Open Letter to ICCRC

Dear ICCRC CEO,

I am writing to you this open letter because, based on data and my personal experience, I can see the profession failing. I have taken months to get to this letter because I am physiologically impacted by the profession and the treatment it meets out to senior members. The motivation of writing this letter began after I began observing an RCIC who was elected to the board in 2015 November. She sent me a letter I considered corrupt and the complaints department failed to act. Out of frustration, I posted a message on the RCIC’s ONLY MONOPOLY “Association” CAPIC discussion board and the responses showed who we really are as consultants. This was the message I posted:

Are we Consultants ready for self-regulation?

November 2015, I attended the ICCRC AGM and got back to find an email in my inbox. It was an email from a member who was elected to the Board of directors of ICCRC. The email was a demand for a bribe (in my view). The amount demanded if I recall, was around $3500 under a flimsy pretext and the email went on to say that this individual was “popular” among colleagues (possibly meaning the election victory). I immediately reported this to ICCRC who elevated it to a complaint which was later closed (without a proper reason).

June 2017, I just concluded an immigration seminar in an Indian city and a participant came up to me and said “I wish you were NOT an ICCRC member”, and I asked him why? He said that his friend had complained to ICCRC about an agent who had mislead his friend and demanded a refund. The response from the ICCRC member associated with the agent were absolute lies which his friend proved as lies to ICCRC. It has been several months and no decision was made with that complaint. He told me that ICCRC and Consultants are a bunch of “frauds”. I asked him why he is approaching me because I am a RCIC and he told me that it was ONLY because he has friends in Canada who I had represented. Please click here to read more!

My dear colleagues, I am not a bearer of good news, and in this communication and a series of communication to follow, I would like to share with you my experiences. I am just an ordinary RCIC with no agenda and an absolute supporter of self-regulation, however, I have seen some of my employees quit because of bad press and some poor complaints management (my view) by the regulator and it is impacting me professionally.

The post pertains to a department in ICCRC and was not targeted towards any particular individual or group. Some of the responses were abusive, attacking my credibility and questioning my trustworthiness. This is my livelihood. A snapshot of what I do is provided in the chart below:

When started?	First advertisement in the Indian papers in mid-1993, Did part time for 7 years. First office with staff in 1999.
Pervious company name	Polar consultants. (Had to change it because India would not allow Polar as too many businesses have the same name, strange!)
Current company name	Polinsys Ltd (Registered in Canada, India, Malaysia and Nepal)
Other establishments:	One Data center and 10 document collection/seminar centers
Partners or Franchisees:	NONE
Agents:	NONE
Staff Strength:	83
Number of total representations:	1000’s
Number of applications currently being represented (live) today	734
Client Demographics	Over 95% of my clients from a small state (province) in India and from Ontario in Canada.
Canada Education Recruitment?	Yes
How many student intakes per year	2016/2017 – 110 students (objective 650 by 2020)

“Immigration Consultant” is the name offered to those who advise and represent Immigration Applications. If this is the right definition, Representation Rates are very important and must be disclosed for participating in elections. In fact, It must be disclosed by every standing member just like Income taxes are disclosed by politicians. Unfortunately, for some RCIC’s, they win elections to sit on the board and take a piece of the Pie of the fees collected. They have nothing to contribute and use the platform to self-promote, and to improve their “branding” (notice the response from the member about whom I had complained) and to attract agents from overseas. For a successful consultant (with high representation rates), the election win will mean a responsibility to contribute ideas and create laws which will benefit the profession by protecting the client. Unfortunately, currently elected board members are void of such ideas because they lack experience and knowledge of the profession. Some of the posts I have seen on the CAPIC discussion board is a testament to this. Click here!

People come in all types and it is not their fault to want to hold a position on the board, however, all efforts have to be made to ensure Representation rates has to be disclosed. This will avoid part-timers who are there for purposes other than to contribute to the profession. We need to stop this massacre of our valuable time, money (fees) and the brutal assassination of a noble profession. I am not implying the more the Represented client number the better. Representation figures show if the individual who is going to sit on the Regulator’s board is a part-timer or an immigration consultant. Agent FREE Live Representation figures (currently being represented with ICCRC and not signed retainers) is easily auditable and cannot be fudged. It is then up to the members to elect part timers or full timers into the board. People who are part-timers will have NO ideas and will not do justice for the over 5000 professionals whose livelihood is at stake. Those part-timers take a piece of the pie of the membership fees through sitting fees, etc. Those part-timers lace their resume with their credentials (Director of ICCRC) even though they lack basic knowledge of the profession and that I believe is one of the reasons why nothing is really happening with the regulator. Those with low representation figures based on platforms are “failure” candidates seeking a position at the cost of the entire industry. That is why we have NOT seen any action on FAKE CONSULTANTS for the past few years, absolutely NONE! Years pass by and nothing is happening. Every year we all pay a pretty high fee to be in this profession. Over 6 years have passed with nothing done about FAKE consultants is shameful.

