Does this in BOLD apply to Fung

Taken together, where a claimant is "guilty of misconduct that injures other creditors or confers an unfair advantage" equitable subordination may be invoked to reorder statutory priorities, for example, reducing secured claims to unsecured claims or even equity claims.16 Courts have noted that equitable subordination is "an extraordinary remedy to be employed [...] sparingly".17 The categories of inequitable conduct for which the doctrine is typically invoked include:

1.       fraud, illegality, breach of fiduciary duties