Form CT ORDER Files Dataset

The Form CT ORDER Files Dataset is the corpus of confidential-treatment orders issued by the U.S. Securities and Exchange Commission and posted to EDGAR under the form type CT ORDER. Each record represents one Commission action — a grant, denial, partial grant, modification, or extension — disposing of a single registrant's confidential-treatment application under Securities Act Rule 406 or Exchange Act Rule 24b-2, and is delivered as a structured metadata.json envelope paired with the signed PDF order on Commission letterhead. Unlike most EDGAR submissions, the SEC itself is the filer of record (every accession number begins with the reserved filer-id prefix 9999999997), while the registrant whose exhibits the order protects is named inside the metadata's entities block and inside the order text. The dataset covers CT ORDER filings on EDGAR from May 2008 — when CT ORDER became a separately tagged submission type — to the present, spanning both the dense pre-2019 application-and-order regime and the sparser residual population that has persisted after the FAST Act Modernization rulemaking moved most material-contract redactions out of the Commission-order path. Records are distributed as monthly ZIP containers in which each accession folder holds exactly one PDF and one JSON file.

Dataset APIs

Dataset Files

What This Dataset Contains

The dataset captures the EDGAR-published Commission record of every confidential-treatment determination issued under one of two parallel rule frameworks. Securities Act Rule 406 (17 CFR 230.406) governs requests to redact material from exhibits filed with registration statements under the Securities Act of 1933. Exchange Act Rule 24b-2 (17 CFR 240.24b-2) governs requests to redact material from exhibits filed with periodic, current, tender-offer, going-private, and proxy filings under the Securities Exchange Act of 1934. Both rules require the applicant to substantiate that the redacted information qualifies as confidential commercial or financial information protected from public release by Exemption 4 of the Freedom of Information Act, codified at 5 U.S.C. 552(b)(4), and to submit an unredacted "complete" version of the exhibit to the Commission's Office of FOIA Services for in-camera review. The CT ORDER is the formal Commission instrument that grants, denies, modifies, or otherwise disposes of the requested protection.

Orders are issued by the Division of Corporation Finance for operating-company filings and by the Division of Investment Management for filings by registered investment companies and certain affiliates, in each case "for the Commission, pursuant to delegated authority" (17 CFR 200.30-1 and 200.30-5). Within Corporation Finance, individual orders are signed in the relevant office — most often the Office of Mergers and Acquisitions, the Office of Chief Counsel, or an industry assistant-director office.

The dataset is distributed as monthly ZIP archives. The form type has never adopted HTML as a primary presentation, so the PDF-plus-metadata pairing is the consistent shape of a record across the entire May-2008-through-present coverage window. Earlier years contain a higher proportion of orders rendered as scanned-image PDFs of paper-signed letters, with corresponding implications for OCR-based text extraction; later years are dominated by machine-typeset, text-extractable PDFs with typeset signatures. The metadata sidecar format and the accession-folder layout are uniform across all years.

Content Structure of a Single CT ORDER Record

What one record represents

One record in the Form CT ORDER Files Dataset corresponds to a single EDGAR submission of form type CT ORDER — that is, one confidential treatment order issued by the U.S. Securities and Exchange Commission and identified by a unique EDGAR accession number. The record bundles two artifacts: a structured metadata.json describing the EDGAR submission envelope, and the order document itself, a short PDF on Commission letterhead signed by a division officer acting under delegated authority. Each record therefore documents one Commission action in response to one confidential-treatment application by one registrant, almost always tied to one specific underlying disclosure filing whose exhibits contain the redacted material.

CT ORDER filings are unusual within EDGAR because the SEC, not the registrant, is the filer of record. Every accession number in this dataset is assigned under the SEC's reserved filer-id prefix 9999999997. The actual subject of the order — the registrant whose competitively sensitive information the Commission has agreed to keep confidential — is captured in the metadata's entities block via its true CIK, file number, IRS EIN, ticker, SIC, and state of incorporation.

Container layout and per-record file structure

Decompression of a monthly container yields a directory tree organized as <YYYY>/<YYYY-MM>/<accession-number-without-hyphens>/, with one leaf folder per CT ORDER filing (for example, accession 9999999997-25-000671 becomes folder 999999999725000671). Each accession folder is flat — no subdirectories — and contains exactly two artifacts:

• metadata.json — the EDGAR submission envelope, always present.
• The order PDF, conventionally named filename1.pdf — the SEC's signed order document.

