I'm going to try to address a couple of your points in order, the first point being that the federal government may or may not have competence to draft the kinds of statutes that are necessary for this.
I don't want to sell Parliament short. I think the federal Parliament could certainly learn from the patterns of regulation that exist in all the provinces. When a new provincial government has to pass a statute to regulate a new area, it may not have the competency to do so instantly, but it has the collected wisdom of all the statutes to base a new statute upon. That's why I said earlier that it's possible to hit the ground running. Whether it's a better idea to begin with provincial regulation.... That requires every province--I'm not sure how it works in the territories--to come up with their own regulation. It could be spotty across the country, and it takes a certain amount of time.
There should be one federal statute across the country.... With the kinds of models we're talking about--all the regulators that exist across the country--the regulation of immigration consultants isn't all that different from what's already happening under the Law Society Act in Ontario for paralegals. In fact, paralegals, as defined under the Law Society Act, embrace what immigration consultants do; they provide services of an equal nature.