In terms of recommendation 4, regardless of who initiates them, right now if a designated public office holder initiates a request for a meeting with a lobbyist to discuss the introduction of a policy or program or the changing of a bill, those particular encounters do not need to be filed in terms of a monthly communication report. The only ones that do are the ones that deal with a financial benefit.
When you're looking at one way those transparencies...certain meetings are likely not being captured because a public office holder is initiating the meeting. This is one way of ensuring that all those key meetings, which is what the act is about, would be captured that way, so that's this particular one.
In terms of recommendation 5, the ultimate undertaking, what we have started to find is that lobbying firms are hiring a consultant lobbyist who is doing work on behalf of a company. So the act requires them to list their client, the person benefiting. Some were initially putting the lobbying firm, but the lobbying firm is not the ultimate beneficiary; it's the gas company or something behind them that hired the lobbying firm. What we have done with those now registering, when we see that, is to put who the ultimate beneficiary is, the firm. So that is showing now on the registration.
To make it clearer in the legislation, my suggestion is that the requirement be there, so that it's the ultimate beneficiary. It avoids the situation whereby somebody may be hiring a middleman and the middleman is using the lobbying firm as their client.