Compliance Department | Chicago, IL | compliance@ziegler.com
2009 Firm Element Continuing Education Training Plan
Dated
Audience
Effective date
August, 20 2009 (Updated)
The Ziegler Companies, Inc.
Immediately
PLAN OVERVIEW
Pursuant to FINRA regulations requiring broker/dealers to have firm-sponsored continuing education (CE)
programs, Ziegler requires all securities-registered personnel to participate in training on an annual basis. The
Company’s program is administered by the Compliance Department.
Based on an annual needs analysis, various training programs require completion by all registered personnel in a
given business unit (see description in Section II below). For training year 2009, we are moving away from the
credit hour requirement and moving to an assigned coursework/topic requirement. Individuals’ requirements
are based upon what business unit they are a part of and must be completed by all registered personnel by
January 31, 2010. In addition to the required coursework, registered personnel also have the option of submitting
outside training to satisfy the elective course portion of their requirement.
Programs offered through other organizations can qualify for CE credit, provided copies of the materials,
certificates, outlines or other requested information have been reviewed and approved by Compliance. A
Continuing Education Request Form can be used to request credit for any non-company sponsored programs.
Complete the Form and submit it to the Compliance Department with the attached back-up documentation.
I. 2009 FIRM ELEMENT TRAINING PLAN
Required Coursework for 2009:
The following coursework is the required training for each business unit for the 2009 CE cycle. These courses are
available through Ziegler’s CE website at www.zieglerce.com. Please access the site to complete this training
before January 31, 2010. The Compliance Department will be notified of your completion.
Business Unit
Administration All Registered Reps
Alternative InvestmentsAll Registered Reps
Assigned Training
Source
Completed By
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Anti-Money Laundering
Quest CE/Ziegler Compliance Staff
January 31, 2010
Ethics: The Importance of Ethical Behavior
FINRA Webcast
January 31, 2010
Conflicts of Interest
FINRA Webcast
January 31, 2010
One Elective
Quest CE /Approved Outside Training
January 31, 2010
Annual Compliance Meeting
Ziegler Compliance Staff
December 31, 2009
Anti-Money Laundering
Quest CE/Ziegler Compliance Staff
January 31, 2010
Ethics: The Importance of Ethical Behavior
FINRA Webcast
January 31, 2010
Conflicts of Interest
FINRA Webcast
January 31, 2010
Two Electives
Quest CE/Approved Outside Training
January 31, 2010
Annual Compliance Meeting
Ziegler Compliance Staff
December 31, 2009
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B.C. Ziegler and Company | Member SIPC & FINRA
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Business Unit
Capital Management All Registered Reps
Capital Markets Trading & Sales
Capital Markets
Investment Banking
Capital Markets
Consulting
Capital Markets Mergers & Acquisitions
/Corporate Finance
Capital Markets Research
Assigned Training
Source
Completed By
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Anti-Money Laundering
Quest CE/Ziegler Compliance Staff
January 31, 2010
Ethics: The Importance of Ethical Behavior
FINRA Webcast
January 31, 2010
Conflicts of Interest
FINRA Webcast
January 31, 2010
Spreading of False Rumors and Market Manipulation
Quest CE
January 31, 2010
Two Electives
Quest CE /Approved Outside Training
January 31, 2010
Annual Compliance Meeting
Ziegler Compliance Staff
December 31, 2009
Anti-Money Laundering
Quest CE/Ziegler Compliance Staff
January 31, 2010
Ethics: The Importance of Ethical Behavior
FINRA Webcast
January 31, 2010
Conflicts of Interest
FINRA Webcast
January 31, 2010
Debt Mark-Ups
FINRA Webcast
January 31, 2010
Spreading of False Rumors and Market Manipulation
Quest CE
January 31, 2010
Two Electives
Quest CE /Approved Outside Training
January 31, 2010
Annual Compliance Meeting
Ziegler Compliance Staff
December 31, 2009
Anti-Money Laundering
Quest CE/Ziegler Compliance Staff
January 31, 2010
Ethics: The Importance of Ethical Behavior
FINRA Webcast
January 31, 2010
Conflicts of Interest
FINRA Webcast
January 31, 2010
Underwriting Disclosure and Due Diligence
Quest CE/Ziegler Legal Department
January 31, 2010
Suitability Issues: An Institutional Focus
FINRA Webcast
January 31, 2010
Spreading of False Rumors and Market Manipulation
Quest CE
January 31, 2010
Two Electives
Quest CE/Approved Outside Training
January 31, 2010
Annual Compliance Meeting
Ziegler Compliance Staff
December 31, 2009
Anti-Money Laundering
Quest CE/Ziegler Compliance Staff
January 31, 2010
Ethics: The Importance of Ethical Behavior
FINRA Webcast
January 31, 2010
Conflicts of Interest
FINRA Webcast
January 31, 2010
Spreading of False Rumors and Market Manipulation
Quest CE
January 31, 2010
Two Electives
Quest CE/Approved Outside Training
January 31, 2010
Annual Compliance Meeting
Ziegler Compliance Staff
December 31, 2009
Anti-Money Laundering
Quest CE/Ziegler Compliance Staff
January 31, 2010
Ethics: The Importance of Ethical Behavior
FINRA Webcast
January 31, 2010
Conflicts of Interest
FINRA Webcast
January 31, 2010
Spreading of False Rumors and Market Manipulation
Quest CE
January 31, 2010
Two Electives
Quest CE/Approved Outside Training
