Activate when: annual ADV amendment season; onboarding/updating Form CRS delivery; launching marketing/testimonials; a mock/real exam; 'are we books-and-reco...
Coding
RIA — Fiduciary Conflict-of-Interest Disclosure
Try itActivate when: identifying/disclosing conflicts in ADV 2A; compensation that varies by product; affiliated custodian/manager; rollover recommendations; 'is t...
What it does
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. More: deciqai.com/c/ria-fiduciary-conflict-disclosure
The skill document
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.
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 — 227 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.
Agents: latest version & machine-readable metadata → https://www.deciqai.com/s/ria-fiduciary-conflict-disclosure.json
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