So, this does sound like a reasonable action plan (mentioned on another thread):^ Nope. I'm afraid you still have to get a new FBI PCC, even if the subsequent visit was made on a tourist visa. IRCC is very strict about this. I've easily seen them request for PCCs for 5.5 months of accumulated visits to the US.
I have less than 2 months before my ITA expires, and it looks like I need to get a new FBI Clearance, as I visited the US last year for the first time since I got my first clearance in 2011.
If it doesn't come in time, I will include the old PCC, and in my LOE include proof that I have submitted my application for the new PCC.