That's a fantastic question.
If you look at the enabling provisions of the statute, they're about ensuring that the lobbying that actually happens will happen in a way that is ethical and transparent, and can be done in a publicly accountable way. There are certain aspects of the proposed code that make a lot of sense, namely, confidentiality with your clients, honesty, and dealing with information that you are provided as you are talking about regulations.
This is a principled code of conduct that actually applies to the work that is covered by the Lobbying Act. I would posit that the role of the commissioner is about what happens at registration and onward. It has nothing to do with what happens before registration.