With respect to Mr. Mooney, you're indicating that one of the concerns you have is that your oversight or governance doesn't apply to those who do any type of services or work up to the point of placing the application with the department. You're saying it should be taken back to the point where fees are paid or fees are arranged.
I suppose a logical extension would be to say, at any point that anyone represents someone with respect to a matter for which a fee will be charged, that should be the starting point.