Yes, but there's no reason to add to this partisanship with this new position being appointed by the ruling party. No party should be able to force the returning officer to appoint a certain person. They should have the power, of course, to suggest anyone. There would be an application process where people would come forward, or the parties would put the people forward, but the returning officer and Elections Canada would be free to appoint whom they want, because there'd likely be several applications.
I agree also with Mr. Lortie that the problem is creating this loophole in the spending disclosure. That's the overall problem. However you structured it, it would be a problem because it's a loophole and it goes against the last four-year trend of closing loopholes.