I believe that section 91 can be amended to the extent that it can allow immigration consultants, based on current framework, to do transactional level work within immigration: work permits, other applications for permanent residents, sponsorship applications, and that's it.
What I would propose then is another provision that will allow a different class of immigration consultants to appear before the IRB, and I want to be clear on this. The IRB actually is maître chez lui. It can control its own procedures. In fact, some tribunals have banned some consultants from appearing before them because we're not doing our job, the government is not doing its job to protect the public, and ICCRC is not doing its job, so the tribunal sometimes has to say they're not going to hear from this person anymore.