Well, I would adopt the Quebec model for immigrant investor immigration. The challenge is bad apples on the ground in case-specific immigrant investments. The Quebec government doesn't have the time and resources to micromanage; instead it manages the dealers. It allows quota to dealers based on the quality level of those investor files. It motivates the dealers to motivate their agents to select good cases. By “good cases”, I mean legitimate.
The same could happen if the minister were to say to the regulatory authorities, “Okay, we're going to hive off some service delivery” to your members. “You, regulator, are going to ensure that quality assurance is positive.” Alternatively, IRCC could, via computer, monitor the quality assurance of specific practitioners and cut access when something's loopy, pending resolution of an investigation.
That's how you do it at the lowest cost.