Per the USGBC LEED V4 BD+C: New Construction Enhanced Commissioning website "The CxA may be a qualified employee of the owner, an independent consultant, or a disinterested subcontractor of the design team."

Can a commissioning group, within the project design firm, with no interaction with the design team be considered a "disinterested subcontractor of the design team", can the group be hired directly through the owner or architect.

The LEED D+C: Commercial Interiors Enhanced Commissioning website does not list any criteria on who can be the commissioning agent, does the same hold true as above.

Thank you