FTP Issues

I just migrated our older BM server to a new server running BM 3.9 Sp1.

I am now having issues with ftp sites the use active FTP. On the old sever I
had an exception from private to public using the stateful filter.
(ftp-port-pasv-st) This has worked on this server for years.

I can access most sites using passive mode, but I have users who use the
Windows XP command line FTP utility which doesn't seem to like passive mode.
I also have a few sites that require an active connection.

As a work around I have been creating less restrictive exceptions to only
servers that need it, and installing FTP software that handles passive mode
better.

Has anyone had this issue with BM 3.9? Or was it not supposed to work on
3.7?

Thanks,

Jim