成唯識論述記 10.234

10.234

述曰：第二解，初是起業之愚，後是不了業之愚，非所發業。此亦非必能發業也，境用別故。

The Commentary states: In the second explanation, the former is the ignorance of initiating karma, and the latter is the ignorance of not understanding karma; they are not the karma initiated. This also does not necessarily mean being able to initiate karma, because the object and function are distinct.