That actually opens up a very large area. The reason it opens up a large area is that the Lobbyists Registration Act was the first lobbying transparency law in the country. Provincial legislatures then followed suit. Ontario and Nova Scotia have very weak acts because their acts basically reflect the way the federal law was 15 years ago. Then the federal law was amended. The strongest laws in the country are not the federal law but the lobbying transparency and accountability laws in Quebec and Newfoundland and Labrador.
I would urge the committee—I know you've heard from the regulators—to look at the Quebec statute and the Newfoundland and Labrador statute. They are among the toughest in the country.
Specific recommendations that the CBA has made that align with provincial laws administer the monetary penalties. They're on the books in Alberta and British Columbia. It's something that CBA recommends this committee look at and adopt as a federal model. Treating directors of companies as in-house lobbyists, which they are, is done in Quebec, Alberta, and British Columbia. It will be done in Manitoba when their law—which just passed—is proclaimed. That's another area.
There is the elimination of the 20% rule. There is no 20% rule in the City of Toronto bylaw. There is no 20% rule in Quebec. They have a triple threshold that doesn't approach that. This 20% is not carved in stone in other jurisdictions either. The CBA thinks the 20% could be removed.
I could go on. I'd be happy to follow up in writing with points of similarity and difference between the acts, if that would be of help to committee members. That would be a Guy Giorno submission, not a CBA submission, because the working group didn't go to the extent of doing an entire national cross-jurisdictional analysis.