Form APP NTC Files Dataset

The Form APP NTC Files Dataset is a normalized collection of every Notice of Application published by the U.S. Securities and Exchange Commission on EDGAR under the form code APP NTC. Each record is one notice — the Commission's public-comment announcement that an applicant has filed for exemptive or other relief under the Investment Company Act of 1940 — packaged as a folder named with the dash-stripped EDGAR accession number and containing two artefacts: a metadata.json submission header and a filename1.pdf rendering of the Notice itself. Because these notices are issued by the SEC rather than by the applicant fund, every accession in the dataset carries the SEC's pseudo-CIK 9999999997 as filer, while the underlying applicant (typically a registered investment company, BDC, fund sponsor, or adviser, identified by an EDGAR file number in the 812-XXXXX exemptive-application series) is named inside the metadata entities[] block and inside the PDF body. The dataset is distributed as monthly ZIP containers holding PDF and JSON files, with continuous coverage from February 2009 — when EDGAR began carrying the APP NTC form code — through the present.

Update Frequency
Daily
Updated at
2026-05-02
Earliest Sample Date
2009-02-01
Total Size
104.2 MB
Total Records
1,316
Container Format
ZIP
Content Types
PDF, JSON
Form Types
APP NTC

Dataset APIs

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Dataset Index JSON API

Download the entire dataset as a single archive file.

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Dataset Files

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What This Dataset Contains

The dataset packages every EDGAR submission under form type APP NTC. A Form APP NTC filing is the Commission's public-comment notice for a 40-APP exemptive application. When a registered investment company (closed-end fund, open-end fund, ETF, BDC) or a related entity files an application — typically under Section 6(c), Section 6(b), Section 12(d)(1), Section 17(a)–(e), Section 22(d), Section 23(c), Rule 17a-7, Rule 17a-8, Rule 17d-1, Rule 22d-1, Rule 12d1-4, or other provisions of the Investment Company Act of 1940 — seeking an order exempting it from one or more provisions of the Act or its rules, the staff of the Division of Investment Management prepares and publishes a Notice of Application. The Notice solicits public comment, briefly describes the relief sought, identifies the relevant statutory and rule citations, summarises the conditions the applicant has agreed to accept, and states the deadline for requesting a hearing.

Form APP NTC is therefore an SEC-authored, SEC-filed document about a third-party applicant, not a disclosure document filed by an issuer about itself. This explains why the EDGAR header shows the SEC's pseudo-CIK as filer and why the structural footprint of each record is small and uniform. The dataset covers the entire APP NTC population on EDGAR from February 2009 forward and is distributed as monthly ZIP containers. Inside each container, files are organized one folder per accession, with each folder holding the structured metadata JSON and the rendered Notice PDF.

Content Structure of a Single Record

What one record represents

One record is a single Notice of Application published on EDGAR under form type APP NTC. The unit of record is the EDGAR accession number. Each accession becomes one folder, named with the dash-stripped accession string (the filing 9999999997-25-003817 is materialized as the folder 999999999725003817). Inside that folder the dataset ships exactly two artefacts:

  1. metadata.json — the structured EDGAR submission header.
  2. filename1.pdf — the rendered Notice of Application.

Every accession in this dataset begins with the prefix 9999999997 because Form APP NTC notices are filed onto EDGAR by the SEC as the issuing authority rather than by the applicant fund. The applicant's actual CIK is preserved inside the metadata payload and inside the EDGAR URLs that point at the underlying document.

File layout of a record

Each record is a two-file bundle:

  1. metadata.json — a single JSON object containing the structured EDGAR header for the filing (form type, accession number, filing timestamp, item dates, document inventory, applicant entity block, and EDGAR cross-links). Always present; on the order of 1–2 KB.
  2. filename1.pdf — the binary PDF of the published Notice, beginning with a %PDF-1.x header (typically PDF 1.4–1.6). The dataset packager renames the EDGAR primary document to the placeholder filename1.pdf regardless of its original name on EDGAR. PDFs typically run from a few tens of kilobytes to roughly 150 KB and contain the entire body of the Notice.

