dissenting.
The “evident partiality” analysis necessarily entails a fact-intensive inquiry, and in this area of the law, bright-line legal rules are sparse, and analogous cases are difficult to find. Mariner Fin. Group, Inc. v. Bossley, 79 S.W.3d 30, 34 (Tex.2002). Given the facts of this case, the court errs in concluding that the arbitrator, an attorney, exhibited evident partiality by failing to disclose an attorney-client relationship with a trade association which was neither a party nor a witness and whpse relationship with the arbitrator could not reasonably have been perceived as creating an impression of partiality in the eyes of an objective observer. See Burlington N.R.R. Co. v. TUCO, Inc., 960 S.W.2d 629, 636-37 (Tex.1997).
Though our case law gives relatively little guidance on where to draw the fine on disclosure of indirect ties such as the one at issue here, it is clear that not every relationship, connection, or interest is subject to disclosure under the TUCO standard. See Mariner Fin. Group, Inc., 79 S.W.3d at 32 (quoting TUCO as stating a “neutral arbitrator need not disclose relationships or connections that are trivial.”). That is why it is so important for courts to scrutinize both the nature and the directness of the interest or relationship in determining whether disclosure is required.
Under TUCO ⅛ objective test, “the consequences for nondisclosure are directly tied to the materiality of the unrevealed information.” Mariner Fin. Group, Inc., 79 S.W.3d at 32. To warrant vacatur of the arbitration award based on evident partiality, the arbitrator’s connection to a party, its counsel, or a witness should be material and strongly suggestive of partiality. See Mariner Fin. Group, Inc., 79 S.W.3d at 33 (noting that the relationship in TUCO arose from a lucrative business referral to one of the arbitrators and thus was not trivial); J.D. Edwards World Solutions Co. v. Estes, Inc., 91 S.W.3d 836, 844 (Tex.App.-Fort Worth 2002, pet. filed) (finding evident partiality where arbitrator failed to disclose attorney-client relationship with party to arbitration); accord Texas Commerce Bank v. Universal Techical Inst. of Tex., Inc., 985 S.W.2d 678, 680-81 (Tex.App.-Houston [1st Dist.] 1999, pet. dism’d w.o.j.). Here, the arbitrator, Stephen Paxson, had no undisclosed connection to any party, lawyer, or witness in the arbitration. The “unrevealed information” was an attorney-client relationship between Paxson and Greater Houston Builders Association (“GHBA”), a large trade association that was neither a witness nor a party and which had no cognizable interest in the arbitration.
Though our high court has adopted a very broad standard for arbitrator disclosures, the standard is not without limits and those limits are defined by reasonableness. See TUCO, Inc., 960 S.W.2d at 636 (holding that a potential arbitrator should disclose facts that, to an objective observer, might create a “reasonable impression” of partiality; and “the parties must have access to all information which might reasonably affect the arbitrator’s partiality.”) (emphasis added). An outside observer might form any impression about the arbitrator’s partiality, but unless the impression is a reasonable one to objective eyes, it will not support a finding of evident partiality. See id.
Because the reasonableness of an impression of partiality is dependent on whether the undisclosed information was material, the outcome in this case hinges *37on the materiality of the Paxson-GHBA attorney-client relationship vis-a-vis the arbitration. See Mariner Fin. Group, Inc., 79 S.W.3d at 32. As explained below, though additional facts not present here could have made that relationship material and thus made disclosure necessary under TUCO, this relationship in and of itself did not give rise to a reasonable impression of arbitrator partiality and thus did not require the arbitrator to disclose it.
Houston Village Builders, Inc. (“Village Builders”) and its parent company, Lennar Homes are only two of approximately 1350 members of GHBA. Individual membership in an association of that size does not carry with it the rights, privileges, control, and influence typically enjoyed by an association’s leadership, management, or elected board of directors. Consequently, an objective observer would not attribute any significant influence to an individual member, and thus could not reasonably conclude that two of GHBA’s 1350 members could have such weight and influence by virtue of mere membership that the association’s lawyer, while serving as an arbitrator in a non-GHBA dispute, might feel compelled to rule for them simply because they are members.
