap and
large cap companies and the foreign equity
securities portion of this Portfolio tends to
emphasize developed market companies. This
Portfolio may also invest in other asset classes
described
income
securities, Non-Traditional Assets, Alternative
Investment Products and cash. However, it tends
to have little or no allocation to those asset
classes, except for cash. This Portfolio has the
same risk profile as an All Growth Portfolio.
ALIGN UMA Select Opportunistic Equity Portfolio.
The ALIGN UMA Select Opportunistic Equity
Portfolio seeks to provide growth of capital, with
limited consideration for volatility. Under normal
market conditions, this Portfolio generally invests
nearly all of its assets in mutual funds, ETFs and
SMAs that in turn principally invest in equity
securities. This Portfolio may also invest in other
asset classes described above, including fixed
Assets,
securities, Non-Traditional
income
Alternative
Investment Products and cash.
However, it tends to have little or no allocation to
those asset classes, except for cash. This Portfolio
has the same risk profile as an All Growth
Portfolio.
ALIGN UMA Select Capital Growth Portfolio. The
ALIGN UMA Select Capital Growth Portfolio seeks
to provide growth of capital. Under normal market
conditions, this Portfolio primarily invests its
assets in mutual funds, ETFs and SMAs that in
turn principally invest in equity securities or fixed
income securities. This Portfolio normally will have
a significantly higher underlying asset allocation
to equity securities than fixed income securities.
This Portfolio may also invest in other asset
classes described above, including Non-Traditional
Assets, Alternative Investment Products and cash.
This Portfolio has the same risk profile as a
Capital Growth Portfolio.
its
fixed
ALIGN UMA Select Capital Growth (Municipal)
Portfolio. The ALIGN UMA Select Capital Growth
(Municipal) Portfolio has the same objective,
underlying investments, target allocations and
risk profile as the ALIGN UMA Select Capital
Growth Portfolio described above, except that this
Portfolio primarily
income
invests
allocation in actively managed mutual funds, ETPs
and SMAs that in turn principally invest in
municipal securities.
above,
including
fixed
ALIGN UMA Select Traditional Equity Portfolio. The
ALIGN UMA Select Traditional Equity Portfolio
seeks to provide growth of capital, with some
consideration for volatility. Under normal market
conditions, this Portfolio generally invests nearly
all of its assets in mutual funds, ETFs and SMAs
that in turn principally invest in equity securities.
While this Portfolio may invest in companies
across all market capitalizations, the equity
securities portion of this Portfolio tends to
emphasize mid cap and large cap companies. This
Portfolio may also invest in other asset classes
described
income
securities, Non-Traditional Assets, Alternative
Investment Products and cash. However, it tends
to have little or no allocation to those asset
classes, except for cash. This Portfolio has the
same risk profile as an All Growth Portfolio.
ALIGN UMA Select Growth with Income Portfolio.
The ALIGN UMA Select Growth with Income
Portfolio seeks to provide moderate growth of
capital and some current income. Under normal
market conditions, this Portfolio primarily invests
its assets in mutual funds, ETFs and SMAs that in
turn principally invest in equity securities or fixed
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income securities. This Portfolio may also invest in
other asset classes described above, including
Non-Traditional Assets, Alternative Investment
Products and cash. This Portfolio has the same
risk profile as a Growth with Income Portfolio.
may also include other investments deemed
appropriate by Baird, such as funds included on
the Recommended Mutual Fund List. This Portfolio
has the same risk profile as an All Growth
Portfolio.
included
ALIGN UMA Select Growth with
Income
(Municipal) Portfolio. The ALIGN UMA Select
Growth with Income (Municipal) Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the ALIGN UMA
Select Growth with Income Portfolio described
above, except that this Portfolio primarily invests
its fixed income allocation in actively managed
mutual funds that in turn principally invest in
municipal securities.
Baird Research Equity ETF Portfolio. The Baird
Research Equity ETF Portfolio seeks to provide
aggressive growth of capital. The Baird Research
Equity portfolio provides a globally-diversified
allocation to equity securities by investing in
stocks
in the Baird Recommended
Portfolio, which is complimented by investing in
ETPs, primarily ETFs,
for diversified equity
exposure. The Portfolio may also include other
investments deemed appropriate by Baird, such
as ETPs included on the Recommended Mutual
Fund List, or ETF Focus List. This Portfolio has the
same risk profile as an All Growth Portfolio.
in
fixed
including
Non-Traditional
is
investing
in
ALIGN UMA Select Income with Growth Portfolio.
The ALIGN UMA Select Income with Growth
Portfolio seeks to provide current income and
some growth. Under normal market conditions,
this Portfolio primarily invests its assets in mutual
funds, ETFs and SMAs that in turn principally
invest
income securities or equity
securities. This Portfolio normally will have a
higher underlying asset allocation to fixed income
securities than equity securities. This Portfolio
may also invest in other asset classes described
above,
Assets,
Alternative Investment Products and cash. This
Portfolio has the same risk profile as an Income
with Growth Portfolio.
Baird Research Income Portfolio. The Baird
Research Income Portfolio seeks to provide
income while outperforming the MSCI ACWI index
on a risk-adjusted basis over full market cycles.
The Baird Research Income Portfolio provides a
solution for certain income-oriented investors
seeking to benefit from broader diversification.
The Portfolio invests in stocks included in Baird’s
then
Rising Dividend Portfolio, which
complimented by
the ALIGN
Diversified Yield Sleeve and mutual funds included
on the Baird Recommended Mutual Fund List for
exposure to non-US dividend stocks and high
yield fixed income. This Portfolio has the same
risk profile as an All Growth Portfolio.
ALIGN UMA Select
Income with Growth
(Municipal) Portfolio. The ALIGN UMA Select
Income with Growth (Municipal) Portfolio has the
same objective, underlying investments, target
allocations and risk profile as the ALIGN UMA
Select Income with Growth Portfolio described
above, except that this Portfolio primarily invests
its fixed income allocation in actively managed
mutual funds that in turn principally invest in
municipal securities.
included
included
Baird Research Capital Growth (Taxable) Portfolio.
The Baird Research Capital Growth (Taxable)
Portfolio seeks to provide growth of capital. Under
normal market conditions, the Baird Research
Capital Growth (Taxable) Portfolio provides a
globally-diversified asset allocation with a target
allocation of 80% to equity securities and 20% to
fixed income securities. The Portfolio invests in
in the Baird Recommended
stocks
Portfolio, which is then complimented by investing
in sleeves of mutual funds used in the ALIGN Mid
Cap Sleeve, ALIGN Small Cap Sleeve, the ALIGN
International Equity Sleeve, ALIGN Short-Term
Taxable Fixed
Income Sleeve, and ALIGN
Intermediate Taxable Fixed Income Sleeve. The
Portfolio may also include other investments
deemed appropriate by Baird, such as funds
included on the Recommended Mutual Fund List.
Baird Research Equity Portfolio. The Baird
Research Equity Portfolio seeks
to provide
aggressive growth of capital. The Baird Research
Equity portfolio provides a globally-diversified
allocation to equity securities by investing in
stocks
in the Baird Recommended
Portfolio, which is then complimented by investing
in sleeves of mutual funds used in the ALIGN Mid
Cap Sleeve, ALIGN Small Cap Sleeve and the
ALIGN International Equity Sleeve. The Portfolio
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This Portfolio has the same risk profile as a -
Capital Growth Portfolio.
Recommended Mutual Fund List, or ETF Focus
List. This Portfolio has the same risk profile as an
Income with Growth Portfolio.
investing
in ETPs, primarily ETFs,
Baird Research Capital Growth ETF (Taxable)
Portfolio. The Baird Research Capital Growth ETF
(Taxable) Portfolio seeks to provide growth of
capital. Under normal market conditions, the
Baird Research Capital Growth (Taxable) Portfolio
provides a globally-diversified asset allocation
with a target allocation of 80% to equity
securities and 20% to fixed income securities. The
Portfolio invests in stocks included in the Baird
Recommended Portfolio, which is complimented
by
for
diversified equity and fixed income exposure. The
Portfolio may also include other investments
deemed appropriate by Baird, such as ETPs
included on the Recommended Mutual Fund List,
or ETF Focus List. This Portfolio has the same risk
profile as a Capital Growth Portfolio.
include
other
investments
Baird Research Capital Growth (Tax-Exempt)
Portfolio. The Baird Research Capital Growth
(Tax-Exempt) Portfolio seeks to provide growth of
capital. Under normal market conditions, the
Baird Research Capital Growth (Tax-Exempt)
Portfolio provides a globally-diversified asset
allocation with a target allocation of 80% to
equity securities and 20% to fixed income
securities. The Portfolio invests in stocks included
in the Baird Recommended Portfolio, which is then
complimented by investing in sleeves of mutual
funds used in the ALIGN Mid Cap Sleeve, ALIGN
Small Cap Sleeve, the ALIGN International Equity
Sleeve, ALIGN Short-Term Tax-Exempt Fixed
Income Sleeve, and ALIGN Intermediate Tax-
Exempt Fixed Income Sleeve. The Portfolio may
also
deemed
appropriate by Baird, such as funds included on
the Recommended Mutual Fund List. This Portfolio
has the same risk profile as a Capital Growth
Portfolio.
included
such
as ETPs
included
on
included
Baird Research Growth with Income ETF (Taxable)
Portfolio. The Baird Research Growth with Income
ETF (Taxable) Portfolio seeks to provide moderate
growth of capital and some current income. Under
normal market conditions, the Baird Research
Growth with Income (Taxable) Portfolio provides a
globally-diversified asset allocation with a target
allocation of 60% to equity securities and 40% to
fixed income securities. The Portfolio invests in
in the Baird Recommended
stocks
Portfolio, which is complimented by investing in
ETPs, primarily ETFs, for diversified equity and
fixed income exposure. The Portfolio may also
include other investments deemed appropriate by
the
Baird,
Recommended Mutual Fund List, or ETF Focus
List. This Portfolio has the same risk profile as a
Growth with Income Portfolio.
Baird Research Growth with Income (Taxable)
Portfolio. The Baird Research Growth with Income
(Taxable) Portfolio seeks to provide moderate
growth of capital and some current income. Under
normal market conditions, the Baird Research
Growth with Income (Taxable) Portfolio provides a
globally-diversified asset allocation with a target
allocation of 60% to equity securities and 40% to
fixed income securities. The Portfolio invests in
in the Baird Recommended
stocks
Portfolio, which is then complimented by investing
in sleeves of mutual funds used in the ALIGN Mid
Cap Sleeve, ALIGN Small Cap Sleeve, the ALIGN
International Equity Sleeve, ALIGN Short-Term
Taxable Fixed
Income Sleeve, and ALIGN
Intermediate Taxable Fixed Income Sleeve. The
Portfolio may also include other investments
deemed appropriate by Baird, such as funds
included on the Recommended Mutual Fund List.
This Portfolio has the same risk profile as a
Growth with Income Portfolio.
included
Baird Research Income with Growth ETF (Taxable)
Portfolio. The Baird Research Income with Growth
ETF (Taxable) Portfolio seeks to provide high
current income and some growth of capital. Under
normal market conditions, the Baird Research
Income with Growth (Taxable) Portfolio provides a
globally-diversified asset allocation with a target
allocation of 40% to equity securities and 60% to
fixed income securities. The Portfolio invests in
stocks
in the Baird Recommended
Portfolio, which is complimented by investing in
ETPs, primarily ETFs, for diversified equity and
fixed income exposure. The Portfolio may also
include other investments deemed appropriate by
the
Baird,
such
as ETPs
included
on
Baird Research Growth with Income (Tax-Exempt)
Portfolio. The Baird Research Growth with Income
(Tax-Exempt) Portfolio seeks to provide moderate
growth of capital and some current income. Under
normal market conditions, the Baird Research
Income (Tax-Exempt) Portfolio
Growth with
provides a globally-diversified asset allocation
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
include
other
investments
Portfolio, which
is
also
deemed
appropriate by Baird, such as funds included on
the Recommended Mutual Fund List. This Portfolio
has the same risk profile as an Income with
Growth Portfolio.
include
other
investments
The descriptions of the ALIGN UMA Select
Portfolios are current as of the date of this
Brochure. However, Baird may change
the
objective, investments, target allocations or risk
profile for any Portfolio at any time. Baird may
also offer other model portfolios under the
Program from time to time.
with a target allocation of 60% to equity
securities and 40% to fixed income securities. The
Portfolio invests in stocks included in the Baird
then
Recommended
complimented by investing in sleeves of mutual
funds used in the ALIGN Mid Cap Sleeve, ALIGN
Small Cap Sleeve, the ALIGN International Equity
Sleeve, ALIGN Short-Term Tax-Exempt Fixed
Income Sleeve, and ALIGN Intermediate Tax-
Exempt Fixed Income Sleeve. The Portfolio may
also
deemed
appropriate by Baird, such as funds included on
the Recommended Mutual Fund List. This Portfolio
has the same risk profile as a Growth with Income
Portfolio.
An ALIGN UMA Select Portfolio is subject to the
risks associated with the Portfolio’s particular
strategies and investments. A client should review
the risks associated with those strategies and
investments described under
the heading
“Principal Risks” below.
included
Recommended
Funds
and
and
The ALIGN UMA Select Portfolios Program makes
available certain UMA Recommended Funds and
certain UMA Recommended SMA Strategies. The
process Baird uses for selecting and removing
UMA
UMA
Recommended SMA Strategies under the ALIGN
UMA Select Portfolio Program is described under
the heading “Portfolio Manager Selection and
Evaluation—Selection
Evaluation—UMA
Programs” above.
An ALIGN UMA Select Portfolio may include funds
included on Baird’s Recommended Mutual Fund
List and products and SMA Strategies offered by
Baird and Associated Managers.
Baird Research Income with Growth (Taxable)
Portfolio. The Baird Research Income with Growth
(Taxable) Portfolio seeks to provide high current
income and some growth of capital. Under normal
market conditions, the Baird Research Income
with Growth (Taxable) Portfolio provides a
globally-diversified asset allocation with a target
allocation of 40% to equity securities and 60% to
fixed income securities. The Portfolio invests in
stocks
in the Baird Recommended
Portfolio, which is then complimented by investing
in sleeves of mutual funds used in the ALIGN Mid
Cap Sleeve, ALIGN Small Cap Sleeve, the ALIGN
International Equity Sleeve, ALIGN Short-Term
Income Sleeve, and ALIGN
Taxable Fixed
Intermediate Taxable Fixed Income Sleeve. The
Portfolio may also include other investments
deemed appropriate by Baird, such as funds
included on the Recommended Mutual Fund List.
This Portfolio has the same risk profile as an
Income with Growth Portfolio.
included
The Portfolio asset allocations and the investment
options
in the ALIGN UMA Select
Program are evaluated on an ongoing basis,
generally at least quarterly.
Unified Advisory Select Portfolios
strategies
because
they
Portfolio, which
is
UAS Portfolios involve the use of various different
investment
are
customized for each client. A client’s particular
investment strategy is typically determined by the
client in consultation with the client’s DDK
Consultant. Certain mutual funds, ETPs, SMA
Strategies and PWM-Managed Portfolios are
available to clients to pursue an investment
objective or
implement a customized asset
allocation strategy.
Baird Research Income with Growth (Tax-Exempt)
Portfolio. The Baird Research Income with Growth
(Tax-Exempt) Portfolio seeks to provide high
current income and some growth of capital. Under
normal market conditions, the Baird Research
Income with Growth (Tax-Exempt) Portfolio
provides a globally-diversified asset allocation
with a target allocation of 40% to equity
securities and 60% to fixed income securities. The
Portfolio invests in stocks included in the Baird
then
Recommended
complimented by investing in sleeves of mutual
funds used in the ALIGN Mid Cap Sleeve, ALIGN
Small Cap Sleeve, the ALIGN International Equity
Sleeve, ALIGN Short-Term Tax-Exempt Fixed
Income Sleeve, and ALIGN Intermediate Tax-
Exempt Fixed Income Sleeve. The Portfolio may
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and
Evaluation—Selection
Mutual Funds and ETPs. The UAS Portfolios
Program makes available two categories of
mutual funds and ETPs: (1) UMA Recommended
Funds and (2) UAS Available Funds. The process
Baird uses for selecting and removing mutual
funds and ETPs under the UAS Portfolios Program
is described under the heading “Portfolio Manager
Selection
and
Evaluation—UMA Programs” above.
two
“Methods of Analysis, Investment Strategies and
Risk of Loss—Investment Strategies” above. To
implement a client’s UAS Portfolio strategy, UAS
Managers may use any of the mutual funds, ETPs,
SMA Strategies and PWM-Managed Portfolios
made available by Baird for use in the Program.
UAS Portfolio strategies will have one of the
following investment objectives: (1) All Growth
Portfolio, (2) Capital Growth Portfolio, (3) Growth
with Income Portfolio, (4) Income with Growth
Portfolio, (5) Conservative Income Portfolio, or
(6) Capital Preservation Portfolio, which are
described under “Investment Strategies—Asset
Allocation Strategies” above.
information about
the
and
Evaluation—Selection
SMA Strategies. The UAS Portfolios Program
makes available
categories of SMA
(1) UMA Recommended SMA
Strategies:
Strategies; and (2) UAS Available SMA Strategies.
The process Baird uses for selecting and removing
SMA Strategies under the UAS Portfolios Program
is described under the heading “Portfolio Manager
and
Selection
Evaluation—UMA Programs” above.
A client should ask the client’s DDK Consultant for
additional
investment
styles, philosophies, strategies, analyses and
techniques the DDK Consultant will use in order to
meet the client’s objectives.
PWM-Managed Portfolios. The PWM-Managed
Portfolios made available under the UAS Portfolios
Program include the following:
• The ALIGN Strategic Sleeves;
A UAS Portfolio is subject to the risks associated
with the Portfolio’s particular strategies and
investments. A client should review the risks
associated with those strategies and investments
described under the heading “Principal Risks”
below.
Principal Risks
• the Baird Recommended Portfolio, Baird Rising
Dividend Portfolio, and AQA Portfolios described
under
the heading “Methods of Analysis,
Investment Strategies and Risk of Loss—
Methods of Analysis—Certain PWM-Managed
Portfolios” above; and
• certain ALIGN Elements Portfolios and ALIGN
Strategic Portfolios described under the heading
“ALIGN Programs” above.