There are no sidecar HTML renditions, no exhibit files, no graphics, and no auxiliary attachments inside a record folder. The complete-submission SGML text file (<accession>.txt) referenced from documentFormatFiles exists on EDGAR and is reachable through linkToTxt, but is not bundled into the dataset; the rendered PDF is shipped instead. Image files associated with EDGAR submissions are also excluded.

metadata.json top-level fields

The metadata object is flat and uses the same key set across every record:

  • formType — always the literal string "APP NTC".
  • accessionNo — the canonical dashed accession number, e.g. "9999999997-25-003817". The leading 9999999997 segment is the SEC's pseudo-CIK used as filer for issued notices.
  • linkToFilingDetails — absolute URL to the primary PDF on sec.gov/Archives/edgar/data/<applicant-cik>/<accession-no-dashes>/filename1.pdf. The CIK in this path is the applicant fund's CIK, not the 9999999997 prefix.
  • description — human-readable label, typically "Form APP NTC - 40-APP Notice - Item YYYYMMDD", sometimes with multiple Item YYYYMMDD date stamps concatenated when more than one item date is recorded.
  • linkToTxt — URL to the complete submission SGML text file on EDGAR (<accession>.txt).
  • linkToHtml — URL to the EDGAR filing-index page (-index.html or -index.htm).
  • linkToXbrl — empty string for every APP NTC record.
  • filedAt — ISO-8601 timestamp with timezone offset, typically Eastern Time (e.g. "2025-11-25T17:55:46-05:00").
  • items — array of EDGAR "Item" tags formatted as "Item YYYYMMDD: " (the trailing colon and space are part of the value). One or two entries are typical, and the same dates also surface in description. Duplicate entries occasionally appear even when only one substantive item date is in play.
  • documentFormatFiles — ordered array describing each document in the underlying EDGAR submission. The first entry is the PDF Notice itself (type: "APP NTC", sequence: "1", size in bytes as a string, documentUrl pointing at EDGAR). The second entry is the complete submission text file (type: " ", sequence: " ", description: "Complete submission text file").
  • entities — array of applicant/filer entity objects (see below). Often a single entry.
  • seriesAndClassesContractsInformation — array reserved for mutual-fund series/class identifiers; consistently empty for APP NTC records.
  • dataFiles — array reserved for auxiliary structured data; consistently empty.
  • id — 32-character hexadecimal content hash (e.g. "f2242f67ac6cd88ba38c285bb6cae2a4"), useful as a stable record identifier.

entities[] applicant block

Each entry in entities describes one applicant or co-applicant carried on the EDGAR header for the Notice:

  • companyName — applicant name with a role suffix in parentheses, almost always "(Filer)", e.g. "Antares Private Credit Fund (Filer)".
  • cik — the applicant fund's actual EDGAR CIK (distinct from the 9999999997 accession prefix). This is the CIK that appears in linkToFilingDetails and linkToTxt.
  • type — the form-type label as recorded on the entity row; "APP NTC".
  • act — the Securities Act under which the entity is filing. Uniformly "98", the EDGAR code for the Investment Company Act of 1940.
  • fileNo — the EDGAR file number for the applicant's exemptive proceeding, almost always in the 812-XXXXX series reserved for applications for exemptive relief under the 1940 Act. The file number persists across the application's life cycle (the original 40-APP, any 40-APP/A amendments, the APP NTC notice, and the eventual order).
  • filmNo — the EDGAR film number assigned to this particular submission.
  • irsNo — the applicant's IRS employer identification number; frequently "000000000" when none has been provided.
  • stateOfIncorporation — two-letter U.S. state code ("DE", "MA", "MD", "NY" are common for fund formations) or other jurisdiction code.
  • fiscalYearEndMMDD string (e.g. "1231", "0731", "0930"); may be absent if not on file.
  • tickers — optional array of ticker symbols when the applicant is publicly listed (e.g. ["MRCC", "MRCCL"] for a listed BDC, ["OWSCX"] for a mutual-fund share class). Omitted for non-listed funds.

When a Notice covers a group of related applicants — a fund family applying jointly with its adviser, distributor, or affiliated funds — the entities array carries each co-applicant. For many APP NTC notices, however, only the principal filer entity appears in entities and additional co-applicants are named only inside the PDF body.

filename1.pdf Notice body

The PDF is the Commission's published Notice of Application and follows the conventions of SEC release notices in the Investment Company Act release series. The internal layout is consistent across the dataset and runs in the following order:

