Thank you.
We've planned our timing well for this presentation. I am involved with this to answer any questions. Having been around the practitioners' business for 20 years, I know we have done this before and we're going to do it again.
Everyone has been provided material, and I'd just like to be able to explain that. The first four pages of our material is a representation that was made in July 2005, again to the standing committee, and we're back here four years later doing the same thing again. This time, I'd like to be able to explain it better, from the technical perspective, to explain the wording. I've actually taken out abstracts from IP 9, which Mr. Mooney has alluded to, and which Mr. John Ryan has alluded to, and I would like to go a little deeper into these, because we've argued with the department ever since June 28, 2002, to explain this, and we don't seem to be getting through.
In our speaking notes, in the paper we presented, on pages 5, 6 and 7, we have provided the exact wording of the manual that contains the defect. I have underlined the words that are effective. Again, section 13.1 says “represent, advise, or consult”. The use of the word “or” makes “represent” independent, “advise” independent, and “consult” independent. If you look at IP 9, it basically says anybody can give advice to anybody before the application is filed. Mr. Telegdi mentioned that in New Delhi people lining up were advised by a consultant, and so on. We hear horror stories. This will continue.
I have highlighted or underlined the part where the manual clearly says that before the submission, any advice can be given. Before the submission, application forms can be prepared, and this is the problem. If you look at the call you've made for this meeting, it addresses the issue of people who are beyond the purview of CSIC.The last part here, 9.2, talks about how to make a complaint. It says to just send the information over to CSIC so they can be careful in choosing future consultants, or to the Better Business Bureau. It doesn't direct people to CBSA, to enforcement. We need to be able to do enforcement.
The last part of my paper describes the penalties under sections 126, 127, and 128. They do not say those are for Canadians; they are for everyone in the whole world.
With that, I would like to thank you for your indulgence. Thank you.