Information & Ethics committee  And that may lead to—

Information & Ethics committee  Or a referral to—

Information & Ethics committee  And in some cases I may even determine before initiating an investigation that I have reasonable grounds. Once I determine that I do have reasonable grounds, I must send it to the RCMP.

Information & Ethics committee  Lobbying....

Information & Ethics committee  Yes.

Information & Ethics committee  As I said earlier, in looking at the definition of a public office holder, parliamentary secretaries are not designated public office holders.

Information & Ethics committee  There is no requirement, no.

Information & Ethics committee  Yes.

Information & Ethics committee  There are four files that I have referred.

Information & Ethics committee  We were talking about a question of process and where I am, actually, after conducting one of the administrative reviews. I felt I had reasonable grounds to refer the matter directly to the RCMP, which is what I did. I didn't wait to open an investigation. So there actually were four referrals to the RCMP.

Information & Ethics committee  It's one of those questions that has come up each time over the years. There are two ways I've heard the question phrased: how much is a lobbyist being paid; and how much is the lobbyist actually spending on the lobbying activity. It's probably something that will come up again, and it's worthy of debate.

Information & Ethics committee  With Parliament it was pretty specific as to the types of communications they wanted to capture in terms of it being a designated public office holder, and through the regulations it further defined the oral, and arranged, and who was initiating it. What we've found in doing the reporting is that 80% of this is overreporting.

Information & Ethics committee  Well, it's done on a daily basis in terms of monitoring the media and other public information. You'll often see in articles that person X is lobbying either on a particular issue or.... So we will look at that in terms of determining whether, upon further analysis, the individual....

Information & Ethics committee  By me, yes.

Information & Ethics committee  That's the first, in terms of additional guidance to the code.