  • Header block — Commission release identifiers (Investment Company Act Release No. IC-XXXXX), the file number (812-XXXXX), the issuance date, and the caption naming the applicant(s).
  • Summary of Application — a short paragraph stating in plain language the relief sought, often phrased "Applicants request an order …" followed by a description of what the order would permit.
  • Applicants — a list naming the principal applicant and any co-applicants, with state of organization and a one-line description of each.
  • Filing Dates — the date the application was filed and the dates of any amendments.
  • Hearing or Notification of Hearing — the deadline by which interested persons may request a hearing, the procedure for submitting such requests (typically through the SEC's Secretary), and a statement that an order disposing of the application will be issued unless the Commission orders a hearing.
  • Addresses — postal and electronic addresses for the Commission's Secretary and for serving the applicants' counsel.
  • For Further Information Contact — the name and telephone number of the staff attorney(s) in the Division of Investment Management's Chief Counsel's Office or the relevant branch handling the application.
  • Supplementary Information / Applicants' Representations — narrative paragraphs summarising the factual background, the applicants' business, and the operative representations supporting the application.
  • Applicants' Legal Analysis — citation and discussion of the specific statutory sections and rules from which exemption is sought. Common citations include Section 6(c) (the Commission's general exemptive authority), Section 6(b), Section 12(d)(1)(A) and (B) (fund-of-funds limits), Section 17(a) (affiliated transactions), Section 17(b) (exemptions from Section 17(a)), Section 17(d) and Rule 17d-1 (joint transactions and joint enterprises with affiliates), Section 17(e) (compensation for affiliated agents), Section 22(d) and Rule 22d-1 (variable pricing), Section 23(c) (closed-end fund repurchases), Section 26(c), Rule 17a-7, Rule 17a-8, and Rule 12d1-1 through Rule 12d1-4. The analysis explains why the requested order is consistent with the protection of investors and the purposes of the Act.
  • Applicants' Conditions — a numbered list of conditions the applicants have agreed will govern reliance on any order. Conditions typically restrict how the relief may be used and impose investor-protection safeguards (board oversight, disclosure, recordkeeping, voting, fee approvals).
  • Order line and signature — closing language stating the order, signed for the Commission by the Secretary or a Deputy Secretary, with the date.

The PDF is produced from the SEC's notice-publishing pipeline. Embedded text is generally selectable and extractable via standard PDF text-extraction tooling, although byte-level layout and font choices vary across years.

Included content

A record packages the structured EDGAR header in metadata.json; the full text of the Notice in filename1.pdf; cross-links to the original EDGAR locations of the PDF, the complete-submission SGML text file, and the filing-index page; and the identifiers required to follow the application across EDGAR (the accession number, the 812- file number, the applicant CIK, and the IC release number visible inside the PDF). The PDF byte size advertised in documentFormatFiles[0].size matches the on-disk PDF byte count exactly and can serve as an integrity check.

Excluded or separate content

Several artefacts that exist on EDGAR are not packaged into the dataset:

  • The complete-submission SGML text file (<accession>.txt) is referenced in documentFormatFiles and reachable via linkToTxt, but is not bundled into the record folder.
  • Image files associated with the EDGAR submission are excluded.
  • The 40-APP application itself (the underlying application document submitted by the applicant) and any amendments to it (40-APP/A) live under a separate accession number under the applicant's own CIK, not the SEC's pseudo-CIK, and are not part of an APP NTC record. They are reachable on EDGAR via the shared 812- file number.
  • The Commission's eventual order granting (or denying) the requested relief is published as a separate release and is not part of the APP NTC record.
  • Fund series and class identifiers (seriesAndClassesContractsInformation) are not populated for these notices.

Changes in required content or structure over time

The structural envelope of an APP NTC notice has been stable across the dataset's coverage. Form APP NTC was introduced as the EDGAR form type for Notices of Application following the 2008–2009 modernisation that moved exemptive-application notices into the EDGAR document stream. Coverage in this dataset begins in February 2009. From that introduction through the present, the SEC's notice template — Summary, Applicants, Filing Dates, Hearing, Addresses, For Further Information Contact, Supplementary Information, Applicants' Representations, Applicants' Legal Analysis, Applicants' Conditions, and Order — has not been materially restructured.

What does change is the substantive content reflecting evolving exemptive-relief practice rather than the form itself: the statutory provisions and rules cited; the categories of relief (fund-of-funds reliance under amended Section 12(d)(1) and the Rule 12d1-4 framework adopted in 2020 and effective in 2022, multi-class relief, ETF master-feeder relief, interfund lending relief, co-investment relief under Section 17(d) and Rule 17d-1, BDC-affiliate relief, and ETF-related relief which became less frequent after the 2019 adoption of Rule 6c-11); the typical applicant types (a steady increase in BDC-related and interval-fund applications across the late 2010s and 2020s); and the conditions templates, which have evolved with shifts in Commission staff positions. The metadata schema wrapping each notice has remained constant in field set.

Changes in data format over time

The dataset has carried APP NTC notices as PDF primary documents throughout its February 2009 to present span. The %PDF version embedded in individual files has drifted upward over the years (from PDF 1.3/1.4 in early filings toward PDF 1.6 in recent ones) as the SEC's publishing toolchain has been updated, but the consumer-facing format — a single text-bearing PDF as the primary document, accompanied by a complete-submission SGML wrapper on EDGAR — has not changed. There has been no HTML era for APP NTC primary documents. The renaming convention (filename1.pdf placeholder regardless of the EDGAR-side filename) and the two-file-per-folder layout have been uniform throughout.

