The "CIRC APCH-VMC ONLY" limitation is how UAL gives type ratings since about 2003. In 2001 when I upgraded on the 737 we actually did an IMC circling approach in the sim on the Maneuvers Val part of the check-ride. Thus no limitation for that type of mine. The B-757, B767, and A-320 that UAL gave me did not have that as part of the syllabus and thus the limitation. It's not a problem as Op Specs at UAL require 1000 - 3 for circling approaches anyway.