No, the minister wrote:
You specifically cite sections 386 and 387 of the Code, which pertain directly to certain aspects of fraudulent real estate transactions. It's my understanding that these offences are not charged often; rather, the general fraud offence under section 380 of the Code would be the offence most frequently charged for the crimes you are concerned about. This fraud offence is broadly worded and very familiar to prosecutors and judges. The essence of fraud is a deception of some kind coupled with an actual deprivation of money or property, or merely a risk of such deprivation. When coupled with section 21 of the Code, which makes everyone who participates in crimes that are committed by others guilty of those crimes as well, I believe the fraud offence covers all manner of fraudulent acts.