I didn't mention this in my complaint to the Commissioner of Lobbying, but I think I should follow up on it in that there is a requirement under the Lobbyists' Code of Conduct to lobby in a way that meets the highest ethical standards. I think sending out a letter like that would not meet the standard of that principle set out in the Lobbyists' Code of Conduct. Since CCI is registered to lobby the federal government, they have to follow those principles and all the rules in the code.
That's the way to stop it. You can't be offering the flip side of cash for access where you have the access and you want cash. If you make it explicit and say that you can guarantee something, you're into the Criminal Code's influence-peddling section. I think the lobbyists' code is there as a non-criminal civil ethics code way of stopping that, and the commissioner should rule on that issue in this situation.