Interpretation and extraction notes

  • The 9999999997 segment that prefixes every accession number is not the applicant's CIK; it is the SEC's pseudo-CIK used because the Commission itself files these notices into EDGAR. To recover the applicant fund's CIK, read entities[0].cik or parse the data/<cik>/ segment of linkToFilingDetails or linkToTxt.
  • The 812-XXXXX file number is the most durable cross-reference for tracking an exemptive proceeding. A single application typically generates multiple EDGAR submissions over its life cycle (the underlying 40-APP, any 40-APP/A amendments, the APP NTC notice, and the order), and all of them share the same fileNo.
  • The IC release number and the order date that legally identify the Notice live inside the PDF body; they are not surfaced as structured fields in metadata.json. Recovering them requires PDF text extraction.
  • The items array entries consist of "Item YYYYMMDD: " strings, including the trailing colon and space; downstream code must trim or pattern-match accordingly. Duplicate entries occasionally appear.
  • description and items both encode the item date, but description is a free-form human label — its prose ordering should not be relied upon for parsing. Prefer items for date extraction and filedAt for the precise timestamp.
  • The tickers array is present only when EDGAR has a ticker on file for the applicant. Its absence should not be read as evidence the applicant is privately held, only that no ticker was tagged on the submission.
  • The PDF byte size in documentFormatFiles[0].size is reported as a string and matches the local file size exactly; it can serve as an integrity check after extraction.
  • A single Notice may concern multiple co-applicants (for example, a registered fund, its adviser, and its distributor), but the entities block frequently carries only the principal applicant. When complete co-applicant coverage is required, identities must be extracted from the PDF body.
  • Because the PDF is the sole carrier of substantive Notice text, any analysis of relief categories, statutory citations, or applicant conditions requires PDF text extraction; the JSON metadata identifies the filing but not its content.

Who Files or Publishes This Dataset, and When

Publisher and applicant

An APP NTC is published by the SEC itself, not by the entity seeking relief. Every APP NTC accession in this dataset is filed under the SEC's pseudo-CIK 0009999999997 (rendered 9999999997), the EDGAR identifier the Commission uses for documents it issues rather than receives. In substance, the publisher is the Commission acting through staff of the Division of Investment Management (Chief Counsel's Office / Office of Investment Company Regulation), which drafts the notice, sets the hearing-request and comment deadline, and posts it to EDGAR.

The applicant is a different entity. It is named inside the body of the notice and reflected in the EDGAR header entities[] block (often confusingly suffixed (Filer)), with its own CIK and an EDGAR file number in the 812- series (e.g., 812-15792). The 812- docket persists across the entire application lifecycle — the original 40-APP, any 40-APP/A amendments, the APP NTC, and the eventual APP ORDR.

The applicant population consists primarily of:

A single notice frequently names multiple co-applicants (especially in BDC co-investment orders). Only the lead applicant's CIK typically populates the EDGAR metadata; the full co-applicant set must be read from the notice text.

When the record is created

APP NTC publication is event-driven, not periodic. A notice is issued only after the following upstream sequence:

  1. An applicant files an exemptive application on Form 40-APP under the Investment Company Act of 1940, with any subsequent 40-APP/A amendments responding to staff comments.
  2. Division of Investment Management staff completes substantive review and concludes the application is ready to be put out for public notice.
  3. The Commission, acting under Rule 0-5 (17 CFR 270.0-5), causes a notice of the application to be published on EDGAR (and in the Federal Register).

The APP NTC itself is therefore the administrative signal that staff has cleared the application for notice and order — the transition from non-public review to the public-comment phase. It is not a filing made by the applicant.

Each notice opens a public comment / hearing-request window, commonly 25 days from the date of issuance. If no hearing is ordered, the Commission proceeds to issue the requested relief on Form APP ORDR.

Cadence is typically a few notices per week across the registered fund / BDC industry, rising and falling with structural trends (multi-class relief, ETF relief, co-investment relief, fund-of-funds relief). EDGAR coverage of the APP NTC form code runs from February 2009 through the present; before 2009 the same notices were published only as Federal Register releases ("1940 Act Releases"), even though the underlying Rule 0-5 notice-and-order procedure dates to the Act's 1940 enactment.