The descriptions of the PWM-Managed Portfolios
are current as of the date of this Brochure.
the objective,
However, Baird may change
investments or target allocations for any PWM-
Managed Portfolio at any time. Baird may also
offer other PWM-Managed Portfolios under the
Program from time to time.
conditions and other
Risk is inherent in any investment product and
DDK and Baird do not guarantee any level of
return on a client’s investments. There is no
assurance that a client’s investment objectives
will be achieved, and a client could lose all or a
portion of the amount invested. The management
of client accounts and recommendations made to
clients are based in part upon the use of forward-
looking projections, which in turn are based upon
certain assumptions about how markets will
perform in the future. There can be no guarantee
that markets will perform in the manner assumed
and the actual performance of markets and a
client’s Account could differ materially from those
assumptions. Also, a client’s Account value may
fluctuate, sometimes dramatically, depending
upon the nature of the client’s investments,
market
factors. By
participating in a Service, a client may be subject
to certain risks, including, but not limited to the
risks described below. The risks discussed below
vary by Service, investment style or strategy, and
the investments in the client’s Account, and each
risk may or may not apply to a client. Clients
should not pursue a strategy or invest in an
Discretionary Management by UAS Managers. If a
client has selected the discretionary management
option of the UAS Program, the DDK Consultant,
acting as UAS Manager, will manage the client’s
Account in accordance with the UAS Portfolio
strategy selected by client. UAS Managers, as a
group, utilize a wide variety of investment styles,
philosophies, strategies and techniques, including
the investment strategies described in the section
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the associated
investment goals, investment time horizon and
risk tolerance. A client should inform the client’s
DDK Consultant of these considerations so the
DDK Consultant can assist in determining the
client’s investment objectives and asset allocation
strategies.
investment product unless they are prepared to
accept
risks. Clients are
encouraged to discuss with their DDK Consultant
the risks that apply to them. A client should also
review
the prospectus or other disclosure
document for any security or other investment
product in which the client invests, as it will
contain important information about the risks
associated with investing in such security or other
investment product.
Investment Risk Information
The investment risks of the Services generally
include the following:
Conflicts of Interest Risks. Issuers, advisors or
other sponsors of investment products or their
affiliates may engage in business practices that
conflict with the interests of investors. Among
other things, these business practices can have a
negative impact on the market price of the
investment product. Clients are encouraged to
review
the prospectus or other disclosure
document for the investment product and also
discuss with their DDK Consultant the conflicts of
interest risks that may apply to them.
Stock Market Risks. Equity security prices vary
and may fall, thus reducing the value of a client’s
investments. Certain stocks selected for a client’s
Account may decline in value more than the
overall stock market.
Market Risks. A client’s Account may change in
value due to overall market fluctuations. General
economic conditions, political developments,
international events and other factors may cause
the overall market to decline, which in turn may
reduce the value of the client’s Account regardless
of the relative strength of the securities held in
the Account. Securities prices often vary for
reasons unrelated to matters directly affecting the
issuers of the securities.
fluctuate
client
accounts
about
Equity Securities Risks. Equity securities may
experience sudden, unpredictable drops in value
or long periods of decline in value. This may occur
because of factors that affect the securities
markets in general, such as adverse changes in
economic conditions, the general outlook for
corporate earnings, interest rates or investor
sentiment. Equity securities may also lose value
because of factors affecting an entire industry or
sector, such as increases in production costs, or
factors directly related to a specific company,
such as decisions made by its management.
Management and Securities Selection Risks.
A client’s Account may
in value
differently than, or in the opposite direction as,
the overall market or applicable benchmark
because of the selection of individual securities for
the Account. The judgments made by the persons
managing
the
attractiveness, value and potential appreciation of
particular securities may prove to be incorrect.
For example, while the stock markets may
experience increases in value, the client’s Account
may experience a decline in value due to the
underperformance of the stocks selected for
investment in the client’s Account.
Common Stock Risks. Common stocks are
susceptible to general stock market fluctuations
and to volatile increases and decreases in value
as market confidence in and perceptions of their
issuers change. These investor perceptions are
based on various and unpredictable
factors
including: expectations regarding government,
economic, monetary and fiscal policies; inflation
and
interest rates; economic expansion or
contraction; and global or regional political,
economic and banking crises. Holders of common
stocks are generally subject to greater risk than
holders of preferred stocks and debt obligations of
the same issuer because common stockholders
generally have inferior rights to receive payments
from issuers in comparison with the rights of
Investment Objective and Asset Allocation
Risks. A client’s investment objective and asset
allocation strategies involve the risk that certain
asset classes selected for the client’s Account may
not perform as well as other asset classes during
varying periods. In addition, clients who pursue
more aggressive investment objectives and asset
allocation strategies, while hoping to achieve high
returns, may face greater risk of loss than clients
with more conservative objectives and strategies.
In developing investment objectives and asset
allocation strategies, clients should carefully
consider their financial situation and needs,
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preferred stockholders, bondholders and other
creditors.
and/or repay principal and an agency’s decision to
downgrade a security.
less
liquid
larger companies. Therefore,
Fixed Income Security Risks. Fixed income
securities are subject to certain risks, including
interest rate risk, credit risk and liquidity risk. In
addition, they are subject to maturity risk.
Generally, the longer a bond’s maturity, the
greater the interest rate risk and the higher its
yield. Conversely, the shorter a bond’s maturity,
the lower the interest rate risk and the lower its
yield. Non-rated, split-rated, below investment
grade, and asset-backed securities, including
mortgage-backed securities and CMOs, have
additional, special risks.
them more susceptible
Capitalization Size Risks. A client may be
invested in small and mid cap stocks, which are
often more volatile and
than
investments in larger companies. The frequency
and volume of trading in securities of such
companies may be substantially less than is
typical of
the
securities of such companies may be subject to
greater and more abrupt price fluctuations. In
addition, small- and mid-size companies may lack
the management experience, financial resources
and product diversification of larger companies,
making
to market
pressures and business failure.
foreign
Interest Rate Risk. The value of some
investment products, particularly fixed income
securities, is affected significantly by changes in
interest rates. Generally, when interest rates rise,
the product’s market value declines and when
interest rates decline, its market value rises. In
addition, a rise in interest rates may have a
negative impact on the issuer, which, in turn,
could have a negative impact on the market value
of the investment product.
Foreign Issuer and Investment Risks.
Securities of
issuers, ADRs, Global
Depositary Receipts (“GDRs”) and European
Depositary Receipts (“EDRs”), and investments in
foreign markets generally, are subject to certain
inherent risks, such as political or economic
instability of the country of issue, the difficulty of
predicting international trade patterns and the
possibility of imposition of exchange controls.
Such securities may also be subject to greater
fluctuations in price than securities of domestic
corporations. Investors in foreign markets may
face delayed settlements, currency controls and
adverse economic developments as well as higher
overall transaction costs. In addition, fluctuations
in the U.S. dollar’s value versus other currencies
may enhance, erode, reverse gains or widen
losses from investments denominated in foreign
currencies. For instance, foreign governments
may limit or prevent investors from transferring
their capital out of a country. This may affect the
value of a client’s investment in the country that
adopts such currency controls. Exchange rate
fluctuations also may impair an issuer’s ability to
repay U.S. dollar denominated debt, thereby
increasing the credit risk of such debt. In
addition, there may be less publicly available
information about a foreign company than about a
domestic company. Foreign companies generally
are not subject to uniform accounting, auditing
and financial reporting standards comparable to
those applicable to domestic companies. With
respect to certain foreign countries, there is a
possibility of expropriation or
confiscatory
taxation, or diplomatic developments, which could
affect investment in those countries.
Credit Risk. The value of some investment
products, particularly fixed income securities, is
affected by changes in the product’s credit quality
rating or the issuer’s financial condition. If the
credit quality rating or the issuer’s financial
condition declines, so may the value of the
investment product. Issuers may experience
unanticipated financial problems and may be
unable to meet its payment obligations. Municipal
obligations in particular may be adversely affected
by political and economic conditions and
developments (for example, legislation reducing
state aid to local governments.) Bonds receiving
the lowest investment grade rating or a non-
investment grade rating may have speculative
characteristics and, compared to higher grade
debt obligations, may have a weakened capacity
to make principal and interest payments due to
changes in economic conditions or other adverse
circumstances. Ratings agencies such as Moody’s,
Fitch and S&P provide ratings on bonds based on
their analyses of information they deem relevant.
Ratings are essentially opinions or judgments of
the credit quality of an issuer and may prove to
be inaccurate. In addition, there may be a delay
between events or circumstances adversely
affecting the ability of an issuer to pay interest
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Investments
related
incidents
market
depth,
incidents,
Emerging Markets Risks.
in
emerging markets can involve risks in addition to
and greater than those generally associated with
investing in more developed foreign markets. The
extent of economic development, political
stability,
infrastructure,
capitalization, and regulatory oversight can be
less than in more developed markets. Emerging
market economies can be subject to greater
social, economic,
regulatory, and political
uncertainties. All of these factors can make
emerging market securities more volatile and
potentially less liquid than securities issued in
more developed markets.
Similar adverse consequences may arise from
technology
affecting
governmental authorities,
regulatory bodies,
financial market systems, exchanges, brokers-
dealers, banks, insurance companies, custodians,
or other market participants. Although issuers and
their service providers may adopt business
continuity plans, information security controls,
and risk management programs designed to
prevent or mitigate such
these
measures are subject to inherent limitations,
including the possibility that certain risks may not
be identified or fully addressed. As a result, client
Accounts and investments may be negatively
affected.
Intelligence Risks.
increasingly use AI systems
the
that
could
compromise
technology
Such
incidents may
in
fact
inaccurate,
regulatory
scrutiny,
rely
on
third-party
AI
or
penalties,
reputational
investigate,
or
remediate
in
the
section
titled
their
own
information
Artificial
Issuers of
in
investments
various aspects of their business operations,
creating competitive market pressures to increase
the development and use of AI systems. Failure to
effectively develop or use AI systems may place
an issuer at a competitive disadvantage. At the
same time, AI systems present significant risks
that could materially affect an issuer’s business
and financial performance. AI Tools rely on
complex models, large datasets, and evolving
algorithms. AI Tools are highly-useful but
complex and fallible systems that can exhibit bias,
hallucinations, deceptive behaviors and other
flaws due to the construction of their underlying
models and the composition of their training data,
which can result in outputs that seem plausible
but are
incomplete, or
misleading. The use of erroneous outputs can
undermine customer trust and expose issuers to
litigation,
substantial
remediation costs, and reputational harm. AI tools
require timely access to high‑quality, compliant
data, and any disruption in data availability can
impair or disable AI Tool functionality. Issuers
often
systems,
infrastructure, and data, which can create vendor
dependency, limit visibility into and validation of
AI model performance, and increase the risk of
disruption in data availability. The regulatory
environment for AI is rapidly evolving and may
involve inconsistent or conflicting requirements
across
jurisdictions. Compliance may require
significant investment, changes to AI systems, or
the discontinuation of certain AI‑enabled features.
Non‑compliance may lead to fines, enforcement
actions, or operational constraints. AI systems are
vulnerable to cyberattacks or other adversarial
actions that can impair system performance and
Information Security, Cybersecurity and
Technology-Related Risks. As issuers and their
service providers increasingly rely on digital
technologies, such as
Internet, cloud
computing, and AI‑enabled systems, they face
heightened information security, cybersecurity,
including
and other technology‑related risks,
incidents
the
confidentiality, integrity, or availability of their
systems, data, or
infrastructure.
Technology-related incidents may result from
deliberate adversarial actions (such as cyber
attacks) or unintentional events (such as systems
or human error) and could have a materially
adverse impact on the issuer’s performance and
involve
operations.
unauthorized access, disclosure, use, corruption,
degradation, or destruction of systems or data
(such as
through hacking, malware, social
engineering or theft of digital devices); or the
disruption of systems access to authorized users
(such as through denial of service attacks). Such
events can impede critical functions, compromise
sensitive business and protected customer
information, and may result in financial losses,
business interruptions, impediments to the ability
to process transactions, breaches of applicable
privacy, data protection, or other laws, regulatory
fines
harm,
reimbursement or other remediation costs, and
increased compliance or operational expenses.
Substantial costs may be incurred to prevent,
detect,
future
technology related incidents. Issuers’ increasing
use of AI systems introduces additional risks
discussed
“Artificial
Intelligence Risks” below. Issuers may also rely
on third party or cloud based platforms that
security,
present
cybersecurity, and other technology‑related risks.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
use
protected
municipal securities, which would in turn affect
Baird’s ability to acquire and dispose of municipal
securities at desirable yield and price levels.
Investment in tax-exempt debt obligations poses
additional risks. In many cases, the IRS has not
ruled on whether the interest received on a tax-
exempt obligation is tax-exempt, and accordingly,
purchases of these municipal securities are based
on the opinion of bond counsel to the issuers at
the time of issuance. Thus, there is a risk that
interest may be taxable on a municipal security
that is otherwise expected to produce tax-exempt
interest.
integrity and compromise sensitive business and
protected customer information. The impairment
of AI systems or the unauthorized disclosure of
sensitive business or protected information can
result in material disruption and damage to
legal and
significant
business operations,
regulatory
remediation
liabilities, substantial
expenses, and reputational harm. AI systems may
information,
inadvertently
potentially giving rise to intellectual property
infringement claims and substantial damages.
Public concerns regarding fairness, transparency,
and responsible use of AI may reduce demand for
an issuer’s products or services. Failure to use AI
responsibly may harm an issuer’s reputation and
competitive position.
securities,
and/or
issued by
Government Obligation Risks. Client assets
may be invested in securities issued, sponsored or
guaranteed by the U.S. Government, its agencies
and instrumentalities. However, no assurance can
be given that the U.S. Government will provide
financial support to U.S. Government-sponsored
agencies or instrumentalities where it is not
obligated to do so by law. For instance, securities
issued by the Government National Mortgage
Association (“Ginnie Mae”) are supported by the
faith and credit of the United States.
full
Securities
the Federal National
Mortgage Association (“Fannie Mae”) and the
Federal Home Loan Mortgage Corporation
(“Freddie Mac”) have historically been supported
only by the discretionary authority of the U.S.
Government. While the U.S. Government provides
financial support to various U.S. Government-
sponsored agencies and instrumentalities, such as
those listed above, no assurance can be given
that it will always do so.
falling. Since
interest
federal
taxation,
in such
for purchases or withdrawals.
Money Market Fund Risks. A money market
fund is a type of mutual fund that generally
invests in short-term debt instruments. Many
investors use money market funds to store cash.
There are three primary types of money market
funds: (1) government money market funds
(funds that invest nearly all assets in cash,
repurchase
government
agreements collateralized by cash or government
securities); (2) retail money market funds (funds
that have policies and procedures reasonably
designed to limit beneficial ownership to natural
persons); and (3) institutional money market
funds (funds that permit beneficial ownership by
institutions and natural persons). The rules
governing money market funds vary based on the
type of money market fund. Government and
retail money market funds generally try to keep
their net asset value (NAV) at a stable $1.00 per
share using special pricing and valuation
conventions. Institutional money market funds
are required to calculate their NAV in a manner
such that the NAV will vary based upon the
market value of assets and liabilities of the fund
(also known as a “floating NAV”). An investment
in a money market fund is not insured or
guaranteed by the FDIC or any other government
agency. Although some money market funds seek
to preserve the value of an investment at $1.00
per share, there can be no assurance that will
occur, and it is possible to lose money should the
fund value per share fall. In some circumstances,
money market funds may be forced to cease
operations when the value of a fund drops. In
that event, the fund's holdings may be liquidated
and distributed to the fund's shareholders. This
liquidation process could take time to complete.
During that time, the amounts a client has
invested in the money market fund would not be
In
available
addition, retail and institutional money market
Municipal Securities Risks. Repayment of
municipal securities depends on the ability of the
issuer or project backing such securities to
generate taxes or revenues. Municipal securities
may also decrease in value during times when tax
income on
rates are
municipal securities is normally not subject to
regular
the
income
attractiveness of municipal securities in relation to
other investment alternatives is affected by
changes in federal income tax rates applicable to,
or the continuing federal tax-exempt status of,
such interest income. Any proposed or actual
changes
rates or exempt status,
therefore, can significantly affect the liquidity,
for
marketability and supply and demand
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
redemptions
in
asset classes. Client accounts with concentrated
positions are susceptible to greater volatility and
increased risk of loss than an Account that is
diversified across several issuers and industries or
sectors and asset classes. A client should not
engage in strategies using concentration unless
the client is prepared to experience significant
losses in the value of the client’s Account.
funds are required to impose redemption fees
(also known as liquidity fees) and suspend
redemptions (also known as redemption gates) in
circumstances. Government money
certain
market funds may also impose redemption fees
and suspend
those same
circumstances. More specific information about
how a money market fund calculates its NAV and
the circumstances under which it will impose a
redemption fee or suspend redemptions is set
forth in the prospectus for that money market
fund.
to
lower
to make a market
for
Frequent Trading and Portfolio Turnover
Risks. Some of the investment strategies offered
to clients in this Brochure may involve frequent or
active trading for client accounts, which could
result in high portfolio turnover. Strategies that
involve frequent or active trading increase the
management and securities selection
risks
because the persons managing the accounts are
making more trading decisions, which may prove
to be incorrect. A portfolio with a high turnover
rate will also incur more transaction costs than
one with a lower rate. Higher transaction costs
may negatively impact the return of the portfolio.
High portfolio turnover may also cause a client to
experience adverse tax consequences due to the
fact that the client may have increased instances
of realized gains and losses and such gains and
losses may commonly be characterized as short
term gains and losses under applicable tax law.
Illiquid Securities and Liquidity Risks.
Liquidity risk is the risk that certain investments
may be difficult or impossible to sell at the time
and price that a client would like to sell. Clients
the price, sell other
may have
investments or forego an investment opportunity,
any of which may have a negative effect on the
management or performance of client accounts.
The liquidity of a particular investment depends
on the strength of demand for the investment,
which is generally related to the willingness of
broker-dealers
the
investment as well as the interest of other
investors to buy the investment. During periods of
economic uncertainty, significant economic and
market downturns and periods in which financial
services firms are unable to commit capital to
make a market in, or otherwise buy, certain
investments, a client may experience challenges
in selling such investments at optimal prices. In
addition, recent regulatory changes applicable to
financial intermediaries that make markets in
debt securities have restricted or made it less
desirable for those financial intermediaries to hold
large inventories of debt securities. Because
market makers provide stability to a market
through their intermediary services, a reduction in
dealer inventories may lead to decreased liquidity
and increased volatility in the fixed income
markets. In the event the client directs Baird to
liquidate an illiquid investment, the client should
understand that Baird may have difficulty finding
a buyer in the market for such investment and
such investment may be held in the Account for a
period of time while Baird attempts to satisfy the
client’s liquidation request.
Concentration Risks. A client’s Account may
consist of a portfolio of securities that
is
concentrated in an issuer or group of issuers, an
industry or economic sector or group of related
industries or sectors, or concentrated in limited
Asset-Backed Securities Risks. Asset-backed
securities are securities secured or backed by
mortgage loans, student loans, automobile loans,
installment sale contracts, credit card receivables
or other assets and are issued by entities such as
commercial banks, trusts, financial companies,
industrial companies,
finance subsidiaries of
savings and loan associations, mortgage banks
and investment banks. These securities represent
interests in pools of assets in which periodic
payments of interest or principal on the securities
are made, thus, in effect passing through periodic
payments made by the individual borrowers on
the assets that underlie the securities, net of any
fees paid to the issuer or guarantor of the
securities. Asset-backed securities are issued in
multiple classes (or tranches) and their relative
payment rights may be structured in many ways.
Asset-backed securities may be subject to greater
risk of default during periods of economic
downturn than other instruments. Asset-backed
securities also can be more sensitive to interest
rate risk than other types of fixed income
securities. Modest movements in interest rates
(both increases and decreases) may quickly and
significantly reduce the value of certain types of
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
these securities. Asset-backed securities are
subject to a number of other risks, including, but
not limited to, market and valuation risks,
liquidity risk, and prepayment risk.
