What is the current state of the law on fiduciary relationships?

Placing the concept of fiduciary in its historical perspective, LaForest J. observed at page 408: …One may begin with the following words of Dickson J. (as he then was) in Guerin v. The Queen, 1984 CanLII 25 (SCC), [1984] 2 S.C.R. 335, at p. 384: …where by statute, agreement, or perhaps by unilateral undertaking, one party has an obligation to act for the benefit of another, and that obligation carries with it a discretionary power, the party thus empowered becomes a fiduciary…. It is sometimes said that the nature of fiduciary relationships is both established and exhausted by the standard categories of agent, trustee, partner, director and the like. I do not agree. It is the nature of the relationship, not the specific category of actor involved that gives rise to the fiduciary duty. The categories of fiduciary, like those of negligence, should not be considered closed. [[emphasis added]] This conceptual approach to fiduciary duties was given analytical structure in the dissenting reasons of Wilson J. in Frame v. Smith, 1987 CanLII 74 (SCC), [1987] 2 S.C.R. 99, at p. 136, who there proposed a three-step analysis to guide the courts in identifying new fiduciary relationships. She stated that relationships in which a fiduciary obligation has been imposed are marked by the following three characteristics: (1) scope for the exercise of some discretion or power; (2) that power or discretion can be exercised unilaterally so as to effect [sic] the beneficiary’s legal interests; and, (3) a peculiar vulnerability to the exercise of that discretion or power…, Wilson J.’s mode of analysis has been followed as a “rough and ready guide” in identifying new categories of fiduciary relationships: .. [authorities omitted]