Iowa Code

Iowa Code § 633.155 (2026)

Self-dealing by fiduciary prohibited

✓ current as of July 2026
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No fiduciary shall in any manner engage in self-dealing, except on order of court after notice to all interested persons, and shall derive no profit other than the fiduciary’s distributive share in the estate from the sale or liquidation of any property belonging to the estate. Every application of a fiduciary seeking an order under the provisions of this section shall specify in detail the reasons for such application and the facts justifying the requested order. The notice shall have a copy of the application attached, or, if published, it shall contain a detailed statement of the reasons and facts justifying the requested order. [C51, §1427; R60, §2452; C73, §2473; C97, §3397; C24, 27, 31, 35, 39, §12048; C46, 50, 54, 58, 62, §638.8; C66, 71, 73, 75, 77, 79, 81, §633.155] Referred to in §633.156, 633.642

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Notes of Decisions
Cited in 20 cases (4 in the last 5 years), 1971–2026 · leading case: Coster v. Crookham, 468 N.W.2d 802 (Iowa 1991).
Coster v. Crookham, 468 N.W.2d 802 (Iowa 1991). · cites it 16× “Iowa Code § 633.155 provides in material part: No fiduciary shall in any manner engage in self-dealing, except on order of court after notice to all interested persons, and shall derive no profit other than the fiduciary’s distributive share in the estate from the sale or…”
Matter of Est. of Snapp, 502 N.W.2d 29 (Iowa Ct. App. 1993). · cites it 8× “Iowa Code section 633.155, in pertinent part, provides: No fiduciary shall in any manner deal with himself, except on order of court after notice to all interested parties, and shall derive no profit other than his distributive share in the estate from the sale or liquidation of…”
Iowa Supreme Court Bd. of Prof'l Ethics & Conduct v. Remer, 646 N.W.2d 91 (Iowa 2002). · cites it 4× “See Iowa Code § 633.155 (2001). The granting of court approval is conditioned on giving notice and an opportunity to be heard to all interested persons.”
Jackson v. Schrader, 676 N.W.2d 599 (Iowa 2003). · cites it 2× “Iowa Code section 633.155 recognizes that self-dealing by a fiduciary in a probate setting may occur if approved by court order.”
In Re Guardianship of Jordan, 616 N.W.2d 553 (Iowa 2000). · cites it 6× “Iowa Code § 633.155 (1987). The granting of court approval requires notice and opportunity to be heard on the part of all interested persons.”
Matter of Est. of Phoenix, 493 N.W.2d 79 (Iowa Ct. App. 1992). · cites it 6× “Iowa Code section 633.155 (1981) provides: No fiduciary shall in any manner engage in self-dealing, except on order of court after notice to all interested persons, and shall derive no profit other than the fiduciary’s distributive share in the estate from the sale or…”
Harvey v. Leonard, 268 N.W.2d 504 (Iowa 1978). “This case law has been codified in § 633.155, The Code, 1977, passed since the self-dealing transactions in the present case, which prohibits self-dealing transactions on the part of fiduciaries unless such transactions are allowed by court order after all interested persons…”
Iowa Supreme Court Attorney Disciplinary Bd. v. Richard J. Murphy, 800 N.W.2d 37 (Iowa 2011). “§ 633.155. A conservator may make gifts on behalf of a ward from assets of the conservatorship, but only when authorized by the court under special circumstances.”
Hanrahan v. Kruidenier, 473 N.W.2d 184 (Iowa 1991). · cites it 2× “See Iowa Code §§ 633.155 and 633.160 (1991). See Coster v.”
In Re Est. of Jarvis, 185 N.W.2d 753 (Iowa 1971). · cites it 2× “Following hearing on charges by Fred that John was personally involved in the problem of marshalling assets and would be involved in self-dealing contrary to Code section 633.155, the lower court on March 18, 1967 appointed Andrew J.”
Matter of Est. of Atwood, 577 N.W.2d 60 (Iowa Ct. App. 1998). · cites it 2× “Iowa Code section 633.155 (1981) states: No fiduciary shall in any manner engage in self-dealing, except on order of court after notice to all interested persons, and shall derive no profit other than the fiduciary’s distributive share in the estate from the sale or liquidation…”
Iowa Supreme Court Bd. of Prof'l Ethics & Conduct v. Remer, 617 N.W.2d 269 (Iowa 2000). · cites it 2× “The issue in that case was whether there was “adequate reason for the transaction[s]” in which the conservator engaged as required by Iowa Code section 633.155 (1987). In re Guardianship & Conservatorship of Jordan, 616 N.”
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