Regulatory framework

  • Statutory authority. Most APP NTCs notice applications under Section 6(c) of the 1940 Act, which lets the Commission exempt any person, security, or transaction from any provision of the Act if the exemption is "necessary or appropriate in the public interest and consistent with the protection of investors and the purposes fairly intended by the policy and provisions of [the Act]." Other commonly cited bases include Section 17(b) (specific exemptions from the Section 17(a) affiliated-transaction prohibitions), Section 17(d) and Rule 17d-1 (joint enterprises and arrangements involving affiliated persons — the foundation of BDC and private-credit co-investment relief), and Sections 10(f), 12(d)(1)(J), 23(c), 57(c)/(i), 6(b) (employees' securities companies), and occasionally 26(c), 27, or 32(a).
  • Procedural authority. The notice-and-order mechanism is governed by Rule 0-5 under the 1940 Act, which requires the Commission to give appropriate notice and an opportunity for interested persons to request a hearing before issuing an order on an application.

Important distinctions

  • SEC publisher vs. named applicant. Pseudo-CIK 9999999997 denotes the SEC as issuer of the notice; it should never be linked to issuer-level data. All linkage to fund family, adviser, or asset data must go through the applicant CIK in entities[0].cik (and the corresponding /Archives/edgar/data/<applicant-CIK>/... path).
  • APP NTC is not the application. The substantive application is on 40-APP / 40-APP/A, filed by the applicant. APP NTC is the SEC's public summary, not the underlying request.
  • APP NTC is not the order. An APP NTC grants no relief; it is procedural. The operative document is the subsequent APP ORDR. Some noticed applications never reach an order (e.g., withdrawn via APP WD), so the presence of an APP NTC does not by itself confirm that relief was granted.
  • APP NTC/A. If an application is materially modified after initial notice, the SEC may re-notice it on APP NTC/A, typically restarting the comment clock.
  • 1940 Act only. APP NTC is specific to the Investment Company Act (EDGAR header act = 98). Exemptive or no-action relief under the Securities Act of 1933, the Exchange Act of 1934, or the Investment Advisers Act of 1940 runs through entirely separate channels and does not appear in this dataset.
  • No filer-status concept. Unlike registrant-driven forms, APP NTC carries no accelerated-filer or foreign-private-issuer distinctions; the only gating question is whether the applicant is seeking 1940 Act relief.

How This Dataset Differs From Similar Datasets or Filings

Form APP NTC sits inside a tightly bounded family of EDGAR filings that document the lifecycle of exemptive relief under the Investment Company Act of 1940. The clearest way to place it is along two axes: who authored the document (applicant vs. SEC) and where it falls in the procedural sequence (application -> notice -> order, with withdrawal as an alternate terminal state).

Form APP and Form 40-APP (the application)

Form APP and the modern Form 40-APP are the applications themselves, filed by the applicant. They contain the substantive legal record: factual background, the specific sections and rules from which relief is sought, proposed conditions, precedent citations, and supporting representations. 40-APP is the operative EDGAR form type for most contemporary exemptive applications; legacy APP filings cover earlier matters.

Form APP NTC, by contrast, is the SEC-authored notice that such an application has been filed. The application is filer-authored, often long, and argumentative; the notice is short, Commission-issued, and structured around fixed elements (summary of relief, statutory provisions, hearing/comment instructions). Sequencing matters: every APP NTC presupposes a prior application, but not every application reaches the noticed stage. APP/40-APP is therefore broader at the front end; APP NTC is the narrower downstream subset that the staff was prepared to recommend for public comment.

Use the application for legal theory and full record; use APP NTC to track which applications advanced to formal notice.

Form APP ORDR (the order)

Form APP ORDR is the Commission's order granting or denying the requested relief, issued after the APP NTC comment period closes. Notice and order are paired procedural bookends: APP NTC opens the public phase and states what is being considered; APP ORDR closes it and states what was actually granted, typically with conditions.

Practitioners cite orders, not notices, as precedent. Researchers studying outcomes need APP ORDR; researchers studying volume, timing, or pending matters at the noticed stage need APP NTC. APP NTC also captures matters that were noticed but never produced an order.

Form APP WD (the withdrawal)

Form APP WD records an applicant's withdrawal of an application. For any single matter, the terminal state is mutually exclusive: order, withdrawal, or lapse. APP NTC and APP WD are both useful for lifecycle analysis but answer different questions. Without APP WD, an APP NTC count will overstate the number of applications that ultimately yielded relief.

The application/notice/order trio

The defining distinction across this family:

  • Application (APP, 40-APP): filed by the applicant; full legal argument; initiates the matter.
  • Notice (APP NTC): issued by the SEC; summary of the application; opens the comment window.
  • Order (APP ORDR): issued by the SEC; dispositive; grants or denies relief, often with conditions.

