I think it's clear that the point of the recommendation is that transparency should trump some of those circumstances where small groups are doing occasional lobbying, assuming they are actually engaged in registerable activity; that is, they're paid and communicating to government about specific policy changes and the various activities defined in the Lobbying Act as it is now.
I think the commissioner could potentially look at special cases and make recommendations where a small group is not being paid or receiving any sort of financial benefit. These may be exemptions to this particular rule, but I think it's probably more important to have a clear rule related to the transparency of all registered activities.
You mentioned earlier the case of a former prime minister. I think a number of individuals at that level sit on boards of directors of corporations, and to the extent that they do registerable activity at the federal level, they would be considered consultant lobbyists and have to register any form of any single communication. That would be an important distinction.