The original EDGAR submission also generates a complete-submission .txt wrapper, which is referenced by URL in metadata.json (linkToTxt) but is not redistributed inside the folder. Image files, if any were attached, are excluded by the dataset. CT ORDER submissions are essentially always a single PDF in practice, so the per-record payload reduces cleanly to one structured-metadata file plus one order document.

The file types found in the dataset are PDF (the signed order) and JSON (the metadata sidecar). The linkToXbrl, dataFiles, and seriesAndClassesContractsInformation fields are empty because confidential-treatment orders carry no financial structured data and no fund series/class information.

metadata.json

The metadata sidecar describes the EDGAR filing envelope. Top-level keys include:

• formType — always the literal string "CT ORDER".
• accessionNo — the hyphenated EDGAR accession number, always beginning with 9999999997- (e.g., "9999999997-25-000671").
• filedAt — the EDGAR acceptance timestamp as an ISO-8601 string with timezone offset.
• description — a human-readable label, typically "Form CT ORDER - Confidential treatment order".
• linkToFilingDetails — direct URL to the primary CT ORDER PDF on sec.gov; the URL path embeds the registrant's true CIK (/Archives/edgar/data/<cik>/...).
• linkToTxt — URL to the EDGAR-aggregated complete-submission .txt.
• linkToHtml — URL to the EDGAR filing-index HTML page.
• linkToXbrl — empty for this form type.
• documentFormatFiles — array with one entry per document in the EDGAR submission. Each entry carries sequence, size (bytes, as a string), documentUrl, type, and where present a free-text description. The first entry is the order PDF with type "CT ORDER"; the second is the complete-submission text wrapper, typically with description "Complete submission text file".
• entities — array of registrant filer objects (see below).
• dataFiles — empty for this form type.
• seriesAndClassesContractsInformation — empty for this form type.
• id — a 32-character internal record identifier.

Each entities[] object describes the registrant the order is directed at, not the SEC. It carries:

• companyName — typically with a trailing role suffix such as "(Filer)".
• cik — the registrant's true CIK, distinct from the SEC's 9999999997 filer prefix in the accession number.
• fileNo — the SEC file number tied to the registrant (e.g., "005-93677" for an Exchange-Act-registered company).
• filmNo — the EDGAR film number for this acceptance.
• irsNo — the issuer's EIN.
• stateOfIncorporation — a two-letter US state code or non-US jurisdiction code.
• fiscalYearEnd — MMDD.
• act — "33" for Securities Act filings or "34" for Exchange Act filings; a direct structural signal of which rule framework (Rule 406 vs. Rule 24b-2) the order was issued under.
• sic — the SIC code with industry description.
• type — restates the form type ("CT ORDER").
• tickers — array of ticker symbols associated with the registrant.

The CT ORDER PDF

The order is a short, machine-typeset document on SEC letterhead — one page in the great majority of cases, occasionally extending to two when the exhibits list is long. Despite minor cosmetic variation across years and divisions, the internal anatomy is highly stereotyped and appears in the following order:

