In my opinion, I think we have a very clear definition of what registerable communication is.
I just want to go back to the last panel, because there was a little bit of a miscommunication about who has to register and who has to report. If you're being paid to do the work, you have a registration obligation based on the threshold. It's not a communications obligation. The communications obligation is triggered once you're registered. If you are registered and then you have that spontaneous conversation, if it's oral and arranged in advance, it would be captured. Under the commissioner's recommendations, it would be all of those spontaneous communications about registerable activity.
I think that's going to cause way more problems for the people at this table than it's going to cause for the lobbying community, because you are also going to have to track that information for verification of whether or not there has been a violation of the act...apparently 19,000, which I will take at face value.
As for what's not working so well, I would like to see the commissioner have further powers to exempt. I would like to see the commissioner have discretion to say, you've only worked in government for nine months, we're going to give you a little bit more leeway as it relates to how long your prohibition should be. I think it's a little weird that someone should be prohibited for longer than they actually worked in government, but again, there's a sliding scale there.
There are certain people in government who have a little more influence, and so they're going to be treated a little bit differently. However, if you're limited to one department, maybe you should be limited to that department for what you can or can't do. It shouldn't be all of government, for example.
I think that's something that you could take valuable committee time to look at. This is something that impacts people's professional lives, 100%, both at the beginning of a career and at the end of their career. They might say, “I'm going to retire at a certain time and I'd like to share that expertise in the private sector.” That sometimes gets in the way. Quite frankly, sometimes that's not what they signed up for.
Certainly, in 2005, before the Federal Accountability Act, there were people who had a different vision for what their retirement life was going to be, and then there was a five-year ban that was placed on them. It could be very difficult to do that type of planning with what I'm going to call a sliding scale, unless it's Parliament that establishes what that sliding scale is.