Fiduciary duty requires investment advisers to disclose conflicts, maintain arm's-length conduct and avoid third-party remuneration. Investment advisers must disclose material business and disciplinary information, holdings in recommended products, conflicts of interest, product features and warnings; act in a fiduciary capacity with ongoing conflict disclosure; not accept remuneration for recommended products from anyone other than the client; maintain arm's-length relationships and client-level segregation between advisory and distribution; refrain from transacting on their own account contrary to advice for a short restricted period unless they revise and notify the client in advance; and implement risk profiling, suitability and transparent implementation services with disclosed fees.