In April 2018, the SEC proposed an Interpretation Regarding Standard of Conduct for Investment Advisers.  In that proposal, the SEC has proposed to interpret the duty of loyalty (which, combined with the duty of care, constitutes fiduciary duty) as requiring advisers to put client interests ahead of their own and make full and fair disclosure of all material facts of the relationship.  More particularly, the SEC stated that advisers must seek to avoid conflicts of interest and make full and fair disclosure of material conflicts that could affect the relationship.  If you stopped reading the release at this point, you might think this is a clear articulation of what the duty means and how we practice in the area of conflicts.
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