What is the regulation for the location of sew-on rank?

It seems like they lined up the top of the new rank with the bottom of where the Velcro was...but I can’t find anything saying that it’s wrong

WO1 (Join to see) - I looked to see if the stitching from the Velcro could be seen, couldn't find it (on my iPad). I'm normally a Regulation guy, but they need to put it over the top of the spot where the Velcro was.

LTC Jason Mackay yes, sir. I will have them fix it when I report back to Fort Rucker. Thank you!

WO1 (Join to see) - DA PAM 670-1 para 19-6

"(2) Subdued. All officers will wear subdued grade insignia on utility uniforms, the cold-weather coat, and on the ECWCS jackets. On the utility uniforms, the subdued grade insignia will be worn centered on the front hook and loop face pad. On the ECWCS jackets, the subdued insignia is worn either centered on the hook- and-loop face pad or centered on the front tab. Wearing cloth rank insignia tab on the front tab of the ECWCS parka is authorized, as described in paragraph 19–8d, below."

Para 4-8
"e. Soldiers may sew on the U.S. Army tape, name tape, rank, and all authorized badges as an option. Hook-and-loop fasteners for U.S. Army tape and name tape may be left on or removed when sewing on the uniform. If worn, badges must be all sewn on or all pinned on; Soldiers are not authorized to mix sew-on badges with pin-on badges. When personnel sew on badges, the following must also be sewn on the combat uniform coat: name tape, U.S. Army tape, and grade insignia. If a nametape, U.S. Army tape or grade insignia is sewn on, then personnel must sew all three of these items on the uniform coat. This requirement does not apply to the patrol cap. If Soldiers choose to sew on U.S. Army name tape, rank or authorized skill badges, it will be at their own expense. Soldiers may wear pin-on badges with sewn on name tape, U.S. Army tape, and grade insignia. Soldiers are not authorized to wear pinned on badges in a field or deployed environ- ment."

So between these two, the intent was to simply put the rank where the Velcro (hook and loop) is, or was.

When I converted mine, I took the rank with Velcro, and took a seam ripper and removed the Velcro part, leaving the perfectly sewn square that fit exactly over the old Velcro Pyle portion on the coat.