Hard Core consultants are a litmus test for the industry. Because their volumes are so high, they pick up “tremors” in the profession in advance. An effort must be made by Management to bring them into ICCRC’s consultant group. If the board members operate with an agenda, the management must be free of it and must open their doors and seek out the true leaders based on professional strength (Service platform-based Representation rates). ICCRC and the profession will have a lot to gain from their input. Their absence in the process is telling. I am sure, all of them will be willing to work for FREE because their contributions are going to impact the profession positively and they themselves stand to gain when the profession gains. People who depend on an income from ICCRC are members who are not professionals and lack representation rates. If the minister feels that we are still evolving even after 6 years and more in existence, then in my opinion, self-regulation is a failure. RCIC’s paid by the regulator are Jack of all trades and must NOT be encouraged.

I had posted my representation rates prior to the election of 2017, and the reason was to make the membership think of the importance of these figures and to make sure those participating in the elections disclose theirs. It has NOT worked because there are members who deviate and attack and demean when such information is provided and even this year, elections in ICCRC had no disclosure of Representation Rates. We all just go with smiling faces and these individuals know to “talk the talk and walk the walk”. Candidates always have a way to avoid this figure by stating their “Years of experience”. In fact, if they have “Years of experience” with low representation rates, it shows failure rate and not success rate. Click here!

The power hungry nature of the membership can be seen on the discussion titled @Are we consultants ready for self-regulation?@ on the Association (CAPIC) discussion board!

Does ICCRC know its membership?? Does ICCRC know about the different practice platforms? Do they know about specialization platforms? Knowingly or unwittingly, each member has a practice platform, examples of some of them are:

Independent Consultant
Boutique Consultant
Family Consultant
Consultant – Agent-Based
Consultant – Specialization
Consultant – Agent-Based Mass representation
Consultant – Multi Office single country
Consultant – Hard Core
And more…..

Three factors influence the setting up of platforms: Volume in Representation based on Practice platform, Stake Holding etc. Every effort must be made to discourage International Agents, which is the prime cause of FAKE consultants.

Many of these elected individuals or “Board Members” disregard the hard work done for the profession by ordinary RCIC’s and have a self-promotion campaign inside the profession. We can see group pictures of them posted on the ICCRC portal and I had one member from another country say that the Canadian Regulator looks like a “Social Club”. They even self-promote themselves on the ICCRC newsletter pages. Their election victory is also used to make off for their lack of representation figures by signing up agents because of their position. This also works in favour of Fake Consultants. I have also learned that winning elections allow RCIC’s to charge higher fees because they believe they have the branding.

Power hungry MOB like behaviour by RCIC’s: My post in the only “Association Portal” made me feel humiliated. Words like “If you have Balls”, “Get Out”. “I don’t trust you” are words used by extremists or thugs, and not from a professional organization. The silence and the participation of senior members were telling. In most professional bodies, business leaders are also Professional leaders but not in this profession. Here business leaders (Hardcore consultants) are attacked, snarled at, and asked to “Get out” even though they silently do tremendous work for the common good. When I say I have no agenda and i do not want to stand for elections, i mean every word of what i say but some of you claim to know more about me than me. Let me put it in writing to you Sir, I do not intend to stand for any position in ICCRC. I consider a position on the board as a very responsible position and I will not be ready for that position unless I have at least 10 hours a week to contribute. I work with a conscience. I have invested a lot of time, money and effort to negotiate with a department of the Indian Government in acknowledging RCIC’s as the legitimate people to represent immigration clients and I was snubbed by ICCRC. Thank you!

Racism in ICCRC?: Are “hardcore consultants” ignored and attacked because most or all “Hardcore consultants” are 1^st Generation Immigrants? By having a few people manage or control the organization and every effort made to select only the “Yes Man” person, it defeats new ideas and approaches. “HardCore Consultants” are not “Yes Man”. They have their own ideas and will have hundreds of approaches and solutions for each problem, ignoring them is shameful and costs everyone. Please read the challenges faced by “Hard Core Consultants” so that you can understand the challenges posted by Fakes

The complaints system need to be radically changed and NO RCIC can decide on a complaint. RCIC’s are grouped in very extreme groups (within the profession), who work against each other. Lots of politics, rivalry and infighting, and many aims for Power and PPmP. With such extreme groups and infighting, it is not possible to be fair. My complaint is genuine and I had a member of the Board send me an email about an inappropriate demand for an amount to be paid out. If that complaint was dismissed, I find it strange. There is proof and no action was taken.

