Citizenship and Immigration committee  As part of Fraud Prevention Month we issue a number of videos in multiple languages. This year, for March 2017, they were issued on social media in English, French, Spanish, Arabic, Mandarin, and Hindi. In response to questions, the last time we appeared before the committee concerning members of the public being aware of filing complaints, we have actually responded to that.

Citizenship and Immigration committee  Not specifically through the embassies, but we do produce awareness advertising in local ethnic papers. We are also contemplating an expanded advertising campaign that will be part of next year's fiscal budgeting, which is being put together right now.

Citizenship and Immigration committee  It is very clear that those staff are not licensed in their own right and, therefore, may not represent clients. They would be functioning as administrative staff. We do allow consultants to register what we refer to as an “agent”, which is a person on the ground overseas who would receive documents and payments from clients, which are then remitted to the licensed consultant.

Citizenship and Immigration committee  We have. Through our fraud prevention activities in several local ethnic papers and media, we do provide information about using only an authorized representative. This year, as I mentioned in my opening remarks, we have picked approximately six languages. Last year, it was different languages again, so we're reaching out in ethnic papers, as well as social media worldwide to use—

Citizenship and Immigration committee  Authorized representatives.

Citizenship and Immigration committee  Again, if it's an unauthorized person, and we received information, it just gets referred to CBSA.

Citizenship and Immigration committee  Information on the complaints process is actually included in the retainer agreement entered into between a licensed consultant and the client.

Citizenship and Immigration committee  Not specifically, no.

Citizenship and Immigration committee  No, I believe Mr. Jade has covered it. One issue, as I've mentioned, is that under CNCA there are a lot of restrictions to how we operate. That may not have been the will of the government in 2011. But Mr. Jade has pointed out where we are in 2017, with the committee's concern about ghost and fraudulent representatives.

Citizenship and Immigration committee  We are currently investigating what powers and authority would be appropriate to have as well as the structure in which to do that. I could say yes, but obviously going after unauthorized representatives Canada-wide involves due process in terms of complaints and discipline. I would say that right now, internally, we are looking at both the governance structure and mandates and what we would consider appropriate to effectively represent the public.

Citizenship and Immigration committee  Yes. Since ICCRC became the regulator—we are six years old—we have received, as of the end of December, 1,710 complaints filed against consultants. Of those, all but 500 have been closed. We have, as I mentioned, a service contract with external investigators who are RCMP officers.

Citizenship and Immigration committee  Mr. Jade had an interesting suggestion. We did try to issue a cease and desist letter several years ago to someone who was acting as a ghost, and they shoved back at us and said we didn't have any legal mandate so don't threaten us. So under CNCA, as a private company right now, with no statutory powers to investigate, compel witnesses, or obtain documents, we are limited to doing nothing more than referring to CBSA.

Citizenship and Immigration committee  I have heard of that. The jurisdiction of the council is only, as the committee has already heard, to discipline and regulate its own members. We have no lawful authority to go after individuals, whether in Canada or outside of Canada, who are not regulated by the council. That is one issue.

Citizenship and Immigration committee  If the council receives a complaint and we determine that the person is not a licensed consultant or member of a law society, with that complainant's permission, we prepare the information that we have available to us and forward it to CBSA for their consideration. In many cases, the CBSA does work with us co-operatively, because part of that prosecution is obtaining, in our case, a registrar's certificate to confirm that the person is not licensed and authorized through ICCRC.

Citizenship and Immigration committee  I'm sorry, I don't. I am aware of certain very specific cases where I have been asked to provide a certificate, and a number of months or a year later the investigating officer at CBSA has contacted me, thanked the council for its assistance in the prosecution, and advised of that outcome.