I think you have a hold on a lawyer when there's a disciplinary proceeding. To be a lawyer is a significant part of your identity. If the law society intervenes, there's that fear, that anxiety, and the public shaming or the risk of losing that licence, and that's significant. Nobody grows up dreaming to become an immigration consultant. The loss of that calling or that profession, I think, is less of a hold for positive behaviour.
In terms of the ICCRC regulations, I'll give you an example. I had someone who hired a licensed immigration consultant. The application for her sister was in Hong Kong, and the application was there for years. The consultant said it was delayed because the consulate in Hong Kong was asking for updated IELTS results.
Ultimately it was rejected, and then she came to me. In fact, the client had done an access to information request, and she obtained information. The notes seemed to suggest this application was denied six years ago by Hong Kong. I emailed Hong Kong and told them here was this email, here was the ATIP response, could they tell me whether their office sent this email requesting further language proficiency? Hong Kong responded within three days and told me they had never sent that email. That file was closed six years ago.
I took that and sent it to the ICCRC. I got a call from an investigator, and the investigator was incredibly speculative. He told me I couldn't prove the consultant did this. It could be someone on his staff. I replied of course I couldn't prove it, but you would have to take this to the next level, so this was my impression of the ICCRC.
As a final point, LMIAs are going to be $15,000 or $20,000, as long as you can get permanent residency out of them. Take the LMIAs out of PR.