This thread got off track quick. To answer the original question, you do not have to have cloud clearance requirements to conduct a circling maneuver unless required by your ops specs. VMC is defined by visibility, ceiling, and as mentioned cloud clearance requirements. The only definition of cloud clearance requirements is in FAR 91.155 which covers VFR flight rules. Because you are operating under IFR in a circle to land maneuver these do not apply. Bottom line, check your ops-specs. If they say that it is only "clear of clouds" for a circle to land maneuver, this is what is intended and is legal to do.