Confusing these three is the most common error in this area. Each is a separate EDGAR form type and a separate dataset.

Periodic 1940 Act filings (N-CEN, N-1A, N-2, N-CSR)

These are registration and periodic reports filed by registered investment companies in the ordinary course: Form N-1A and Form N-2 register open-end and closed-end funds; Form N-CEN is the annual census report; Form N-CSR carries certified shareholder reports. Filer populations overlap with APP NTC applicants, but content does not. Periodic filings document a fund's ongoing structure, holdings, governance, and financial condition; APP NTC documents a discrete legal request to deviate from a statutory default. There is no content substitution between the two.

Section 6(c) exemptive orders as a conceptual category

Section 6(c) is the most commonly invoked statutory basis for exemptive relief, but APP NTC matters frequently rely on additional or alternative provisions (17(b), 17(d), 12(d)(1)(J), 10(f), and others). "Section 6(c) orders" as a doctrinal category is therefore neither coextensive with APP NTC nor with any single EDGAR form type. Doctrinal research generally requires the full lifecycle (application, notice, order) filtered by the cited statutory provisions, not APP NTC alone.

No-action letters

No-action letters are a separate relief mechanism: staff-issued (typically Division of Investment Management), reflecting a position not to recommend enforcement on specified facts. They are not formal exemptions, do not go through public notice and comment, and are not filed on EDGAR as APP-family records. Treating a no-action letter as equivalent to an APP NTC matter misstates both the legal weight and the procedural posture of the relief.

Boundary summary

Form APP NTC captures a Commission-issued procedural artifact — a public notice — sitting between an applicant-authored application (APP / 40-APP) and a Commission-issued outcome (APP ORDR), with APP WD as the alternate terminal state. It is not the application, not the order, not a periodic disclosure, and not informal staff guidance. Its content is summary and procedural: enough to identify the relief under consideration and solicit comment, but not the full request or its resolution. Used alone, it best supports mapping the population, timing, and subject matter of Investment Company Act applications that reached the noticed stage from February 2009 forward; for any individual matter, it must be paired with the underlying application and the order or withdrawal.

Who Uses This Dataset

Form APP NTC notices are the public record of exemptive-relief requests under the Investment Company Act of 1940. The dataset is used by a narrow set of professional functions, each focused on a different slice of the record: the requested-relief recitals, statutory citations, named applicants, the 812-XXXXX file number, or the comment-window instructions.

Investment-management lawyers

In-house fund counsel and outside 1940 Act specialists are the heaviest users. They search prior notices to build precedent libraries when drafting new applications for multi-class, co-investment, fund-of-funds (Section 12(d)(1)(J)), manager-of-managers, interfund lending, and Section 17(d)/Rule 17d-1 joint-transaction relief. They extract recitals, conditions, and statutory citations (Sections 6(c), 17(b), 17(d), 12(d)(1)(J)) to produce drafts, comparison memos, and redlines against the closest matching prior notice.

Fund CCOs and compliance officers

Compliance teams at registered funds, BDCs, and advisers track the conditions other applicants have accepted, since those conditions become the operating constraints once relief is relied on. They focus on the conditions section, board-oversight language, and reporting commitments to update Rule 38a-1 procedures, board reporting templates, and affiliated-transaction or interfund-lending policies.

Regulatory affairs and product teams at sponsors

Regulatory staff at ETF, BDC, closed-end, and open-end sponsors monitor new APP NTC filings to see what the staff is currently willing to grant and where its posture has shifted. Applicant identity, cited rule, and notice date drive product-development decisions: launch under existing precedent, wait for a pending order, or file a fresh application.

Fund administrators and operations teams

Administrators configure systems around the relief that will apply once a notice ripens into an order: multi-class accounting, in-kind transactions, affiliated transactions. They use the named applicant entities and affiliated-fund lists to scope which legal entities the order covers and align operational procedures with the conditions.

ETF and BDC product counsel scoping launches

Counsel planning actively managed ETFs, share-class ETFs, non-transparent active ETFs, ETFs-of-ETFs, non-listed BDCs, interval funds, and tender-offer funds use prior notices to scope launch timelines. Matching to an existing precedent shortens the path to an order; a novel request implies a longer review. Rule 6c-11 reduced individual ETF orders, but the pre-2019 record still informs structures outside its scope.

RegTech and SEC-data product teams

Teams building exemptive-relief trackers and 1940 Act precedent-search tools ingest the dataset for structured extraction of applicant name, 812-XXXXX file number, cited provisions, relief category, and comment deadline. The 812- file number is the join key linking each APP NTC to its underlying application, amendments, and eventual APP ORDR order, enabling end-to-end docket tracking.

