The Form 6B ORDR Files Dataset is a corpus of SEC Commission orders issued under Section 6(b) of the Investment Company Act of 1940, each granting tailored exemptive relief to a named "employees' securities company." One record corresponds to a single EDGAR accession number under the 6B ORDR form type and bundles the signed order PDF together with a structured metadata sidecar describing the EDGAR submission header. Because these documents are issued by the Commission itself rather than by a registrant, they are posted under the EDGAR staff pseudo-CIK 9999999997, with the substantive applicant — the operating-company sponsor or parent of the employees' securities company — carried in the structured entities array. The dataset covers all 6B ORDR filings posted to EDGAR from February 2009 onward, the period during which Commission-issued orders of this category have been routed through EDGAR under the 6B ORDR form type.
Programmatically retrieve the full list of dataset archive files, download URLs and dataset metadata.
Dataset Index JSON API
Download the entire dataset as a single archive file.
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Download a single container file (e.g. monthly archive) from the dataset.
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The dataset packages every Commission order disposing of a Section 6(b) exemptive application for an employees' securities company that has been disseminated through EDGAR under the 6B ORDR form type. Section 6(b) authorizes the SEC to exempt employees' securities companies from any provision of the Investment Company Act, and from any rule or regulation thereunder, to the extent the exemption is consistent with the protection of investors. An employees' securities company is a private investment vehicle organized so that employees of an operating company (and certain related persons) can invest alongside or in parallel with their employer; because such vehicles are sponsored by an operating business rather than offered to the public, they require tailored relief from the registration, governance, capital-structure, affiliated-transaction, and reporting requirements that the Act otherwise imposes on registered investment companies.
A 6B ORDR filing is the Commission's order disposing of an application for that relief. The applicant first files an application on Form N-6B (and historically related N-6 application forms). After staff review, public notice, and the absence of a hearing request, the Commission issues an order granting (in whole or in part) the requested exemptions; that issued order is what the 6B ORDR form type captures on EDGAR. Each record is materialized as a per-accession folder (named with the digits-only accession number, no hyphens) inside a monthly ZIP container, and the file types found in the dataset are PDF and JSON. There are no HTML body documents and no exhibit subdirectories: the order is delivered as a single PDF, and metadata.json carries the structured header data. The dataset's record count is small relative to most EDGAR form-type datasets, reflecting the rarity of Section 6(b) applications and the lengthy, individualized review process they entail; many calendar months contain no new records at all.
Each record folder contains, at minimum, two artifacts:
metadata.json — a structured sidecar derived from the EDGAR submission header that inventories the filing and identifies the parties.metadata.json is the structured anchor of the record. Its top-level fields describe the filing as accepted by EDGAR:
formType — fixed at "6B ORDR" for this dataset.accessionNo — the hyphenated SEC accession number, e.g., 9999999997-14-015920. The 9999999997- prefix marks it as a staff-issued document.filedAt — ISO-8601 timestamp with timezone offset capturing EDGAR acceptance time.description — short human-readable label such as "Form 6B ORDR - 40-6B Order".linkToFilingDetails — URL to the filing index on sec.gov.linkToTxt — URL to the consolidated .txt submission on sec.gov.linkToHtml — URL to the EDGAR filing index page.linkToXbrl — empty for this form type.documentFormatFiles — array enumerating every document in the original EDGAR submission, with sequence, size, documentUrl, type, and an optional description for each. This array always includes the primary order PDF and the consolidated submission text file.dataFiles — empty for this form type.seriesAndClassesContractsInformation — empty for this form type; the series-and-class construct is reserved for registered open-end funds and does not apply to 6B orders.entities — array describing the parties associated with the filing.id — internal record identifier.Each object in entities describes one party with EDGAR header attributes: companyName (with the role appended in parentheses, e.g., "BlackRock Inc. (Filer)"), cik, type ("6B ORDR" as it appears on the header), act ("40" for the Investment Company Act of 1940), fileNo (typically a 813- prefix, the file-number range used for 6B applications), filmNo, irsNo, stateOfIncorporation, fiscalYearEnd, sic (with a textual SIC description, occasionally containing HTML-escaped ampersands carried over from EDGAR), and tickers when the underlying applicant entity is publicly traded.
Because 6B ORDR submissions are staff-issued, the accession-level filer CIK is the Commission pseudo-CIK 9999999997, while the substantive applicant — the operating-company parent or sponsor of the employees' securities company — is the entity carried in the entities array. Joining 6B ORDR records to other EDGAR datasets should therefore key on the entity-level CIK and file number rather than on the accession-level filer CIK.
