Article 61-2-10 of the 2004 ICRRA states that there will be a “certain number” of Counsellors. There are currently 19 Counsellors who sit in teams of three. Their appointment is for two years only. Limited training was provided by the Ministry of Justice. In addition to being employed by the Ministry of Justice, the Counsellors are administered by the IB. Accordingly there remains an absence of independence. The conclusions of the Counsellors are not binding on the IB and the final decision still rests within the IB, the original decision maker. Lawyers have no access to these conclusions which remain strictly internal. An effective “objection procedure” to an administrative decision requires transparency and access to independent judicial review. The introduction of Refugee Examination Counsellors provides neither. One test of whether this new procedure is effective might be if the reversal f first refusals increases.