These are interesting questions in light of the various changes to the instructions since June 26. First, the facts:
- The latest instructions indicate that PCC should NOT be sent to the CIO
- The latest instructions also indicate all documents should be sent to the CIO (and do not acknowledge an exception for PCCs where those instructions are)
- The latest OP6 indicates the CIO should check for all documents in the application before deeming it eligible for processing
- Visa officers and any other staff that may check applications are human beings, prone to errors and confusion just like the rest of us
- As of June 26 there are annual caps in place (1000 applications per NOC code, 20,000 applications for non-AEO FSW total)
Given the annual caps, the risk of delaying one's application or of having it sent back are high, meaning that one may not be eligible to apply until next year (and then depending on whether/how the rules change again...)
Without really understanding the specifics of anyone's situation I can't really give you advice, but one thing to consider is to think about your specific situation as you make your own decisions.
Example 1: if one has a police certificate already or can get it before all the other documents are ready (perhaps one has already been waiting for it before sending the application in to the CIO or you are lucky enough to be able to get one quickly) then the worst that happens if you send the PCC to the CIO - unnecessarily, perhaps - is that the CIC eventually asks you to send another one in to the visa office. Ok, that would mean more paperwork but also that your application has already been processed and you are in the system. You made it in under the caps and avoided the risk that the application be sent back because somewhere along the way someone thought it did need to be sent in. After sending the application in you can get another PCC so that if/when you need to send it to the visa office you have one that is less than 3 months old at the time the visa office gets it. Minimum risk, maximum benefit (albeit with extra effort for an extra PCC).
A twist would be to send a certified copy of the PCC to show one has it and show the application is somewhat complete and add a note that you'll send it to the visa office when requested, per the latest instructions in EG7000. This twist makes sense if you assume you can get the PCC to the visa office within the 3 months since it was issued (since per the new instructions it has to be received by the visa office within 3 months of its issue date)
Example 2: one does not yet have a police certificate and is just applying for it. Say one needs an FBI PCC because one lived in the US for 6 months after 18 years of age. That means it will take 13 weeks to get it back. In 13 weeks the CIO may receive many applications and some caps may be reached (nobody knows this for sure but it is likely a valid fear). Therefore, here it may be worth sending the application in without the PCC, explaining very clearly on the checklists that the newest instructions state that one should not send the PCC to the CIO and therefore one will submit it upon request. This way, you hopefully get your application in before the caps fill up if there's no confusion about whether you actually needed to send the PCCs or not (given the changing rules and human element involved). In the meantime, you work diligently to have the PCC in time to submit it to the visa office.
Anyway, that's just one way of thinking through the options.
