Thank you, Mr. Chairman.
CSIC very recently established the Canadian Migration Institute, the CMI, a wholly owned subsidiary of CSIC, which now responds to a need for quality French-language training for members and programs for legitimate providers of immigration services who are not certified Canadian immigration consultants, CCICs. That's what they are called.
Over the last three years, it became apparent to the board that the marketplace had not, nor would it, provide adequate educational opportunities in French to those wishing to undertake immigration consulting as a career. At the same time, CSIC identified the opportunity to use those same educational vehicles as a means of giving back to the community by allowing NGOs and government employees access to training that was previously available only to CCICs.
In four short years, I believe that CSIC has become an effective and respected regulator of certified immigration consultants. However, more is required of the Government of Canada to deal with unauthorized representatives who seek to circumvent the Regulations and the will of Parliament. For example, it is not CSIC's role to carry out investigation and enforcement activities related to the Immigration and Refugee Protection Act—that remains the purview of the Government of Canada. The Immigration and Refugee Protection Act provides for general offences and penalties. It is our view that more is required of the Government to enforce these provisions as they pertain to unauthorized representatives.
Our position is that stronger enforcement by the Government of Canada is required and that this can be achieved by clarifying roles within the federal government, adjusting the way federal organizations administer regulations, and making statutory revisions.
CSIC however believes that increased enforcement is only one of the ways in which the government can better fulfill its role under the model. Much more effort must be made by the government to inform immigration applicants of the existence of the protections provided by authorized representative bodies such as the law societies, the Chambre des notaires and the CSIC through its web site and printed materials. Empowering the consumer to make a more informed choice at the outset, when he or she is considering hiring a representative, is a far more cost-effective approach than depending on expensive enforcement after the fact.
CSIC is of the view that there is a need to clarify the respective roles of CIC, the IRB, CBSA, RCMP and local policing agencies relating to the investigation of unauthorized or improper practices and enforcement. For example, it is unclear whose role it is to investigate those who provide consulting services for a fee but are not “authorized representatives” under the Act and which of these organizations has been adequately directed and resourced to conduct investigations and take enforcement action as warranted. It is our view that there should be clearer directives as to what would trigger an investigation.