1. Header. The Commission's name, formatted as UNITED STATES / SECURITIES AND EXCHANGE COMMISSION, followed by the order date.
2. Title line. ORDER GRANTING CONFIDENTIAL TREATMENT UNDER THE SECURITIES EXCHANGE ACT OF 1934 for Rule 24b-2 applications, or ... UNDER THE SECURITIES ACT OF 1933 for Rule 406 applications. Less commonly the title reads ORDER DENYING CONFIDENTIAL TREATMENT or reflects a withdrawal disposition. The title line is the most reliable single field for classifying a record as a grant, denial, or other disposition.
3. Subject identifier. The registrant's legal name, the SEC File No. keyed to that registrant (e.g., 5-93677), and an internal CTR# tracking number (e.g., CTR#8492) — the SEC's monotonically incrementing sequence identifier for confidential-treatment requests. The CTR# does not appear in metadata.json and is recoverable only by parsing the PDF text.
4. Recital paragraph. Names the rule under which the application was made (Rule 24b-2 or Rule 406), identifies the underlying host filing whose exhibits contain the redactions (e.g., a Schedule 13E-3, Form 10-K, Form 10-Q, Form 8-K, S-1, S-4, F-1, N-1A, or other registered investment-company filing), and gives the date that host filing was filed. This sentence is the cross-walk that connects the order to the substantive submission it protects.
5. Determination paragraph. Cites the FOIA exemption relied upon — almost universally 5 U.S.C. 552(b)(4), the exemption for confidential commercial or financial information — and states that the relevant Division has determined not to publicly disclose the redacted material. For denial dispositions this paragraph is reframed as a determination that the applicant has not adequately demonstrated qualification under Exemption 4.
6. Exhibits list. Enumerates exactly which exhibits, or which portions of which exhibits, are covered by the order. Exhibit references follow the host-filing's exhibit-numbering convention (e.g., Exhibit 10.1, Exhibit (c)(7), Exhibit (d)(2)), and may include parenthetical scope qualifiers such as portions of or certain information in.
7. Time-period clause (when present). Older Rule 24b-2 grants frequently fixed an explicit expiration date for confidential treatment (through [date]), reflecting the pre-2019 requirement that applicants justify a finite period of protection. Many post-2019 orders omit an explicit term.
8. Signature block. For the Commission, by the Division of Corporation Finance, pursuant to delegated authority (or by the Division of Investment Management), followed by the signer's name and title (e.g., Chief, Office of Mergers and Acquisitions; Senior Special Counsel; Assistant Director). Contemporary orders carry typeset signatures; older orders sometimes appear as scanned images of paper-signed letters.

Included content

Each record carries the EDGAR envelope metadata plus the order document itself. Together these two artifacts capture: the registrant's identity (CIK, EIN, file number, ticker, SIC, state of incorporation, fiscal year end), the EDGAR acceptance timestamp, links back to the canonical sec.gov locations (filing-index HTML, complete-submission TXT, primary-document URL), the Commission's disposition (grant, denial, or other), the rule and statutory basis for the application (Rule 406 vs. Rule 24b-2; Securities Act vs. Exchange Act), the FOIA exemption relied upon, the identity and date of the underlying host filing whose exhibits are protected, the specific exhibits or portions of exhibits covered, any time period imposed, and the issuing division and named signer.

Excluded or separate content

Several adjacent artifacts are by design not present inside the per-record folder:

• The EDGAR-aggregated complete-submission .txt wrapper is referenced via linkToTxt but is not redistributed in the folder.
• Image files originally attached to the EDGAR submission are excluded by the dataset. CT ORDER submissions rarely contain images, so this exclusion is mostly nominal.
• The underlying confidential-treatment application itself — the registrant's substantive request, with its supporting affidavits, justifications, and unredacted exhibits — is not part of the EDGAR public submission and therefore not in the dataset. Applications are submitted to the SEC's Office of FOIA Services and held non-public.
• The host filing whose exhibits the order protects (the 10-K, 8-K, S-1, Schedule 13E-3, etc.) is a separate EDGAR submission with its own accession number. The CT ORDER record references it textually in the recital paragraph but does not embed it.

Changes in required content and practice over time

Through April 2019, Rule 406 and Rule 24b-2 required registrants to file an application requesting confidential treatment for any redacted information in a filed exhibit, and Commission staff reviewed each application before issuing an order. Under this regime, every redaction in a material contract, license agreement, supply agreement, or comparable exhibit triggered an application and ultimately an order, and grants frequently included finite time-period clauses reflecting the applicant's stated business justification.

In March 2019 the Commission adopted Release No. 33-10618 (the FAST Act Modernization and Simplification of Regulation S-K rulemaking), which amended Item 601(b)(10) of Regulation S-K to permit registrants to redact confidential information from most material-contract exhibits without filing a confidential-treatment application, provided the redacted information is both not material and would likely cause competitive harm if disclosure. Parallel changes were made for Form 8-K and certain other filings, and the amendments became effective in April 2019.

The order-based regime continues to operate alongside this self-redaction regime. Registrants may still file Rule 406 or Rule 24b-2 applications — particularly to extend confidential treatment beyond the term of a previously issued order, to seek protection for filings outside the scope of the streamlined rules (such as Schedule 13E-3 going-private exhibits, certain Investment Company Act filings, and tender-offer exhibits), or where they prefer the certainty of a Commission determination. As a result, post-2019 CT ORDER volume declined sharply relative to the 2008-2018 era, and the mix of underlying host filings shifted toward going-private transactions, tender offers, investment-company matters, and extension-of-prior-order requests. Post-2019 orders also more often omit the explicit time-period clause that was common in earlier grants, reflecting more narrowly scoped requests.

