How to migrate Master Data (Rule set etc.) from GRC 5.3 to 10.1 without using the "Migration Tool"

Greetings,
We are currently on GRC 5.3 SP 18 (Java ONLY) and migrating to GRC 10.1. I referred the Migration Guide which outlines that GRC 5.3 needs to be upgraded to SP 20 as pre-requisite for using the "Migration Tool" . Our BASIS team is reluctant to perform this upgrade from SP 18 to SP 20.
Having said thus, I'm exploring options of migrating data from 5.3 to 10.1 without using the "Migration Tool:.
Rule set Migration:
I'm in the process of preparing the 9 different files (listed below) and later utilize the "Upload Rule" option for migrating the Rule set data from 5.3 to 10.1.
While I'm able to gather data for most of the files I'm not sure how can I obtain the data pertaining to the two files (Function Actions and Function Permissions) underlined and highlighted in Red below.
1. Business Process
2. Function
3. Function Business Process
4. Function Actions
5 .Function Permissions
6. Rule Set
7. Risk
8. Risk Description
9. Risk Rule Set Relationship
10. Risk Owner Relationship
Can someone please enlighten me and share their experience with regards to this exercise. Really appreciate your help !
- Janantik.

I have done this successfully before. Because you are having issues, I would NOT recommend using the migration tool to move the ruleset. Instead:
1. Download the ruleset files from 5.3
2. The 5.3 tcode-permission file, which defines which tcode permissions from SU24 need to be checked during risk analysis, needs to be split into the two files you mention above in red.
FUNCTION_ACTION : this file represents S_TCODE objects and TCD fields mapped to each function (Function to Tcode relationship). In the 5.3 file, you will filter on object S_TCODE and field TCD, and you will get a complete list that now represents "FUNCTION_ACTION". BUT instead of having all the jumbled permission info, you will just have 3 columns: Function - Tcode - Status.
3. The remaining permissions that are left over, after taking out the S_TCODE -TCD items, represent the "FUNCTION_PERMISSION" file in GRC 10.
4. Manually create the excel spreadsheets for each file.
5. Copy and past each sheet to a unique .txt file.
6. Upload the ruleset manually through SPRO-->GRC-->Access Control-->Access Risk Analysis-->SoD Rules-->Upload SoD Rules.
7. Select each file and then upload to the correct Logical Group.
This is a huge pain, but it works. Let me know how this goes and if you need any assistance.
-Ken

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