Madam Chair, and esteemed members of the committee, thank you for having invited me here today.
My name is Alli Amlani, and I participated in meeting number 55 in 2017, so I'm very familiar with the subject.
I've been an immigration consultant since the beginning of 1988. I've served on various boards of immigration consulting associations since 1992, including almost eight years in total as an elected director at both the regulatory bodies, CSIC, and thereafter, ICCRC— as the vice-chair of CSIC and a chair for two years at ICCRC.
I was also the co-founder of the immigration education program, which is the prototype immigration practitioners certificate program that remains the entry requirement for the profession today.
Having built the profession from almost the very start on principles of ethical practice and provisions of professional services to the needy, who are the real people, I repeat from what I said the last time that it's a serious undertaking when people put their full trust in another with their and their family's aspirations and dreams that could be shattered due to the smallest of oversights or a perpetrated plan.
I have, in the past 31 years, become very conversant and intimately familiar with schemes some people adopt to defraud others and to undermine the integrity of our immigration policy. They exploit people around the world. They are overseas and in Canada and include, but are not limited to, travel agents, student advisers, articulate business people, unauthorized representatives and, unfortunately, authorized representatives as well. I'm very familiar with their practices.
Coming back to the point of today's meeting, looking at clauses 291 to 300, first of all, I'd like to congratulate and compliment the standing committee for having made the 21 recommendations, each one of them well-thought-out and detailed. Some of them were already in practice, but not under statutes. I continue to have concerns about some of the recommendations. A few would need a phenomenal amount of funding—I use the word “extravagant”—or probably appear impractical, and those are the questions that I've heard in the little while that I've been here.
I salute the unprecedented and herculean effort of IRCC to have accepted the key recommendations and brought them to fruition through the budget implementation act and clauses 291 to 300 that we are going to address today. I say “unprecedented” because, as I stated in my last appearance, attempts to implement federal statute regulations as recommended by three previous standing committee reports had not been successful.
I will get down to what my exact concerns are about the present proposal. While we await regulations and bylaws, a few proposed changes need to be further examined or discussed, and if consensus is reached, tweaked. I have already provided a 45-page version that is highlighted and synchronized with my speaking notes, which carry the clause numbers. It'll make it easier if that's how you want to refer to it.
We discussed the compensation fund this morning, and I'm going to address it further. This was part of the contribution agreement with the first regulator body in 2004 that was provided $700,000 in funding and $500,000 as a conditional loan, which was eventually written off. Experience has shown that a target collection of $1 million and maintaining that balance was mostly spent on administration, even while there were no claims made during that period. The funds in CSIC's compensation fund disappeared with the demise of that body, which was replaced in 2011.
In 2011, when the new regulatory body came in, they again started with the requirement of the compensation fund. The contribution agreement mentioned that as part of the condition, but after long, in-depth deliberations by all committees, the ICCRC board and IRCC found it did not serve a useful purpose, and it was subsequently deleted from the contribution agreement in 2015.
Having seen the abuse of professional insurance that all the consultants are covered by—and I don't want to go too deep into what kinds of abuses are there—I feel that it creates an exposure for the college to introduce the compensation fund at the additional costs. Besides the exposure, there are additional costs in terms of administration, human resources, and an undue financial burden on the members in terms of fees.
We must remember that this was one of the reasons that the past regulator was replaced. After 15 years of self-regulation, no claim for compensation has ever been made. In 15 years, no claims. A compensation fund could always be established. My recommendation is that it's too premature to do it right now; it can always be done later if needed.
With regard to board meetings on one of the recommendations, it suggests only one board meeting. I suggest four meetings for accountability. One meeting is an overseeing board, which, by the way, just looks at it. Accountability requires four meetings.
On committees—and this is your last panel of questions—where is the involvement of members? They should be on the committees. My suggestion is that the committees be populated by licensees—