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The whitelist header row checks appear to be shifted by one.
For example if you take the template whitelist and simply delete the "is Accredited" and "Non-Accredited Limit" columns you get an error per below. As these columns are not required unless the Pegged STO is attached this should not result in an error.
If you delete the Exempt from "Exempt From % Ownership" column you get
delete the "Can Buy From STO" column you get