Citizenship and Immigration committee  I believe this needs to be taken back to first principles. The government needs to ask whether or not there's a continuing need in 2017 and the next decade for consultants to be regulated in the way they currently are. I have not seen a lot of positive results from the current regime.

Citizenship and Immigration committee  My simple answer to that is no, because I think there's just so much variation among the individual cases that you could not fix a fair standard fee, even for a study permit or a work permit, because of the circumstances of the applicants. If they have past criminal convictions or other matters, I would say that there's no way to fairly fix that amount, and it would also be anti-competitive in my view.

Citizenship and Immigration committee  No, I do not believe that would be prudent at this time.

Citizenship and Immigration committee  My answer has a couple of parts. First, I would say that in my understanding, the unpaid work that, say, a church organization or another community group would do is not impacted by the regime now. People are allowed to get help from a family member, a friend, or a community group that's not compensated, and I think that's fine to continue, and as long as there's no financial motivation to overstep your area of knowledge or competence, I don't see a lot of issues coming out of a situation in which someone in a church basement is giving someone terrible advice—

Citizenship and Immigration committee  First of all, I'm not sure that I necessarily believe that price issue has been tested in 2017. I look at the number of lawyers practising immigration law in Nova Scotia, for example, now versus 15 years ago. You might have had one guy who was sort of an oddity 15 years ago. Now, we have 20 or 25 members in a variety of different practices, some with big firms....

Citizenship and Immigration committee  Just to finalize that, lawyers are doing more than they ever did to provide access to justice. Immigration fees are often offered on a flat-fee basis. There's an obligation to consider the means of the applicant, and also to look at pro bono work. I don't know if the federal government has asked that question.

Citizenship and Immigration committee  Thank you for the question. You're correct that the law societies generally do have the ability to take immediate action. I guess what I see as one of the distinctions between the law societies and ICCRC is that they are generally closer to the ground. Because they are provincially regulated, they seem to be able to keep a closer eye on the occupation ban than ICCRC is.

Citizenship and Immigration committee  I have a couple of things. Obviously, as the gentlemen with the union said, more enforcement would be good, but I think it's also perhaps time for the government to go back to first principles. Why is the government continuing to try to regulate this occupation? Are there alternatives?

Citizenship and Immigration committee  Again, my second point is that in my view regulation is based on a false premise, that requiring very basic training in immigration law, policies and procedures, and imposing a code of conduct similar to that of lawyers is sufficient to give an individual a minimum level of competence to practise immigration law.

Citizenship and Immigration committee  Thank you very much. I would like to begin by thanking the committee members for the invitation to appear today. It is a privilege to have the opportunity. This is my second time before the committee, and I'm very pleased to be here. As noted, I am counsel with the Atlantic Canadian firm McInnes Cooper.

Citizenship and Immigration committee  Sorry. Just to finish the point, they need to see lawyers as partners in effective client service. That's what I'm asking for.

Citizenship and Immigration committee  I can't follow that.

Citizenship and Immigration committee  First of all, I think you talked about humanizing the experience. Too often, although people haven't been hung up on, they come away feeling as though they have been. Maybe they asked one question, they got an unsatisfactory answer, and then there was sort of silence from the other side, indicating that it was time to go.

Citizenship and Immigration committee  Yes. You asked about the role or the space for lawyers. I think that IRCC sometimes does not design things to facilitate collaboration between IRCC, the client, and the lawyer involved. For example, using the online portal for authorized representatives, I can create applications, but I can't share an individual application or a view of that application with a client.

Citizenship and Immigration committee  I think that announcement is positive. I think that shortening the guide is certainly useful, and looking at the language again is useful. For in-Canada applications, it's a processing time issue, which you would be well aware of. There's a commitment, I believe, to shorten the average processing of the in-Canada applications from 24 to 12 months, and a dedication of more money and resources to that.