Enforcement and fund-governance litigators

Lawyers handling enforcement matters and Section 36(b) cases use the notice plus matched order as a contemporaneous public statement of the representations and conditions an applicant agreed to. The factual recitals and conditions are the citable parts.

Academic researchers in financial regulation

Researchers build datasets of relief categories, notice-to-order processing times, and applicant characteristics. The February 2009 to present coverage supports time-series work on how relief categories have shifted, including the migration of ETF relief from individual orders to Rule 6c-11. Applicant identity, filing date, statutory citations, and comment-window dates are the core fields.

Trade-press reporters covering fund regulation

Reporters at fund-industry trade publications and financial news outlets use APP NTC notices as a leading indicator of new structures and strategies, often weeks or months before launch. They focus on applicant name, relief summary, and first-of-its-kind language.

Comment-window monitors and competitor tracking

Each notice opens a comment window, triggering a workflow for competitor legal teams, trade associations, and investor advocates deciding whether to submit a comment opposing or modifying the requested relief. The comment-deadline language and the precise scope of relief in the recitals are the operative parts; alerting on new APP NTC filings drives the decision within the window.

Across all roles, the durable anchors are the 812-XXXXX file number, cited statutory provisions, relief category, applicant entities, and comment window. These fields support the core workflows the dataset enables: precedent search, condition benchmarking, docket tracking, and comment-window monitoring.

Specific Use Cases

The following workflows are concrete realizations of those anchors, each tying specific record fields to a defined output.

Building a 1940 Act exemptive-relief precedent library

Investment-management lawyers drafting a new 40-APP application pull all prior notices citing the same statutory provisions (for example Section 12(d)(1)(J), Section 17(d) and Rule 17d-1, or Rule 12d1-4) by extracting the Applicants' Legal Analysis section and the numbered Applicants' Conditions list from filename1.pdf. The output is a precedent table keyed by 812-XXXXX file number, applicant name, and relief category that feeds redline drafting against the closest matching prior notice.

Benchmarking applicant conditions for compliance policies

Fund CCOs extract the Applicants' Conditions block from each PDF and group conditions by relief type (co-investment, interfund lending, multi-class, affiliated transactions). The result is a normalized condition catalog that drives updates to Rule 38a-1 written procedures, board-reporting templates, and affiliated-transaction approval workflows so internal policies match the constraints staff currently accepts.

End-to-end docket tracking via the 812- file number

RegTech teams use entities[].fileNo (the 812-XXXXX series) as a join key across the 40-APP application, any 40-APP/A amendments, the APP NTC notice, and the eventual APP ORDR order. Combining this dataset with the related APP ORDR feed produces a docket database with notice-to-order processing time, terminal status (order, withdrawal, lapse), and pending-matter inventories per applicant.

Monitors ingest filedAt and the hearing-deadline language extracted from the PDF Hearing block to generate alerts the moment a new notice opens a public comment window. The output is a dated queue of open comment windows scoped by relief category, used by competitor counsel, trade associations, and investor advocates to decide whether to file a comment letter before the deadline.

Mapping fund-sponsor exemptive activity for product strategy

Regulatory affairs teams at ETF, BDC, and interval-fund sponsors aggregate entities[].companyName, entities[].cik, entities[].tickers, and the relief summary parsed from the PDF Summary of Application section. The result is a sponsor-level map of pending and noticed relief that informs product-launch decisions: launch under existing precedent, wait for a pending order on a comparable matter, or file a fresh application.

Time-series research on shifts in exemptive-relief practice

Academic researchers and policy analysts use the February 2009 to present coverage, parsing filedAt, the IC release number from the PDF header, and cited statutory provisions to build longitudinal series. Typical outputs include the migration of ETF relief out of individual orders after Rule 6c-11 (2019), the rise of Rule 12d1-4 reliance after 2022, and trends in BDC and interval-fund applications across the late 2010s and 2020s.

Trade-press leading-indicator monitoring

Reporters at fund-industry publications watch new APP NTC filings as an early signal of novel fund structures, often weeks or months before launch. They extract applicant name from entities[], the relief summary from the PDF, and "first-of-its-kind" language from the Applicants' Representations to produce coverage of pending structures before they appear in registration statements.

Dataset Access

Dataset Index JSON API: https://api.sec-api.io/datasets/form-app-ntc-files.json

This endpoint returns dataset metadata including the dataset name, description, last update timestamp, earliest sample date, total record count, total size, form types covered, container format, and the file types present inside containers. It also returns the download URL for the entire dataset archive and a list of all monthly container files with per-container metadata such as size, record count, last updated timestamp, and individual download URL. Use this endpoint to monitor which containers were updated in the most recent refresh run and decide which monthly archives to download incrementally.