January 31, 2010
Annual Compliance Meeting
Ziegler Compliance Staff
December 31, 2009
Anti-Money Laundering
Quest CE/Ziegler Compliance Staff
January 31, 2010
Ethics: The Importance of Ethical Behavior
FINRA Webcast
January 31, 2010
Conflicts of Interest
FINRA Webcast
January 31, 2010
Spreading of False Rumors and Market Manipulation
Quest CE
January 31, 2010
Two Electives
Quest CE/Approved Outside Training
January 31, 2010
Annual Compliance Meeting
Ziegler Compliance Staff
December 31, 2009
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B.C. Ziegler and Company | Member SIPC & FINRA
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Business Unit
Wealth Management All Registered Reps
Assigned Training
Source
Completed By
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Anti-Money Laundering
Quest CE/Ziegler Compliance Staff
January 31, 2010
Ethics: The Importance of Ethical Behavior
FINRA Webcast
January 31, 2010
Conflicts of Interest
FINRA Webcast
January 31, 2010
Considerations for Working w/ Seniors
FINRA Webcast
January 31, 2010
Electronic Communication for Registered Representatives
Quest CE
January 31, 2010
Spreading of False Rumors and Market Manipulation
Quest CE
January 31, 2010
A Professional’s Guide to NASD Rules on Variable Annuity
and Variable Insurance Prospecting
Quest CE
January 31, 2010
Fixed and Variable Annuities vs. Mutual Funds
Quest CE
January 31, 2010
Taxable Fixed Income Investing
Quest CE
January 31, 2010
Managed Futures
Quest CE
January 31, 2010
Annual Compliance Meeting
Ziegler Compliance Staff
December 31, 2009
Variable Annuities: Requirements for Supervisors
FINRA Webcast
January 31, 2010
Supervisory Considerations for Working with Seniors
FINRA Webcast
January 31, 2010
A Supervisors Role in Deterring the Spreading of False
Rumors and Market Manipulation
Quest CE
January 31, 2010
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Wealth Management
Supervisors
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AVAILABLE ELECTIVE COURSEWORK FOR 2009
In the required training outlined above, each business unit is assigned either one, two or three elective courses.
One option for completing electives include self-study courses which are offered through www.zieglerce.com. A
complete list of self-study courses is listed herein. Email Ben George with the course name to have it added to
your profile.
Elective Training Available Through Ziegler’s CE Website
401(k) and Qualified Plans
A Professional’s Guide to Ethical Decision Making
A Professional’s Guide to NASD Rules on Variable Annuity and Variable Insurance Prospecting
A Supervisors Role in Deterring the Spreading of False Rumors and Market Manipulation New - 2009
Advanced Asset Allocation New - 2009
An Introduction to Non-Traded REITs New - 2009
Annuities Essentials
Annuities: Owner Driven and Annuitant Driven Contracts
Annuity Basics
Anti-Fraud Programs
Anti-Money Laundering Regulations and New Red Flag Requirements New - 2009
Anti-Money Laundering Regulations and Ramifications
Anti-Money Laundering Training for Agents
Anti-Money Laundering Training for Broker-Dealers
Anti-Money Laundering Training for Home Office Personnel
Bank Secrecy Act
Basics of 403(b) Plans
Basics of Bond Investing
Basics of Investing
Basics of Stock Investing
Business Continuity Planning
Class B Mutual Fund Shares
Disability Income Insurance
Economic Growth and Tax Relief Reconciliation Act of 2001
Economic Indicators
B.C. Ziegler and Company | Member SIPC & FINRA
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Elective Training Available Through Ziegler’s CE Website
Effects of Market Uncertainty on Retirement Planning
Electronic Communication for Registered Representatives
Equity Indexed Annuities
Ethics and Professional Conduct
Ethics for the Financial Services Professional
Ethics and the Securities Futures Professional
Executive Bonus Plans
Financial Performance Evaluation
FINRA Rule 2821 Supervisory Training
Fixed and Variable Annuities vs. Mutual Funds
Futures Markets
Gifts and Gratuities: Guidance on Rule 3060
Gramm-Leach Bliley Act Overview
Hedge Fund Investing
How to Read a Prospectus
Hybrid Securities
Identity Theft Prevention and the Financial Services Industry
Income Planning for Heirs
Income Planning for Retirement
Insider Trading
Introduction to 529’s
Introduction to Blue Sky Laws
Introduction to Derivatives
Introduction to EIAs
Introduction to Estate Planning
Introduction to FINRA Rule 2821 for Registered Representatives
Introduction to Gift and Estate Taxation
Introduction to Mutual Fund Investing
Introduction to Suitability and the Senior Protection Model Regulation
Investment Advisor Code of Ethics
IRA Basics
IRA Goldbook
Long Term Care Insurance
Managed Futures
Margin Trading
Mergers and Acquisitions
Meeting the Federal Trade Commission’s Safeguards Rule
Mutual Fund Class Share
Online Identity Theft Scams “Phishing”
Options Basics
Pension Protection Act of 2006
Prevention of Personal Identity Theft
Principles of Asset Allocation
Professional Sales Presentations
Retirement Planning
Rule 144 and 144A
Rule 3012 and Rule 3013: Supervisory Controls
Rules on Internet Availability of Proxy Materials
Sarbanes-Oxley Overview
Split Dollar Plans
Spreading of False Rumors and Market Manipulation New - 2009
Structured Sale Annuities
Suitability Obligation to Institutional Customers
B.C. Ziegler and Company | Member SIPC & FINRA
