ria-fiduciary-conflict-disclosure
RIA — Fiduciary Conflict-of-Interest Disclosure
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.