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Conflict of Interest

Comptroller's Handbook

Conflicts of Interest

June 2000

A bank that provides asset management services for clients may be required to manage a variety of actual or potential conflicts of interest. Conflicts of interest and self-dealing transactions normally arise whenever the bank’s ability to act exclusively in the best interest of account beneficiaries or clients is impaired. A fiduciary is required by a long history of case law to put the interests of account beneficiaries before the interests of the bank. The fiduciary owes its beneficiaries undivided loyalty and must administer each trust for the exclusive benefit of account beneficiaries and the purposes for which the account was created.

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