Obviously, I'm a regulated Canadian immigration consultant and I support the ICCRC completely, because I know that they investigate contraventions and take action against regulated members. Whether the ICCRC is closed, or a federal statute is established, irrespective of which model is used, if action is not taken against ghosts, none of it would really matter. If all consultants work for lawyers, as Mr. Nurse suggested, and the law societies don't take action, then ghosts will continue and the public will not be protected.
I took a matter to the Law Society of Upper Canada about a ghost agent and they said that the person was not a member and that they couldn't act in response. We need, on the one hand, as you suggested, to decide which regulatory model must be followed. But irrespective of which model will be followed in the future, action needs to be taken against ghost consultants. The research has shown, according to the access to information requests I've made—