To: The Right Honourable Prime Minister of Canada and The Honourable Minister Marc Miller

From: Concerned Immigration Professionals

Dear Mr. Prime Minister and Minister Miller,

We trust this message finds you in good health. As dedicated immigration professionals who prioritize the highest standards of professionalism and ethical conduct, we respectfully bring to your attention a critical issue that impacts not only our profession but also the integrity of Canada's immigration system.

The proliferation of unauthorized and unregulated immigration consultants, often referred to as 'ghost consultants,' or ‘unlicensed consultants’ operating both within and beyond Canada's borders, poses a growing threat to the professionalism and effectiveness of licensed Canadian immigration consultants. These individuals frequently operate without accountability or oversight, delivering substandard advice and services that not only harm clients but also cast a shadow over the reputation of legitimate consultants.

We firmly believe that addressing this issue is essential for maintaining the integrity of Canada's immigration system and safeguarding the interests of those seeking immigration services. To this end, we propose the following measures, fully cognizant of Canadian charter laws and CICC mandates:

1. Comprehensive Regulatory Revision:  We strongly urge The Law Society of Upper Canada, the College of Immigration and Citizenship Consultants (CICC), the Canada Border Services Agency (CBSA), and Immigration, Refugees and Citizenship Canada (IRCC) to engage in a comprehensive revision of the current regulatory framework. This revision should mandate that all practicing immigration consultants hold either Canadian Permanent Residency, Citizenship, or a valid work permit. Moreover, for consultants operating under a work permit, we recommend synchronizing their CICC membership with the validity of their work permit, terminating it concurrently upon its expiration. This modification is intended to enhance the Government of Canada's oversight of individuals managing immigration cases and streamline the investigative process when necessary.

2. Strengthened Enforcement and Oversight: These measures will significantly reduce the influence of unregulated consultants operating internationally. Additionally, we advocate for more robust enforcement and oversight mechanisms to penalize and deter the operations of unlicensed consultants, both within and outside Canada.

3. Recognition and Support for Licensed Consultants: We respectfully seek recognition and support for lawyers in good standing and licensed consultants, granting them distinct advantages and privileges over unlicensed individuals per Canadian charter laws and CICC mandates.

4. Equitable Regulation: We acknowledge that some lawyer groups are calling for the revocation of Rule 13(2) in the CICC Code of Conduct, which permits RCICs to compensate agents who procure clients, provided they are pre-registered with the College. This rule has raised concerns as it may inadvertently pave the way for unregulated agents to offer immigration services, contrary to section 91 of the IRPA. In response, we propose exploring measures that grant more authority to regulators in immigration law, similar to lawyers' exclusive rights in property transactions. This could limit representation to Canadian citizens, permanent residents, and work permit holders who are licensed professionals, thereby ensuring that unauthorized and unlicensed practitioners are excluded from this field. We believe this approach will contribute to cleaning the current chaos in the industry. 

In conclusion, as dedicated members committed to upholding the highest standards of practice, we firmly believe that these steps, including equitable regulations, are vital for preserving the integrity of Canada's immigration system and the profession of immigration consulting. We kindly request your serious consideration and prompt action on this matter. Should the government choose to engage us in this endeavor, we stand ready, willing, and able to address this issue and achieve tangible results. Your support in tackling this challenge represents a significant stride towards ensuring continued trust and professionalism within our field.

Concerned Immigration Professionals