---
name: ria-fiduciary-conflict-disclosure
description: "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."
---

# RIA — Fiduciary Conflict-of-Interest Disclosure

> **Industry front door for [principal-agent](../principal-agent/SKILL.md).** 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](../principal-agent/SKILL.md) 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](../principal-agent/SKILL.md).

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*Part of **deciqAI Knowledge Skills** — 225 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/s/ria-fiduciary-conflict-disclosure** · Built by deciqAI · github.com/deciqAI · Contributions welcome.*