The act actually says that a person shall not consult with, advise, or represent a person who has an application before the minister or the board, so that's a different stage. It would be possible to have an office where you simply gave advice to the public and did not deal with the department. That is not captured by IRPA. I've always maintained that this should be captured by legal profession legislation that says that no person in the province can give advice to the public for a fee unless they're a member of a law society. So I think that would, in theory, be able to be captured by legal profession legislation.
On April 1st, 2008. See this statement in context.