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Comment by Brenda Leong
Director of AI Division, ZwillGen PLLC (technology law firm), AI governance and legal expert
We are moving from AI-as-tool, where a human uses a machine to support their own analysis or recommendations, to AI-as-agent, where the machine initiates, decides, and executes, potentially without human involvement. A fiduciary gap emerges in a world of agentic AI. Without a fiduciary standard, the Duty of Loyalty functionally disappears.
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(2026)
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