The rules for creating an EDI file need to be strict, but the rules for processing them can be as loose as the people consuming the file want them to be. I agree with you that I cannot see any valid rationale behind how the two 13 records can be merged into one, but that doesn't mean that somewhere along the line, someone went and built a system which does that for stupid reasons and they now need them lumped together in order to interface with that system.
If that's what he has to work with, then that's what he has to work with and there's not much option beyond trying to hammer a round peg into a square hole.





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