In addition, part of this issue really boils down to a very simple difference. The commissioner's duty to refer a matter to the RCMP arises when she has reasonable grounds to believe that there may have been an offence under the Lobbying Act or any other law. Then the RCMP will conduct their investigation and consult with their legal counsel. In essence, they look at whether they can prove all elements of the offence beyond a reasonable doubt, in a court of law, which is a higher standard of proof. That is the way the system works.
That explains the discrepancy, in my mind anyway, between the number of cases referred to the RCMP and then, months later, the RCMP in consultation with the prosecutors decide that no, they are not going to be laying charges in this case because they don't believe there is a reasonable probability of conviction.