As long as there is due process, I don't have any issue with monetary penalties. I will say this, though, and I say this sincerely: if somebody is a registered consultant lobbyist and they get named in a report as being offside of these rules, I can't overstate the effect that has on that person's livelihood. That is a very severe sanction. Nobody is going to want to hire somebody who has danced on the wrong side of the line. So don't buy into this notion that having your name in a report isn't a serious penalty; it is.
If the commissioner sees value in having some additional sanction at her or his disposal, I don't see any problem with that. The only thing is that when you bring in the Criminal Code as the underpinning for this, in some cases you're making it harder to convict someone because of the very high standards within the Criminal Code. So it is almost paradoxical. We think we have a tough law because we're underpinning it with the Criminal Code, but in actual fact you may have an unenforceable law because of the ambiguity that is around a lot of this stuff. Again, it's what you are achieving at the end of the day.
I don't see the monetary penalty having any detrimental effect that doesn't already exist if somebody has been named as not following the rules. Who is going to hire somebody if they can't keep this legislation straight and be on the right side? How can they possibly give anyone advice on how to do it?