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Elective Training Available Through Ziegler’s CE Website
Section 1035 Exchanges
Section 529 Plans
Suitability of Variable Annuities
Suitability of Variable Life Insurance
Suitability of Variable Products
Supervision of Electronic Communications
Supervision of Life Insurance Professionals
Supervision of Registered Representatives
Taxable Fixed Income Investing New - 2009
The Truth About Variable Annuities
Types of Fixed Annuities
Understanding Annuities
Understanding ERISA New - 2009
Understanding IRAs
Variable Universal Life I
Variable Universal Life II
Wrap Fee Accounts
B.C. Ziegler and Company | Member SIPC & FINRA
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Employees may also elect to complete training hosted or provided by outside vendors. In these cases, the
employee must submit a Continuing Education Request Form to Compliance for approval along with the required
backup documentation. Credit granted for this type of training will vary and will depend upon the coursework
provided.
Elective Training Through Other Vendors
Securities-specific training provided or hosted by outside training vendors
Must be related to the investment activities the employee is engaged in. Those training sessions which are not specifically
related to sales of registered products are not eligible for credit.
II. DESCRIPTION OF ANNUAL CONTINUING EDUCATION REQUIRMENTS
Training Content
Continuing Education programs or topics are chosen based upon a variety of factors which are reviewed by
Compliance in the needs analysis process. These topics are relevant to the business units and categories of
employees.
Training Due Dates
The required CE training must be completed prior to February 1, 2010 or the employee needs to submit in writing
by January 1, 2010 their intent to attend specific training programs prior to January 31, 2010.
Categories of Employees
 Administrative Employees
All registered individuals who are not assigned to one particular business unit, are required to take the
following training:
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Alternative Investments
All registered individuals who are part of this business unit, are required to take the following training:
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Anti-Money Laundering
Ethics: The Importance of Ethical Behavior
Conflicts of Interest
One Elective
Annual Compliance Meeting
Anti-Money Laundering
Ethics: The Importance of Ethical Behavior
Conflicts of Interest
Two Electives
Annual Compliance Meeting
Ziegler Capital Management/Portfolio Managers
Those individuals who are registered and work in a sales capacity within the Investment Advisor, including
Portfolio Managers, Sales Persons, Internal Wholesalers and External Wholesalers, are required to take the
following training:
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Anti-Money Laundering
Ethics: The Importance of Ethical Behavior
Conflicts of Interest
Spreading of False Rumors and Market Manipulation
Two Electives
Annual Compliance Meeting
B.C. Ziegler and Company | Member SIPC & FINRA
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Capital Markets — Trading & Sales
Those registered individuals who work in investment banking, trading or serve as registered assistants to one
of these functions are required to take the following training:
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Capital Markets — Investment Banking
Those registered individuals who work in investment banking, trading or serve as registered assistants to one
of these functions are required to take the following training:
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Anti-Money Laundering
Ethics: The Importance of Ethical Behavior
Conflicts of Interest
Spreading of False Rumors and Market Manipulation
Two Electives
Annual Compliance Meeting
Capital Markets — Mergers & Acquisitions/Corporate Finance
Those registered individuals who work in investment banking, trading or serve as registered assistants to one
of these functions are required to take the following training:
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Anti-Money Laundering
Ethics: The Importance of Ethical Behavior
Conflicts of Interest
Underwriting Disclosure and Due Diligence
Suitability Issues: An Institutional Focus
Spreading of False Rumors and Market Manipulation
Two Electives
Annual Compliance Meeting
Capital Markets — Consulting
Those registered individuals who work in investment banking, trading or serve as registered assistants to one
of these functions are required to take the following training:
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Anti-Money Laundering
Ethics: The Importance of Ethical Behavior
Conflicts of Interest
Debt Mark-Ups
Spreading of False Rumors and Market Manipulation
Two Electives
Annual Compliance Meeting
Anti-Money Laundering
Ethics: The Importance of Ethical Behavior
Conflicts of Interest
Spreading of False Rumors and Market Manipulation
Two Electives
Annual Compliance Meeting
Capital Markets — Research
Those registered individuals who work in investment banking, trading or serve as registered assistants to one
of these functions are required to take the following training:
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Anti-Money Laundering
Ethics: The Importance of Ethical Behavior
Conflicts of Interest
Spreading of False Rumors and Market Manipulation
Two Electives
Annual Compliance Meeting
