I would say that you're in reaction mode. The Commissioner of Lobbying has to take a first look and there has to be an apparent offence.
As we saw in the case of conflict of interest, if the conflict of interest isn't yet apparent, you can't launch an investigation, even if you consider, based on the information you have, that there might be a potential conflict of interest or that an offence has been committed.
You don't start an investigation until the commissioner has given you a mandate or a referral.
Is that correct?