Split-Rated,
and
equity,
securities
include market
selection
Non-Rated,
Below
Investment Grade Securities (High Yield or
“Junk” Bonds) Risks. Investing in securities or
other investment products that are not rated,
split-rated or are below investment grade (also
known as high yield or “junk” bonds) involve
significant, special risks. As a result, they may not
be suitable for some clients. The risks associated
with these investments include, but not limited to,
price volatility risk, credit risk, default risk, and
liquidity risk. Clients investing in securities or
other investment products that are not rated,
split-rated or are below investment grade should
have a high tolerance for risk, including the
willingness and ability to accept significant price
volatility, potential lack of liquidity and potential
loss of their investment.
credit
capitalization
risk,
foreign
including equity,
fixed
investment
style,
ETF may vary from its net asset value. ETFs
invest in and hold securities and other assets,
such as stocks, bonds, commodities and
currencies, and have stated investment objectives
and principal strategies. ETFs can have many
different investment objectives and strategies,
including
income, balanced,
fixed
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. Many ETFs seek to track the
performance of an index or other underlying
benchmark. Passively managed ETFs will not be
able to replicate exactly the performance of the
indices the ETFs track because the total return
generated by the securities will be reduced by
management fees, transaction costs and other
expenses incurred by the ETF. ETFs have other
risk,
risks, which may
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
rate
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk.
Certain ETFs pursue Complex Strategies, which
are subject to special risks. The degree of these
and other risks will vary depending on the type of
ETF selected.
securities
selection
credit
capitalization
risk,
foreign
that
fund
Mutual Fund Risks. Mutual funds can have
investment objectives and
many different
strategies,
income,
balanced, international, and global strategies, and
strategies that focus on a particular market
capitalization,
economic
industry or sector, or geographic region. Mutual
funds have risks, which may include market risk,
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
risk,
risk,
rate
investment style
issuer and
investment risk, and emerging market risk.
Certain mutual funds pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of mutual fund selected. Also, investment
return and principal value will fluctuate, and
shares, when redeemed, may be worth more or
less than their original cost.
that
Closed-End Fund Risks. Unlike mutual funds
which continuously offer and redeem their shares
on a daily basis at net asset value, closed-end
funds typically raise money by selling a fixed
number of shares of common stock in a single,
one-time offering, much the way a company
issues stock in an initial public offering. Closed-
end funds can have many different investment
objectives and strategies, including equity, fixed
international, and global
income, balanced,
strategies, and strategies
focus on a
particular market capitalization, investment style,
industry or sector, or geographic
economic
shares are not
region. Closed-end
redeemable, meaning
investors cannot
require closed-end funds to buy back their shares,
although closed-end fund shares are listed and
traded on an exchange. For many reasons,
closed-end fund shares often trade at a discount
to their net asset value and the market prices of
closed end fund shares often fall below their
public offering prices. Clients are therefore
cautioned about buying shares of a closed-end
fund in its initial public offering. Closed-end funds
Exchange Traded Fund Risks. An ETF is
different from a mutual fund in that an ETF does
not sell its shares directly to public investors and
does not redeem shares from public investors.
Rather, shares of an ETF are commonly purchased
or sold in the secondary market on a securities
exchange, like common stocks. An ETF maintains
a net asset value but, based on demand and
other factors, the market price of shares of an
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
for purposes of making
securities
selection
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
capitalization risk, investment style risk, foreign
issuer and investment risk, and emerging market
risk. Certain UITs pursue Complex Strategies,
which are subject to special risks. The degree of
these and other risks will vary depending on the
type of UIT selected. Also, investment return and
principal value will fluctuate, and units, if and
when redeemed, may be worth more or less than
their original cost.
credit
capitalization
risk,
foreign
closed-end
often engage in leverage to raise additional
capital
investments
through borrowings and issuances of senior
securities (such as preferred stock). Such
leverage may present the opportunity to enhance
potential returns but also involve the risk of
exacerbating losses and depreciation in the value
of the underlying securities. Closed-end funds
have other risks, which may include market risk,
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate
risk,
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk.
Certain
funds pursue Complex
Strategies, which are subject to special risks.
Some closed-end funds are organized as interval
funds, which differ from traditional closed-end
funds in that their shares do not trade on the
secondary market, but instead their shares are
subject to repurchase offers from the fund.
Closed-end funds structured as an interval fund
will, therefore be relatively less liquid. Interval
funds also often impose a redemption fee when
shares are sold back to the fund. The degree of
these and other risks will vary depending on the
type of close-end fund selected.
is selected by
negative
tax
consequences.
Risks Common to All Funds; Purchase and
Redemption Risks. Funds are generally subject
to the same risks as the securities or other assets
in which they invest. In addition, from time to
time Baird, a DDK Consultant, or an investment
manager may decide to add or remove a Fund to
or from an investment strategy or Service. In
addition, they may decide to increase or decrease
their clients’ account allocations to a Fund. In
general, they will place transactions for all
affected Accounts at one time, which may cause
the Fund to experience relatively large purchases
or
redemptions. Significant purchases and
redemptions may adversely affect the Fund in
question and consequently, a client’s investment.
A Fund receiving large purchase orders may have
difficulty investing the cash, which may have a
negative impact on the Fund’s performance. A
Fund experiencing large redemption orders may
have to sell portfolio securities, which may
negatively impact performance and which may
have
Large
redemptions could also reduce liquidity as the
Fund may suspend or delay redemptions. These
risks are more pronounced with respect to newer
Funds and those with smaller asset sizes.
equity,
Risks Associated with Certain Investment
Strategies
Growth and Value Investment Style Risks.
Investment styles or strategies that focus on
growth stocks may perform better or worse than
styles or strategies that focus on value stocks or
that are broader or more diversified. Similarly,
investment styles or strategies that focus on
value stocks may perform better or worse than
styles or strategies that focus on growth stocks or
that are broader or more diversified. A particular
style of investing may go out of favor at times
and for extended periods. Growth stocks are often
characterized by high price-to-earnings ratios and
may be more volatile than stocks with lower
Unit Investment Trust Risks. A UIT is a pooled
in which a portfolio of
investment vehicle
securities
the sponsor and
deposited into the trust for a specified period of
time. The portfolio of a UIT is designed to follow
an investment objective over a specified time
period, although there is no guarantee that the
objective will be met. UITs can have many
different investment objectives and strategies,
income, balanced,
fixed
including
international, and global strategies, and strategies
that focus on a particular market capitalization,
investment style, economic industry or sector, or
geographic region. UITs are passively managed
and follow a “buy and hold” strategy, meaning
that UITs buy a fixed portfolio of securities and
hold on to that portfolio until their termination
date at which time the portfolio is liquidated with
the net proceeds paid to investors. UITs, thus,
generally have a relatively higher risk of loss than
other funds in the event of adverse changes in
market or economic conditions. UITs have other
risks, which may
include management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
price-to-earnings ratios. Value stocks are subject
to the risk that the broader market may not agree
with the manager’s assessment of, or recognize,
the investments’ intrinsic value.
trading markets cannot predict future prices,
volume patterns or trends. There is no guarantee
that technical investment methods used are
designed properly, are updated with new data as
it becomes available, or can accurately predict
future market or investment performance. In
order for technical investment methods to work,
there must be sufficient data about the markets
available so that trends can be identified and
predictions can be made. A technical method may
fail to identify trends or be able to accurately
predict future prices if a market does not have
sufficient data or trends or if the market behaves
erratically.
ESG Considerations Risk. Consideration of ESG
factors in the investment process may cause an
advisor or manager to forgo opportunities to
recommend or invest in certain companies or to
gain exposure to certain industries or regions.
Therefore, there is a risk that, under certain
market conditions, an Account pursuing strategies
that consider ESG factors may underperform
accounts that do not consider such factors. There
are not universally accepted ESG factors and
advisors and managers typically consider them in
their discretion.
and Risk
of
Other Strategy Risks. The risks associated with
other types of investment strategies are described
under the heading “Portfolio Manager Selection
and Evaluation—Methods of Analysis, Investment
Strategies
Loss—Investment
Strategies” above.
Non-Traditional Assets and Complex
Strategies Risks
such as
commodities,
an
investment
traditional
Non-Traditional Assets Risks. Non-Traditional
currencies,
Assets,
securities indices, interest rates, credit spreads,
private companies, and Digital Assets, are subject
to risks that are different from, and in some
instances, greater than, other assets like stocks
and bonds. Some Non-Traditional Assets are less
transparent and more sensitive to domestic and
foreign political and economic conditions than
more
investments. Non-Traditional
Assets are also generally more difficult to value,
less liquid, and subject to greater volatility
compared to stocks and bonds.
by
the
Risks.
Investments
investments
that were not predicted by
can be no assurance
that
in
securities.
Quantitative Strategy Risks. Some investment
managers may employ quantitative investment
methodologies or processes to make investment
the quantitative
decisions. The success of
investment methodologies and processes used by
investment managers depends on the analyses
and assessments that were used in developing
such methodologies and processes, as well as on
the accuracy and reliability of models and data
provided by third parties. Incorrect analyses and
assessments or inaccurate or incomplete models
and data would adversely affect performance.
manager’s
Additionally,
methodologies and processes are predictive in
nature, based on historical outcomes and trends.
Certain low-probability events or factors that are
assigned little weight may occur or prove to be
more likely or may have more relevance than
expected, for short or extended periods of time,
which may adversely affect
the portfolios
generated
investment manager’s
quantitative methodologies and processes. It is
also possible that prices of securities may move in
directions
the
investment manager’s quantitative methodologies
and processes or may fail to move as much as
predicted, for reasons that were not expected.
There
these
methodologies will enable a client to achieve the
client’s objective.
investment and
trading activities
Commodities
in
commodities markets or a particular sector of the
commodities markets, and
in
securities or other instruments denominated in or
indexed or linked to commodities, are subject to
certain risks. Those investments generally will
subject a client Account to greater volatility than
investments
The
traditional
commodities markets are impacted by a variety of
factors, including changes in overall market
movements, domestic and foreign political and
economic conditions, interest rates, inflation rates
and
in
commodities. Prices of commodities may also be
affected by factors such as drought, floods,
weather, livestock disease, embargoes, tariffs and
Technical Strategy Risks. Some investment
managers and DDK Consultants may employ
technical analysis or investment methodologies to
make investment decisions or recommendations.
The primary risk of using technical analysis is that
past price and volume patterns and trends in the
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
or
consuming
at an unfavorable price. A client should not
engage in short sales unless the client is prepared
to experience significant losses in the client’s
Account.
contracts
other
other regulatory developments. The prices of
commodities can also fluctuate widely due to
supply and demand disruptions
in major
regions. Certain
producing
commodities may be produced in a limited
number of countries and may be controlled by a
small number of producers or groups of
producers. As a result, political, economic and
supply related events in such countries could have
a disproportionate impact on the prices of such
commodities. No active trading market may exist
for certain commodities investments, which may
impair the value of the investments.
instruments
in
that
Derivative Instrument Risks. The values of
options, convertible securities, futures, swaps,
derivative
and
forward
instruments is derived from an underlying asset,
such as a security, commodity, currency, or
index. Derivative instruments often have risks
similar to the underlying asset, however, in
certain cases, those risks are greater than the
risks presented by
the underlying asset.
Derivative instruments may experience dramatic
price changes and imperfect correlations between
the price of the derivative and the underlying
asset, which may increase volatility. Derivatives
generally create leverage, and as a result, a small
movement in the underlying asset's value can
result in large change in the value of the
derivative instrument. Derivatives are also subject
to liquidity risk, interest rate risk, market risk,
credit risk, management risk and counterparty
risk. The use of these
is not
appropriate for some clients because they involve
special risks. A client should not invest in these
instruments unless the client is prepared to
experience volatility and significant losses in the
client’s Account.
Currency Risks. Investments in currencies, and
investments in securities or other instruments
denominated in or indexed or linked to currencies,
are subject to certain risks. Those investments
are subject to all of the risks associated with
foreign investing generally. In addition, currency
markets generally are not as regulated as
securities markets. Also, changes in currency
exchange rates could adversely
impact the
investment. Devaluation of a currency by a
country will also have a significant negative
impact on
investment
the value of any
currency. Currency
denominated
investments may also be positively or negatively
affected by a country’s strategies intended to
make its currency stronger or weaker relative to
other currencies.
the
the underlying security or
Leverage and Margin Risks. Leveraging
strategies may amplify
impact of any
decrease in the value of underlying securities in
the client’s Account, thereby increasing a client’s
risk of loss. The use of leverage may also increase
an Account’s volatility. Strategies
involving
margin can cause a client to lose more money
than deposited in the client’s margin account. A
client should not engage in strategies involving
leverage or margin unless the client is prepared
to experience significant losses in the value of the
client’s Account.
Options Risks. In purchasing a put or call
option, the purchaser faces the risk of loss of the
premium paid for the option if the market price
moves in a direction opposite to what the
purchaser had expected. In selling or writing an
option, the seller faces significantly more risk. A
seller of a call option faces the risk of significant
loss
if the prevailing market price of the
underlying security or index increases above the
strike price, and a seller of a put option faces the
risk of significant loss if the prevailing market
price of
index
decreased below the strike price.
Hedging Risks. When a derivative instrument is
used as a hedge against an opposite position, any
loss on the derivative instrument should be
substantially offset by gains on the hedged
investment, and vice versa. Although hedging can
be an effective way to reduce the investment risk,
it may not always perfectly offset one position
with another. As a result, there is no assurance
that hedging transactions will be effective.
Short Sales Risks. Short selling runs the risk of
loss if the price of the securities sold short does
not decline below the price at which they were
originally sold. This risk of loss is theoretically
unlimited, as there is no cap on the amount that
the price of a security may appreciate. In
addition, a
lender may request, or market
conditions may dictate, that securities sold short
be returned to the lender on short notice, which
may result having to buy the securities sold short
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
in
the marketplace and
Assets
involve
technological
limited
short
sales,
risks may
trading,
settlement,
and
securities
include: market
selection
validators, miners,
or
credit
capitalization
risk,
foreign
limited number of
Digital Assets Risks. Digital Assets are not
appropriate for some clients because they involve
substantial risk of loss including special risks not
present in traditional financial markets. Digital
Assets derive value primarily from the demand for
such assets
their
association with decentralized networks and other
technology. Digital Assets may lack an intrinsic
for Digital Assets are
value and markets
susceptible
to extreme and sudden price
movements and fragmented liquidity. Markets for
Digital Assets continue to evolve, but
lack
certainty regarding the status of regulation and
investor protections. The use and custody of
Digital
and
cybersecurity risks, including the potential for
system outages, protocol
flaws, operational
disruptions, hacking incidents, or failures of
third-party platforms and service providers that
support
storage
infrastructure. Many Digital Assets depend on
protocol
external
developers whose actions or inaction can impact
network stability or asset functionality and affect
value. Market structure risks—such as reliance on
a
trading venues or
counterparties—may impair the ability to transact
or liquidate positions during periods of market
stress. A client should not invest in these
instruments unless the client is prepared to
experience extreme volatility and significant
losses in the client’s Account.
have the potential for significant growth in value.
Hedge funds and funds of hedge funds are also
subject to a higher risk of incorrect valuations.
Many hedge funds hold investments for which
market quotations are not readily available, which
necessitates the use of “fair value” pricing. Fair
value pricing is an inherently subjective process
and may not accurately reflect the prices that can
actually be obtained upon sale of the assets for
which fair values are used. Investments in hedge
funds and funds of hedge funds also have reduced
liquidity compared to other investments and are
generally subject to a higher risk of volatility.
Investing in hedge funds and funds of hedge
funds involves other special risks, including, but
to, risks associated with Non-
not
Traditional Assets,
leverage,
derivative instruments, and Complex Strategies.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
risk,
rate
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk. Hedge
funds and funds of hedge funds are complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in hedge funds or funds
of hedge funds should have a high tolerance for
risk, including the willingness and ability to accept
significant price volatility, potential
lack of
liquidity and potential loss of their investment.
Complex Investment Product Risks
funds have unique
in
certain
that may
sectors,
for those
fee
an
incentive
Hedge Funds and Funds of Hedge Fund
Risks. Hedge funds typically engage in one or
more Complex Strategies, including the use of
Non-Traditional Assets, short sales, leverage and
other derivative instruments. Funds of hedge
funds typically invest substantially all of their
assets in other hedge funds. Hedge funds and
funds of hedge
tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Some
hedge funds and funds of hedge funds are subject
to limited regulation and offer limited disclosure
and transparency. Also, the costs of hedge funds
and funds of hedge funds are typically higher than
other types of funds. Investment advisers or
funds often receive a
managers
management
or
plus
performance-based fee. Because of the existence
of a performance-based fee, fund managers may
be motivated to make riskier investments that
Private Equity Funds and Funds of Private
Equity Funds Risks. Private equity funds are
pools of actively managed capital that invest
primarily in private companies with the intent of
creating value in the companies in which they
invest by improving operations, reducing costs,
selling non-core assets and maximizing cash flow.
Private equity funds usually have an investment
focus on
objective or strategy
industries,
companies
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes of investments. Funds of private equity
funds typically invest substantially all of their
assets in other private equity funds. Private
equity funds and funds of private equity funds
have unique tax characteristics. A client should
consult with a tax advisor before investing in
those funds. Private equity funds and funds of
limited
private equity
funds are subject to
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
to administrative service
in certain sectors,
compared
other
expect
debt
funds
have
unique
receive a management
risk,
foreign
transaction
investments
should not
expect
to
regulation and offer
limited disclosure and
transparency. Also, the costs of private equity
funds and funds of private equity funds are
funds.
typically higher than other types of
Investment advisers or managers for those funds
often receive a management fee plus an incentive
fee or carried interest. Private equity funds and
funds of private equity fund are also generally
fees and
subject
portfolio company transaction fees. Because of
the existence of a carried interest, fund managers
may be motivated to make riskier investments
that have the potential for significant growth in
value. Investments in private equity funds and
funds of private equity funds also have reduced
investments.
liquidity
to
Investors
receive
to
should not
distributions from a fund for a number of years.
Private equity investing is very risky. Many
investments made in portfolio companies are not
profitable. In addition, investments made by
private equity funds and funds of private equity
funds may be concentrated in one or more
economic
industries or sectors, geographic
regions, stages of development or operation, or
sizes of companies. Investing in private equity
funds and funds of private equity funds involves
other special risks, including, but not limited to,
dependence upon key personnel and conflicts of
interest risks. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, and emerging market risk.
Private equity funds and funds of private equity
funds are complex
that have
significant, special risks. As a result, they may not
be suitable for some clients. Clients investing in
private equity funds and funds of private equity
funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
funds
involves special
below investment grade or “junk” bonds. Trading
markets for the investments held by those funds
are also limited and their investments may be
illiquid. Oftentimes, the interest rate paid by the
companies is determined by a reference interest
rate, such as the federal funds rate, which is
periodically reset. These types of investments are
sometimes referred to as floating rate corporate
debt, floating rate loans or floating rate bank
loans. Private debt
funds usually have an
investment objective or strategy that may focus
on companies
industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
and sizes, including focusing investments on
smaller capitalization, distressed or bankrupt
companies. Private debt funds commonly use
borrowings or leverage to make investments.
Funds of private debt funds typically invest
substantially all of their assets in other private
debt funds. Private debt funds and funds of
tax
private
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
debt funds and funds of private debt funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private debt funds and funds of private debt funds
are typically higher than other types of funds.
