to the relationship between, say, guardian and ward, principal and agent, or trustee and beneficiary. In these latter instances, the inherent character of the relationship is such that the law has traditionally imported general fiduciary obligations. The insurer-insured relationship is contractual; the parties are parties to an arms-length agreement. The principle of uberrima fides does not affect the arms-length nature of the agreement, and cannot be used to find a general fiduciary relationship. The insurance contract, as noted above, imposes certain specific obligations on its parties. These obligations, however, do not import general fiduciary duties into each and every insurance relationship. Before such fiduciary obligations can be imported there must be specific circumstances in the relationship that call for their imposition. In Murray v. Beard, 7 N.E. 553, 554-55 (N.Y. 1886), applying the doctrine of faithless servant, the New York Court of Appeals held that a broker could not recover commissions from his employer, holding that "An agent is held to uberrima fides in his dealings with his principal; and if he acts adversely to his employer in any part of the transaction ... it amounts to such a fraud upon the principal, as to forfeit any right to compensation for services." Limitations Uberrima fides is strictly limited in English law to the formation of the insurance contract. During the mid-20th century, American courts expanded it much farther into a post-formation implied covenant of good faith and fair dealing. Violation of that implied covenant came to be seen as a tort, now known as insurance bad faith. See also Adverse selection Information asymmetry List of Latin phrases References External links Uberrima Fides And Concealment in the Marine Policy Application from the Maritime Law Association of the United States New Hampshire Ins. v. C'Est Moi, Inc. Contract law Insurance law Latin legal terminology