I'm sure the other witnesses, too, have opinions about that.
I think where I would start is that because immigration is so clearly under federal jurisdiction—there are immigration statutes within the provinces as well, but who gets to come to Canada is under federal jurisdiction—the Supreme Court said, in the Mangat case, that regulating that is certainly within the federal jurisdiction should the feds decide to do so. It's also, as you say, within provincial jurisdiction, and there are reasons, as you've described, for possibly giving it to the provinces.
Downtown Legal Services is consulting with the Canadian Council for Refugees and other organizations as well. We're not married to the one federal statute model. We're still in the consultation process, which is why we haven't given you a brief yet. We're still working on that.
However, we're here to say that we need a statute. Whether it's a set of provincial statutes across the country that incorporate regulation into the law societies or a federal statute that does this the same way as a law society does, we need a statute, because without a statute we're lost.