Investment advisers or managers for those funds
fee plus a
often
performance fee. Private debt funds and funds of
private debt fund are also generally subject to
operational expenses and
fees.
Because of the existence of a performance fee,
fund managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Investments in private debt
funds and funds of private debt funds also have
reduced liquidity compared to other investments.
Investors
receive
distributions from a fund for a number of years.
Private debt investing is very risky. Investments
made by private debt funds and funds of private
debt funds may be concentrated in one or more
economic
industries or sectors, geographic
regions, stages of development or operation, or
sizes. Investing in private debt funds and funds of
private debt
risks,
including, but not limited to, dependence upon
key personnel, conflicts of interest risks, market
risk, management and securities selection risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
issuer and
investment style
risk,
foreign
Private Debt Funds (or Private Credit Funds)
and Funds of Private Debt Funds Risks.
Private debt funds (also known as private credit
funds) are pools of actively managed capital that
invest primarily in loans or debt instruments
issued by companies in private transactions.
Sometimes, repayment of the loan is secured by
assets of the companies obtaining the loans.
However, the companies often have low or no
credit ratings. Thus, investments held by private
debt funds generally are subject the same risks as
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
fund
risks, currency
risk, growth
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
investment
risks and
leveraging risks. Private debt funds and funds of
private debt funds are complex investments that
have significant, special risks. As a result, they
may not be suitable for some clients. Clients
investing in private debt funds and funds of
private debt funds should have a high tolerance
for risk, including the willingness and ability to
accept lack of liquidity and potential loss of their
investment.
risk, credit
risk,
foreign
deteriorating economic conditions in those areas.
Investing in REITs involves other special risks,
including, but not limited to, real estate portfolio
(including development, environmental,
risk
competition, occupancy and maintenance risk),
liquidity risk, leverage risk, distribution risk,
risk,
capital markets access
counterparty risk, conflicts of
interest risk,
risk, and
dependence upon key personnel
regulatory risk. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, interest
rate
issuer and
investment risk, and emerging market risk. REITs
involve significant, special risks and may not be
suitable for some clients. Clients investing in
REITs should have a high tolerance for risk,
including the willingness and ability to accept
significant price volatility and volatility of regular
distribution amounts, potential lack of liquidity
and potential loss of their investment.
warehouses,
investments. Some may
in properties
industries,
involved
located
improved management
real estate
funds
typically
in which
they are
Real Estate Investment Trusts (“REITs”) and
Private REIT Risks. A REIT is a corporation,
trust or association that owns and typically
operates income-producing real estate or real
estate-related assets. The income-producing real
estate assets owned by a REIT may include office
buildings, shopping malls, multi-family housing,
student housing, hotels, resorts, hospitals and
health care facilities, self-storage facilities, data
centers,
telecommunications
facilities, and mortgages or loans. Many REITs are
registered with the SEC and their common stock
and preferred stock are publicly traded on a stock
exchange. These are known as publicly-traded
REITs. Others may be registered with the SEC but
are not publicly traded. These are known as
private REITs (also known as non-traded or non-
exchange traded REITs). There is no public
trading market for private REITs and the sole
method for disposing of the shares may be limited
to a periodic offer to redeem the shares by the
issuer, if the issuer offers a redemption program.
Private REITs are generally subject to limited
regulation and offer
limited disclosure and
transparency. The shareholders of a REIT are
responsible for paying taxes on the dividends that
they receive and on any capital gains associated
with their investment in the REIT. Dividends paid
by REITs generally are treated as ordinary income
and are not entitled to the reduced tax rates on
other types of corporate dividends. Prices of REIT
securities and trading volumes may be more
volatile that other investments. Many REITs focus
on a particular sector of the real estate market,
such as apartments, student housing, hotels and
hospitality, health care, office buildings, shopping
malls, warehouses, self-storage facilities and the
like. Those REITs are subject to risks associated
with sectors
focused.
Additionally, many REITs may own properties that
are concentrated in a particular geographic region
or regions, which subject them to the risk of
Private Real Estate Funds and Private Real
Estate Fund of Funds. Private real estate funds
are pools of actively managed capital that directly
invest primarily in investments in real estate and
real estate-related
investments. Private real
estate funds may invest in any number of types of
real estate, such as office, apartment, retail,
lodging, industrial and other real estate and real
focus
estate-related
in certain
investment
sectors or
certain
in
geographic regions or that have certain sizes of
operations or investment requirements. Some
may focus investment on properties the manager
or
sponsor believes are undervalued or
undercapitalized or that require repositioning,
or
redevelopment,
additional capital to reach their full value. Private
real estate funds commonly use borrowings or
leverage to make investments. Trading markets
for investments held by those funds are limited
and their investments may be illiquid. Funds of
private
invest
substantially all of their assets in other private
real estate funds. Private real estate funds and
funds of private real estate funds have unique tax
characteristics. A client should consult with a tax
advisor before investing in those funds. Private
real estate funds and funds of private real estate
funds are subject to limited regulation and offer
limited disclosure and transparency. Also, the
costs of private real estate funds and funds of
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
for those
for those
fees and
should not
expect
to
investing
for
significant growth
reduced
liquidity compared
investments made
by
industries or
risks may
fund
risks, currency
securities
include: market
selection
risk,
foreign
infrastructure
funds
are
private real estate funds are typically higher than
other types of funds. Investment advisers or
managers
funds often receive a
management fee plus a performance fee. Private
real estate funds and funds of private real estate
fund are also generally subject to operational
expenses and transaction fees. Because of the
existence of a performance fee, fund managers
may be motivated to make riskier investments
that have the potential for significant growth in
value. Investments in private real estate funds
and funds of private real estate funds also have
reduced liquidity compared to other investments.
Investors
receive
distributions from a fund for a number of years.
Private real estate
is very risky.
Investments made by private real estate funds
and funds of private real estate funds may be
concentrated in properties involved in one or
more economic industries or sectors, geographic
regions, stages of development or operation, or
sizes. Investing in private real estate funds and
funds of private real estate funds involves special
risks, including, but not limited to, dependence
upon key personnel, conflicts of interest risks,
market risk, management and securities selection
risk, investment objective and asset allocation
risk, interest rate risk, credit risk, capitalization
risk, investment style risk, foreign issuer and
investment risk, emerging market risk, illiquid
securities and liquidity risks, concentration risks,
investment
risks and
leveraging risks. Private real estate funds and
funds of private real estate funds are complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in private real estate
funds and funds of private real estate funds
should have a high tolerance for risk, including
the willingness and ability to accept lack of
liquidity and potential loss of their investment.
and sizes of investments. Private infrastructure
funds have unique tax characteristics. A client
should consult with a tax advisor before investing
in those funds. Private infrastructure funds are
subject to limited regulation and offer limited
disclosure and transparency. Also, the costs of
private infrastructure funds are typically higher
than other types of funds. Investment advisers or
funds often receive a
managers
management fee plus an incentive fee. Private
infrastructure funds are also generally subject to
administrative service
investment
transaction fees. Because of the existence of
incentive fees, fund managers may be motivated
investments that have the
to make riskier
potential
in value.
Investments in private infrastructure funds also
to other
have
investments. Investors should not expect to
receive distributions from a fund for a number of
years. Private infrastructure investing is very
risky. Many investments are not profitable. In
addition,
private
infrastructure funds may be concentrated in one
or more economic
sectors,
geographic regions, stages of development or
operation, or sizes of companies. Investing in
private infrastructure funds involves other special
risks, including, but not limited to, dependence
upon key personnel and conflicts of interest risks.
risk,
Other
management and
risk,
investment objective and asset allocation risk,
interest rate risk, credit risk, capitalization risk,
investment style
issuer and
investment risk, and emerging market risk.
Private
complex
investments that have significant, special risks. As
a result, they may not be suitable for some
clients. Clients investing in private infrastructure
funds should have a high tolerance for risk,
including the willingness and ability to accept lack
of liquidity and potential loss of their investment.
telecommunication,
Private
utilities,
infrastructure
Private Infrastructure Funds Risks. Private
infrastructure funds are pools of actively managed
capital that invest primarily in infrastructure
projects and assets and may involve exposure to
a
range of economic or market sectors,
geographic locations and asset types. Examples of
infrastructure investments may include, among
and
others,
transportation.
funds
usually have an investment objective or strategy
that may focus on certain sectors, industries,
geographic regions, size ranges or stages of
development or operations, or on certain types
Exchange Traded Notes Risks. An ETN is a
type of debt security that trades on an exchange
and provides a return linked to the performance
of an underlying benchmark. The underlying
benchmark can be a particular security, bond,
commodity, currency, or other Non-Traditional
Asset type, a group or basket of companies,
securities, commodities, currencies, derivative
instruments, Non-Traditional Asset investments or
other assets, or an index or other benchmark
linked to stocks, market volatility, bonds, interest
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
throughout
in managed
currencies,
Assets,
leverage,
(such as metals, agricultural products, and energy
products), currencies, interest rates, and indices.
Managed futures often obtain this exposure
through derivative instruments, which may be
traded on U.S. or foreign exchanges or markets.
Managed futures often employ computerized,
systematic and often proprietary trading models
and systems. Investing
futures
involves special risks, including, but not limited
to, liquidity risks and risks associated with
and other Non-
commodities,
Traditional
derivative
instruments and Complex Strategies. Other risks
may include: market risk, management and
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk,
foreign issuer and investment risk, and emerging
market risk. Managed futures can be speculative
investments because of the types of investments
they make and they involve significant, special
risks. As a result, they may not be suitable for
some clients. Clients investing in these funds
should have a high tolerance for risk, including
the willingness and ability to accept significant
price volatility, potential lack of liquidity and
potential loss of their investment.
credit
capitalization
risk,
foreign
rates, Treasury yields, yield curves and spreads,
derivative instruments, strategies, commodities,
currencies or other assets. ETNs trade on
the day at prices
exchanges
determined by the market. Unlike ETFs, issuers of
ETNs do not buy or hold assets to replicate or
approximate the performance of the underlying
benchmark. Also in contrast to ETFs, ETNs also do
not calculate their net asset value, are generally
not redeemable on a daily basis, and are not
registered under the Investment Company Act of
1940. Issuers may also have the right and option
to redeem ETNs. Redemptions are made at the
ETN’s “indicative value” or “closing indicative
value”. An ETN's closing indicative value is
computed by the issuer and is distinct from an
ETN's market price, which is the price at which an
ETN trades in the secondary market. Issuers of
ETNs may also issue and redeem notes as a
means to keep the ETN’s market price in line with
its indicative value, which have caused significant
fluctuations in ETN prices. Investing in ETNs
involves special risks, including, but not limited
to, risks associated with Non-Traditional Assets
and derivative instruments and the risk that the
actual market price for an ETN may vary
significantly from the indicative value computed
by the issuer. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate
risk,
risk,
risk,
investment style
issuer and
investment risk, and emerging market risk. ETNs
are complex investments and involve significant,
special risks. As a result, ETNs may not be
suitable for some clients.
inverse
pools
(typically
structured
Managed Futures Risks. Managed futures are
commodity
as
investment partnerships) managed by a futures
trading adviser that trade speculatively in various
derivative instruments and other investments.
There are significantly higher fees and expenses
associated with investments in managed futures
than other types of funds. Sponsors or managers
for these pools often receive a management fee
plus incentive or performance-based fee. Because
of the existence of a performance-based fee,
managers may be motivated to make riskier
investments that have the potential for significant
growth in value. Managed futures may seek
exposure to different asset classes, such as equity
securities, fixed income securities, commodities
Leveraged Fund and Inverse Fund Risks.
Leveraged funds and inverse funds may be
structured as ETNs, ETFs or open-end mutual
funds. Leveraged funds seek to deliver multiples
of the performance of the index or benchmark
they track. Inverse funds seek to deliver the
opposite of the performance of the index or
benchmark they track. Leveraged inverse funds
seek to achieve a return that is a multiple of the
inverse performance of the underlying index. Most
funds “reset” daily,
leveraged and
meaning that they are designed to achieve their
stated objectives on a daily basis. Because of the
effects of compounding, volatility and the fund
expenses, the returns of a leveraged or inverse
fund over longer periods of time can differ
significantly from the performance (or inverse of
the performance) of their underlying index or
benchmark during the same period of time. To
achieve their objectives, leveraged and inverse
funds typically employ aggressive investment
techniques, such as the use of leverage, short
sales, swap contracts, futures, options and other
derivative instruments. Investing in leveraged
funds and inverse funds involves special risks,
including, but not limited to, risks associated with
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those
funds and they
Non-Traditional Assets, short sales, leverage, and
derivative instruments. Other risks may include:
market risk, management and securities selection
risk, investment objective and asset allocation
risk, stock market risk, equity securities risk,
common stock risk, fixed income securities risk,
interest rate risk, credit risk, foreign issuer and
investment risk, and emerging market risk.
Leveraged funds and inverse funds are complex
investments that have an increased risk of loss
compared to other
involve
significant, special risks. As a result, they may not
be suitable for some clients. A client should not
invest in these securities unless the client is
prepared to experience significant losses in the
value of the client’s Account.
risk, capital markets access
Investing
risks may
securities
include: market
selection
or leverage to make investments in portfolio
companies. Adverse interest rate movements can
negatively
impact a BDC’s ability to make
investments. Investments made by BDCs are
typically illiquid, and valuing such investments is
challenging. It is possible that valuations on
investments used are materially different from the
values that BDCs will ultimately receive upon
investments. Changing
disposition of
market and economic conditions affecting a BDC’s
investments may cause significant volatility in the
BDC’s net asset value and stock price. Due to the
nature of BDCs’ investments, securities issued by
BDCs are subject to greater liquidity risk than
other investments. A debt security or preferred
stock issued by a BDC, in many cases, is non-
rated or is rated below investment grade, which
can carry its own risks. Investing in BDCs involves
other special risks, including, but not limited to,
portfolio company credit and investment risk,
risk,
leverage
risk, and
dependence upon key personnel
regulatory risk. Other risks may include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, and
interest rate risk. BDCs can be speculative
investments because of the types of investments
they make and involve significant, special risks.
As a result, BDC investments may not be suitable
for some clients. Clients investing in BDCs should
have a high tolerance for risk, including the
willingness and ability to accept significant price
volatility, potential lack of liquidity and potential
loss of their investment.
risk, credit
risk,
risk,
foreign
emerging market
Structured Products Risks. Structured products
are a hybrid between two asset classes (typically
issued in the form of a CD or note) but instead of
having a pre-determined rate of interest, the
return is linked to the performance of an
underlying asset class, such as single security or
basket or index of securities; a commodity or
basket or index of commodities, including futures;
and a foreign currency or basket of foreign
in structured products
currencies.
involves special risks, including, but not limited
to, risks associated with derivative instruments.
risk,
Other
risk,
management and
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, fixed income securities risk, interest
rate
issuer and
risk,
investment
commodities risk and currency risk. Structured
products are complex investments and involve
special risks. As a result, they may not be suitable
for some clients.
is
Master Limited Partnership Risks. An MLP is a
form of publicly-traded partnership that is taxed
tax
as a partnership. MLPs have unique
characteristics. A client should consult with a tax
advisor before investing in MLPs. An MLP must
generally earn at least 90% of its income from
certain qualifying sources, which includes income
and gains from certain activities involving natural
resources such as oil, natural gas, natural gas
liquids, refined petroleum products, coal, carbon
dioxide and biofuels. An MLP
is generally
structured as a limited partnership or limited
liability company and managed and operated by a
general partner or manager. Owners of an MLP
are called “limited partners” or “unit holders”.
Unit holders own interests or units in the MLP
(“units”) that are traded on a stock exchange.
MLPs make distributions to unit holders of their
Business Development Company Risks. A
BDC
closed-end
typically a domestic,
investment company that is operated for the
purpose of making equity and debt investments in
small and developing businesses, as well as
financially troubled businesses. As a result,
investments made by BDCs tend to be risky and
speculative. Investment advisers or managers for
BDCs often receive a management fee plus
incentive or performance-based fee. Because of
the existence of a performance-based
fee,
managers may be motivated to make riskier
investments that have the potential for significant
growth in value. BDCs commonly use borrowings
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risk,
common
stock
to other primary
risks,
risks,
foreign
including, but not
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities
risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, emerging market risks, fixed
income security risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
available cash flows. Many MLPs focus on a
particular sector or industry. Those MLPs are
subject to risks associated with sectors or
industries in which they are focused. The value of
an investment in an MLP and the amount of
distributions it makes may depend on the prices
of the underlying commodity, such as oil or
natural gas. Many MLPs are sensitive to changes
in the prevailing level of commodity prices. MLPs
have also shown sensitivity to interest rate
movements. Investing in MLPs involves other
special risks,
limited to,
macroeconomic risk, interest rate risk, liquidity
risk, operating risk, capital markets access risk,
growth risk, distribution risk, conflicts of interest
risk, and regulatory risk. MLPs are complex
investments that have significant, special risks. As
a result, MLPs may not be suitable for some
clients. Clients investing in MLPs should have a
high tolerance for risk, including the willingness
and ability to accept potential lack of liquidity and
potential loss of their investment.
information
about
upon
Portfolio’s
Additional
certain
Complex Investment Products and other
investments pursuing Complex Strategies,
including the risks associated with those
investments, is available on Baird’s website
at bairdwealth.com/retailinvestor and on
FINRA’s website
at www.finra.org/
Investors. A client is encouraged to read the
disclosure documents
included on those
websites carefully before investing.
foreign
issuer and
investment
Risks Associated with Certain Investment
Objectives and Asset Allocation Strategies
the headings
Capital Growth Portfolio. A Capital Growth
Portfolio will generally be invested in a manner
that seeks to provide growth of capital. Capital
Growth Portfolios have historically experienced
moderately high fluctuations in annual returns
and overall market value, typically as a result of
changes to market and economic conditions. The
Portfolio’s investments are subject to a risk of
price declines, especially during periods when
stock markets in general are declining. A Capital
Growth Portfolio’s primary risks generally include:
market risk, management and securities selection
risk, investment objective and asset allocation
risk, stock market risk, equity securities risk,
common stock risk, and capitalization risks.
Depending
specific
the
investments, the Portfolio may also be subject to
other primary risks, including investment style
risks,
risks,
emerging market risks, fixed income securities
risk, interest rate risk, credit risk, asset-backed
securities risks, below investment grade (high
yield or “junk” bonds) securities risks, and the
risks described under
“Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
Each Account is subject to the risks associated
with the investments in the Account. Generally,
an Account will be subject to the risks associated
with the portfolio listed below that corresponds to
the investment objective of the Account or the
asset allocation strategy pursued by the Account.
