Section 91 was designed to help get at the problem—as the committee I'm sure is aware—of people who are operating in the fashion of ghost consultants. Getting at that was the objective of the day, and it was around making a framework that was the best way to get at it.
I want to point out that there is also subsection 91(4), which allows IRCC to enter into agreements with organizations so that they don't run afoul of subsection 91(1). We do that in the oversees refugee selection process, for example with the IOM and the UNHCR.
We have a framework, but we also have explicit abilities to allow for those that really help the immigration system in a certain way—and we did it on Syria, for example, with the UNHCR.