Education Agents Performing Unauthorized Immigration Services
Many educational agents or unauthorized consultants claim that they are able to help for free or a recovery administrative fee basis because they are not being paid immigration service-related fees directly by the client. This unfortunately is an overly narrow reading of s. 91 IRPA.
If the application’s success (i.e. student getting a seat at the school) pays you, you are receiving consideration (albeit on what we often call ‘contingency’). Furthermore, even if you do not actually sign a Use of Representative Form but are contributing (i.e. advising) as it pertains to immigration advice on a study permit application – you are advising with respect to an application.
It is also not simply good enough to have a ghost-signing RCIC on your contact list, or hire one internally for your organization. While the former might squeak by on ethical standards or not get caught, the second clearly does not change the issue of consideration. Furthermore, in most cases if you try and seek remuneration or some benefit back, that too could constitute consideration.
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