All Growth Portfolio. An All Growth Portfolio will
generally be invested in a manner that seeks to
provide growth of capital. All Growth Portfolios
have historically experienced high fluctuations in
annual returns and overall market value, typically
as a result of changes to market and economic
conditions. The Portfolio’s investments are subject
to a high risk of price declines, especially during
periods when stock markets in general are
declining. An All Growth Portfolio’s primary risks
generally include: market risk, management and
Growth with Income Portfolio. A Growth with
Income Portfolio will generally be invested in a
manner that seeks to provide moderate growth of
capital and some current income. Growth with
Income Portfolios have historically experienced
moderate fluctuations in annual returns and
overall market value, typically as a result of
changes to market and economic conditions and
interest rates. The Portfolio’s investments are
subject to a risk of price declines, especially
during periods when stock markets in general are
declining or when interest rates are rising. A
Growth with Income Portfolio’s primary risks
generally include: market risk, management and
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to other primary
risks,
risks,
foreign
to other primary
risks,
risks,
foreign
securities selection risk, investment objective and
asset allocation risk, stock market risk, equity
securities risk, common stock risk, fixed income
securities risk, interest rate risk, credit risk, and
capitalization risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
subject
including
investment style
issuer and
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
especially during periods when interest rates are
rising. A Conservative Income Portfolio’s primary
risks generally include: market risk, management
and securities selection risk, investment objective
and asset allocation risk, fixed income securities
risk, interest rate risk, credit risk, money market
fund risk, equity securities risk, and common
stock risks. Depending upon the Portfolio’s
specific investments, the Portfolio may also be
including
subject
investment style
issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
income. Relative
to
interest
rates are
fixed
risks,
foreign
Capital Preservation Portfolio. A Capital
Preservation Portfolio will generally be invested in
a manner that seeks to preserve capital while
generating current
the
portfolios described above, Capital Preservation
Portfolios have historically experienced smaller
fluctuations in annual returns and overall market
value as a result of changes in stock market
conditions, but have experienced fluctuations in
relation to changes in interest rates and economic
conditions. The Portfolio’s investments are subject
to risk of price declines, especially during periods
when
rising. A Capital
Preservation Portfolio’s primary risks generally
include: market risk, management and securities
selection risk, investment objective and asset
allocation risk,
income securities risk,
interest rate risk, credit risk, and money market
fund risk. Depending upon the Portfolio’s specific
investments, the Portfolio may also be subject to
other primary risks, including foreign issuer and
investment risks, asset-backed securities risks,
and below investment grade (high yield or “junk”
bonds) securities risks.
Income with Growth Portfolio. An Income with
Growth Portfolio will generally be invested in a
manner that seeks to provide current income and
some growth of capital. Income with Growth
Portfolios have historically experienced moderate
fluctuations in annual returns and overall market
value, typically as a result of changes to interest
rates and market and economic conditions. The
Portfolio’s investments are subject to a risk of
price declines, especially during periods when
interest rates are rising or when stock markets in
general are declining. An Income with Growth
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
fixed income securities risk, interest rate risk,
credit risk, money market fund risk, stock market
risk, equity securities risk, common stock risk,
and capitalization risks. Depending upon the
Portfolio’s specific investments, the Portfolio may
also be subject to other primary risks, including
investment style
issuer and
investment risks, emerging market risks, asset-
backed securities risks, below investment grade
(high yield or “junk” bonds) securities risks, and
the risks described under the headings “Non-
Traditional Assets and Complex Strategies Risks”
and “Complex Investment Product Risks” above.
to
to
perception
take advantage of
of market
economic
The
Conservative Income Portfolio. A Conservative
Income Portfolio will generally be invested in a
manner that seeks to provide current income.
Relative
the portfolios described above,
Conservative Income Portfolios have historically
experienced smaller fluctuations in annual returns
and overall market value as a result of changes in
stock market conditions, but have experienced
fluctuations in relation to changes in interest rates
Portfolio’s
conditions.
and
investments are subject to risk of price declines,
Opportunistic Portfolio. An Opportunistic
Portfolio will generally be invested in a manner
that seeks to provide long term growth through
capital appreciation and/or income by utilizing an
active management style that shifts the amount
of investment made in different asset classes and
market sectors
the
manager’s
pricing
anomalies, those market or industry sectors
deemed favorable for investment by the manager,
the current interest rate environment and/or
other macro-economic trends identified by the
manager to achieve growth while accounting for a
client’s specific short, intermediate and long term
investment and/or cash flow needs. Depending
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the
recommended
investment
Portfolios
have
that generally do not meet
the
investments made,
less
if an Available
Product
experiences
organizational,
is a higher risk
that
fixed
income
security
Product
that
experiences
investment strategy used, some
upon
Opportunistic
historically
experienced high fluctuations in annual returns
and overall market value, typically as a result of
changes to market and economic conditions.
Depending upon the investment strategy used
and
the Portfolio’s
investments may be subject to a high risk of price
declines, especially during periods when stock
markets in general are declining. An Opportunistic
Portfolio’s primary risks generally include: market
risk, management and securities selection risk,
investment objective and asset allocation risk,
stock market risk, equity securities risk, common
stock risk, and capitalization risks. Depending
upon the Portfolio’s specific investments, the
Portfolio may also be subject to other primary
risks, including investment style risks, foreign
issuer and investment risks, emerging market
risks,
risks, below
investment grade (high yield or “junk” bonds)
securities risks, and the risks described under the
headings “Non-Traditional Assets and Complex
Strategies Risks” and “Complex
Investment
Product Risks” above.
the
list of
Baird
products.
Available Investment Products are investment
products
the
qualifications and standards that Baird establishes
for its recommended product lists. As a result,
there is a higher likelihood that some Available
Investment Products will have poor performance
and will significantly underperform compared to
an applicable benchmark index or peer group.
Available Investment Products are also subject to
significantly
review by Baird
rigorous
compared to recommended investment products.
Investment Product
Thus,
experiences significant performance problems or
if the manager or sponsor of an Available
significant
Investment
management,
operational,
compliance, legal, regulatory or other problems,
there
the Available
Investment Product will be made available (and
will continue to be made available) to clients by
Baird. An investment by a client in an Available
Investment
the
occurrence of any such event could negatively
impact the client’s Account. Available Investment
Products should only be used by a client if the
client wishes to take more responsibility for
monitoring and managing the assets in the
client’s Account,
recommended
products does not contain an investment product
that meets the client’s particular needs, and the
client understands the risks of doing so.
Recent Events
priorities,
changes
in
Global
financial markets have continued to
experience periods of elevated volatility, driven by
a combination of economic, political, and broader
macroeconomic developments. Conditions across
major economies have been influenced by shifting
geopolitical
policy
relationships, and evolving investor expectations.
Additional Considerations. A client should note
that an Account pursuing a particular investment
objective or asset allocation strategy will from
time to time be subject to actual risks that are
higher or lower than, or different from, the risks
described above under certain circumstances. See
“Investment Strategies—Important Information
about Implementation of Investment Objectives
and Investment Strategies” above for more
information. In addition to the specific risks
described above, a client’s Account may be
subject to additional risks, depending upon the
particular investments in the client’s Account. A
client should discuss the risks of particular
investments with the client’s DDK Consultant. A
client should also note that there is no guarantee
as to how an Account will perform in the future. It
is possible that an Account could experience more
dramatic return or market value fluctuations than
occurred in the past.
Available Investment Product Risks
The use of Available Investment Products,
including SMA Strategies made available under
the BSN and DC Programs, and including UAS
Available SMA Strategies and UAS Available Funds
made available under the UAS Program, are
subject to additional risks compared to the use of
Within the United States, the current U.S.
administration has demonstrated
intent on
implementing policy changes through executive
orders and legislation, contributing to a less
certain policy environment. Potential adjustments
to federal programs, regulatory initiatives, and
legislative priorities create additional factors for
markets to assess, which may cause meaningful
inflation reduction
market uncertainty. While
remains a central
for policymakers,
focus
achieving the U.S. Federal Reserve Board’s long
term inflation target of 2% continues to prove
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upon the client’s request, provide advice on proxy
voting or what other action the client could take.
UMA Programs
challenging. Although annual price increases have
generally moderated, the price of many goods
and services remains elevated compared to levels
from a few years ago. Leadership changes at the
Federal Reserve and political divisions and discord
add further uncertainty to the economic outlook.
Under the ALIGN UMA Select Portfolios and UAS
Portfolios Programs, a client may retain the right
to vote proxies with respect to the securities held
in the client’s Account, or the client may delegate
such right to the Overlay Manager. A client may
select either option by making the appropriate
election in the client’s advisory agreement. For
information about the Overlay Manager’s voting
policies and procedures, clients should review the
Overlay Manager’s Form ADV Part 2A Brochure.
Separately Managed Accounts
Internationally, geopolitical risks have increased
as the U.S. and Israel are engaged in a military
conflict with Iran. The conflict has disrupted
global trade and caused an increase in the price
of oil. The continuation or escalation of military
strikes could lead to a lengthy period of military
conflict, and Iran’s military attacks and other
hostile actions against other countries present a
risk of widening the conflict. In addition, the war
between Ukraine and Russia is now passing its
fourth anniversary, instability in parts of the
Middle East persist, and relations between the
U.S. and other countries are strained.
Rapid advancements in artificial intelligence (AI)
and automation are increasingly influencing global
economic trends, corporate decision making, and
financial market dynamics. Expanding investment
in these technologies is contributing to shifts in
how industries operate, compete, and allocate
resources. The fast pace of technological change,
potential disruptions to existing business models,
and evolving regulatory responses
introduce
additional uncertainty and may contribute to
market volatility.
instances. For
Taken together, these developments may have a
significant negative impact upon global economic
conditions and contribute to a heightened risk
environment. As a result, fluctuations in asset
prices may increase, and such volatility could
adversely affect the value of a client’s Account .
Under the Baird Affiliated Managers Program, DDK
Recommended Managers Service, Baird SMA
Network Program, and Dual Contract Program, a
client may retain the right to vote proxies with
respect to the securities held in the client’s
Account, or, in most instances, the client may
delegate such right to the investment manager
selected to manage the client’s Account (which
may include Baird, the Overlay Manager or an
Implementation Manager). A client may select
either option by making the appropriate election
in the client’s advisory agreement (and in the
case of a dual contract arrangement under the
Dual Contract Program, by providing proper
instructions to the manager directly). Some
managers do not offer proxy voting services in
connection with certain strategies, such as option
strategies. Clients pursuing those strategies will
automatically retain the right to vote proxies in
those
information about a
manager’s voting policies and procedures, clients
should review the manager’s Form ADV Part 2A
Brochure.
Discretionary Services
Voting Client Securities
Baird Advisory Choice Program and Other
Non-Discretionary Accounts
Under the ALIGN Strategic Portfolios, BairdNext
Portfolios, DDK Investment Management, and
Russell Programs, a client may retain the right to
vote proxies with respect to the securities held in
the client’s Account, or a client may delegate such
right to Baird.
If a client retains proxy voting authority, Baird will
forward proxy materials that Baird actually
receives to the client. The client will then be
solely responsible for analyzing the materials and
casting the vote.
Under the Baird Advisory Choice Program and
with respect to any other Accounts over which the
client retains discretionary investment authority,
a client retains the right to vote proxies with
respect to the securities held in such Accounts.
Accordingly, the client is responsible for voting
proxies and otherwise addressing all matters
submitted for consideration by security holders,
and DDK and Baird are under no obligation to
take any action or render any advice regarding
such matters. The client’s DDK Consultant may,
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If a client delegates voting authority to Baird,
Baird will vote proxies solicited by, or with respect
to, securities held in the client’s Account for the
exclusive benefit of the client and in accordance
with policies and procedures adopted by Baird.
specific voting guidelines (e.g., Taft-Hartley
guidelines). For those matters for which the
independent proxy voting service does not
provide a specific voting recommendation, each
DDK Consultant or Baird portfolio manager will
cast the vote in a manner he or she believes is in
the best interest of clients. The votes cast for a
client’s Account may differ from those votes cast
for other Baird clients based on differing views of
DDK Consultants and other Baird portfolio
managers.
Baird has adopted written policies and procedures
that are reasonably designed to ensure that it
votes client securities in the best interests of
clients. Those procedures address material
conflicts of interest that may arise between
Baird’s interests and those of its clients. Although
a description of Baird’s proxy voting policies and
procedures is provided below, Baird will furnish a
copy of its proxy voting policies and procedures to
clients upon their request. Additionally, clients
may obtain information on how Baird actually
voted proxies with respect to the securities held in
their accounts by contacting their DDK Consultant
or by calling (414) 765-3500.
interests. Baird utilizes
governance
services,
Baird uses ISS’s electronic vote management
system to cast votes on behalf of clients. In
connection with Baird’s use of that system, ISS
pre-populates how client votes should be cast
based upon ISS’s voting recommendations. The
system allows Baird to change the pre-populated
vote (to the extent permitted by Baird’s proxy
voting policies) up until a certain time prior to the
applicable meeting (the “voting cut-off time”).
Baird’s proxy voting policies are designed to
address situations when additional information
becomes available after the votes are pre-
populated in the system and before the voting
cut-off time. However, there is no guarantee that
all information that could affect Baird’s proxy
voting decision will be received or considered by
Baird prior to a vote being cast.
voting
recommendations.
(or
responsible
interests of
In situations in which a client has delegated to
Baird voting authority with respect to securities in
the client’s Account, Baird will vote proxies in a
manner that Baird believes is consistent with the
client’s best
an
independent provider of proxy voting and
corporate
currently
Institutional Shareholder Services (“ISS”), to
analyze proxy materials and votes and make
ISS
independent
provides proxy voting guidelines regarding its
position on various matters presented by
companies to their shareholders for consideration.
Baird will typically vote shares in accordance with
the recommendations made by ISS. However,
ISS’s guidelines are not exhaustive, do not
address all potential voting issues, and do not
necessarily correspond with the opinions of DDK
Consultants or other Baird portfolio managers
managing a client’s Account. In the event the
client’s DDK Consultant or Baird portfolio manager
believes the ISS recommendation is not in the
best interest of the client, the DDK Consultant or
Baird portfolio manager, as applicable, will bring
the issue to Baird’s Proxy Voting Sub-Committee
through a proxy challenge process. The Sub-
Committee will
for
then be
determining how the vote will be cast. The
decision made by
the Proxy Voting Sub-
Committee on the proxy challenge applies to all
advisory accounts managed by
the DDK
Consultant or Baird portfolio manager (or team of
DDK Consultants or Baird portfolio managers),
unless the client has directed Baird to utilize
The proxy voting policies and procedures also
address instances in which Baird’s interests may
appear to conflict with client interests, such as
when Baird or an affiliate of Baird is managing or
administering
to manage or
seeking
administer) a corporate retirement, pension or
employee benefit plan or providing (or seeking to
provide) advisory or other services to a company
whose management is soliciting proxies. In such
instances, there may be a concern that Baird
would be inclined to vote in favor of management
because of Baird’s relationship or pursuit of a
relationship with the company. In situations
where there is a potential conflict of interest,
Proxy Voting Sub-Committee will
Baird’s
determine the nature and materiality of the
conflict. If the conflict is determined to not be
material, the Sub-Committee will vote the proxy
in a manner the Sub-Committee believes is in the
best
the client and without
consideration of any benefit to Baird or its
affiliates. If the potential conflict is determined to
be material, Baird’s Proxy Voting Sub-Committee
will take one of the following steps to address the
potential conflict: (1) cast the vote in accordance
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
authorized party) will need to provide voting
instructions to Baird. To the extent the client (or
other authorized party) does not provide timely
voting instructions, Baird will vote such securities
to the extent permitted by law and in compliance
with the rules of the New York Stock Exchange
and the SEC relating to such matters.
with the recommendations of ISS or other
independent third party; (2) refer the proxy to
the client or to a fiduciary of the client for voting
purposes; (3) suggest that the client engage
another party to determine how the proxy should
be voted; (4) if the matter is not addressed by
ISS, vote in accordance with management’s
recommendation; or (5) abstain from voting.
Legal Proceedings and Corporate Actions
Generally, none of DDK, Baird or any Other
Manager responsible for managing all or a portion
of the assets in a client’s Account will render
advice or take action on a client’s behalf with
respect to securities that are or were held in the
client’s Account, or the issuers thereof, which go
into default or become the subject of legal
proceedings, such as class action claims, defaults
or bankruptcies. Also, they may or may not vote
or advise clients on other corporate actions, like
tender offers, that are not solicited by a proxy
statement. At a client’s request, Baird will forward
information that Baird actually receives to the
client.
While Baird uses its best efforts to vote proxies,
there are instances when voting is not practical or
is not, in Baird’s or DDK Consultants’ view, in the
best interest of clients. For example, casting a
vote on a foreign security may involve additional
costs or may prevent, for a period of time, sales
of shares that have been voted. Also, when a
client has entered into a securities lending
program, Baird generally will not seek to recall
the securities on loan for the purpose of voting
the securities; however, Baird reserves the right
to recall the shares on loan on a best efforts basis
if the client’s DDK Consultant becomes aware of a
proxy proposal where the proxy vote is materially
important to the client’s Account.
In addition to the services described above, Baird
has engaged ISS for vote execution and record-
keeping services.
Other Proxy Voting Information
Clients wishing to direct particular votes once
they have granted Baird discretionary voting
authority may do so by contacting their DDK
Consultant. However, if Baird has been granted
discretionary voting authority, neither DDK nor
Baird will provide a client with notice that Baird
has received a proxy solicitation, nor will they
consult with the client before casting a vote,
unless the client otherwise directs them to do so.
Client Information Provided to
Portfolio Managers
Under the Baird Affiliated Managers Program, DDK
Recommended Managers Service, Baird SMA
Network Program, and Dual Contract Program,
and UMA Programs, DDK and Baird provide
information about the client to the
certain
investment managers managing
the client’s
Account (which may include the Overlay Manager
or an Implementation Manager) when the client
establishes the advisory relationship with such
managers. Such information includes the client’s
investment objectives and risk tolerance and tax
lot information for the applicable Account assets.
Under the DDK Recommended Managers Service,
DDK and Baird also provide to the investment
manager a client’s age, investment timeframe,
and liquidity requirements.
Except to the extent a client has delegated proxy
voting authority to Baird, DDK and Baird have no
authority, direct or implicit, and accept no
responsibility for taking any action or rendering
any advice with respect to the voting of proxies
related to securities held in a client’s Accounts.
Providing Baird Voting Instructions
Unless specifically requested to do so by a client,
DDK and Baird do not generally provide such
information about the client on an ongoing basis
to the investment manager managing the client’s
Account.
Baird also generally provides the following to the
client’s manager unless otherwise instructed by a
client: trade confirmations, account statements,
and access to client’s Account on Baird’s system.
As mentioned above, Baird may be the holder of
record for certain securities in a client’s Account.
If the client retains voting authority over such
securities (or delegates such authority to party
other than Baird), and a proxy is solicited with
respect to any such securities, the client (or other
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
their
Client Contact with Portfolio Managers
DDK and Baird do not place any restrictions upon
clients who wish to contact or consult with Other
accounts. DDK
Managers managing
encourages clients to discuss their accounts with
their DDK Consultant.
reimbursed the customer for the loss. The
findings also included that Baird 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.
Baird was censured and fined $200,000.
certain of
the
its
to adopt or
to
provide
designed
to Baird’s clients and
Additional Information
Disciplinary Information
In April 2016, Baird, without admitting or denying
the findings, consented to the sanctions and
findings of the Financial Industry Regulatory
Authority, Inc. (“FINRA”) that it violated NASD
Conduct Rule 3010, FINRA Rule 3110, and FINRA
Rule 2010, by failing to establish and maintain a
supervisory system and procedures reasonably
designed to ensure that customers who purchased
mutual fund shares received the benefit of
applicable sales charge waivers. In May 2015,
Baird began a review to determine whether Baird
had provided available sales charge waivers to
eligible customers. Based on this review, in May
2015, Baird self-reported to FINRA that various
eligible customers had not received available
sales charge waivers. Baird was found to have
retirement plan and
disadvantaged certain
charitable organization customers
that were
eligible to purchase Class A shares in certain
mutual funds without a front-end sales charge.