The order is delivered as a binary PDF beginning with a standard %PDF-x.x header. Internally, a Section 6(b) order is a relatively short, formally structured Commission release. Although individual orders vary, the document typically contains:
812- for the underlying exemptive application or 813- for the employees'-securities-company file), and the date of issuance.The order may also incorporate, by reference, the descriptive content of the underlying application without reproducing it in full. The conditions imposed are typically the most operationally significant portion of the document because they delimit how the employees' securities company may operate going forward.
A record includes:
metadata.json.documentFormatFiles of every document in the original EDGAR submission, with sizes, sequence numbers, types, and direct URLs back to sec.gov.entities, with CIK, file number, SIC, state of incorporation, and (where applicable) tickers.Image files from the original EDGAR submission are excluded by design. The underlying application on Form N-6B is a separate EDGAR submission with its own accession number and is not packaged inside the 6B ORDR record; it is referenced only indirectly through the file number and through the order's narrative recitals. Notice releases (typically published before the order under a separate release number) and any third-party comment letters are likewise separate filings and not bundled here. No structured data exhibits are associated with this form type.
The substantive structure of a Section 6(b) order has been stable across the dataset's coverage period: the statutory framework has not changed, and the conventional Commission-release format (caption, release header, factual recitals, discussion, ordering paragraphs, conditions, signature) has been retained throughout. Variations across records are driven primarily by the applicant's circumstances — the breadth of relief sought, the specific affiliated-transaction provisions implicated, and the conditions negotiated with the staff — rather than by changes in form requirements.
The packaging of each record is uniform across the covered period: a per-accession folder containing metadata.json plus the order PDF (and, where present in the original submission, the consolidated submission text file). Because the document is delivered as PDF rather than HTML or tagged ASCII, extraction of the order's text requires PDF text extraction rather than markup parsing, and the PDF is the authoritative rendering of the signed order.
9999999997; the substantive applicant lives in entities. Joins to registrant-level datasets should key on the entity CIK and on the 813- file number rather than on the accession-level filer.fileNo field is informative about the proceeding type: 813- numbers are reserved for employees' securities companies under Section 6(b), while related application accession numbers in adjacent EDGAR datasets typically use the 812- series for exemptive applications generally.description fields sometimes carry the alternative label "40-6B Order", reflecting the historical "Form 40-6B" naming convention for orders issued under Rule 0-2 in connection with Section 6(b) applications.dataFiles, seriesAndClassesContractsInformation, and an empty linkToXbrl — are structural rather than missing-data signals: these constructs do not apply to Commission-issued exemptive orders, and their emptiness is uniform across the dataset.6B ORDR records are not registrant filings. Each one is an order issued by the SEC itself, acting in its adjudicative capacity under Section 6(b) of the Investment Company Act of 1940. On EDGAR, the "filer" is the Commission, and the documents are posted under the synthetic accession-number prefix 9999999997-, which EDGAR reserves for Commission-originated documents (orders, notices, and related staff actions) rather than for filer-submitted disclosures. The substantive subject of each order is the applicant: an employees' securities company that has requested exemptive relief from one or more provisions of the Investment Company Act. The applicant submits the underlying exemptive application separately; the 6B ORDR record captures only the Commission's resolution of that application.
Although the Commission is the issuer of the record, the orders concern a narrow class of applicants:
These are private, employee-only pooling vehicles, not retail-facing registered investment companies. They seek 6(b) treatment when they cannot fit cleanly within Section 3(c)(1) or Section 3(c)(7).
A 6B ORDR exists only when both of the following occur:
The order identifies the applicant, lists the statutory sections and rules from which relief is granted (commonly involving affiliated transactions, joint arrangements, custody, capital structure, and recordkeeping), and sets out the conditions of the relief. Each order corresponds to one Commission action; the record is event-driven, not periodic.
The substantive authority is Section 6(b) of the Investment Company Act, which permits the Commission to exempt employees' securities companies from any provision of the Act or its rules to the extent consistent with the protection of investors. Procedurally, the underlying application is processed under the Commission's rules of practice for exemptive applications, including Rule 0-5 under the Act, with orders issued through the Division of Investment Management. Because the record is a Commission order rather than a registrant filing, it does not implicate Securities Act registration, Exchange Act periodic reporting, or Investment Company Act registration directly.
