If former FBI director Louis Freeh wanted a cozy business relationship with the NCAA, he more than got his wish.

Documents show that Freeh -- the controversial author of the report used to punish Penn State in the wake of Jerry Sandusky scandal -- has been angling since at least 2010 to do business with the NCAA. On Thursday, he began working for the NCAA.

Freeh is one of the 10 so-called independent investigators in the NCAA's new Complex Case Unit. The sweeping change to the NCAA enforcement model was recommended by the Rice Commission on College Basketball in the wake of its investigation into the Varsity Blues hoops scandal.

Five of the 16 persons on that new unit are employed by Freeh Group International Solutions. That's the same firm that was criticized for conflict of interest this year for soliciting NCAA business while conducting what was supposed to be independent review of Penn State in the Sandusky scandal.

That conflict of interest claim was made before all the Freeh employees popped up in the new enforcement model. There are no more than three persons from any other firm on the Complex Case Unit. All members of the unit will be paid by the NCAA.

A confidential report released in February by a group of seven Penn State trustees said Freeh's firm has been "speculating … about ways to get business from the NCAA" since 2010.

Upon Emmert's hiring that year, Freeh suggested his firm "launch a targeted" business development plan aimed at the NCAA, according to the trustees.

There have long been calls for the NCAA to dump its sometimes controversial enforcement model in place of independent, third-party investigators.

According to an email released by the trustees, Amy Chisholm, one of the five Freeh employees in the Complex Case Unit, contacted the NCAA in 2012 and suggested her company become involved in forming what essentially evolved into the NCAA's new Independent Accountability Resolution Process (IARP), also announced Thursday.

Several persons involved in college athletics told CBS Sports on Thursday they were surprised Freeh was among those investigators chosen, if only because of the appearance of a conflict of interest. One of those observers jokingly suggested the NCAA hire a "vice president of optics" considering the Freeh-heavy makeup of the Complex Case Unit.

Essentially, it's hard to be an independent investigator of NCAA schools when you're trying to do business with the NCAA.

The IARP was developed to "minimize perceived conflicts of interest," according to the NCAA's press release. The Complex Case Unit on which Freeh serves has no school or conference affiliation. That group also includes powerful attorney Tom Mars, who will act as an "advocate" in deciding which cases go forward.

The unit will hear only the most high-profile cases going forward with those found guilty by the Independent Resolution Panel having no chance to appeal.

No appeal?

That's another controversy for another time. We'll see how schools react to a final judgment on college matters from a 15-person group that includes exactly one college administrator -- Tennessee athletics director emeritus Joan Cronan.

There has been no clear definition of what high-profile or complex cases will be heard or whether any of those cases include those involved in the Varsity Blues scandal.

Meanwhile, the NCAA desperately wants to regain its credibility on the enforcement front. The Freeh Report, released in July 2012, concluded that former Penn State coach Joe Paterno and school administrators failed to protect the welfare of children in the Sandusky scandal. Almost immediately, the report was discredited by some Penn State trustees for shoddy interviewing techniques that allegedly led to flawed conclusions, according the critics.

The NCAA adopted the findings in the report to punish Penn State football with unprecedented penalties. At least one member of the NCAA Executive Committee -- who cited a violation of the NCAA Constitution in justifying the Penn State sanctions -- said he had not read the report.

Freeh has doggedly defended the credibility of the report. The former FBI director was appointed by President George H. W. Bush in 1991. Freeh left office in 1993. His company, Freeh Group International Solutions, calls itself "a global risk management firm serving in the areas of business integrity and compliance."

In 2012, while the Penn State case was ongoing, PSU trustees pointed to the Court of Arbitration of Sports overturning a FIFA decision on a World Cup bribery scandal that was based on one of Freeh's investigations. The court said Freeh "did not sufficiently investigate" key evidence.

If you believe any of those criticisms, a discredited Freeh report was used to convict Penn State in arguably the biggest scandal in NCAA history. Now the author of that report and his company have essentially become partners in a different endeavor.