Thank you. That answers my question.
Professional orders with these oversight responsibilities actually find it very difficult in many cases to provide evidence that someone is practising the profession without being a member. It is something that can be difficult to prove. That is why in most cases, at least in Quebec, there is protection for professional titles. For example, Quebec law states clearly that I cannot claim to be an engineer and give out business cards that say "Thierry St-Cyr, engineer" if I am not a member of the professional order.
In your work to try to provide oversight in this profession, would it perhaps be easier for you if you had to prove only that someone was presenting himself as an immigration consultant, rather than having to prove that he has actually provided advice and has actually been paid for doing so?