Key Takeaways

  • Missouri agents owe fiduciary duties including loyalty, obedience, disclosure, confidentiality, accounting, and reasonable care
  • The customer vs. client distinction determines what duties are owed
  • All licensees must treat all parties honestly and fairly regardless of agency relationship
  • Agency relationships are created by written agreement, not by disclosure forms
  • Agents must disclose personal interest in any transaction to all parties
Last updated: January 2026

Missouri Agency Relationships and Duties

Understanding fiduciary duties and the distinction between clients and customers is essential for Missouri real estate practice.

Fiduciary Duties to Clients

Missouri agents owe the following fiduciary duties to their clients:

The Six Fiduciary Duties

DutyDescription
LoyaltyPut client's interests above your own
ObedienceFollow client's lawful instructions
DisclosureReveal all material information to client
ConfidentialityProtect client's private information
AccountingAccount for all money and property
Reasonable CareUse skill, care, and diligence

Loyalty

  • Must not have conflicting interests
  • Cannot profit without disclosure
  • Client's interests come first

Obedience

  • Follow all lawful instructions
  • Cannot follow unlawful directions
  • Must decline illegal requests

Disclosure

  • Reveal all known material facts
  • Share relevant market information
  • Disclose conflicts of interest

Confidentiality

Information that must be kept confidential:

ConfidentialExample
MotivationWhy client is buying/selling
Financial abilityHow much client can afford
Price limitsBottom line or maximum
Personal informationFamily circumstances

Note: Confidentiality survives the agency relationship.

Customer vs. Client

Definitions

TermDefinition
ClientPerson represented by the agent
CustomerPerson NOT represented by the agent

Duties to Customers

Even when not representing someone, licensees owe:

DutyDescription
HonestyCannot lie or deceive
FairnessMust treat fairly
Material disclosureDisclose adverse material facts
No misrepresentationCannot make false statements

Creating Agency Relationships

How Agency is Created

MethodResult
Written agreementCreates agency relationship
Disclosure formInformation only, does NOT create agency
Verbal agreementMay create agency but not enforceable

Key Point: Agency is created by written listing agreements or buyer representation agreements, not by the Broker Disclosure Form.

Personal Interest Disclosure

When to Disclose

Licensees must disclose personal interest to all parties when:

SituationAction Required
Buying for selfDisclose licensee status
Selling own propertyDisclose licensee status
Related party transactionDisclose relationship
Financial interestDisclose any profit interest

How to Disclose

  • In writing
  • Before entering into contract
  • To all parties in transaction

Termination of Agency

How Agency Ends

MethodDescription
CompletionTransaction closes
ExpirationAgreement term ends
Mutual consentBoth parties agree
RevocationPrincipal withdraws
RenunciationAgent withdraws
DeathOf either party
IncapacityOf either party
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Missouri Agency Duties
Test Your Knowledge

Which of the following is a fiduciary duty owed to clients in Missouri?

A
B
C
D
Test Your Knowledge

What creates an agency relationship in Missouri?

A
B
C
D