Now for the PRTD issuance and codes put there: as has been noted here before, RC means an H&C application (PRTD application on the basis of H&C reasons) has been approved, hence 'passed.' Implication for the returning PR have been confirmed here many times, that the PR can apply for a new PR card without worry.
But the other code that is commonly seen is "R" (no second letter), which is - simply - passed, with the meaning that the residency obligation is met. Hence I can only conclude that anyone who has this code CAN apply for a PR card renewal with no worries whatsoever.
Currency caveat:
While the operational manuals you cite and link can still be very helpful, particularly helpful in understanding general procedure (I have, for example, referred to them often over the course of the last fifteen years, and still consult them often -- I have long had copies of these and all the other ENF manuals on my computer hard drive, along with copies of the Citizenship manuals which are no longer accessible at the IRCC website, at least not easily found), they were last updated nearly a DECADE ago. And they are guidelines, largely advisory, oriented to explanation. They do not dictate required practice or mandatory application of the referenced provisions of law.
(Most salient example of provisions in these manuals not followed is the part of Section 7.5 in ENF 23 (page 25) which states that "
In the case of a permanent resident outside Canada accompanying a Canadian citizen, it is not necessary to determine who is accompanying whom, nor is it necessary to determine for what purpose." While this is generally the case, there are many cases in which counsel for the Minister argues the contrary, and in some cases IRCC, the IAD, and Federal Court have declined to follow it, some explicitly referring to it.)
Current PDIs are more reliable, but these too come with the caveat (often explicitly stated in the PDI) that they contain statements of policy, procedure, and guidance used by IRCC staff but are publicly published "
as a courtesy" to "
stakeholders." Around a decade ago, going back to before the name change to IRCC, CIC began the process of migrating the guidelines in operational manuals into Program Delivery Instructions (PDIs), but this stalled in regards to both the enforcement and overseas processing manuals. This migration is still in process. Note, for example, that the general PDI for "
Permanent resident (PR) card and PR status" still refers to ENF 23 and OP 10 but only links to the latter. More and more of what is covered in ENF 23 is now covered by PDIs like those specifically covering PR card renewals, processing complex PR card applications, PR status determinations, among others (several of these linked here:
https://www.canada.ca/en/immigration-refugees-citizenship/corporate/publications-manuals/operational-bulletins-manuals/permanent-residence/card.html )
Counterfoil Codes:
Just a note that these codes are most clearly spelled out in the enumeration of particular IRPA provisions in Section 3.1 in ENF 23, beginning at the bottom of page 7. "R" is a category code. The actual code on the counterfoil should include at least a hyphen and the numeral 1. Examples include "R-1" (for PR in RO compliance), "RC-1" (for positive H&C determinations), "RX-1" (PR not in RO compliance but determined to have been in Canada within previous year, given PR TD allowing travel to Canada for appeal), and so on.
Impact of Positive RO Compliance Determination:
Remember: a determination of RO compliance, or a determination of whether to allow H&C relief, are date specific and there is a new and different calculation for each day. Generally a month or three or more does not change things much, especially given the somewhat liberal approach IRCC employs in determinations other than overseas PR TD applications (for which there is a presumption the individual does not have valid PR status), so there is generally not much that would change the outcome when comparing a determination based on the date a PR TD was made versus one based on a date the PR actually arrives at a PoE or a somewhat later date a PR card application is made.
The caveat here is that if there is a significant difference in the key factors, comparing circumstances as of the date of the PR TD application versus a later date (such as date a PR card application is made), the outcome can be different.
Thus, even in regards to a positive H&C decision, reflected by the RC-1 coding, while it is fair to say (and many including me have said this) that it is generally safe for a PR to apply for a new PR card despite being in breach of the RO,
it warrants cautioning it is NOT for sure safe. In particular, for example, if additional absences after the positive H&C determination are such they could be seen as a change in circumstances since the positive H&C decision, there is a risk the PR card application could trigger inadmissibility proceedings. Among the occasional scenarios we see discussed in the forum, for example, there are some that involve PRs who came to Canada briefly (with the RC-1 coded PR TD) and soon departed Canada, returning abroad for an extended period of time. If they applied for a PR card while here, then left, depending on all the usual factors they could be at risk of inadmissibility proceedings, or at risk of an alert being placed in GCMS which increases the likelihood of a Residency Determination attendant the PoE examination when they next return to Canada.
Summary: For the PR who returns to Canada with a RC-1 coded PR TD, it should be safe to SOON make a PR card application after arriving so long as they continue to stay. Risks vary otherwise.
The thing about a PR who returns to Canada using a PR TD coded R-1 is that almost always means that as of the date they made the application for a PR TD they were actually in compliance with the RO. That will mean they are very likely to still be in RO compliance when they travel here, or at least not in breach by much. PRs in RO compliance can safely apply for a PR card.
There are scenarios warranting some caution.
We have seen, for example, some PRs who applied for a PR TD relying on H&C considerations issued a PR TD coded R-1 not RC-1. Since they are in breach, and there is not a definitively positive H&C determination, they should probably be more cautious before making the PR card application.
Some PRs may have been in RO compliance relying in significant part on presence in Canada approaching five years ago, and if there is a significant delay between the date they applied for the PR TD and their travel to Canada, and in the meantime not only have they been losing credit as days passed to the point they are in breach before coming here, and they will continue to be in breach for some time after arriving (days here offset by loss of that date five years previous), they too might want to exercise some caution. The risk should be low (they should be close enough to compliance that in conjunction with being here to stay they are not subjected to inadmissibility proceedings), but if they have additional absences or otherwise it is apparent they are not settling here to stay, they might be wise to get into compliance again before making a PR card application.
