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					                               Compliance Department | Chicago, IL | compliance@ziegler.com


                       2009 Firm Element Continuing Education Training Plan
Dated                 August, 20 2009 (Updated)
Audience              The Ziegler Companies, Inc.
Effective date        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              Assigned Training                                Source                                Completed By
Administration -
All Registered Reps           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
Alternative Investments-
All Registered Reps           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




B.C. Ziegler and Company | Member SIPC & FINRA                                                                             1
Business Unit             Assigned Training                                       Source                                Completed By
Capital Management -
All Registered Reps          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
Capital Markets -
Trading & Sales              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
Capital Markets              Anti-Money Laundering                               Quest CE/Ziegler Compliance Staff     January 31, 2010
Investment Banking           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
Capital Markets              Anti-Money Laundering                               Quest CE/Ziegler Compliance Staff     January 31, 2010
Consulting                   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
Capital Markets -
Mergers & Acquisitions       Anti-Money Laundering                               Quest CE/Ziegler Compliance Staff     January 31, 2010
/Corporate Finance
                             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
Capital Markets -
Research                     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




B.C. Ziegler and Company | Member SIPC & FINRA                                                                                   2
Business Unit              Assigned Training                                              Source                              Completed By
Wealth Management -
All Registered Reps           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   Quest CE                            January 31, 2010
                               and Variable Insurance Prospecting
                              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
Wealth Management
Supervisors                   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     Quest CE                            January 31, 2010
                               Rumors and Market Manipulation



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                                                                                         3
         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                                    4
         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                      5
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:
    -   Anti-Money Laundering
    -   Ethics: The Importance of Ethical Behavior
    -   Conflicts of Interest
    -   One Elective
    -   Annual Compliance Meeting

   Alternative Investments
    All registered individuals who are part of this business unit, are required to take the following training:
    -   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:
    -   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                                                                                         6
   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:
    -   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

   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:
    -   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:
    -   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:
    -   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:
    -   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                                                             7
   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:
    –   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

    -   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.
    -   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.
    -   Employees who complete the Series 6 or 7 examinations as the recommended number of self study hours
        for these examinations is 90—120 hours.
    -   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
   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

   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                                                              8
   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.

   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.

   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                                                                  9

				
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