Although he was non-executive chairman, Thompson may still be bound by the same rules as the executive directors who worked at Farepak full-time.
If the Department of Trade and Industry find the directors guilty of any wrongdoing, they could be disqualified from holding office at public or private companies for between two and 15 years.
The DTI has just begun its investigation into the collapse of the company, which cost its customers£50 million. It is far from clear whether any blame will be attributed to the directors.
Livingston MP Jim Devine has also called on regulators to launch an investigation into the unusual share trading prior to the collapse of Farepak.
Almost three times more shares than usual changed hands in Farepak's parent company, European Home Retail, the day before the firm's shares were suspended in August.
Around 52,000 shares changed hands on August 23, compared with a daily average of 17,000. A further 147,000 shares had been traded four days earlier.
Devine said: 'This does seem rather bizarre and is another revelation in this ongoing scandal.'
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