The Falbaums were not required to prove Paxson was actually biased in favor of Village Builders and Lennar Homes. See TUCO, Inc., 960 S.W.2d at 636. But they must point to something that would have caused an objective observer to conclude that his impartiality might be compromised because he was GHBA’s lawyer. See id. An objective observer could not conclude, without speculating, that it somehow would be better for GHBA (or Paxson) if one side prevailed. The impression of partiality must be reasonable and a reasonable impression is not based on speculation, conjecture or surmise, but on an objective view of the facts. See TUCO, Inc., 960 S.W.2d at 636 (holding that the impression of partiality must be reasonable); Briones v. Levine’s Dept. Store, Inc., 446 S.W.2d 7, 10 (Tex.1969) (holding that a reasonable inference cannot be based on speculation).
The majority asserts that its conclusion is reasonable and not speculative because the record shows that Paxson represented GHBA in two unrelated cases that involved similar issues. Though the majority points to GHBA’s interest in these cases, it does not explain how or why that interest is any indication of a GHBA interest in the Falbaums’ dispute with Village Builders and Lennar Homes.1 The majority does not identify any reason it would or might be better for GHBA if either side prevailed, nor does the majority explain how or why GHBA might have an interest in seeing Village Builders or Lennar Homes prevail over the Falbaums in the arbitration. Whatever position GHBA may have taken (or Paxson may have asserted on behalf of GHBA) in two other cases is no indication of a cognizable interest in an unrelated non-GHBA arbitration. GHBA had no stake in the subject matter of the arbitration, and the arbitration could not possibly have created any binding precedent for any other case. See El Dorado Tech. Servs., Inc. v. Union General de Trabajadores de Puerto Rico, 961 F.2d 317, 321 (1st Cir.1992) (“It is black letter law that arbitration awards are not entitled to the precedential effect accorded to judicial decisions.”) Because there was nothing to suggest to an objective observer that what might happen in the arbitration would or could have any implication for GHBA, it is pure speculation for the majority to conclude that GHBA’s interest in two unrelated cases might give the impres*38sion of Paxson’s partiality in the arbitration.
Moreover, it is not reasonable to conclude that a 1350-member trade association or its lawyer would be concerned with the outcome of a non-association dispute between two individual members and third parties. Trade associations are typically concerned with furthering the interests of the industries they serve rather than advancing the private interests of their individual members. Nothing in the record suggests that GHBA is motivated by anything other than the collective interests of its members. There is certainly nothing that would suggest to an objective observer that GHBA provides support or assistance to individual members in connection with their individual disputes with third parties or that GHBA counseled, assisted, or supported Village Builders or Lennar Homes regarding their dispute with the Falbaums. It is not reasonable to attribute the views and desires of two individual members to a large association to which they belong. The views of an individual member do not necessarily reflect the views of an organization; and the goals and desires of an individual member do not necessarily reflect the interests and objectives of the organization. GHBA had no interest of any kind in the arbitration and there was no reasonable basis for an objective observer to conclude that its lawyer, while serving as an arbitrator in a non-GHBA dispute, would favor either side in the arbitration.
Though the majority does not suggest or identify any reason it would or might be better for GHBA if Village Builders and Lennar Homes prevailed in the arbitration, the majority implicitly attributes an “industry member should always win” mentality to GHBA. An objective observer would not do so. An objective observer would consider the nature and purpose of an organization like GHBA, and conclude that trade associations, which are typically concerned with promoting good industry practice, would condemn, not sanction, conduct of an industry member that fell below that standard. Consequently, an objective observer would not conclude, as the majority does, that a trade association that was a stranger to a builder-homeowner dispute might have an “interest” in it solely because it sided with builders in two other, unrelated cases. Applying that logic, one could just as easily resolve that an objective observer might conclude that the American Bar Association has an interest in seeing the lawyer prevail over the client in every legal malpractice case, or that the American Medical Association has an interest in seeing the doctor prevail over the patient in every medical malpractice case. Neither conclusion is reasonable. An objective observer would not conclude that GHBA had an interest in seeing the builder prevail over the homeowner in every residential construction case and would not conclude that GHBA had an interest in seeing Village Builders and Lennar Homes prevail over the Falb-aums in this arbitration.
Nor would an objective observer conclude that Paxson’s representation of GHBA in two unrelated cases might impact his impartiality as an arbitrator in the Falbaums’ dispute with Village Builders and Lennar Homes. When an attorney dons an arbitrator hat, he takes an oath to consider only the evidence presented by the parties, to cast aside any personal opinions he might have, and to base his award on the applicable law and the facts before him. It is only when there is something which might cause an objective observer to reasonably question the arbitrator’s ability to do so, that disclosure is required. See TUCO, Inc., 960 S.W.2d at 636.