The substantive legal architecture is otherwise stable across the dataset: every order rests on Rule 406 or Rule 24b-2, every grant invokes FOIA Exemption 4 at 5 U.S.C. 552(b)(4), and every order is issued under delegated authority from the Commission to the relevant division.

Interpretation and extraction notes

Several nuances matter when working with these records.

The accession-number prefix 9999999997 is universal for this form type and identifies the SEC as filer of record; it is not the registrant's CIK. Cross-walking from a CT ORDER to the registrant requires reading entities[].cik (or extracting the CIK from the linkToFilingDetails path, which takes the form /Archives/edgar/data/<cik>/...).

The entities[].act field is a fast structural signal of the rule basis: "33" indicates a Securities Act Rule 406 order, "34" an Exchange Act Rule 24b-2 order. The PDF title line carries the same information in human-readable form and additionally distinguishes grants from denials and other dispositions.

The CTR# tracking number, the issuing division and office, the named signer, the exhibit list, the underlying host filing's identity and date, the FOIA-exemption citation, and any time-period clause are all PDF-only fields — they do not appear in metadata.json and require text extraction from the PDF body. For older scanned orders, this requires OCR.

The exhibits list uses the host-filing's own exhibit-numbering convention. Resolving an exhibit reference (e.g., Exhibit 10.1 or Exhibit (c)(7)) to the actual redacted document requires retrieving the host filing referenced in the recital paragraph; the dataset itself does not embed those host filings, but linkToFilingDetails and the registrant CIK provide enough information to navigate to the host filing on EDGAR.

Finally, denial orders, withdrawal-related orders, and orders modifying or extending earlier grants exist alongside the dominant grant population. They are distinguishable primarily by the title line and the body of the determination paragraph rather than by any structured-metadata field, so any classification pipeline must read the PDF text rather than relying on metadata.json alone.

Who Files or Publishes This Dataset, and When

Who files the record

The filer of a CT ORDER is the SEC itself, not the registrant whose information is protected. Each record is a confidential-treatment order issued by the Division of Corporation Finance or the Division of Investment Management, acting under authority delegated by the Commission, and posted to EDGAR by SEC staff. This inverts the normal EDGAR pattern: the registrant whose contracts or exhibits are the subject of the order appears inside the order text as the named party, but is not the EDGAR filer of the CT ORDER record.

The two relevant populations

Issuing population (the filer). SEC staff in two divisions:

• Division of Corporation Finance issues orders on applications from operating-company registrants under the Securities Act and Exchange Act.
• Division of Investment Management issues orders on applications from registered investment companies, BDCs, and entities under the Investment Company Act and Investment Advisers Act regimes.

Subject population (named in the order). Any registrant that previously submitted a confidential-treatment application. In practice this spans domestic operating companies filing registration statements (S-1, S-3, S-4, S-11, F-1, F-3, F-4) and Exchange Act reports (10-K, 10-Q, 8-K, 20-F, 40-F), foreign private issuers, smaller reporting companies, EGCs, and registered investment companies on N-series forms.

The dataset captures the Commission's order, not the registrant's underlying application.

The triggering event

A CT ORDER is event-driven, not periodic. The chain is:

1. A registrant files, or proposes to file, an exhibit containing commercially sensitive information, typically a material contract under Item 601(b)(10) of Regulation S-K (or its analogues for foreign and fund forms).
2. The registrant submits a confidential-treatment application (CTA) under Securities Act Rule 406 (17 CFR 230.406) for Securities Act filings, or Exchange Act Rule 24b-2 (17 CFR 240.24b-2) for Exchange Act filings, supplying the unredacted text, a justification, and a proposed term.
3. The reviewing Division evaluates the application against the substantive standard incorporated through FOIA Exemption 4 (5 U.S.C. 552(b)(4)), which protects trade secrets and confidential commercial or financial information.
4. The Division issues a written order granting confidential treatment (often for three, five, seven, or ten years), denying it, granting it in part, or extending a prior order. That order is posted to EDGAR as a CT ORDER filing.

