I can't speak for the lobbying commissioner.
As you say, lobbying rules used to be under the conflict of interest regime. There's certainly a good rationale for putting them together. The thing that's kind of unusual about the Lobbying Act is the power for the lobbying commissioner to establish some rules. That's not usual with somebody who is administering an act. I don't establish any of the rules that I'm administering; I just interpret them and apply them. For the commissioner to be able to establish the rules is an unusual power.
My feeling on whether the two should go together depends on the extent of the.... There's nothing that necessitates their being connected and consistent with each other. There's terminology used under the lobbying regime that is the same as what's used under my former regime, but it means different things. It's very confusing. There are a number of terms there, and I'd have to dig them out. Care needs to be given to make sure...and it's the same with the difference that I mentioned between the code and the act.
In the code, by the way—it must have been with the recommendations for the code—it's not organized very well. I did a bunch of drafts because I'm a former drafter, of all things, so I actually did a number of drafts as to how the code could be better presented. There are lots of technical improvements that could be made to these things, but none of them is earth-shaking.