There is no statutory deadline for these orders. They appear when the Commission completes review of an ESC application and issues a final order — typically following application filing, publication of a notice of application, lapse of the comment period without a hearing request, and then issuance. The interval from application to order can range from several months to substantially longer depending on complexity and conditions negotiation. Section 6(b) has been part of the Act since its 1940 enactment, but earlier orders were published through the Investment Company Act release series and the Federal Register rather than as discrete EDGAR submissions; the dataset begins in February 2009, the period during which the Commission has consistently disseminated these orders through EDGAR under the 9999999997- accession scheme.
6B ORDR is the Commission's output. The applicant's input is a separate filing (historically associated with Form N-6B and related application formats). For the applicant's narrative, requested relief, and factual representations, consult the underlying application, not the order.9999999997- prefix, but they are distinct record types; the order is the definitive action.6B ORDR records. This form is specific to Section 6(b) and the ESC population.6B ORDR (with its own notice) rather than a modification of the original. Each Commission action is a discrete record in the dataset.The Form 6B ORDR Files Dataset belongs to a small, tightly defined family of EDGAR records documenting the Investment Company Act of 1940 exemption process for employees' securities companies. The most useful comparisons are with the other filings on the same procedural track (the application and the pre-decisional notice), the broader ICA exemptive-application machinery, and parallel order datasets keyed to other ICA sections.
N-6B is the applicant-authored petition that initiates the proceeding. It contains the substantive request: organizational structure, capital composition, investment program, the statutory provisions from which exemption is sought, and proposed conditions. The 6B ORDR is the Commission-authored grant at the end of the same proceeding.
6B ORDR: dispositive, what the SEC granted and on what terms.They are complementary, never substitutes.
6B NTC is the public notice the SEC issues after receiving an N-6B, summarizing the application and opening a hearing-request window before the Commission acts.
6B ORDR: final action, reflects the Commission's own findings, conditions, and ordering language.NTC and ORDR are typically paired records for the same matter; the ORDR is the operative document.
40-APP is the general ICA exemptive application form covering relief under sections such as 6(c), 17(b), 17(d), and others, filed by registered investment companies, advisers, and affiliated parties. 40-APP-NT is the corresponding notice.
6B ORDR: confined to Section 6(b), confined to employees' securities companies, with a small per-year flow of records since February 2009.Also note: 40-APP is an application form, not an order; even within its track, the analogous order document is a separate release, not a 40-APP itself.
40-OIP and 6B ORDR are both Commission-issued orders, which is where the resemblance ends.
6B ORDR: concludes an uncontested exemptive application by granting relief.Confusing the two misreads adversarial process initiation as permissive relief.
"40-6B" has been used historically for filings in the same Section 6(b) pathway. The current dataset is scoped strictly to filings carrying the 6B ORDR form type from February 2009 forward. Pre-2009 records or those filed under legacy form-type strings fall outside this dataset and require EDGAR full-text search.
Outside the employees' securities company context, the SEC follows the same notice-then-order pattern for other ICA exemptive applications, most visibly under Section 6(c). These generate their own NTC/ORDR pairs with parallel document structure but different statutory grounding, different eligible applicants, and far higher volumes.
6B ORDR: one specific slice keyed to Section 6(b) and employees' securities companies only.The Form 6B ORDR Files Dataset is defined by the intersection of three narrow attributes:
Adjacent datasets extend the picture along the timeline (N-6B, 6B NTC), broaden the substantive scope (40-APP/40-APP-NT, 6(c) NTC/ORDR pairs), or sit alongside as a different category of Commission action (40-OIP). None substitute for 6B ORDR when the question is what exemptive relief the SEC actually granted to a specific employees' securities company and under what conditions.
Because the universe of orders is small and Section 6(b) practice is precedent-driven, the dataset is consumed by a tightly defined set of users who care about the statutory provisions cited, the exemptions granted, the conditions imposed, and the applicant's profile.
1940-Act specialists in private funds and asset management groups use the dataset as a precedent library when drafting new Section 6(b) applications. They mine each order for which subsections of Sections 17, 18, 22, and 23 the Commission has been willing to exempt, the language describing permitted co-investments and principal transactions, and the conditions Investment Management has historically required (independent oversight, eligibility tests, capital caps, board composition, recordkeeping, exit terms).
Lawyers at banks, broker-dealers, asset managers, insurers, and large fund sponsors that already operate ESCs compare their existing orders against more recent grants to see whether permitted activities have expanded or narrowed and whether an amendment is warranted. Applicant identity, organizational description, and conditions carve-outs matter most.
Counsel structuring new ESCs use the dataset to align vehicle terms with available relief: how orders define eligible participants (employees, former employees, family members, related trusts), how contributions and withdrawals are handled, treatment of co-investment with affiliated funds and proprietary accounts, and whether leverage, secondaries, or in-kind distributions are permitted. The output is the LPA, side letters, and internal policies that operationalize the order.
