You may wish to consider amending section 91. Basically, we're here because of Mangat v. the Law Society of British Columbia and that turned out to be a paramountcy issue. That's why doing federal legal work, like immigration, is allowed in the first place.
If you eliminate that, but allow the consultants to perhaps register with their provincial law societies, then the provincial law societies might be able to take jurisdiction over them, just like the Law Society of Upper Canada is taking jurisdiction over paralegals. That might be the other option.
I see where you're going, sir, and the option might be to force consultants to go through the provincial law societies.