Following oral argument, on January 24, 2018, the Circuit Court of Florida, Leon County, declared ICA insolvent and placed the company in liquidation, appointing Florida's Department of Financial Services as receiver. We nonetheless continue to refer to appellant as ICA throughout this opinion.

We acknowledge the value of disclosure, transparency, and ethical conduct on the part of all arbitrators. See Ostrager, supra , at 535 (noting disclosure "enables the parties to identify potential problems at the outset and[ ] to avoid later claims of prejudice by losing parties"). Mainstream arbitral guidelines such as ARIAS and the American Arbitration Association require comprehensive disclosure. See id . at 535-36 (citing the Code of Ethics for Arbitrators in Commercial Disputes); ARIAS-U.S. Practical Guide to Reinsurance Arbitration Procedure, ¶ 3.6. It would appear that Alex Campos violated these ethical codes; and future parties may well be wary of his participation on panels. However, it is well-established that such ethical violations do not compel vacatur of an otherwise-valid arbitration award. See Ostrager, supra , at 536 (citing Merit Ins. Co. v. Leatherby Ins. Co. , 714 F.2d 673 , 680 (7th Cir. 1983) ). An arbitrator's "failure to make a full disclosure may sully his reputation for candor but does not demonstrate evident partiality." Sphere Drake Ins. v. All American Life Ins. , 307 F.3d 617 , 622-23 (7th Cir. 2002).

In Florasynth, Inc. v. Pickholz , 750 F.2d 171 (2d Cir. 1984), we were confronted with another tripartite arbitration panel and observed that the "two [party-appointed arbitrators] were not to act merely as partisan advocates directing argument to a third [arbitrator] who would act as umpire" and that the arrangement instead suggested "the three arbitrators were intended to serve and act as one board." Id. at 173 . However, that observation was dictum only, see ids="628843" index="87" url="https://cite.case.law/f2d/750/171/"> id. at 174-74 ; see also Scandinavian Reinsurance , 668 F.3d at 76 n.21 (noting that Florasynth only "suggest[ed]" party-appointed arbitrators not act as advocates), and we therefore are not bound by that language today.

The district court was disturbed by Campos's lack of candor, but also by the length and number of his connections. Not all of them are significant. Even holding Campos to the standard of a neutral arbitrator, the relationships between his company, Vensure, and John Iorillo, Robert Morely, and Benton Morely are likely too remote, indirect, and removed in time from the arbitration to be material. See Lucent Techs ., 379 F.3d at 31 ; Scandinavian Reinsurance , 668 F.3d at 72, 74 . And the presence of two insurance agencies within the same Arizona business park does not reach the level of clear partiality. See Merck , 2016 WL 4491441 , at *10. Campos's on-going relationship with Ricardo Rios is more direct, intimate, and more closely proximate to the arbitration; Rios also offered testimony before the panel. Rios's credibility (in which Campos may have been invested) could have been material to the Award.

Several tests have been proposed for neutrals. See Sanford Home for Adults v. Local 6, IFHP , 665 F.Supp. 312 , 320 (S.D.N.Y. 1987) (proposing a three-part test for evaluating the partiality of an arbitrator: "(1) the financial interest the arbitrator has in the proceeding; (2) the directness of the alleged relationship between the arbitrator and a party to the arbitration proceeding; and (3) the timing of the re