Citizenship and Immigration committee  I don't think that we can necessarily speculate on specific fact scenarios. I don't anticipate that a code of conduct would specify about putting things into forms, but it—

Citizenship and Immigration committee  I would just clarify that what's being addressed within the immigration consultant sphere under section 91, for example, is not necessarily legal advice. That's not the term that's used. It's immigration “advice” and “representation”.

Citizenship and Immigration committee  We certainly looked at that option, along with a range of options, and cost did factor into it. In that scenario, unlike the current one that is proposed, there would be enhanced liability risk for the government, for example, if we're directly regulating the immigration consulta

Citizenship and Immigration committee  Exactly. There would still be fees, but by virtue of being in government it would likely be more expensive to run, in terms of start-up costs, because it's not an area where we have existing functions or expertise.... The government itself does not regulate a lot of that—

Citizenship and Immigration committee  Not in front of me, no.

Citizenship and Immigration committee  That would be something we'd want to look at closely as we develop it and provide advice on what it will look like. We'll look at best practices. We'll look at what experts might view as the best practices and have that inform what the code of conduct would look like.

Citizenship and Immigration committee  When an application is submitted to IRCC, only authorized consultants can provide advice to clients. As a result of our investments, we can provide more public education outside Canada.

Citizenship and Immigration committee  Yes.

Citizenship and Immigration committee  The model that was adopted was a statutory self-regulation, so, as set out in the bill, this would not be an agent of Her Majesty. It would be independent and at arm's length from the government.

Citizenship and Immigration committee  Certainly we consulted heavily with Justice as this was being developed. We don't foresee any great risks around liability, but we do get a lot of litigation in general.

Citizenship and Immigration committee  I should say that we don't anticipate any liability risks.

Citizenship and Immigration committee  Indeed. Budget 2019 did announce investments of $51.9 million, I believe, over five years. That took into account what our estimates were about administering the new model, including increased investigations and a new AMPS regime.

Citizenship and Immigration committee  The college itself would be self-funded by fees.

Citizenship and Immigration committee  In terms of the consultants' qualifications, the standards will be established by the board through regulation. There will be minimum standards. In the case of consultant qualifications, all consultants must meet this objective.

Citizenship and Immigration committee  Yes, of course. Subclause 31(1) of the bill states that the public register must be in a searchable format. The register will be available to the public, and the public can search for a consultant.