I believe there's mutual respect between our two offices. We have to operate within different standards when it comes down to the level or threshold of proof of evidence that we require.
The lobbying commissioner will look at a matter and, as per the act, the moment that she forms her grounds to believe that there is a potential violation of the offence, the file will be referred to the RCMP to investigate.
Now, when we look at it, where we sometimes may differ is on the assessment of the circumstances. Then again, at this stage, the RCMP does have the information in relation to the specifics of the offence. At that point, this is what forms the basis of our conclusion.
Again, I believe that we each operate within our own limitations when it comes to the act. As it comes to our investigation, we have to evaluate what it is, and we have to function within some of the terminology and the notion. To give an example that was mentioned earlier, the significant part of the duties is an area that we have to navigate. I know that the act allows for the Commissioner of Lobbying to provide some interpretation bulletins.
Again, in the context of the investigation, we have to assess everything. Interpretation bulletins do provide some parameters for lobbyists to operate; however, when it comes down to the application of the law, we have to function specifically as it relates to what is contained in the act. Right now the act does not speak to 20%. That is in interpretation bulletins that are not statutory instruments and, as such, are not binding in court.
We have to operate within what is a significant part of the duties, to provide an example, which could be very challenging and complex to do.