The findings also stated that these customers
were instead sold Class A shares with a front-end
sales charge or Class B or C shares with higher
ongoing fees and the potential application of a
contingent deferred sales charge. Baird was
censured and required to pay restitution to
affected customers estimated to be approximately
$2.1 million including interest.
supervisor within
In September 2016, the SEC announced that
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
subadvisors
participating in Baird’s wrap fee programs offered
Private Wealth Management
through
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
implement policies and
failed
specific
procedures
information
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. Baird also was ordered to cease
and desist committing or causing any violations
and any future violations of Section 206(4) of the
Advisers Act and Rule 206(4)-7 thereunder and
pay a civil money penalty in the amount of
$250,000.
In July 2016, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that the firm and a
its Private Wealth
firm
Management business did not
reasonably
supervise a former Financial Advisor who misused
a customer’s funds. The findings stated that the
supervisor did not reasonably follow-up on red
flags associated with a trade correction request
submitted by the Financial Advisor that should
have alerted him to the Financial Advisor's misuse
of a customer’s funds. The supervisor also did not
follow certain of Baird’s written supervisory
procedures (“WSPs”) relating to trade corrections.
After the supervisor realized that the Financial
Advisor misused the customer’s funds, Baird
In March 2019, Baird, without admitting or
denying the findings, consented to an order of the
SEC, which found that it violated Sections 206(2)
and 207 of
for making
the Advisers Act
inadequate disclosures to advisory clients about
mutual fund share classes. The order was part of
a voluntary self-reporting program initiated by the
SEC called the “Share Class Selection Disclosure
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Initiative.” Under
brokerage
customers
an
it charged
supervisory
system
firms bought
fees and/or
the conflict of
unfair
certain
commission when
its published
minimum commission amount of $100 on 7,277
retail equity trades and failed to establish and
maintain a
reasonably
designed to prevent charging a customer a
commission that is unreasonable or unfair in
violation of FINRA Rules 3110, 2121, and 2010.
Baird also consented to a censure, a fine in the
amount of $150,000, and the payment of
restitution of $266,481 plus interest. The findings
related to FINRA’s routine examination of Baird in
2020. During that examination, Baird modified its
minimum commission schedule and supervisory
procedures. Baird also took steps to make
payments to the affected customers, which on
average amounted 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. The brokerage customers identified by
FINRA did not include any DDK client and no DDK
client was alleged to have been charged an unfair
commission.
its
the program,
(or SCSD)
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 settlement terms imposed by the
SEC,
including returning money to affected
investment advisory clients. The central issue
identified by the SEC was that, in many cases,
investment advisory
for or
recommended to their investment advisory 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
advisory clients, and the investment advisory
firms did not adequately disclose their receipt of
interest
12b-1
associated with those 12b-1 paying share classes.
Baird and many other firms self-reported under
the program and entered
into substantially
identical orders. By self-reporting and consenting
to the order, Baird agreed to a censure and to
cease and desist from committing or causing any
violations and future violations of Sections 206(2)
and 207 of the Advisers Act. Baird also agreed to
establish a distribution fund and to deposit into
that fund the improperly disclosed 12b-1 fees
received by Baird plus prejudgment interest,
which will be paid to affected advisory clients.
More information about the order is contained in
Baird’s Form ADV, which is available on the SEC’s
Investment Advisory Public Disclosure website at
https://www.adviserinfo.sec.gov/IAPD/Default.as
px or in the SEC’s press release about the SCSD
Initiative at https://www.sec.gov/news/press-
release/2019-28.
other
reports about an
reports was engaged
to disclose
In June 2019, Baird, without admitting or denying
the findings, consented to the sanctions and to
the entry of findings of FINRA that between late
April 2013 and early July 2013 it published
research
issuer without
disclosing that the research analyst who authored
in employment
the
discussions with the issuer that constituted an
actual, material conflict of interest and that the
failure
research analyst’s
the
employment discussions with the issuer in the
research reports made those reports misleading.
Baird was censured and fined $150,000.
the
In September 2023, Baird entered into an Offer of
Settlement with the SEC, 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
business-related
associates’
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
text and
properly retaining business-related
instant messages
off-channel
and
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.
While Baird had policies and procedures in place
prohibiting such off-channel communications, 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
findings were
adviser businesses, and
reported to the SEC. Baird took steps prior to and
In August 2022, Baird, without admitting or
denying the findings, consented to the entry of
findings of FINRA, which found that it charged
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
have an application pending to register, as
registered representatives and associated persons
of Baird to the extent necessary or appropriate to
perform their job responsibilities.
communications. As part of
Certain Relationships and Arrangements
Baird and Associated Parties
including
for eligible
the
those
amount
the
training,
after the SEC’s review, including implementing a
new communication tool designed
for Baird
associates’ personal devices, conducting training,
and periodically requiring requisite associates to
provide an attestation relating to their business-
related
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,
surveillance program,
technology solutions and similar matters related
to off-channel communications.
timing
of
state
investment
Financial
Advisors
located
Baird PWM has relationships or arrangements with
other Baird businesses units and the Associated
Parties described below,
referral
programs that pay special compensation to DDK
referrals. Additional
Consultants
referral programs,
information about
including
referral
of
compensation, is disclosed on Baird’s website at
bairdwealth.com/retailinvestor.
These
relationships or arrangements present a conflict of
interest because they provide a financial incentive
to Baird and DDK Consultants to use, select or
recommend the investment products and services
of Baird and Associated Parties over those of
unassociated parties and those that pay the
greatest level of compensation. Baird addresses
this potential conflict through disclosure in this
Brochure. Further, when acting as fiduciaries,
Baird and DDK Consultants are required to select
or recommend investment products only when
they determine it to be in the client’s best interest
to do so.
In March 2026, Baird entered into an Offer of
Settlement with the Massachusetts Securities
Division to settle a regulatory matter relating to
the
adviser
representative registration approvals for two of
Baird’s
in
Massachusetts. The Division alleged that, for a
limited period in early 2025, the two individuals
provided investment advisory services before
their Massachusetts registrations were completed
as a form was missing from their application
materials. 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.
Additional information about Baird’s disciplinary
history is available on the SEC’s website at
www.adviserinfo.sec.gov.
Baird Asset Management
Baird’s Asset Management business, Baird
Advisors, Baird Equity Asset Management, and
Chautauqua Capital Management (“CCM”), part of
provide
Baird Equity Asset Management,
investment management services to institutional
clients and Funds. DDK Consultants who refer
clients to Baird Asset Management are eligible for
referral compensation to be paid by Baird. DDK
Consultants, therefore, have a financial incentive
to favor the services provided by Baird Asset
Management over
those provided by other
managers.
Other Financial Industry Activities and
Affiliations
Baird’s Broker-Dealer Activities
Baird Funds
including
Baird PWM offers brokerage accounts and related
services to its clients. Baird is also engaged in a
broad range of broker-dealer activities through
its Global
other business units,
Investment Banking, Fixed
Income Capital
Markets (including Baird Public Finance) and
Institutional Equities and Research Departments.
Certain DDK and Baird associates and certain
management persons of Baird are registered, or
Baird is the investment adviser and principal
underwriter for Baird Funds, Inc. (the “Baird
Funds”). Baird Advisors provides
investment
management, administrative, and other services
to certain Baird Funds investing primarily in fixed
income securities (the “Baird Bond Funds”). Baird
Equity Asset Management and CCM provide
investment management and other services to
certain Baird Funds investing primarily in equity
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
provides, and the success of its services generally
depends upon Baird’s ability to sell the securities
of such issuers. Baird may, therefore, have an
incentive to favor the securities of issuers for
which Baird provides such services over the
securities of issuers for which Baird does not
provide such services.
of
referral
securities (the “Baird Equity Funds”), and
Greenhouse Funds LLLP, a party related to Baird,
is the investment subadvisor to one of those
Funds, the Baird Equity Opportunity Fund. In
certain instances, DDK Consultants who refer
clients to the Baird Funds are eligible for referral
compensation to be paid by Baird. Due to the
amount
compensation, DDK
Consultants have a financial incentive to favor the
Baird Equity Funds over the Baird Bond Funds.
Baird Trust
engaging
Trust
for
Baird is affiliated, and may be deemed to be
under common control, with Baird Trust, a
Kentucky-chartered trust company, because both
entities are indirectly wholly owned by BFG. Baird
and DDK Consultants receive compensation from
Baird Trust for referring clients and providing
ongoing relationship management services to
clients
trust
Baird
administration services as described under the
heading “Services, Fees and Compensation—
Additional Service Information—Trust Services
Arrangements” above.
Baird Capital
A DDK Consultant who refers a client to Baird
Investment Banking for a possible transaction in
which Baird Investment Banking earns a financial
advisory or underwriting fee receives a portion of
such fee. A DDK Consultant who refers a client to
Baird Public Finance for a municipal advisory or
underwriting opportunity receives a portion of the
compensation earned by Baird Public Finance on
that opportunity. Baird and DDK Consultants thus
have an incentive to recommend the securities
issued in those offerings. A DDK Consultant who
refers a corporation
to Baird’s Institutional
Equities business for a stock buy-back program
receives a portion of the commissions earned by
Baird’s Institutional Equities business. Baird and
its DDK Consultants may, therefore, have an
incentive to buy, and to recommend that clients
sell, the securities of issuers that are part of
Baird’s buyback services.
Sagard
Baird is engaged in a global private equity
business through Baird Capital (“Baird Capital”).
Baird and DDK Consultants may refer clients to
Baird Capital. DDK Consultants who assist in
obtaining a client’s investment in a private equity
fund offered through Baird Capital are eligible for
referral compensation.
Baird has a financial incentive to the extent it
would recommend that a client invest in a
portfolio company owned by a Baird Capital
private equity fund. A list of the portfolio
companies held by Baird Capital private equity
funds is located on Baird Capital’s website located
at https://www.bairdcapital.com/portfolio/baird-
capital-portfolio.aspx.
additional
compensation
Baird Global Investment Banking
Baird Institutional Equities and Research
Baird Public Finance
Sagard-affiliated
its Global
information
Baird’s direct parent corporation, BFC, has a
minority ownership interest (about 5%) in Sagard
Holdings Management, Inc. (“Sagard”) and the
right to appoint a member to Sagard’s board of
directors, which
is currently a management
person of Baird. Baird has agreed to use best
efforts, to the extent consistent with its fiduciary
duties, best
interest obligations, and other
regulatory responsibilities, to offer to clients
investment products managed by affiliates of
Sagard. Baird has an incentive to do so because
not reaching minimum thresholds would give
Sagard a right to redeem BFC’s ownership
interest
in Sagard and reaching significant
thresholds would give BFC the right to increase its
ownership interest. DDK Consultants do not
receive
for
any
investment
recommending
products. Additional
identifying
investment products will be
Sagard-affiliated
provided to clients prior to investment.
municipal
advisory,
55ip
55I, LLC (d/b/a 55ip, “55ip”) uses research and
other services from Riverfront, an affiliate of
Through
Investment Banking,
Institutional Equities and Research, and Public
Finance Businesses, Baird provides investment
banking,
securities
underwriting, stock buyback and related services
to various corporate, municipal, and other issuers
of securities. Baird receives compensation from
such issuers in connection with the services it
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Baird, in the development of its portfolios under
the BSN Program, and Riverfront
receives
compensation from 55ip with respect to those
portfolios. Due to its affiliation with Riverfront,
Baird has a financial incentive to favor 55ip
portfolios that use Riverfront services.
Associated Investment Products and
Services
incentive
to
favor
the
Baird and DDK Consultants may select or
recommend Associated Investment Products and
Services, including the Associated Funds and
Associated SMA Strategies, listed in Appendix A to
this Brochure.
through disclosure
in
Baird and DDK Consultants have a financial
incentive to use, select or recommend Associated
Investment Products and Services because Baird
and BFG benefit financially if a client utilizes those
investment products and services rather than
unassociated investment products and services,
and DDK Consultants benefit financially from the
overall success of Baird and BFG. Similarly, Baird
and DDK Consultants also generally have a
financial
investment
products and services of Baird over Associated
Parties and to favor those of Associated Parties in
which BFG has a materially greater indirect
ownership interest over those of Associated
Parties in which BFG has a materially lesser
indirect ownership interest. Baird addresses this
potential conflict
this
Brochure. Further, when acting as fiduciaries,
Baird and its DDK Consultants are required to
select or recommend investment products only
when they determine it to be in the client’s best
interest to do so. The criteria used by them in
deciding to select or recommend Associated
Investment Products are generally the same as
those used for unassociated investment products.
However, a client should note that certain
Services and certain categories of investment
products only offer investment products and
services of Associated Parties. In those cases,
Baird and DDK Consultants do not impose the
same criteria or level of review.
Relationships and Arrangements with
Investment Managers
managers,
including
Certain Associated Parties are associated with
Baird because BFC, Baird’s parent corporation,
owns some or all of the Associated Parties’ voting
securities. BFC’s parent corporation (and Baird’s
ultimate parent corporation), BFG, may be
deemed to indirectly own or control such voting
securities. Baird is deemed to be under common
control and “affiliated” with an Associated Party
when BFG indirectly owns or controls 25% or
more of such Associated Party’s voting securities
to control such
(or of an entity deemed
Associated Party). Baird considers itself “related”
to an Associated Party when BFG indirectly owns
or controls at least 10% but less than 25% of
such Associated Party’s voting securities (or of an
entity deemed to control such Associated Party).
Baird considers
itself “associated” with an
Associated Party when certain other relationships
or other arrangements exist between Baird and
such Associated Party that might present a
conflict of interest with clients.
An Associated Party receives fees or other
compensation for investment advisory or other
services that it provides to an Associated Fund.
The amount of fees and other compensation paid
by an Associated Fund to an Associated Party is
disclosed in the Associated Fund’s prospectus or
other offering document. An Associated Party also
receives fees from a client for services that it
provides related to the client’s Associated SMA
Strategy. Information about the amount of fees
paid to an Associated Party with respect to an
SMA Strategy is contained in the applicable Baird
Form ADV Part 2A Brochure, the applicable
Program Account Schedule, or in some instances,
the client’s contract with the Associated Party.
Investment
those
participating in the Services, may select Baird, in
its capacity as a broker-dealer, to execute
portfolio trades for their clients, including for
Funds they advise and in which Baird clients
invest. Investment managers may also select
Baird to provide custody, research or other
services. Baird receives compensation for those
services. This may create an incentive for Baird to
favor the investment products and services of
such investment managers. However, Baird is a
fiduciary that is required to act in the best
interest of advisory clients when selecting or
recommending investment managers or their
investment products and services to such clients.
Baird addresses this potential conflict through
disclosure in this Brochure. Baird does not
consider the extent to which an investment
manager directs or is expected to direct trading,
custody or research services to Baird when
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800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
considering
investment
the eligibility of an
manager or its investment products or services
for the Services.
activities of Baird’s advisory clients. In addition,
Baird’s Compliance Department monitors the
personal trading activities of all of Baird’s
associates providing advisory-related services to
clients.
Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
Code of Ethics
Participation or Interest in Client
Transactions
Investment Advisory Accounts
incentive
to recommend an
Subject to the restrictions described below, Baird
and its affiliates and associates may engage in
securities transactions for their own accounts,
including the same or related securities that are
recommended to or owned by Baird clients. These
transactions may include trading in securities in a
manner that differs from, or is inconsistent with,
the advice given to Baird clients, and the
transactions may occur at or about the same time
that such securities are recommended to or are
purchased or sold for client accounts. This creates
a potential for a conflict between the interest of
clients and the interests of Baird and its affiliates
and associates.
Asset-based Advisory Fee arrangements create an
incentive for Baird and DDK Consultants to set the
applicable fee rate at a high level and to
encourage clients to add more money into their
accounts. Baird and DDK Consultants also have
an
investment
advisory account to a client rather than a
brokerage account if the client has, or is expected
to have, lower levels of trading activity in the
client’s account. Select clients may pay a fixed
dollar fee, which presents a conflict in that such
fee does not give the DDK Consultant an incentive
to make recommendations that could benefit the
client’s account, or a performance or incentive
fee, which presents a conflict because it gives the
DDK Consultant an incentive to recommend
riskier investments in order to achieve the level of
performance in the account that would result in
payment of the fee.
Accounts and Investments Provide Different
Levels of Compensation
The types of accounts and investment products
offered
to clients provide Baird and DDK
Consultants different levels of compensation.
Baird and DDK Consultants have an incentive to
generate revenues
from client accounts by
selecting and recommending account types and
investment products that will provide them the
greatest level of compensation.
or
by
Baird’s
Recommendations of Associated Investment
Products and Services
the
they will benefit
To address the potential for conflicts of interest,
Baird has adopted a Code of Ethics (the “Code”)
that applies to
its associates that provide
investment advisory services to clients, including
DDK Consultants, their supervisors, and certain
associates who have access
to non-public
information relating to advisory client accounts
(“Access Persons”). The Code prohibits Access
Persons from using knowledge about advisory
client account transactions to profit personally,
directly, or indirectly, by trading in his or her
personal accounts. The Code also generally
from executing a
prohibits Access Persons
security transaction for their personal accounts
during a blackout period one business day before
or after the date that a client transaction in that
same security is executed. The Code provides for
certain exceptions deemed appropriate by Baird
management
Compliance
Department. In addition, orders for the accounts
of Access Persons and other Baird associates that
are under discretionary management by Baird
may be aggregated with orders for other Baird
client accounts, so long as the order is executed
as part of a block transaction with client orders. A
copy of the Code is available to clients or
prospective clients upon request.
Arrangements—Associated
Baird and DDK Consultants have an incentive to
investment
recommend
use, select or
products and services of Associated Parties
because
financially. See
“Additional Information—Other Financial Industry
Activities and Affiliations—Certain Relationships
and
Investment
Products and Services” above and “Certain Parties
Associated with Baird” on Baird’s website at
bairdwealth.com/retailinvestor.
Baird has also implemented certain policies and
procedures relating to Baird’s and its associates’
trading activities that are designed to prevent
them from improperly benefiting from the trading
139
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Referral Compensation Paid to DDK Consultants
Financial
Industry
Activities
Relationships
referred to as “unbillable assets”) for such period
of time that Baird collects and retains the 12b-1
fee. 12b-1 fees rebated to a client’s Account are
estimated based on the average daily balance of
the mutual fund shares in the Account and the
annual rate of the 12b-1 fee paid by the
applicable fund. If any rebated fees remain in a
client’s Account at the time of billing, those
rebated amounts will be included in the Account
assets subject to the Advisory Fee.
DDK Consultants receive additional compensation
for referring clients to certain Associated Parties
described above. See “Additional Information—
and
Other
Affiliations—Certain
and
Arrangements—Baird and Associated Parties”
above. DDK Consultants also receive additional
compensation for referring clients to unaffiliated
banks that make loans to clients under Baird’s
Securities-Based Lending Program. See “Services,
Fees and Compensation—Additional Service
Information—Securities-Based Lending Program”
above. Such compensation gives DDK Consultants
an incentive to recommend or refer clients to
those Associated Parties and to recommend that a
client participate in the Securities-Based Lending
Program. For more information about referral
compensation paid to DDK Consultants and
related conflicts of interest, please see “Baird
Referral Programs” on Baird’s website at
bairdwealth.com/retailinvestor.
