Not sure if "2. loc doesn't start in the same column" is fixed, too: var-names
(in fixed format, which is used by PSPad) can start from column 11 and can end
in column 72 (OK, they must be shorter than 32 chars, but this is nothing an
editor has to care about).

BTW: do you think it is possible to have two COBOL syntax (fixed and free
format)? They are nearly identical, despite of no areas in fixed and therefore
no special meanings in column 7.
In both formats
- comment can start with *> (anywhere in the source) [in fixed format additional
to * in column 7]
- compiler directives start with >>

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