I followed the practices that were communicated to me in the transition as the chair of the board of SDTC. I was responsible for the governance of that organization, which included four committees. That committee structure was critical, and among the board of directors that I worked with, I genuinely thought I was following all of the conflict of interest guidelines.
The commissioner clearly indicated that I made two mistakes: the technical mistake of not recusing myself instead of abstaining, as well as listening to the advice of legal counsel that he felt was flawed.