I appreciate the question. Thank you.
I think that when it comes to third parties it's particularly difficult, because they tend to function as multi-purpose kinds of organizations, where they might be getting all kinds of money from all kinds of people and organizations from different places, depending on what their primary function is.
Then, when they switch specifically to a campaign period and they become engaged in the electoral process, I think the melding issue you identify is the important one. If they have a general revenue supply and they start to shift towards campaign spending, how do you then start to pay very close attention to the activities of a third party and how much money and what kind of money is being flowed toward campaign activities and which of it is preserved for their organizational purpose, which happens and exists all the time? At the same time, I think you don't want to get to the point where you're auditing to the point of granularity that you deter the activities of the organization and they don't want to function at all.
I think educational aspects are important. It's important to talk to third parties about being compliant. It's about trying to make sure that people are aware of what the rules are and what they require. Apart from that, again, it's difficult when you start to look at some of these third parties that are not that: Some of them are working primarily as political entities and don't necessarily have big purposes outside.
As for what's there, sometimes I get concerned because there seems to be a bit of a lack of concern around the activities. You can see in some jurisdictions—for example, in Ontario—that there can be court cases that remove the rules around third parties or that create the possibility of not having a level playing field. I think that would be very bad, so I'm thinking that it's important to keep the rules we have.
Again, I think we're always catching up. There's always the activity that's going on, and the law and the regulations are always a bit of a step behind in trying to figure out how to be compliant. In-kind contributions are another challenge, because that's much harder to trace than the flow of money.