Yes, but they have direction.
This is not numbered. I guess this is point number 1 in your thing, and I quote: “This decision leaves a gap in the Commissioner's powers and will potentially allow” a broad claim of solicitor-client privilege over corporate-held documents to inhibit an OPC investigation, “with no possibility of independent verification” of the appropriateness of the solicitor-client claim, “other than through a formal application to court”.
What's wrong with a formal application to court, for a court to decide whether or not solicitor-client privilege has been lawfully claimed? With no disrespect to your office, I would think that a judge has the expertise and legal training to make that determination better than your office does.
My question is what's wrong with that? Is your concern that it would take too long for a decision to be made on this very specific issue? If so, and if that's the only issue, why can't you make an immediate application to the Federal Court to determine whether or not this particular claim for solicitor-client privilege is lawful? That is the only question.