Sponsor-firm compliance teams extract the conditions in each order to build internal checklists: investor eligibility verification, recordkeeping, board or advisory committee approvals for affiliated transactions, periodic certifications, and reporting. During exams or internal audits, the order text is the controlling document.
Consultants and administrators servicing ESCs advise sponsors on whether a contemplated activity falls within an existing order, whether a fresh application or amendment is needed, and how a proposed structure compares to recent precedent. They focus on scope of relief, statutory provisions named, and recurring conditions language to produce structuring memos and applications-readiness assessments.
KM lawyers and practice support staff in investment management groups ingest the corpus to tag orders by applicant type, statutory sections exempted, and conditions imposed, building internal precedent tables drafting attorneys consult before preparing a new application. Bulk coverage from 2009 onward beats ad hoc EDGAR retrieval.
Staff attorneys reviewing incoming Section 6(b) applications use prior orders as their internal precedent baseline. A structured dataset of all 6B ORDR filings supports cross-order consistency review, tracking how conditions have evolved, and retrospective policy analysis of the ESC framework.
Securities law and finance academics studying the Investment Company Act use the dataset as a complete ESC-order corpus for empirical study: trends in applicant types, statutory provisions most frequently exempted, evolution of conditions, and order timing. It supports law review articles and working papers on regulatory exemption.
When ESC arrangements surface in internal investigations, regulatory inquiries, or sponsor-participant disputes, counsel use the order to fix the exact scope of permitted activity. Conditions on affiliated transactions, valuation, and investor eligibility are the typical pressure points where deviations are tested.
Teams building retrieval-augmented systems for investment management practice ingest the PDFs and metadata to surface Section 6(b) precedent, conditions language, and exempted provisions in response to drafting prompts or compliance questions. The dataset is sized and structured for embedding pipelines.
Product, finance, and HR-compensation leads at sponsor firms designing employee co-investment programs use approved orders to scope what is feasible before engaging counsel: who can participate, how capital flows, and which affiliated transactions are reachable. The order text frames the economic and governance design of the vehicle.
Across all of these users, the load-bearing fields are the same: statutory provisions from which relief is granted, scope and conditions of the exemption, and the identity and structure of the applicant ESC.
The dataset's small, tightly-scoped corpus of Section 6(b) Commission orders supports a handful of concrete workflows in 1940-Act practice, ESC operations, and regulatory research.
Building a precedent table for a new Section 6(b) application. Drafting counsel parse the order PDFs across all accessions to extract which subsections of Section 7, Section 17(a), Section 17(d), Section 17(e), and Section 17(g) the Commission has exempted, and the verbatim conditions imposed (independent oversight, eligibility tests, recordkeeping, affiliated-transaction approvals). The output is an internal precedent grid that anchors the language of a fresh N-6B application.
Mapping conditions language for ESC compliance checklists. Sponsor compliance teams pull the ordering paragraphs and enumerated conditions from each order applicable to their vehicle, then convert them into investor-eligibility verifications, board or advisory-committee approval workflows, valuation procedures, and periodic reporting calendars used during exams and internal audits.
Comparing an existing order against more recent grants. In-house investment management counsel join records on the entity-level CIK and 813- file number in metadata.json to surface their firm's prior orders, then diff them against newer orders for similar applicants to decide whether permitted activities have expanded enough to justify an amendment application.
Tagging the corpus for a 1940-Act knowledge management system. KM teams ingest the PDFs plus the entities, sic, stateOfIncorporation, and fileNo fields to classify orders by applicant type (bank, broker-dealer, asset manager, insurer), statutory provisions exempted, and recurring conditions, producing a searchable precedent index that beats ad hoc EDGAR retrieval.
Empirical research on ESC regulatory practice. Academics use the complete February-2009-onward corpus to quantify trends in applicant industries (via SIC codes), the mix of statutory provisions most frequently exempted, and the evolution of conditions over time, supporting law review and finance working papers on Investment Company Act exemption practice.
Powering a retrieval-augmented drafting assistant. Legal-tech teams chunk the order PDFs and embed them alongside the structured metadata.json fields so that drafting prompts ("conditions for co-investment with affiliated funds in recent ESC orders") return citation-grade passages with linkbacks to the EDGAR filing index via linkToFilingDetails.
Scoping feasibility for a new employee co-investment program. Product, finance, and HR-compensation leads at a sponsor firm review approved orders for comparable peers to map who may participate, how contributions and withdrawals operate, and which affiliated transactions are reachable, framing the vehicle's economic and governance design before engaging outside counsel.
