I think that, in looking at that particular recommendation, the committee may want to consider the value at which gifts can raise concerns about perceived influence on a public office holder and therefore warrant triggering the public disclosure requirements of the act.
One thing I would note is that the act does require disclosure to the commissioner if there is a series of small gifts from a single donor that add up to $200. So it's not just a single $200 gift that triggers that, it is if there is a multitude of small gifts given by a single donor to a single public office holder; that can trigger it. And that threshold, when it was established, when the act was passed as part of the Federal Accountability Act, I mean, was intended to be a meaningful threshold in the sense that it was felt that at that point, the public might view a gift being given in that amount or more as potentially being given for nefarious purposes as opposed to a lower value gift. There was a real attempt to figure out the right threshold to communicate to the public around that.
The other thing I would note is that the act doesn't strictly place a requirement only on public office holders to disclose gifts. That disclosure requirement also attaches to the spouses, common-law partners, and independent children of public office holders on gift disclosure. So that is one of the provisions of the act that isn't specific to the public office holder. In some ways, it is more invasive in the sense that it also applies to their immediate family.
For example, if you had a spouse of a public office holder with a career outside the public sector, if that spouse were to attend a business lunch, as might be the norm in that particular industry, and that business lunch was paid for by the client or the person who they're having lunch with and that lunch was over $35, that spouse would then have to disclose the fact that occurred and put that on the registry. I think that's something the committee may want to really think about. When you think about the level of disclosure around gifts, at least the way it's currently crafted in the act, this isn't strictly an obligation of the public office holder. It does extend to family members. That's just something the committee may want to consider.