> Whatever regulatory outcome occurs here will affect all trading firms, which means that all advisors will have been paid by someone at some stage in the past

> Whatever regulatory outcome occurs here will affect all trading firms, which means that all advisors will have been paid by someone at some stage in the past affected by any outcome. That's unavoidable, but it doesn't change the absolutely controllable and simple request that the investigator not have a direct relationship with the firm in question. > That is not how conflict of interest works. If there is no current relationship, and no indication of a future relationship (e.g. quid pro quo or a promise of employment), and no obvious link to the firm (e.g. an unpaid board seat, etc), then I am finding it hard to see how a conflict of interest might occur. Conflicts of interest do not have to be concurrent in order to be disqualifying. Recusal as an administrative official is generally warranted when one's impartiality could be reasonably questioned due to some significant past-or-present relationship with the parties involved that reaches beyond their role as a public servant.