In-house CxA with In-house Design, MEP, and Construction Teams

We're under a scenario that a developer (owner) has in-house design team, in-house MEP team, and in-house construction team working on a single project. In other words, the developer is the owner, the design firm, and the general contractor although the teams are of different departments. The developer is considering bringing an in-house qualified CxA (of another department) to perform enhanced commissioning for the project. So technically, the CxA would be an employee of the design firm, an employee of the general contractor, but at the same time, a qualified employee of the owner. Would this scenario work, or is this too much of the grey area?