4. Conclusions and recommendations
Over the course of its first year and a half of operations, the ICCRC had successfully established itself as an arms-length organization that regulates immigration consultants. Although spending more than originally anticipated over this time period, the ICCRC was able to undertake the majority of the activities outlined in the contribution agreement in the four areas of capacity building, communications, competencies, and compliance and was able to operate without requiring additional funding from CIC above what agreed to at the outset. The assessment of these four areas of activity showed no major issues and, overall, the evaluation found the organization has established the foundations required to fairly regulate immigration consultants. In addition, the financial analysis conducted by CIC’s Financial Management Branch shows that financial viability had not been achieved as of December 2013 and the financial situation of the organization was unfavourable according to the department’s standards. However, ICCRC’s financial situation has steadily been improving and it has started repaying the contribution to CIC, as per the negotiated schedule.
Recognizing that the ICCRC is a young organization that is still developing its capacity, there is room for improvement on certain aspects.
- While the foundations of ICCRC’s governance and management structure have been established, the organization still needs to finalize its internal policies and procedures.
- The organization also must continue to monitor spending and maintain a strong membership base to ensure ongoing financial viability.
- The ICCRC needs to improve its website and continue its work on external communications to ensure that its mandate and key activities are clearly communicated to stakeholders (e.g., public, potential applicants, CIC).
- Where possible, the ICCRC needs to provide more information to its various stakeholders, including the public, on how it handles complaints and the disciplinary actions taken.
- The ICCRC should proactively engage in discussions with CIC regarding any originally planned activities agreed upon in the Contribution Agreement that are still outstanding, e.g., compensation fund.
CIC was involved with the organization by providing support during its establishment and ongoing operation, both in the form of operational guidance and financial support. Overall, CIC and the ICCRC were successful in establishing a good working relationship and CIC provided adequate support during the creation of the organization. The relationship between the ICCRC and CIC is now more arms-length, with the CIC role limited to monitoring the repayments from the ICCRC and liaising with the organization on an as-needed basis on matters of mutual interest. From an internal perspective, the evaluation identified a few issues that CIC should address to ensure that the department is working only with authorized representatives (including members of the ICCRC) and that stakeholders, both internal and external to CIC, are sufficiently informed about the regulatory body and the use of authorized consultants.
Recommendation #1: CIC should ensure that staff processing immigration applications have a common understanding of the regulations, the role of the regulatory body, and the processes for CIC to validate the use of authorized representatives and to file complaints regarding authorized and unauthorised representatives. This should be done by:
- Clarifying the process for how CIC validates the use of authorized representatives and for how complaints should be filed;
- Updating the relevant manuals (e.g., IP9) in a timely manner to reflect any changes to these processes;
- Issuing operational bulletins in a timely manner to ensure processing centres and visa offices are aware of any changes to the processes; and
- Updating relevant training material and/or courses to ensure that they include information on the regulations, the use of authorized representatives, the role of the ICCRC as the regulatory body, and the process in place within CIC for validating authorized representatives and for filing complaints.
Recommendation #2: CIC should establish a communication strategy to raise public awareness regarding authorized representatives. This strategy should ensure that stakeholders (e.g., the public and potential applicants) understand the role of immigration consultants and that an authorized representative must be used if applicants choose to be represented.
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