*39An objective view of the facts shows GHBA’s only connection to the arbitration is that the arbitrator was one of the lawyers that performed legal work for the association. But the arbitrator’s attorney-client relationship with GHBA is not tantamount to an attorney-client relationship with its individual members. In representing GHBA, Paxson does not represent each of its 1350 members. See Sutton v. Mankoff, 915 S.W.2d 152, 157-58 (Tex.App.-Fort Worth 1996, writ denied) (holding that an attorney retained to represent an entity does not represent its individual members). Though Paxson’s client list includes . companies that are members of GHBA, he also has represented third parties against members of that association. The disclosure materials stated that Pax-son concentrated 70% of his law practice in the construction area, primarily representing general contractors, builders, developers, designers, owners, subcontractors, and speciality contractors involving private commercial and residential projects. Common sense suggests that a lawyer who concentrates in the construction area and represents a host of non-builders as part of his legal practice, from time to time, would be adverse to builders who are members of GHBA, particularly given the size of the trade association. Thus, it would not be reasonable for an objective observer who knew these facts about Paxson’s law practice to conclude that an arbitrator in Paxson’s position might be influenced into ruling in favor of a trade-association member merely “to protect his status as the association’s counsel.”2 Nor would it be reasonable for an objective observer to draw this conclusion even if these facts had not been disclosed because in the context of a non-GHBA dispute, the GHBA membership of Village Builders and Lennar Homes does not reach the materiality threshold necessary to require disclosure of the arbitrator’s attorney-client relationship with GHBA.
Apparently, the only published case in which a court has found evident partiality based on non-disclosure of an attorney-client relationship between the arbitrator and a non-party/non-witness is Schmitz v. Zilveti, 20 F.3d 1043, 1044 (9th Cir.1994). In that case, the non-party was the parent company of one of the parties to the arbitration and a former client of the attorney arbitrator’s law firm. See Schmitz v. Zilveti, 20 F.3d 1043, 1044 (9th Cir.1994). The majority asserts that Paxson’s attorney-client relationship with GHBA can be compared to that of the arbitrator in Schmitz. Noting the absence of any evidence in that case that the parent company controlled the actions of the subsidiary,3 the majority states that the Schmitz court nevertheless concluded the arbitrator’s firm’s prior representation of the parent company was “likely to affect impartiality or [might] cre*40ate an appearance of partiality.” Id. at 1049.
This analogy to the facts of Schmitz is flawed because there are significant factual differences between this case and Schmitz. In Schmitz, the non-party (parent) had an ownership interest in a party to the arbitration — an interest that, by its very nature, gives rise to a relationship of control and influence. It is this relationship — and the financial interest it implicates — that supported evident partiality in Schmitz. An objective observer might form a reasonable impression that an arbitrator whose law firm served as counsel to a parent corporation (non-party) for thirty-five years might be biased in favor of that corporation’s subsidiary (party). Thus, the Schmitz court was correct in finding evident partiality in that case. The facts presented by our record are notably different.
Here, there is nothing to show or even suggest any relationship of control or influence, or any financial interest, between any party or witness to the arbitration and GHBA (the arbitrator’s client), or vice ver-sa. Unlike the arbitrator in Schmitz, Pax-son has never had an attorney-client relationship with one who was in a position of control or influence, by stock ownership or otherwise, with a party to the arbitration. GHBA has never had an ownership interest in Village Builders or Lennar Homes, nor has it ever had any equivalent control relationship or financial interest with or in these parties. Nor is there anything to suggest to an objective observer that Village Builders or Lennar Homes (parties) have any influence or control over GHBA (non-party) and, as previously noted, it would not be reasonable to infer such control or influence in this factual context.
Though Village Builders and Lennar Homes are GHBA members, there is nothing to suggest to an objective observer that either company or any of their employees then played (or anticipated playing) any role in GHBA’s management, operation, or administration. Nor is there anything that would suggest that mere members of GHBA (who are not officers or employees of GHBA) had any past, current, or anticipated future involvement or voice in the selection or retention of GHBA’s legal counsel. And, unlike a scenario involving a parent and subsidiary where control and influence are apparent, it would not be reasonable to conclude that Village Builders or Lennar Homes, only two of 1350 members, were in any position to impact or influence such decisions, or that either of these parties had any current or future influence or control over GHBA’s attorney-client relationship with Paxson.
