Tag: constructive fraud
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Fiduciary Papers #7: What Steps are Required to Properly Manage a Conflict of Interest Held by An Investment Adviser?
While the SEC has provided an interpretative release [SEC Release IA-5248, Commission Interpretation Regarding Standard of Conduct for Investment Advisers (July 12, 2019)] regarding the fiduciary duties of investment advisers, its explanation of the proper management of unavoided conflicts of interest left much to be desired. In this article I modify, and add substantially to,…