Thank you, Avvy.
I'd like to focus my submission on three points.
The first is with respect to conditional permanent residency. As expected, and as we see at the clinic, the mandatory imposition of a two-year permanent residency condition that a sponsored person live with their spouse has led to an increase in vulnerability, and an increase of situations where we see domestic violence and exploitation, as this condition is being used to further tip power imbalances between spouses. The government, in their mandate letter, has already committed to repealing this, so we want to say that we hope this repeal is done immediately and also is applied retroactively to those spouses who have already been affected by this condition.
The second point refers to the bona fides of spousal relationships, specifically, subsection 4(1) of the Immigration and Refugee Protection Act regulations. In 2010 there was a government amendment saying that spouses and their sponsors needed to prove both a genuine relationship, number one, and, number two, that a relationship was not entered into primarily for immigration purposes. Previously, spouses only needed to prove one or the other.
This has led to situations of absurdity, basically, where an immigration officer or the Immigration and Refugee Board has determined that a spousal relationship is genuine but still rejects it because the primary purpose, they determine, is for immigration purposes. This is a waste of time. This is a waste of taxpayer money to go through these appeals. It only serves to unjustly and unfairly separate families. We believe that this amendment, which is overly harsh and redundant, should be repealed.
The third is with respect to paragraph 117(9)(d) of the regulations.