Our recommendation is specifically for designated public office holders who leave and go to work for corporations as corporate lobbyists. Basically what the 20% rule allows is that if you spend less than 20% of your time lobbying or doing lobbying activity, you don't need to register or to declare those meetings. Our view is that the act was very clear on the five years for designated public office holders. There were no ifs, ands, or buts when you leave. If you worked in the system, you were captured by the five years with no exemptions. What you got is a situation where people will go in and work as a corporate lobbyist, and they'll hide under the 20%. They do less than 20%, so their advice that they are being given by their legal departments is that they don't need to register, so why do it? Our view is that it's a big loophole. Plug that hole. If you were a DPOH, you're bound by the five-year rule. There are no ifs, ands, or buts.
On February 2nd, 2012. See this statement in context.