The comment document contains all of the content in the comments. It begins at the CP immediately following the Header Document and is FibRgLw97.ccpAtn characters long.

The locations of individual comments within the comment document are specified by a PlcfandTxt whose location is specified by the fcPlcfandTxt member of FibRgFcLcb97. The locations of the comment reference characters in the Main Document are specified by a PlcfandRef whose location is specified by the fcPlcfandRef member of FibRgFcLcb97.