Assignment Task
Scenario:
You are a newly registered and newly employed Registered Migration Agent. Your new employer is Mr Coe of Ethical Migration Pty Ltd. Ethical Migration has an office in Australia with five RMAs and four administrative staff.
Ethical Migration currently only offers migration and citizenship related services. Mr Coe provides an orientation to your new workplace and systems. Before he assigns you any client work however, he has a project for you. He directs you to the MARA Code of Conduct Consultation
He asks you to analyse that document, and prepare a memo identifying a list of proposed code changes that would require Ethical Migration to update their processes, and to recommend what new processes should be implemented. He says ‘We think we comply with the current Code of Conduct, but I need to know about possible issues that will require us to change or review our current processes. Not general changes, like competence, or coercive conduct.”. He specifically wants to know about possible implications of the following specific issues:
1. Ethical Migration has an arrangement with an offshore firm (Golden Passports Inc), a business that offers ‘Citizenship By Investment’ to Hong Kong citizens. Golden Passports specializes in Citizenship By Investment for Malta, Vanuatu and St. Kitts. If they get an enquiry about investment visas for Australia, they refer the client to Ethical Migration. Mr Coe has a close relationship with Golden Passports, and twice a year, they run joint seminars in Hong Kong with advertising featuring Mr Coe. Mr Coe is concerned to understand whether he should exercise greater control over the advertising, and whether he should exercise greater control over their communications with potential clients.
2. Ethical Migration Pty Ltd has written contracts with Medisure Group to offer health insurance to visa holders, and SuperFX to offer international currency transfer services. They earn commissions from both of these arrangements. Mr Coe wants to know if the new code might require them to specifically identify these commissions, and how they should do that.
3. Mr Coe has always wanted to be a marriage celebrant, and offer those services to clients. He understands this was not possible under the existing code, but wonders if the proposed changes might permit it?
4. Ethical Migration charges a fixed fee for initial consultations. They provide a copy of the consumer guide, prospects sign a client agreement, and get a copy. He tells you this is a cumbersome process and wonders whether he might be able to streamline it under any new code.
5. Ethical Migration normally only identifies, and requires the person who will be paying the fees, and the responsible RMA to sign the client agreement. He wonders what changes they might have to make to their Client Agreement, and this signing procedure, under any proposed changes.
6. Ethical Migration back up servers to a cloud service. Ethical Migration does not encourage applicants to access their applications via ImmiAccount or provide any details that might allow them to do that. He wants to know if that will still be permitted under the proposed changes, and if so, what processes are required, and how should he implement these changes.
7. Identify at least two other specific matters identified in the Consultation Document which you believe may require process changes, and discuss them. Make recommendations about possible process changes. You are permitted to make a reasonable estimate of what Ethical Migration’s current processes are, eg. how they currently run their business.
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