I really don't know.
My links pages were in place for years before I even got my AdSense account. I went by the rule of not having more than 50 links on a page, etc. I had a page where one could fill out a form and request a links exchange and that page was one of the ones pointed out by Google as not complying with TOS.
I am really confused about links pages and it makes me assume that the rules have changed and Google does not like link EXCHANGES. Maybe just outgoing links but not reciprocated ones perhaps? Beats me. I removed them to keep my ads serving, but why I had to do so I have no idea.