This endpoint does not require an API key.

Example response:

Example
1 {
2 "datasetId": "1f13365b-9ae0-6990-b4a6-849808ca1142",
3 "datasetDownloadUrl": "https://api.sec-api.io/datasets/form-app-ntc-files.zip",
4 "name": "Form APP NTC Files Dataset",
5 "description": "Form APP NTC filings contain notices of applications for exemptive or other relief filed under the Investment Company Act of 1940. These notices are published by the SEC to inform the public that an applicant, typically a registered investment company or business development company, has submitted an application seeking exemptions from specified provisions of the Act pursuant to Section 6(c) or other applicable sections.",
6 "updatedAt": "2026-04-21T02:55:38.088Z",
7 "earliestSampleDate": "2009-02-01",
8 "totalRecords": 1308,
9 "totalSize": 103572662,
10 "formTypes": ["APP NTC"],
11 "containerFormat": "ZIP",
12 "fileTypes": ["PDF", "JSON"],
13 "containers": [
14 {
15 "downloadUrl": "https://api.sec-api.io/datasets/form-app-ntc-files/2025/2025-11.zip",
16 "key": "2025/2025-11.zip",
17 "size": 1842771,
18 "records": 18,
19 "updatedAt": "2026-04-21T02:55:38.088Z"
20 }
21 ]
22 }

Download Entire Dataset: https://api.sec-api.io/datasets/form-app-ntc-files.zip?token=YOUR_API_KEY

Downloads the complete dataset as a single ZIP archive containing all monthly containers from the earliest sample date (2009-02-01) onward. This endpoint requires an API key.

Download Single Container: https://api.sec-api.io/datasets/form-app-ntc-files/2025/2025-11.zip?token=YOUR_API_KEY

Downloads a single monthly container ZIP instead of the full dataset. Each container contains one folder per accession number, holding a metadata.json file and the original filing PDFs. This endpoint requires an API key.

Frequently Asked Questions

What form does this dataset cover?

The dataset covers EDGAR form type APP NTC — Notices of Application for exemptive or other relief under the Investment Company Act of 1940, published by the SEC's Division of Investment Management under Rule 0-5. The form code became active on EDGAR in February 2009, which is also where this dataset's coverage begins.

What does one record in this dataset represent?

One record is one Notice of Application, identified by its EDGAR accession number. Each record is a folder named with the dash-stripped accession (e.g. 999999999725003817) containing exactly two files: metadata.json (the structured EDGAR submission header) and filename1.pdf (the rendered Notice).

Who actually files an APP NTC, and why does every accession start with 9999999997?

APP NTC notices are filed onto EDGAR by the SEC itself, not by the applicant fund. The leading 9999999997 segment in every accession is the SEC's pseudo-CIK used for documents the Commission issues. The applicant — a registered investment company, BDC, adviser, or affiliate seeking 1940 Act relief — is identified inside entities[] and by an EDGAR file number in the 812-XXXXX series.

How is APP NTC different from Form 40-APP and Form APP ORDR?

Form 40-APP is the applicant-authored exemptive application that initiates the matter. APP NTC is the SEC-authored public notice that opens the comment window. APP ORDR is the SEC-authored order that grants or denies the relief. All three share the same 812- file number across an application's lifecycle but live as separate EDGAR form types and separate datasets.

What time period does the dataset cover, and how often are records added?

Coverage runs from February 2009 — when EDGAR began carrying the APP NTC form code — through the present, with records added on the SEC's event-driven cadence, typically a few notices per week. The dataset is distributed as monthly ZIP containers; new records appear in the container for the month in which they are noticed.

What file format is the dataset distributed in?

The dataset is distributed as monthly ZIP containers. Inside each container, every accession is a folder containing a metadata.json file and a filename1.pdf rendering of the Notice. There are no HTML renditions, no exhibits, no images, and no XBRL files — the JSON identifies the filing and the PDF carries all substantive Notice text.

Which statutory provisions and rules are most commonly cited in these notices?

Most notices invoke Section 6(c) of the 1940 Act as the general exemptive authority. Other frequently cited provisions include Section 17(b), Section 17(d) and Rule 17d-1 (the foundation of co-investment relief), Section 12(d)(1)(J) and Rule 12d1-4 (fund-of-funds), Section 22(d) and Rule 22d-1, Section 23(c), and Sections 10(f), 6(b), and 57. The Notice-and-order procedure itself is governed by Rule 0-5.