Dataset Index JSON API: https://api.sec-api.io/datasets/form-6b-ordr-files.json
Returns dataset-level metadata such as the dataset name, description, last updated timestamp, earliest sample date (2009-02-01), total records and total size, the form types covered (6B ORDR), the container format (ZIP), and the file types included (PDF, JSON). The response also contains the download URL for the full dataset archive and a list of individual container files, each with its own size, record count, updated timestamp, and download URL. This endpoint can be polled to detect which containers were updated in the most recent refresh run, so only changed containers need to be re-downloaded. This endpoint does not require an API key.
Example response:
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{
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"datasetId": "1f13365b-9ae0-6a4e-9bb9-915f4effb353",
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"datasetDownloadUrl": "https:/api.sec-api.io/datasets/form-6b-ordr-files.zip",
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"name": "Form 6B ORDR Files Dataset",
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"updatedAt": "2026-04-16T08:44:06.549Z",
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"earliestSampleDate": "2009-02-01",
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"totalRecords": 29,
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"totalSize": 1480017,
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"formTypes": ["6B ORDR"],
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"containerFormat": "ZIP",
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"fileTypes": ["PDF", "JSON"],
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"containers": [
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{
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"downloadUrl": "https:/api.sec-api.io/datasets/form-6b-ordr-files/2026/2026-03.zip",
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"key": "2026/2026-03.zip",
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"size": 13818783,
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"records": 154,
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"updatedAt": "2026-04-16T08:44:06.549Z"
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}
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]
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}
Download Entire Dataset: https://api.sec-api.io/datasets/form-6b-ordr-files.zip?token=YOUR_API_KEY
Downloads the complete dataset as a single ZIP archive containing all Form 6B ORDR filings from February 2009 to the present. This endpoint requires an API key.
Download Single Container: https://api.sec-api.io/datasets/form-6b-ordr-files/2026/2026-03.zip?token=YOUR_API_KEY
Downloads one individual monthly container instead of the full dataset, which is useful for incremental updates based on the updatedAt field returned by the index API. This endpoint requires an API key.
The dataset covers SEC submissions carrying the EDGAR form type 6B ORDR — Commission-issued orders granting exemptive relief under Section 6(b) of the Investment Company Act of 1940 to named employees' securities companies. It does not include the underlying applications (Form N-6B) or the pre-decisional notices (6B NTC), which are separate EDGAR submissions on the same procedural track.
One record corresponds to a single EDGAR accession number under the 6B ORDR form type — that is, one Commission order disposing of a Section 6(b) application. Each record is materialized as a per-accession folder containing a metadata.json sidecar derived from the EDGAR submission header and the original submission documents, most importantly the binary PDF of the signed Commission order.
The Commission itself issues 6B ORDR records. They are not registrant filings: on EDGAR they appear under the staff pseudo-CIK 9999999997, which is reserved for Commission-originated documents such as orders and notices. The substantive applicant — typically the operating-company sponsor or parent of an employees' securities company — is carried inside the entities array of metadata.json rather than in the accession-level filer field.
9999999997 is the EDGAR staff pseudo-CIK reserved for staff-issued instruments such as orders, notices, and no-action letters. Because the 6B ORDR is a Commission action rather than a registrant disclosure, EDGAR posts every record under that pseudo-CIK. Joins to registrant-level datasets should therefore key on the entity-level CIK and the 813- file number found inside entities, not on the accession-level filer.
The dataset begins on 2009-02-01 and runs to the present, covering all 6B ORDR records the Commission has disseminated through EDGAR since February 2009. Section 6(b) itself dates to the Investment Company Act's 1940 enactment, but earlier orders were published through the Investment Company Act release series and the Federal Register rather than as discrete EDGAR submissions, so they fall outside this corpus.
Each per-accession folder contains PDF and JSON files. The metadata.json sidecar captures the structured EDGAR header (form type, accession number, filing timestamp, document inventory, entities, file numbers, SIC codes, and links back to sec.gov), and the order itself is delivered as a binary PDF beginning with a standard %PDF-x.x header. There are no HTML body documents, no XBRL data files, and no exhibit subdirectories, and image attachments from the original EDGAR submission are excluded by design.
6B NTC is the pre-decisional notice the Commission publishes after receiving an N-6B application; it summarizes the application and opens a hearing-request window. The 6B ORDR is the operative final action — the order actually granting (in whole or in part) the requested exemptions and setting out the conditions of relief. NTC and ORDR records are typically paired for the same matter, but only the ORDR reflects the Commission's own findings, conditions, and ordering language.