Citizenship and Immigration committee  We're obviously somewhat hamstrung, as Mr. Oliphant mentioned. Clearly CSIC can't take action against non-members, but we have an intelligence department that over the last two years has been actively compiling information in a very sophisticated database on the activities of ghost consultants, and we've been reporting that information to enforcement, to CBSA and the RCMP.

Citizenship and Immigration committee  With the new legislation, obviously there is now going to be greater impetus to that function and I think a great deal more urgency on the part of CBSA and RCMP to take action where they can. Now, obviously a lot of the complaints we receive are from outside of Canada, and that raises the issue of how you deal with things internationally.

Citizenship and Immigration committee  Two different examples.

Citizenship and Immigration committee  In terms of our members of CSIC or the ghost agents?

Citizenship and Immigration committee  What are our complaints largely focused upon? I think that's a very good question. The largest number of complaints that CSIC receives with regard to its members are fee disputes, number one; secondly, protection of client property, which is return of original documents; and the third level of complaints we receive is with regard to competency of service, where the client feels that perhaps they have not been properly represented.

Citizenship and Immigration committee  Well, CSIC has an independent complaints and discipline department, with a manager who is a senior member of staff. We have six individuals within the complaints and discipline department who investigate and make reports on incidents, and who investigate and do analysis. Once a complaint is deemed to be significant, an investigation is put in place, and a report is then generated for the complaints and discipline manager, who has several different mechanisms for rectifying the complaint.

Citizenship and Immigration committee  We certainly agree that on the independence issue there is an issue with the minister having absolute control of who is the regulator and, at the same time, members of the regulator having to present cases to the minister's officers for decisions, so that actions by the members might influence the minister's view of the regulator.

Citizenship and Immigration committee  That's an excellent point. In fact, this year we have received a total of 502 complaints. Those complaints generally break down to be some complaints against members of CSIC, but a great number of the complaints we receive, because essentially CSIC is a lightning rod for complaints, are against ghost agents.

Citizenship and Immigration committee  Exactly.

Citizenship and Immigration committee  If I might answer that, I would refer back to two issues that I think are ongoing. In terms of our educational programs that are offered with educational partners for original accreditation and membership, probably the biggest issues we have are cross-cultural communications and learning differences.

Citizenship and Immigration committee  I have an opinion. I believe it comes down to departmental and governmental issues with the constitutionality of the regulation of a profession, such as immigration consultants, on a national basis, given Canada's constitution and normal practice on the governance of professions.

Citizenship and Immigration committee  I understand. I'm sorry. I tend to go on.

Citizenship and Immigration committee  We definitely support the idea, the minister's proposal, to strengthen the legislation to shut out ghost agents from representing clients in any part of the immigration system. That is absolutely crucial. It's something we've advocated for with government for a number of years and have made a number of submissions on.

Citizenship and Immigration committee  We're certainly very hopeful. As I mentioned, we're tracking more than 1,600 to 1,700 ghost agents in our intelligence system. We're certainly hopeful that a very significant number of those individuals can be reformed and they will join the regulator. If the legislation is such that they have no other option but to conform, we would certainly hope, as Monsieur St-Cyr has indicated, that we would be in a position to perhaps double our membership.

Citizenship and Immigration committee  No. That is an extremely fair comment, Mr. Young, and I would agree with you. Our concern about enforcement, to be honest, stems from years of advocating with government to increase the enforcement efforts, to look at the resources devoted to enforcement, and to change the law.