I just tested this with both 2.3 and 2.3 update 1 and I cannot reproduce the problem you are seeing.
Perhaps this is related to a directive that you are using that I am not.
Could you try creating a new managed code console project and replacing the contents of Program1.cbl with the following to see if you still get the error?
program-id. Program1 as "testman66.Program1".
data division.
working-storage section.
01 PREV-BC-CTL.
10 P-BRCLGROUP PIC 9 VALUE ZERO.
10 P-ENPG PIC 9 VALUE ZERO.
10 P-ERATE PIC X(5) VALUE SPACES.
10 P-FORM PIC X VALUE SPACE.
66 P-BC-NPG-RATE RENAMES P-BRCLGROUP THRU P-ERATE.
procedure division.
MOVE SPACES TO P-BC-NPG-RATE
if P-BC-NPG-RATE = spaces
display "ok"
else
display "no"
end-if
goback.
end program Program1.