By concluding that an objective observer might form a reasonable impression “that someone in the Arbitrator’s position might be influenced into ruling in favor of a trade-association member to protect his status as the association’s counsel,”4 the majority fails to credit an outside observer’s objectivity and discernment. An objective observer bases his judgment on observable phenomena — something that is capable of being seen or noticed. In the absence of observable facts that would indicate that two members of a 1350-mem-ber association had some measure of control or influence over the association’s lawyer or within, the association itself, an objective observer could not form a reasonable impression that Village Builders or Lennar Homes would be in a position to impact the arbitrator’s impartiality in a dispute that did not involve the association. If an objective observer formed the *41impression of partiality based solely on Paxson’s ongoing service as counsel for GHBA, that impression would not be reasonable. The connection is simply too attenuated. Absent a nexus that would make the parties’ GHBA membership material, disclosure of this non-party/non-witness attorney-client relationship was not required under TUCO. See Mariner Fin. Group, Inc., 79 S.W.3d at 32.
If there were facts which would suggest to an objective observer that Paxson’s financial interests were implicated by virtue of an attorney-client relationship with a non-party or non-witness, the analysis would change. Indeed, an objective observer might reasonably conclude that an attorney arbitrator might be partial to a party who is in a position to direct or influence his Ghent’s decisions regarding the attorney arbitrator’s current or future legal business for the non-party. See Mariner Fin. Group, Inc., 79 S.W.3d at 33 (noting that the relationship in TUCO grew out of “a lucrative business referral” to one of the arbitrators and thus was not trivial). An' arbitrator’s financial interest in securing or maintaining his non-party chent’s legal business would support evident partiality in a case involving an undisclosed relationship with a non-party chent of the arbitrator. Thus, if there had been some reasonable basis for concluding that Village Builders, Lennar Homes, or their employees were involved in the decision-making for GHBA’s attorney-client relationships, then Paxson’s pecuniary interests would have been implicated and there would have been a basis for finding evident partiality. See id. But there is no reasonable basis for an objective observer to conclude that any pecuniary interests might have been implicated in this case. There is no evidence — not even an allegation — that Village Builders or Lennar Homes (or anyone affiliated with these parties) had or anticipated any involvement in GHBA’s decisions to retain or select the association’s legal counsel or in the association’s decision to retain Paxson as one of its lawyers.
To summarize, though the presence of additional factors, such as Village Builders or Lennar Homes’ participation in selection of counsel for the association or involvement in its management or administration, might compel the need to disclose the unrevealed information, the mere existence of this non-party/non-witness attorney-client relationship in and of itself would not cause an objective observer to reasonably doubt Paxson’s impartiality. See TUCO, Inc., 960 S.W.2d at 636. Nor does the non-disclosure of the Paxson-GHBA attorney-client relationship, standing alone, suggest that Paxson was concealing something important or material concerning his impartiality in a non-GHBA dispute.
This case brings into sharper focus the tension between attaining full and complete disclosure while, at the same time, avoiding the pitfalls and impracticalities of a system that, in effect, would require the arbitrator to make immaterial disclosures and impose very serious consequences on the parties if he failed to do so. Achieving the former at the expense of the latter encourages litigation and unnecessarily weakens the finality of arbitration.
Ideally, the disclosure process should be both meaningful and practical, undergird-ing the ease, efficiency, and finality that has traditionally characterized arbitration and made it a desirable alternative to litigation. The strong public policy favoring arbitration could be frustrated if attorney arbitrators are compelled to disclose attorney-client relationships with non-parties and non-witnesses that have only tenuous, indirect, immaterial, or remote connections to the proceeding or the parties. TUCO and Mariner do not appear to reach that far.