People and ONLY People

People and ONLY People can ensure a successful regulator. In my view, Regulation is best left to IRCC because of the following reasons:

1) Consultants are NOT ready for self-regulation yet. The current platform is unfair, where race plays a vital role. Experience, exposure are key components which will allow an individual to come up with ideas to combat Fake consultants or even customer service. People with limited consulting experience or limited ownership of businesses will participate in arguing policies based on “Theory” and that is how most regulations in ICCRC are set today.

2) The current platform is like a pyramid operation (Ponzi) which could break down one day causing a lot of pain to a lot of people, including the public and the reputation of a country

3) A true professional knows that when regulated by RCIC, there is a level of branding that comes with it. Self Regulation is the best if there are fairness and professionalism. Every year that passes without anything being done against FAKE consultants or Customer Confidence is a year lost forever.

4) If RCIC’s are paid for service through the “membership pot” and the RCIC’s selected is based on Race and the way they talk, Self-Regulation it is self-defeating. NO member must be paid through the “Membership pot”. In other words, if an RCIC is doing a job with the regulator, it must be entirely Voluntary and not paid. This address two core aspects

a. The regulator is free of “Jack of all Trades”. An RCIC is meant to represent clients and not sit in the Complaints dept or any other department. All roles with the Regulator MUST be through hired full-time professionals who do not have an “RCIC” behind their names.

b. When money is taken off the equation, RCIC’s will focus on what they are supposed to be good at, which is to gain client confidence and represent clients.

c. People who do voluntary work in ICCRC without any “benefits” are the true professional. They earn rewards through a strong regulation which increases client confidence thereby increasing their bottom line which is client enrolment. It is in their own interest to volunteer their time and work for ICCRC for FREE when required.

Is ICCRC Operations Model in a Ponzi model?

Reviewing the Business operation and comparing the business model to the performance analysis, it can be viewed by some analysts that the Regulator is operating on a Ponzi game model where new members contribute towards wages and incentives for a select few (and the operating costs of course), There seems to be an emphasis on attracting new members and it is possible that training and selection ethics may be compromised. One reason why ICCRC wants to take in a lot of new members without properly vetting them.

If the mandate of ICCRC is to protect the public, the mandate can only be fulfilled if people on the board are people accepted by the public. If we elect members to the board, they must be people who have gained the trust of the public. What better way to test public acceptance & trust than to see direct representation rates (not Agent representation rates)? If we are representing a lot of clients in relation to the practice platform we have adopted, then it is one test of public acceptance. NO QUESTION ABOUT THAT!

If we elect people with poor representation figures, it is counterproductive to the cause of ICCRC!

It is not “taboo” or “Confidential” to disclose representation figures. I Published my Agent Free representation figures openly at the Association Portal. So can people who stand for elections. NONE of the RCIC’s who stood for elections posted their representation figures in this election cycle or any elections which is very telling. Representation figures are easily auditable and false information can be verified. People with high Agent-Free representation figures are typically trusted by the Public (why else do they have high representation?) and are individuals who will work hard for the profession. People with Agent-Free high representation figures do NOT do anything detrimental to our profession. If someone has a lot of experience with low representation rates, they lack public support. Just common-sense math!

Why are representation figures hidden by all members who stand for Elections to be elected to the board? One of the most easily audited figures is the “Active Representation” rates!

Profession without Borders: Immigration Consultant is a profession without borders and election to the board must reflect that. Unlike a Provincial jurisdiction-based approach adopted by Lawyers, we should be seen to the world as a profession without Borders even though our legal jurisdiction in Canada (Federal) because we deal with Canada services. What better way to highlight this feature than showing the world that ICCRC Board Election is based on Practice platform or Specializations and NOT territorial. I have provided some practice platforms in this open letter, but this has to be developed with careful thought and must be a dynamic list which is open to changes depending on changes in the industry. Practice Platform based board representation demonstrates that our profession is represented professionally rather than territorially. Today, the Regulator does NOT know the membership. This will allow even the regulator to understand the membership better.

Why are representation figures hidden by all members who stand for Elections to be elected to the board? One of the most easily audited figures is the “Active Representation” rates!

PPmP: Piece of the Pie of the Membership Pot

A term I learned from another HardCore Consultant who said that the main reason for self-regulation was PPmP. If any RCIC is being paid out of the membership pot, it is not right. The RCIC is depending on an income from Self Regulation which is not OK.

Racism has NO place in the profession, Inclusivity based on knowledge, practical experience, Agent free operations, Stakeholding and investment in the profession are all factors to be considered when selecting a good consulting team to consult (Volunteer basis FREE) for ICCRC. Self-regulation has not helped the profession, rather, the situation has worsened. When the regulation was NOT there, the rate of representation for Immigration services was higher and the people performing such services was much lower. Currently, the rate of representation is declining and the number of RCIC’s has more than tripled in the recent past.