Thank you, Mr. Chairman.
Good afternoon. The Canadian Migration Institute is honoured to be here today to share our views on Bill C-35.
CMI is the voice of the immigration consulting profession. Since our inception in 2007, we have grown to more than 1,800 fellows, who can be found across Canada and overseas. With representatives from the immigration consulting, legal, and notary professions, CMI is larger than any other similar organization in North America.
Our mandate is to educate, accredit, and advocate on immigration law and policy. We have several chapters throughout Canada that provide regional support through accredited educational programs as well as advocacy on provincial issues.
CMI strongly supports Bill C-35's provisions, which will close legal loopholes that have enabled ghost agents to thrive. For too long, these unlicensed, disreputable individuals have exploited these loopholes to take advantage of prospective Canadians.
However, we do have serious concerns. While the new penalties in the bill give law enforcement agencies such as the CBSA and the RCMP the legal tools to put ghost agents out of business, there is no additional funding provided in the bill to enable these agencies to do this, meaning that consumers will still not get the protection they deserve.
Further, we remain unconvinced that this regulatory review to select a designated body is really necessary. Members of the Canadian Society of Immigration Consultants, most of whom are also fellows of CMI, have invested over $37 million since 2004 to build CSIC's sophisticated regulatory functions. These include rigorous membership standards, a thorough complaints and discipline process, and an intricate IT infrastructure. It would be foolhardy to throw away this investment, especially because we know for a fact that our fellows are satisfied with CSIC as it is today.
Just two months ago we commissioned a survey to determine how our CSIC member fellows feel about their regulator. The results clearly indicated that fellows think CSIC is an effective regulator.
These fellows are on the ground, dealing with CSIC on a day-to-day basis and closely following its activities. That puts them in a unique position to evaluate its suitability as regulator. They realize that CSIC is well governed, a fact that has been confirmed by independent reviews done by recognized leaders in governance. They realize that CSIC has been working diligently to combat ghost agents within the constraints of its limited authority. They see that CSIC does so by reaching out to warn consumers and engages in the tracking of ghost agent activity, and they appreciate that CSIC has held its members accountable through its rigorous complaints and discipline process.
While there is no denying that some CSIC members are dissatisfied, this extremely vocal minority does not speak for our fellows. In fact, this regulatory review has cast a wide shadow over the immigration consulting profession. It is endangering the livelihood of fellows who work hard to provide high-quality service to prospective Canadians. By questioning the competence of their regulator, the government cannot avoid endangering the public's confidence in immigration consulting professionals and the overall immigration system.
I urge the government to carefully consider these points. It has taken many years to build CSIC into what it is today, and consumers should not have to wait while the process of building a regulator begins anew. Further, without concrete funding for enforcement, the effectiveness of the government's crackdown on ghost agents cannot be guaranteed.
Merci beaucoup.