Ongoing Product Fees
If Baird receives 12b-1 fees with respect to
mutual fund shares that are designated as
unbillable assets in a client’s Account, Baird will
retain such 12b-1 fees. This presents a conflict of
interest because it provides Baird and its DDK
Consultants an
incentive to use, select or
recommend mutual fund shares that pay greater
12b-1 fees. Baird addresses this conflict by
adopting a Mutual Fund Share Class Policy
described above and by adopting internal policies
that limit the circumstances under which mutual
fund investments in client accounts can be
designated as unbillable assets and 12b-1 fees
can be retained.
receives ongoing
fees
Marketing Support and Revenue Sharing from
Mutual Fund and UIT Sponsors
invested
Baird
from certain
investment products that are purchased and held
in client Accounts. Those fees, such as distribution
(12b-1) and/or service fees (“12b-1 fees”) from
mutual funds, are based on the value of client
assets
in those products. A DDK
Consultant’s compensation increases as those
fees increase. Thus, Baird and DDK Consultants
have an incentive to use, select or recommend
such products and to recommend such products
that pay the greatest ongoing fees.
Certain mutual funds charge 12b-1 fees, which
are paid to Baird. Baird receives 12b-1 fees on an
ongoing basis as compensation for the services
Baird provides to the applicable mutual fund. The
12b-1 fees paid by a mutual fund are disclosed in
the mutual fund’s prospectus.
Baird receives marketing support or revenue
sharing payments (“marketing support”) from the
sponsors and investment advisers of certain
mutual funds. These payments, which are based
on sales of, or client assets invested in, such
funds, are intended to compensate Baird for
providing marketing, distribution and other
services for the mutual funds. Marketing support
is not paid by sponsors or investment advisers of
mutual funds on mutual fund assets held in
investment advisory Retirement Accounts to the
law. Baird
extent prohibited by applicable
received marketing support payments over the
past two calendar years from the sponsors or
investment advisers of Alliance Bernstein Funds,
American Funds, Franklin Templeton Funds,
Goldman Sachs Funds, Hartford Funds, Invesco
Funds, John Hancock Funds, JPMorgan Funds,
Lord Abbett Funds, MFS Funds, PIMCO Funds and
Principal Funds. Baird also generally receives
marketing support related to the sale of units of
UITs. Sponsors of UITs typically make marketing
or concession payments to the firms that sell their
UITs,
including Baird. These payments are
typically calculated as a percentage of the total
volume of sales of the sponsor’s UITs made by
Baird generally does not allow mutual funds with
12b-1 fees to be purchased for DDK Service
Accounts. If Baird receives 12b-1 fees from a fund
with respect to a client’s mutual fund investment
in the client’s Account and the client’s Account is
subject to an asset-based fee arrangement, Baird
either: (1) rebates such 12b-1 fees to the client’s
Account if the client is paying an asset-based
Advisory Fee on such investment; or (2) excludes
such fund shares from the calculation of the
client’s asset-based Advisory Fee (sometimes
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Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
with Schwab. If Baird receives 12b-1 fees from
Schwab with respect to a mutual fund investment
in a client’s Account, Baird rebates or retains such
fees as further described under the heading
“Ongoing Product Fees” above.
Baird Conference Sponsorships
Trust
Portfolios
and
funds,
the opportunity
Please
see
seminars
supporting Baird
Please
see
the
firm during a particular period. That
percentage typically increases as higher sales
volume levels are achieved. Descriptions of these
additional payments are provided in a UIT’s
prospectus. UIT sponsors that have paid volume
concessions to Baird over the past two calendar
years include Advisors Asset Management (AAM),
First
Guggenheim
Investments. Receipt of marketing support
payments from sponsors and investment advisers
of mutual funds and UITs provides Baird an
incentive to use, select and recommend such
mutual funds and UITs and to favor mutual funds
and UITs with sponsors or investment advisers
that make the greatest levels of such payments.
Baird does not share these payments with DDK
Consultants.
“Revenue
Sharing/Marketing Support and Other Third Party
Payments” at bairdwealth.com/retailinvestor for
more information.
Schwab Clearing Arrangement
Baird hosts a number of seminars and
conferences for DDK Consultants in any given
year, including Baird’s PWM Symposium, which
gives sponsors of investment products, such as
mutual
to make
presentations at, and contribute money toward
the cost of, such seminars and conferences. This
presents a conflict of interest in that it gives Baird
an incentive to promote or market the sponsors’
investment products in order to persuade them to
and
continue
conferences.
“Revenue
Sharing/Marketing Support and Other Third Party
Payments” at bairdwealth.com/retailinvestor for
more information.
DDK Consultants Receive Benefits from Product
Providers
Party
Payments”
for
DDK Consultants generally receive non-cash
compensation and other benefits from Baird and
from sponsors of investment products with which
Baird does business. Such non-cash compensation
and other benefits may include invitations to
attend conferences or educational seminars,
payment of related travel, lodging and meal
expenses, and receipt of gifts and entertainment.
For example, DDK Consultants are invited to
educational conferences hosted by sponsors of
mutual funds, annuities and other investment
products, with the costs associated with such
conference (including travel and lodging) paid by
the sponsors. In addition, DDK Consultants hold
client events with some or all of the costs of such
events paid by sponsors of investment products.
Product sponsors may also provide gifts and
entertainment in connection with those or other
events. These benefits present a conflict of
interest in that they give DDK Consultants an
incentive to use, select or recommend investment
products and their sponsors that provide the
greatest levels of such benefits. Please see
“Revenue Sharing/Marketing Support and Other
Third
at
bairdwealth.com/retailinvestor
more
information.
Baird has a clearing arrangement with Charles
Schwab & Co., Inc. (“Schwab”) whereby Schwab
maintains an omnibus account with certain
mutual fund families for Baird on behalf of Baird
clients. Under the clearing arrangement, Schwab
provides clearing services for most “no load”
funds and “load” funds held by Baird clients.
Although Baird pays Schwab a fee for its clearing
and omnibus services, Schwab generally passes
through to Baird the shareholder servicing fees
that Schwab receives from the funds. Shareholder
servicing fees are not paid by Schwab on mutual
fund assets held in Retirement Accounts to the
extent prohibited by applicable law. The amount
of the shareholder servicing fees paid to Baird is
based on the value of the client assets invested in
those funds. However, the shareholder servicing
fee rate varies based on the type of fund (load or
no load), the value of client assets in those funds,
and the relationship that Schwab has with those
funds (whether or not Schwab receives payments
from those funds or their sponsors, and the rates
of such payments). As a result, Baird has an
incentive to use, select or recommend mutual
funds from which Baird would receive higher
payments from Schwab. However, Baird generally
does not compensate DDK Consultants based
upon the amounts Baird receives from Schwab
except with respect to amounts attributable to
sales loads and 12b-1 fees that Baird would
otherwise receive directly from a fund if it were
not for the existence of the clearing arrangement
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Cash Sweep Program
Information—Securities-Based Lending Program”
above for more detailed information.
Program
Baird
Investment Advisory and Brokerage Account and
Service Recommendations
to
clients
rather
Baird has an incentive to have clients participate
and maintain significant balances in Baird’s Cash
receives
because
Sweep
substantial compensation on client cash balances
that are automatically swept into bank deposit
accounts and invested in money market mutual
funds under the program. Please see “Services,
Fees and Compensation—Additional Service
Information—Cash Sweep Program” above for
more detailed information.
Trust Services Arrangements
Consultant
receive
firm
and
to
it
Compensation—Additional
Baird and DDK Consultants have an incentive to
recommend that a client retain Baird Trust for the
client’s trust services needs rather than an
recommend
unassociated
arrangements that involve Baird and the DDK
Consultant providing investment advisory services
to the client and Baird Trust only providing trust
administration services because
is more
profitable for them. Please see “Services, Fees
and
Service
Information—Trust Services Arrangements” above
for more detailed information.
Margin Loans
to
recommend
fee. Please see
Baird and DDK Consultants generally have a
financial incentive to recommend investment
than
advisory Accounts
brokerage accounts because Advisory Fee
revenue
is recurring, more predictable and
typically greater than the revenues Baird earns,
and the compensation DDK Consultants receive,
from brokerage accounts. In addition, because
Advisory Fees are paid by a client regardless of
the trade activity in the client’s advisory Account,
Baird will receive greater revenue, and the client’s
greater
will
DDK
compensation, from a low trade-activity advisory
Account than from a low trade-activity brokerage
account. Baird and DDK Consultants thus have an
incentive to recommend an investment advisory
Account to a client rather than a brokerage
account if the client has, or is expected to have,
lower levels of trading activity in the client’s
account. However, because Baird’s revenues and
the compensation paid to DDK Consultants from
brokerage accounts increase as the level of
trading increases, Baird and DDK Consultants
have an incentive to recommend a brokerage
account to a client rather than an investment
advisory Account if the client has, or is expected
to have, significant trading activity in the client’s
account. DDK Consultants also have a financial
incentive
certain wealth
management services, such as financial planning.
Please see “Services, Fees and Compensation—
Advisory Fees—Advisory Fee Payments to Baird,
DDK Consultants and Investment Managers”
above for more detailed information.
Loans” above
Account Transfers and New Accounts
Baird has an incentive to recommend that a client
use margin because Baird receives interest on
loans, and Baird and DDK
client margin
Consultants also have an incentive to recommend
that a client use margin, because a margin loan
allows the client to make larger and more
securities purchases. It also increases the value of
a client’s Account and thus the Advisory Fee
associated with that Account because the margin
loan is not deducted for purposes of calculating
the
“Services, Fees and
Compensation—Additional Service Information—
Margin
for more detailed
information.
Securities-Based Lending Program
for
DDK
Consultants
receive
Baird and a client’s DDK Consultant have an
incentive to recommend that the client transfer
the client’s accounts to Baird and establish new
accounts with Baird (including IRA rollovers)
because doing so will result in increased revenues
to Baird and compensation
the DDK
Consultant.
Recommendations to Open Different Types of
Accounts
Baird and DDK Consultants have an incentive to
recommend that a client participate in Baird’s
Securities-Based Lending Program because Baird
and
referral
compensation and such loans allow a client to
keep more assets in the client’s Accounts, which
result in more advisory fees for us and paid to the
client’s DDK Consultant. Please see “Services,
Fees and Compensation—Additional Service
Baird and DDK Consultants have an incentive to
recommend that a client open different types of
accounts with Baird, such as individual accounts,
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Relationships with Issuers of Securities
in companies or
IRA rollovers, joint accounts, 529 plan accounts
and UGMA/UTMA accounts, because if a client has
different types of accounts with Baird, the client
brings more of the client’s investable assets to
Baird, on which fees can be generated, thereby
increasing Baird’s revenues and the client’s DDK
Consultant’s compensation. Also, if a client has
more account types with Baird, the client is
statistically more likely to maintain the client’s
relationship with Baird and the client’s DDK
Consultant for longer periods of time.
Baird Stock Ownership
From time to time, Baird may have proprietary
investments
issuers whose
securities are offered and sold to clients, a DDK
Consultant or another Baird associate may have
significant investments in companies or issuers
whose securities are offered and sold to clients, or
a DDK Consultant or another other Baird
associate (or their spouses, partners or family
members) may have a position as an officer or
director of a company or issuer whose securities
are offered and sold to clients. In such cases,
Baird and/or a client’s DDK Consultant will have
an incentive to recommend that the client invest
in those companies.
DDK Consultants Transferring to Baird
that
increase
A DDK Consultant joining Baird from another firm
has an incentive to recommend that a client to
transfer the client’s accounts from such firm to
Baird because doing so will increase the DDK
Consultant’s compensation. Please see “Services,
Fees and Compensation—Advisory Fees—Advisory
Fee Payments to Baird, DDK Consultants and
Investment Managers” above for more detailed
information.
Principal Trading
compensation
that Baird
with
Baird,
even
if
agent,
commissions.
Most DDK Consultants own common stock of BFG,
Baird’s ultimate parent, and when offered the
opportunity to buy BFG stock they usually do so.
The amount of BFG stock that a DDK Consultant
may purchase is based in part on the DDK
Consultant’s total production level. A client’s DDK
incentive to make
Consultant thus has an
recommendations
the DDK
Consultant’s total production on the client’s
accounts with Baird. Moreover, revenues from
Baird’s PWM department,
in which DDK
Consultants operate, contribute substantially to
BFG’s overall revenues and profitability, and the
performance of BFG’s stock price is largely due to
the profitability of Baird’s PWM department. As a
result, a client’s DDK Consultant’s ownership of
BFG stock creates a financial incentive to make
recommendations to the client that increase the
amount of revenues generated from the client’s
accounts
those
recommendations will not increase the DDK
Consultant’s production, so as to increase the
revenues and profitability of Baird’s PWM
department and thus of BFG, which will serve to
grow the value of the BFG stock. For example,
ownership of BFG stock, the performance of which
is impacted by the success of Associated Parties,
provides a client’s DDK Consultant an incentive to
use, select or recommend Associated Investment
Products and Services to a client even though
such recommendation does not increase the
client’s DDK Consultant’s production.
Other Client Relationships
Baird and DDK Consultants have an incentive to
execute a trade for a client on a principal basis.
The
and DDK
Consultants receive on principal trades, such as a
markup or markdown, is often higher than the
compensation they receive when executing trades
The
such
as
as
compensation
received by Baird and DDK
Consultants is in addition to the asset-based
Advisory Fee a client pays on the client’s advisory
Accounts. Thus, Baird and DDK Consultants have
an incentive to trade as principal rather than as
agent. Principal trades also allow Baird to sell
securities from Baird’s account that Baird deems
undesirable and to buy securities for Baird’s
account that Baird deems desirable. For more
information, please see “Services, Fees and
Compensation—Additional Service Information—
Trading for Client Accounts—Trade Execution
Services Performed by Baird—Principal Trades”
above.
Baird Underwritten Offerings
Baird and DDK Consultants have an incentive to
recommend that clients purchase securities in
Certain client accounts overseen by Baird and
DDK Consultants may have similar investment
objectives and strategies but may be subject to
different fee schedules or commission rates. Thus,
Baird and its DDK Consultants have an incentive
to favor client accounts that generate a higher
level of compensation.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Compensation—Additional Service Information—
Trading for Client Accounts—Trade Execution
Services Performed by Baird” above.
offerings underwritten by Baird because the
underwriting compensation that Baird and DDK
Consultants will earn on those offerings tends to
be higher than the compensation they would
normally receive if clients were to buy them in the
secondary market, and because the profitability of
underwritten offerings to Baird depends upon
Baird’s ability to sell the securities allocated to
Baird in the offering.
to
Allocations of IPOs and Other Public Offerings
“Additional
Baird and DDK Consultants have an incentive to
favor the securities of issuers for which Baird’s
Global Investment Banking, Fixed Income Capital
Markets (including Baird Public Finance) and
Institutional Equities and Research Departments
provide services due
the compensation
received by Baird and Baird Financial Advisors.
Information—Other Financial
See
and Affiliations—Certain
Industry Activities
Relationships and Arrangements—Baird and
Associated Parties” above.
DDK Consultants have the incentive to favor some
clients over other clients when allocating shares
issued in public offerings, particularly those
clients with larger accounts or accounts that
generate high fees and compensation, as a
reward for their past business or to generate
future business.
Trade Error Correction
As a registered broker-dealer, Baird effects
transactions in securities on a national exchange
and may receive and retain compensation for
such services, subject to the limitations and
restrictions made applicable to such transactions
by Section 11(a) of the Exchange Act and Rule
11a2-2(T) thereunder.
It is Baird’s policy that a client’s account will be
fully compensated for any losses incurred as a
result of a trade error for which Baird is
responsible. If the trade error results in a gain,
the gain may be retained by Baird. For more
information, please see “Services, Fees and
Compensation—Additional Service Information—
Trading
for Client Accounts—Baird’s Trading
Practices—Trade Error Correction” above.
Baird’s Other Broker-Dealer and Related Activities
A client may choose to hold cash balances in the
client’s eligible accounts as broker-dealer “free
credits.” To the extent a client elects to hold cash
balances as free credits, a client understands that
Baird does not pay interest on such balances and
Baird may benefit from the possession or use in
the ordinary course of its business of any free
credit balances in the client’s accounts, subject to
restrictions imposed by Rule 15c3-3 under the
Exchange Act.
the size of
the order,
The investment advice provided to a client may
be based on the research opinions of Baird’s
research departments. Baird does, and seeks to
do, business with companies covered by those
research departments and as a result, Baird may
have a conflict of interest that could affect the
content of its research reports.
automated
sell
investments
recommended
non-institutional
participants
in
Baird selects securities trade execution venues
based on
trading
characteristics of the security, speed of execution,
likelihood of price improvement, availability of
transaction processing,
efficient
guaranteed automatic execution levels and other
qualitative factors. Baird receives payment or
liquidity rebates on certain options or equity
securities orders
to some venues
routed
(commonly known as “payment for order flow”).
The existence and amount of payments are
dependent upon the size and type of the routed
order. The
source and amount of any
compensation received by Baird in connection
with payment for order flow will be disclosed to
the
the
transaction upon request. This compensation
gives Baird an incentive to route client orders for
securities transactions to those venues that
Baird and its Associated Parties and associates
may buy or
that are
recommended to or owned by a client for their
own accounts, or they may act as broker or agent
those
for other clients buying or selling
investments. Those transactions may include
buying or selling investments in a manner that
differs from, or is inconsistent with, the advice
given to a client, and those transactions may
occur at or about the same time that such
investments are
to or are
purchased or sold for a client’s account. Baird
may also engage in agency cross transactions and
principal transactions with clients as further
and
described
under
“Services,
Fees
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Addressing Conflicts
provide Baird the greatest levels of compensation,
but Baird’s routing decision is always based upon
obtaining favorable executions for clients rather
than the availability of payment for order flow.
Information about Baird’s order routing practices
are
at:
available
http://www.rwbaird.com/help/account-
disclosures/routing-equity-orders.aspx.
for Baird and
from
time
The foregoing activities could create a conflict of
interest with clients. In addition to the measures
described above, Baird addresses conflicts posed
by those activities through disclosure in this
Brochure, the client’s agreements with Baird, the
Client Relationship Booklet and prospectuses,
offering documents or other disclosure documents
provided or made available to clients. Baird has
also adopted a Code of Ethics and other internal
policies and procedures
its
associates that:
• require them to provide investment advice that
is suitable for advisory clients (based upon the
information provided by such clients);
that
• are designed
securities
to ensure
allocations made to discretionary client accounts
are made in a manner such that all such clients
receive fair and equitable treatment over time;
Baird and its associates, by reason of Baird’s
investment banking or other
broker-dealer,
activities, may
time acquire
to
information deemed confidential, material and
non-public, about corporations or other entities
and their securities. Baird and its associates are
prohibited by applicable law or agreements from
disclosing such information to clients or acting
upon such information with respect to any client
Account. Baird’s other activities thus present a
potential conflict of
interest because such
activities may limit Baird’s ability to advise or
manage client Accounts.