B.C. Ziegler and Company | Member SIPC & FINRA
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Wealth Management Employees
Those registered individuals who are employed by, or associated with Ziegler as a Branch Manager, Financial
Advisor or Registered Sales Assistant within a retail sales office. On an annual basis, these individuals are
required to complete the following training:
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All Registered Representatives
- Anti-Money Laundering
- Ethics: The Importance of Ethical Behavior
- Conflicts of Interest
- Considerations for Working w/ Seniors
- Electronic Communication for Registered Representatives
- Spreading of False Rumors and Market Manipulation
- Fixed and Variable Annuities vs. Mutual Funds
- Taxable Fixed Income Investing
- Managed Futures
- A Professional’s Guide to NASD Rules on Variable Annuity and Variable Insurance Prospecting
- Annual Compliance Meeting
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Registered Supervisors
- Variable Annuities: Requirements for Supervisors
- Supervisory Considerations for Working with Seniors
- A Supervisors Role in Deterring the Spreading of False Rumors and Market Manipulation
Exceptions
Certain individuals are also subject to extensive educational training, which would meet or exceed the firm’s
annual requirements. Those individuals listed below are exempt from the firm's annual CE requirement for
the calendar year they are hired or licensed.
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New Employees of the firm, who complete or participate in firm element CE at their previous firm, may
be awarded credit at Ziegler if they provide documentation showing the CE was completed.
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Employees who complete the Series 6 or 7 examinations as the recommended number of self study hours
for these examinations is 90—120 hours.
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Participants of the ZONE training conducted onsite at the Ziegler offices.
ALL employees must complete Anti-Money Laundering (AML) training each year. There will not be any
exceptions granted from this training requirement.
III. ADMINISTRATION OF THE TRAINING PLAN
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Delivery
Training may be delivered by a variety of methods. They may include, but are not limited to the following:
- Direct participation sessions with instructors or discussion leaders
- Supervised independent study, assigned reading or internally generated material
- Meeting, conferences
- Computer-based training
- Training by approved vendors
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Ziegler’s Continuing Education Vendor
Ziegler has chosen Quest as its CE supplier for online, self-study training materials. All covered persons will
be given access to www.zieglerce.com on which the above-listed training requirements will be available for
completion. Required coursework will be available through this site as will elective training which is available
for use to fill-in credit requirements as needed.
B.C. Ziegler and Company | Member SIPC & FINRA
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Documentation and Record Keeping
Participation in an educational program designed to meet initial and/or ongoing requirements of a
professional designation program in a field related to the securities industry (i.e. CFA, CFP, etc.) may qualify
for credit toward the firm’s annual training requirements. The employee participating in such training must
document and provide an agenda of the training to Compliance. The employee should be prepared to
demonstrate that the content is consistent with the requirements of the Firm Element training plan.
Any program attended for CE credit that is not sponsored by Ziegler requires the employee to maintain copies
of any books, handouts, agendas or outlines provided during the training session. These items must be
retained for three full years. These materials will need to be submitted to Compliance for review in
determining the amount of Firm Element credit which is awarded for such training.
Tracking of all employees’ progress toward completion of the annual training requirements will be maintained
by the Compliance Department in Chicago.
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Feedback
All training programs sponsored by Ziegler will provide for appropriate feedback or evaluation to contribute
to modifications of the program or the planning of future programs.
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Enforcement
Securities regulations and company policy require individuals to participate in the company-sponsored CE
program each year. Individuals who fail to satisfy the required CE training for their particular employee
category will be subject to suspension of their registration. Such a suspension will result in restrictions on
their activities as it relates to their activities in the securities industry (i.e., no securities transactions, no
offering positions to other dealers, no payment of commissions, trail commissions, sales credits, fees (of any
sort) or any compensation requiring specific securities industry registration), until the CE requirements are
appropriately met. The Compliance Department will strictly enforce this policy.
B.C. Ziegler and Company | Member SIPC & FINRA
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