I don't know about the DB2 utility itself, but any authorized program is 
allowed to bypass "region" limits (and that includes MEMLIMIT).
Whether they should, and by how much they should choose to exceed, are 
different questions.

This is little different in spirit (perhaps different in scale) than that 
any authorized program can get storage not within the user region so is 
not bound by the below-2G region limits.

Peter Relson
z/OS Core Technology Design

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