It's one of these situations where reasonable people can reasonably disagree. I take a different path from the Canadian Bar Association's official position this time around, and there's no surprise there. I have been supporting the consultant issue in pre-embryonic times, and over a couple of decades I've found that there's high value in our former public servants' continuing their duties and responsibilities in their post-employment environment.
The policy vehicle that I highly recommend to this committee at the present time is borrowed from the Canada Revenue Agency: a voluntary disclosure program. This can be used within IRCC, CBSA, in file-specific matters where a person need not identify their name. Strike a deal, and if the facts are true then the person can be blessed with forgiveness, and the government gets the evidence it needs to shut down unscrupulous consultants and agents. The same voluntary disclosure program may apply within the regulatory authority. Right now there is no such creature.
The regulated should never fear their regulator. There should be a more collegial atmosphere.