RIA — Fiduciary Conflict-of-Interest Disclosure

Activate when: identifying/disclosing conflicts in ADV 2A; compensation that varies by product; affiliated custodian/manager; rollover recommendations; 'is this a conflict we must disclose?'. Do NOT activate when: no advisory relationship / no agency duty.

Industry front door for principal-agent. Adds domain triggers, example, packs only. Parent Process unchanged. Not legal advice.

Activate when: identifying/disclosing conflicts in ADV 2A; compensation that varies by product; affiliated custodian/manager; rollover recommendations; "is this a conflict we must disclose?" Do NOT activate when: no advisory relationship / no agency duty.

Why this variant

The parent principal-agent analyzes misaligned incentives between an agent and the principal they serve. An RIA is a fiduciary — the principal-agent problem is the regulatory core. The duty: eliminate or fully & fairly disclose every conflict so the client can consent.

Domain inputs → parent's Process

• Enumerate where the advisor's interest diverges from the client's: fee tiers, revenue sharing/12b-1, proprietary products, affiliated custodian, rollover-to-AUM incentives, side compensation.
• For each: can it be eliminated? If not, disclose fully and fairly (specific, not boilerplate) + mitigate.
• Confirm the recommendation still meets the best-interest / duty-of-care standard independent of the advisor's benefit.

Worked example

Recommending a 401(k) rollover into an AUM-fee account. → Classic conflict: advisor earns more if assets roll in. Duty: document why the rollover is in the client's best interest (fees, services, options compared), disclose the compensation conflict specifically. Undocumented = exam finding.

Compliance anchors

• Advisers Act fiduciary duty (SEC 2019 interpretation); ADV 2A conflict disclosure; DOL/best-interest for rollovers as applicable.

Packs

• Solo: conflicts inventory refreshed with ADV annually.
• CCO: rollover best-interest documentation template.

Red flags

• Boilerplate "we may have conflicts" instead of specific disclosure.
• Rollover recommended with no comparison documented.
• Compensation differences by product not surfaced.

Verification

• Conflicts inventory current
• Each conflict eliminated or specifically disclosed + mitigated
• Best-interest rationale documented (esp. rollovers)
• Disclosures match actual practice

---

Part of deciqAI Knowledge Skills. Core method: principal-agent.

---

Part of deciqAI Knowledge Skills — 189 open-source thinking skills that make rigor executable for AI agents. The same skills power every deciqAI agent, which runs them autonomously to operate your company. See it run → https://www.deciqai.com/c/ria-fiduciary-conflict-disclosure · ⭐ Star the repo → https://github.com/deciqAI/knowledge-skills · Contributions welcome.