If I could say one brief thing about administrative penalties, a representative from the Government Relations Institute of Canada, when he testified, and also Joe Jordan, both said that when the commissioner reports that someone's violated the lobbyists' code, it's a serious penalty and no one would want to hire that person again. That's simply not a true claim. Michael McSweeney of the Cement Association of Canada was found to violate rule 8 of the Lobbyists' Code of Conduct and then he was promoted by the association to be president and CEO.
Will Stewart, in the same situation, when he was found guilty by the commissioner of violating the code for assisting Lisa Raitt with a fundraising event...I checked the registry and he has not lost one client since he was found to be in violation of the code. So that's an argument as to why administrative penalties are definitely needed.
In terms of what you should definitely not recommend changing, the Government Relations Institute of Canada said, “We're not talking about simpler rules or looser rules”, when they were here, but they are, actually. They want rule 8 gutted and turned over to the Ethics Commissioner. If that's done, then lobbyists will be allowed to do whatever they want for politicians and public officials they are lobbying, and also to give anything they want to them, because the Ethics Commissioner says there's no conflict of interest created when lobbyists fund raise for politicians they're lobbying and things like that. So the GRIC does want looser, weaker rules, and you should not gut rule 8. It's the most important thing.