Other Conflicts of Interest
• address Baird’s and its associates’ trading
activities and are designed to prevent them
from improperly benefiting from the trading
activities of Baird’s advisory clients; and
• address and limit cash and non-cash benefits
provided to DDK Consultants by third parties in
an attempt to avoid any question of propriety or
any conduct inconsistent with Baird’s high
standards of ethics.
Duration Compensation Will Be Received
Baird offers to clients other investment products
and services not described in this Brochure. These
investment products and
services provide
different levels of compensation to Baird and its
DDK Consultants. Baird and its DDK Consultants
have an incentive to favor those investment
products and services that generate a higher level
of compensation than those that generate a lower
level of compensation. For more information
about the other investment products and services
offered by Baird, clients should contact Baird or a
DDK Consultant.
extend beyond
a
client’s
financial
interest or practices
If a client holds any of the investment products
described above, Baird, its Associated Parties and
associates will receive the fees and payments
described above for the duration of the client’s
In some
relationship with Baird.
advisory
circumstances, the receipt of such compensation
may
advisory
relationship with Baird if the client continues to
hold those assets at Baird.
Fees—Advisory
Managers”
and
and
Referrals
and
Other sections of this Brochure also describe
instances when Baird and its DDK Consultants
may recommend to clients, and may buy and sell
for client’s Account, securities in which Baird and
its Associated Parties and associates have a
material
that
interest. For more
present a conflict of
information, please see “Services, Fees and
Compensation—Advisory
Fee
to Baird, DDK Consultants and
Payments
Investment
“Additional
Information—Other Financial Industry Activities
“Additional
and
above,
Affiliations”
Information—Client
Other
Compensation” below.
If Baird, or an Associated Party or associate of
Baird, receives any compensation or benefit
described in this Brochure from or related to a
client’s investment, they will generally retain the
compensation or benefit. Except as otherwise
described above, Baird generally does not rebate
these amounts to a client’s Account or credit the
amount against the Advisory Fees payable by a
client unless such compensation may not be
retained under applicable law or regulation.
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Review of Accounts
Client Account Review
A client should note that past performance does
not indicate or guarantee future results. None of
DDK, Baird, or investment managers managing
the client’s Account promise or guarantee any
level of investment returns or that the client’s
investment objective will be achieved.
Client accounts are monitored on a periodic basis
by the client’s DDK Consultant and are subject to
review by the Baird Market Director or PWM
Supervision department supervisor (or his or her
respective designee) responsible for supervising
the client’s DDK Consultant. A client’s DDK
Consultant generally reviews the performance of
the client’s Account at least annually. However,
the client’s DDK Consultant may not review the
performance of a client’s SMAs managed by Other
Managers under the Baird SMA Network Program
or Dual Contract Program. Baird has designated
individuals who are responsible for monitoring a
client’s DDK Consultant with respect to the client
account’s trading activity and attempting to
ascertain whether client accounts within each
composite are being treated equitably.
Benchmarks shown in performance reports are for
informational purposes only. DDK’s selection and
use of benchmarks is not a promise or guarantee
that the performance of a client’s Account will
meet or exceed the stated benchmark. When the
client compares Account performance to the
performance of a market index, the client should
recognize that a market index merely reflects the
performance of a list of unmanaged securities
included in the index and the index performance
does not take into account management fees,
execution costs, and other expenses related to
investing for a client’s Account. The securities
included in a client’s Account generally do not
exactly mirror the securities included in the index.
Account Statements and Performance
Reports
performance
comparisons
If Baird provides transaction execution services to
a client, Baird will generally provide the client
with a monthly brokerage account statement
that month.
when activity occurs during
Otherwise, Baird will provide the client with a
quarterly statement if there has not been any
intervening monthly transaction activity.
The benchmarks used by Baird with respect to a
client’s SMA may differ from the benchmarks used
by the manager of the client’s SMA. As a result,
in Baird’s
the
performance reports may differ from reports
provided to clients directly by the investment
manager for the client’s SMA.
A client’s DDK Consultant will provide the client
with a written report on the client’s Account’s
performance as often as the client and the DDK
Consultant may from time to time mutually agree.
Performance reporting may not be available for
Account assets that are not custodied at Baird.
For more information about performance reports
provided by DDK, see “Services, Fees and
Compensation—Description of Advisory Services”
above. DDK or Baird may change or discontinue
performance reporting to a client at any time for
any reason upon notice.
calculation of
Client performance reports usually contain a
portfolio valuation and typically show the asset
allocation of the client’s portfolio, changes in a
client’s portfolio, and account performance
compared to a benchmark market index or indices
(such as the S&P 500® Index or the Bloomberg
U.S.
Intermediate Government/Credit Bond
Index). The benchmark may be a blended
benchmark that combines the returns for two or
more indices.
The performance of investment managers may,
under certain circumstances, be presented to
clients on a “gross” or “gross of fees” basis, which
means the performance results being presented
does not reflect the deduction of Advisory Fees
and other costs that clients have incurred and will
incur when retaining the manager. Had applicable
Advisory Fees and other costs been included in
the manager’s
the performance calculation,
performance results would have been lower than
the performance results presented. Documents
presenting a manager’s performance results on a
gross of
fees basis should contain certain
disclosures about the performance results being
presented. Clients are urged to review carefully
those disclosures because they contain important
information about
the
the
performance results. If a client is presented
performance information for a manager’s strategy
on a gross of fees basis and the client has an
Account managed by that manager pursuant to
that strategy,
the client should obtain a
performance report for the Account and review
that performance information carefully because
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
the performance report for the Account will reflect
the deduction of applicable Advisory Fees and
other costs.
from other sources. Values used in account
statements and performance reports may vary
from prices received in actual transactions and
are not firm bids, offers or guarantees of any type
with respect to the value of assets in an Account,
and the values may be greater than the amount a
client would receive if the securities were actually
sold from the client’s Account.
If a client has assets held by a third party
custodian, the prices shown on a client’s Account
statements provided by the custodian could be
different from the prices shown on statements
and reports provided by DDK or Baird. See
“Services, Fees and Compensation—Additional
Service Information—Custody Services” above for
more information.
Certain Model Providers have adopted trade
rotation policies that allow them to send Model
Portfolio updates to the Overlay Manager after
implemented the Model Portfolio
they have
updates for client accounts managed by them or
after they have otherwise completed trading for
those accounts. As a result, the performance of a
Model Portfolio, as reported by the Model
Provider, will differ, perhaps in a materially
negative manner, from the actual performance
realized by Baird client Accounts pursuing the
Model Portfolio strategy. See “Additional Service
Information—Trading for Client Accounts—Trading
Practices of Investment Managers” above for
more information.
including, but not
limited
to,
role
in developing
the
these
fees
to
Client Referrals and Other Compensation
DDK or Baird may provide compensation to
individuals who refer clients in some instances.
When applicable, the compensation paid is a
percentage of the client’s fee payments or the
value of the client’s Account. The amount of
compensation will vary, with the specific level
determined based upon consideration of various
factors
the
individual’s
client
relationship and the assets under management.
Baird may pay
registered
representatives of Baird and its Associated Parties
as well as to unassociated solicitors that have
entered into a written agreement with Baird.
When preparing a client’s Account statements and
performance reports, DDK and Baird generally
rely upon third party sources, such as third party
pricing services. In some instances, such as when
Baird is unable to obtain a price for an asset from
a pricing service, Baird may obtain a price from
its trading desk or it may elect to not price the
asset. Obtaining a price from its trading desk may
present a conflict of interest. In some cases, Baird
obtains prices from the issuers or sponsors of
investment products in the client’s Account when
prices are not otherwise readily available. This
frequently occurs with respect to the valuation of
annuities and Complex Investment Products. If
the assets in the client’s Account are held by a
custodian other than Baird, Baird may also use
valuation information provided by the client’s
third party custodian.
DDK and Baird and Baird’s Associated Parties and
associates may receive certain economic benefits
in connection with providing advisory services to
clients, which are described in the sections
entitled “Services, Fees and Compensation”,
“Account Requirements and Types of Clients”,
“Additional Information—Other Financial Industry
Activities and Affiliations” and
“Additional
Information—Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading” above.
is unreliable. Valuation data
Financial Information
DDK does not require or solicit prepayment of
more than $1,200 in fees per client six months or
more in advance and, thus, has not included a
balance sheet of Baird’s most recent fiscal year.
Neither Baird nor DDK is aware of any financial
condition that is reasonably likely to impair their
ability to meet their contractual commitments to
DDK and Baird do not conduct a review of
valuation information provided by third party
pricing services, issuers, sponsors, or custodians,
and they do not verify or guarantee the accuracy
of such information. DDK and Baird do not accept
responsibility for valuations provided by third
parties that are inaccurate unless they have a
reason to believe that the source of such
valuations
for
investments, particularly annuities and Complex
Investment Products, may not be provided to
DDK or Baird in a timely manner, resulting in
valuations that are not current. The prices
obtained by DDK and Baird from the third party
pricing services, issuers, sponsors and custodians
may differ from prices that could be obtained
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
clients, nor has either been the subject of a
bankruptcy petition at any time during the past
ten years.
investment
other
compensation
related
to
to
the applicable
Special Considerations for Retirement
Accounts
Each Retirement Account Fiduciary of a client
should understand that DDK or Baird may invest
for the client, recommend that the client invest in,
or make available
to plan
for
participants, Associated Investment Products, that
Baird and its Associated Parties will receive fees
such
or
investments, and that they will retain such
compensation
the extent permitted by
applicable law, rule or regulation, including,
without limitation, Department of Labor (“DOL”)
Prohibited Transaction Exemption (“PTE”) 77-4,
DOL PTE 2020-02 or other advisory opinions
issued by the DOL.
Account, each of which include a summary of all
fees that may be paid by the Associated
Investment Products to Baird or its Associated
Parties; and (iv) the client received information
concerning
the nature and extent of any
differential between the rate of such Associated
Investment Product fees and the Advisory Fees
payable by the client. The differential between the
fees to be charged by DDK and Baird for the
investment advisory services they provide to the
client and, if applicable, the investment advisory
and other similar fees paid by the Associated
Investment Product to Baird or its Associated
Parties with respect to the services Baird or any of
its Associated Parties provides to the Associated
Investment Product is the difference between the
Advisory Fee disclosed in the client’s advisory
investment
agreement and
management, investment advisory and other
similar fees detailed in the applicable prospectus
or other offering or disclosure documents for the
Associated Investment Product.
that
directed
the
fiduciary
Fiduciary
such Fiduciary
is
that
for complying with all
Parties
from
transactions, and
the duty
broker-dealer,
and
terminating
monitoring
a
for
the Associated
If the client’s Account is a Retirement Account
and if DDK is directed to implement a directed
brokerage arrangement for the Account, each
Retirement Account Fiduciary of the client should
understand:
brokerage
the
arrangement must be for the exclusive benefit of
participants and beneficiaries of the Retirement
Account; and
responsibilities
discussed in ERISA Technical Bulletin 86-1. Each
should also
Retirement Account
solely
understand
responsible
fiduciary
in ERISA Technical
responsibilities discussed
Bulletin 86-1, including, without limitation, the
duty to make an initial determination that the
directed broker-dealer is capable of providing best
execution for the client’s brokerage transactions,
the duty to monitor the services provided by the
directed broker-dealer so as to assure that the
client has received best execution of the client’s
brokerage
to
determine that the commissions paid by the client
and any other fees or costs incurred by the client
are reasonable in relation to the value of the
brokerage and other services received by the
client. The client and each Retirement Account
Fiduciary of the client should also understand that
the client and the client’s Retirement Account
Fiduciaries are solely responsible for engaging a
directed
its
performance
directed
brokerage arrangement, and that DDK and Baird
To the extent Baird and its Associated Parties rely
upon PTE 77-4, each Retirement Account
Fiduciary should also understand that when DDK
or Baird invests the assets of a Retirement
Account in an Associated Investment Product that
pays investment advisory fees to Baird or any of
its Associated Parties, Baird and its Associated
Parties will receive such investment advisory fees
in accordance with the terms of DOL PTE 77-4,
and, as required thereby, DDK and Baird will
waive the asset-based Advisory Fees on that
portion of the assets invested in the Associated
Investment Product for such period of time so
invested or Baird will offset the investment
advisory fees received by Baird or any of its
the
Associated
Associated
Investment Product against
the asset-based
Advisory Fee that DDK and Baird charge to the
client. For the purpose of complying with the
terms of DOL PTE 77-4, the client and each
Retirement Account Fiduciary of
the client
acknowledge in the client’s advisory agreement
that: (i) the investment in Associated Investment
Products for the client’s Account is appropriate
because of, among other things, the investment
goals, redeemability, liquidity, and diversification
of those products; (ii) subject to the terms of the
applicable Service, all assets of the client’s
Account may be invested in one or more of the
Associated Investment Products; (iii) the client
and such Retirement Account Fiduciary received
prospectuses or other offering or disclosure
Investment
documents
Products that may be used in connection with the
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Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
are not responsible for determining whether a
directed broker-dealer is capable of providing best
execution.
than
the
client
If a client’s Account is a Retirement Account and if
the client is selecting Associated Investment
Products and Services, each Retirement Account
Fiduciary of the client understands and agrees
that in making such selection: (a) Baird and its
Associated Parties may receive higher aggregate
compensation
selected
if
investment managers, funds or other products
not associated with Baird and thus Baird may
have an incentive to offer Associated Investment
Products and Services; (b) Baird makes available
to the client investment managers, funds and
products not associated with Baird and the client
may obtain additional information about such
unassociated investment managers, funds or
products at any time by contacting the client’s
DDK Consultant; and (c) the client is free to
choose another investment option or participate
in another Baird advisory program that does not
use investment managers, funds or products
associated with Baird at any time by contacting
the client’s DDK Consultant. For more information
Investment Products and
about Associated
Services, please see “Additional Information—
Other Financial Industry Activities and Affiliations”
above.
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777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Appendix A
Associated Investment Products and Services
Entity Type
Name
Relationship
Baird Advisors1
Baird Department
Baird Equity Asset Management1
Baird Department
Chautauqua Capital Management1
Baird Department
55I, LLC (d/b/a 55ip, “55ip”)
Associated
Investment Advisor
GAMMA Investing, LLC
Affiliated
Greenhouse Fund GP LLC
Related
Greenhouse Funds LLLP
Related
LoCorr Fund Management, LLC
Related
Reinhart Partners, LLC
Affiliated
Riverfront Investment Group, LLC
Affiliated
Dual Registrant2
Strategas Securities, LLC
Affiliated
Trust Company
Baird Trust Company1
Affiliated
Baird Funds, Inc.1
Affiliated
Bridge Builder Trust (Baird series)
Affiliated
Mutual Fund
Financial Investors Trust (Riverfront series)
Affiliated
LoCorr Investment Trust
Related
Managed Portfolio Series Trust (Reinhart series)
Affiliated
Pace® Select Advisors Trust (Baird Series)
Affiliated
Advisors’ Inner Circle Fund III (Strategas series)
Affiliated
ETF
ALPS ETF Trust (Riverfront Series)
Affiliated
First Trust Exchange-Traded Fund III (Riverfront series)
Affiliated
Automated Quantitative Analysis (AQA®) Portfolio Series
Affiliated
UIT
Dividend Income Trust (DIT) Series
Affiliated
Strategas Trust, Series 1-1
Affiliated
CIT
Reliance Trust Institutional Retirement Trust (Baird/Chautauqua series)
Affiliated
Greenhouse Master Fund LP
Related
Hedge Fund
Greenhouse Onshore Fund LP
Related
Greenhouse Overseas Fund Ltd.
Related
Chautauqua Global Growth Equity QP Fund, LP
Affiliated
Private Fund
Chautauqua International Growth Equity QP Fund, LP
Affiliated
Chautauqua Series Fund, LLC
Affiliated
Appendix A - 1
DDK Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Venture Partners Management Company III, LLC
Baird Venture Partners III Limited Partnership
Affiliated
BVP III Affiliates Fund Limited Partnership
BVP III Special Affiliates Limited Partnership
Baird Venture Partners Management Company IV, LLC
Baird Venture Partners IV Limited Partnership
Affiliated
BVP IV Affiliates Fund Limited Partnership
BVP IV Special Affiliates Limited Partnership
Baird Venture Partners Management Company V, LLC
Baird Venture Partners V Limited Partnership
Affiliated
BVP V Affiliates Fund Limited Partnership
BVP V Special Affiliates Fund Limited Partnership
Baird Capital Partners Management Company V, LLC
Baird Capital1,3
Baird Capital Partners V Limited Partnership
Affiliated
Investment Advisor
BCP V Affiliates Fund Limited Partnership
Private Equity Fund
BCP V Special Affiliates Limited Partnership
Baird Capital Management Company, LLC
Baird Venture Partners GP VI, LLC
Baird Venture Partners VI LP
Affiliated
BVP VI Affiliates Fund LP
BVP VI Special Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management I LP
Baird Capital Global Fund I LP
Affiliated
Baird Capital Global Fund I-DE LP
BCGF I Special Affiliates LP
BCGF I Affiliates Fund LP
Baird Capital Management Company, LLC
Baird Capital Global Fund Management II LLC
Baird Capital Global Fund II Limited Partnership
Affiliated
BCGF II Affiliates Fund Limited Partnership
BCGF II Special Affiliates Limited Partnership
Appendix A - 2
DDK Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC
Entity Type
Name
Relationship
Baird Capital Management Company, LLC
Baird Capital Global GP III LLC
Baird Capital Global Fund III LP
Affiliated
Baird Capital1,3
BCGF III Affiliates Fund LP
Investment Advisor
BCGF III Special Affiliates LP
Private Equity Fund
Baird Capital Partners Europe Limited4
Baird Capital Partners Europe II LP
Affiliated
Baird Capital Partners Europe II Special Affiliates LP
The Growth Fund
Baird Principal Group Management Company I, LLC
Baird Principal Group5
Baird Principal Group Partners Fund I Limited Partnership
Investment Advisor
Baird Principal Group Management Company II, LLC
Affiliated
Private Equity Fund
Baird Principal Group Partners Fund II Limited Partnership
Baird Principal Group Management Company, LLC
Baird Principal Group Partners Fund III, LP
Holding Company
Sagard Holdings Management, Inc.6
Associated
1. Participates in a Baird PWM Referral Program that pays compensation to DDK Consultants for eligible referrals.
2. Registered with the SEC as a broker-dealer and investment advisor.
3. Baird Capital, Baird’s private equity business.
4. Baird Capital Partners Europe Limited, an English limited company, is regulated and authorized by the Financial
Conduct Authority.
5. Baird Principal Group, a group within Baird that has private equity funds only available to Baird employees.
6. Baird has a contractual relationship with and a small minority investment in Sagard Holdings Management, Inc., a
holding company for various financial services businesses whose investment products are made available to clients under
the Services. See “Additional Information—Other Financial Industry Activities and Affiliations—Certain Relationships and
Arrangements—Baird and Associated Parties” above for more information.
Appendix A - 3
DDK Wrap Brochure
Rev. 03/27/2026
Robert W. Baird & Co. Incorporated
777 East Wisconsin Avenue, Milwaukee, WI 53202
800-RW-BAIRD.rwbaird.com.Member FINRA & SIPC