*42Casting such a -wide net has many negative implications for both the arbitration process and the parties who choose it as a means of resolving their disputes. Potential arbitrators could easily overlook a remote, peripheral, or indirect relationship with a non-party/non-witness group, giving losing parties an easy means of asserting a post-award challenge based on “unrevealed information.” As a result, many an arbitration award could be left hanging by a thread. Given the burdens that accompany compliance with such a sweeping and unforgiving disclosure rule, some potential attorney arbitrators might be reluctant to serve, not only because of the breadth of the undertaking and significant potential for error, but also because of the confidential and sensitive nature of peripheral relationships that arguably might fall within the broad net of required disclosures.5 The unwelcome result is a disincentive for parties to choose arbitration and for lawyers to serve as arbitrators.6
Moreover, an overly broad application of the TUCO standard might actually muddy the waters for parties who are trying to make informed decisions about potential arbitrators. For example, under the majority’s interpretation of TUCO, potential attorney arbitrators might reasonably seek to guard against any future challenge to their arbitration awards by producing long and comprehensive disclosure lists revealing all sorts of remote, indirect, and peripheral non-party/non-witness relationships. As a result, the truly important disclosures might get obscured or overshadowed amid the inconsequential information and the tenuous ties and connections. Paradoxically, though disclosures are meant to clarify and assist in the selection of arbitrators, if not made judiciously, they have the potential to render the entire disclosure process meaningless.
Parties often select arbitration based on its promise of an expedient, inexpensive, and final result. If peripheral connections of the sort at issue here are sufficient to trigger evident partiality, court intervention in the arbitration process will almost certainly increase, undermining the ease, efficiency, and finality arbitration is supposed to provide. See Prudential Securities, Inc. v. Marshall, 909 S.W.2d 896, 900 (Tex.1995) (stating that “the fundamental purpose of arbitration [is] to provide a rapid, less expensive alternative to traditional litigation”). Parties who bargain for arbitration are deserving of these benefits. Of course, they are also entitled to an impartial decisionmaker and a fair process.
Parties cannot be assured a fair process without meaningful arbitrator disclosures. They are the checks and balances for the integrity of the arbitration process, ensuring the parties’ confidence in the neutrality and impartiality of the arbitrator who will decide their dispute. Unquestionably, an arbitrator should and must reveal any circumstances that might hinder the rendering of an objective determination. See TUCO, Inc., 960 S.W.2d at 636. In close cases, potential arbitrators should err on the side of disclosure, revealing information even when the law may not technically require it. See id. at 633. Doing so will help curb abuses by disgruntled parties searching for a means of invalidating an unwanted result based on unrevealed information.
*43Though, in this case, it would have been better if Paxson had expressly disclosed his attorney-client relationship with GHBA, that relationship did not rise to the level of information that an arbitrator is required to reveal under TUCO. The fact Paxson had long served as counsel to GHBA, standing alone, is insufficient to prompt an objective observer to reasonably question his impartiality in a dispute in which that group was not a party or witness and had no interest. In finding that this peripheral relationship had to be disclosed, the court casts too wide a net. Absent facts that reasonably suggest that parties who are members of such a large association have some control or influence, their membership does not make the mere existence of an attorney-client relationship between the arbitrator and a non-party/non-witness trade association material and is not a fact that, to an objective observer, might create a reasonable impression of arbitrator partiality. Therefore, the arbitrator’s failure to reveal this information does not constitute evident partiality and does not warrant vacatur of the arbitration award.
. See ante, op. atp. 33 n. 2 (majority opinion).
. Ante, op. atp. 33.
. See id. at 1043-49. Schmitz is silent as to whether the parent (non-party) controlled the actions of the subsidiary (party), but even if the facts showed that the parent corporation had no day-to-day control over operations of its subsidiary, by definition, the parent owned a controlling interest in the subsidiary’s stock. See United States v. Bestfoods, 524 U.S. 51, 61, 118 S.Ct. 1876, 141 L.Ed.2d 43 (1998) (defining a parent corporation as a corporation that controls the subsidiary through ownership of its stock); Black’s Law Dictionary 344 (7th ed. 1999) (defining "parent corporation” as "[a] corporation that has a controlling interest in another corporation (called a subsidiary corporation), usu. through ownership of more than one-half the voting stock”); see also North Am. Van Lines, Inc. v. Emmons, 50 S.W.3d 103, 120 (Tex.App.-Beaumont 2001, pet. denied) (stating that "control is part of the normal framework of a parent/subsidiaiy relationship”).
. Ante, op. atp. 33.
. See Commonwealth Coatings Corp. v. Continental Cas. Co., 393 U.S. 145, 151, 89 S.Ct. 337, 21 L.Ed.2d 301 (1968) (stating that an arbitrator "cannot be expected to provide parties with his complete and unexpurgated business biography”) (White, J., concurring).
. See id. at 150, 89 S.Ct. 337 ("I see no reason automatically to disqualify the best informed and most capable potential arbitrators.”)