Not very. Most lobbyists follow the rules closely enough that there's only a handful of cases the commissioner has had to investigate in the first place.
There was a case on the rules governing political activities of lobbyists. The commissioner's interpretation came into effect in 2009. A lobbyist was found guilty retroactively for events that took place in 2004, guilty of having placed a minister in a real or apparent conflict of interest. That minister had already been cleared by the Ethics Commissioner of ever having been in a conflict of interest in the first place.
The key here is that the Conflict of Interest Act as it applies to the minister tests for real conflict of interest, and the Lobbying Act, the commissioner's guidance, and the code of conduct test for a real or an apparent one. So I could apparently put you in a conflict of interest you were never in.
We think the language there should be harmonized. The test on both sides of the coin should be for real conflict of interest.