The commissioner will have discretion in applying the legislation and determining in any given situation if an entity in Canada who is in an arrangement with a foreign body meets the definition of a foreign principal. The commissioner will be well placed to make that determination.
In addition to that, I would say that the commissioner will have at their disposal the ability to issue interpretations or bulletins and could communicate information in that way as well. They would completely retain the independence to do that in any given situation.