If everyone's a lobbyist, no one's a lobbyist. But if you're not a DPOH, it's not an issue.
If the goal is to bring transparency to the various groups that are influencing decisions, your challenge is where to put the fence. Who are you interested in finding out about, and who are you not--or is it everyone?
Believe me, I don't minimize the challenge you have, but I don't think it's individuals--it's groups, associations. It's people who have a certain amount of sway in the public policy arena. I bump into these people in the halls, and I'm subjected to completely separate rules from what they are because I'm paid to do it and their benefits are more indirect.