There is no statutory deadline for issuance and no calendar cadence; each record marks the completion of a discrete adjudicative process initiated by the registrant.

Regulatory framework and the 2019 inflection

Core authorities:

• Securities Act Rule 406 — confidential treatment under the 1933 Act.
• Exchange Act Rule 24b-2 — confidential treatment under the 1934 Act.
• FOIA Exemption 4 — substantive standard for nondisclosure.
• Item 601(b)(10) of Regulation S-K — the exhibit rule that drives most material-contract redaction activity.
• Delegated authority to Corporation Finance and Investment Management to issue orders without full Commission action.

SEC Release No. 33-10618 (March 20, 2019), the FAST Act Modernization and Simplification of Regulation S-K rulemaking, amended Item 601(b)(10) to permit registrants to redact information from most material-contract exhibits without filing a CTA, provided the information is not material and is the type the registrant treats as private or confidential. This self-executing redaction regime moved most activity out of the application-and-order path, sharply reducing CT ORDER volume from late 2019 onward. Orders continue to be issued for filings outside the streamlined rule (notably certain Investment Management contexts and extensions of prior orders), but post-2019 volumes are materially lower than the 2008-2019 period.

Historical scope

The dataset covers CT ORDER filings on EDGAR from May 2008 to the present, when CT ORDER became a separately tagged EDGAR submission type. The underlying confidential-treatment regime predates EDGAR; pre-2008 orders exist in Commission files but not as structured electronic records under this code.

Important distinctions

• Filer vs. subject. The EDGAR filer is the SEC; the registrant whose exhibits are protected is named in the order. Treating the named registrant as the filer misclassifies the record.
• Order vs. application. This dataset contains the Commission's orders, not the registrant's CTA submissions (historically Form CT-1 or correspondence-style requests).
• Grants, denials, partial grants, extensions. All fall under CT ORDER. Extension orders are issued when registrants seek renewal of expiring confidential treatment.
• Corporation Finance vs. Investment Management. Different registrant populations and exhibit regimes; Corporation Finance dominates by volume.
• Streamlined redactions are absent. Post-2019 self-executing redactions under amended Item 601(b)(10) generate no CTA and no order, leaving no CT ORDER trace.
• Foreign private issuers appear in the subject population on the same basis as domestic issuers; the form type does not distinguish them.
• Other fund/adviser confidentiality regimes (for example, nonpublic portfolio information rules) follow separate procedures and may not surface as CT ORDER records.

The defining feature: CT ORDER is a Commission-issued adjudicative document deposited into EDGAR in response to a registrant-initiated process governed by Rule 406, Rule 24b-2, FOIA Exemption 4, and Item 601(b)(10) as modernized by Release No. 33-10618.

How This Dataset Differs From Similar Datasets or Filings

A CT ORDER is the Commission's written disposition of a confidential-treatment application — not a registrant disclosure, not a periodic filing, and not an enforcement action. That narrow nature makes it easy to confuse with several adjacent records: the underlying CTA, the host filing carrying the redacted exhibit, post-2019 inline redactions under Item 601(b)(10), other SEC orders and staff letters, and FOIA-related confidentiality records. The distinctions below are practical, not formal.

Closest related datasets and filing types

Confidential Treatment Applications (CTAs). The CTA is the registrant's input under Securities Act Rule 406 or Exchange Act Rule 24b-2; the CT ORDER is the SEC's output. CTAs contain the legal argument, proposed redactions, and competitive-harm justification; CT ORDERs contain only the disposition (grant, denial, or conditional grant), the confidentiality period, and any imposed terms. CTAs were historically paper-filed and largely absent from EDGAR; post-2019, unredacted material is reviewed off-EDGAR and the redacted exhibit becomes the public artifact. The two are paired but asymmetric: argumentative versus dispositive, registrant-authored versus Commission-authored.

Host filings carrying the redacted exhibit (10-K, 10-Q, 8-K, S-1, 20-F). The CT ORDER points to a specific exhibit — typically a material contract filed under Item 601(b)(10), such as a license, supply, or distribution agreement — but does not contain it. The host filing carries the redacted exhibit and the surrounding registrant disclosure. To reconstruct what was redacted, researchers must join CT ORDER records to the host filing by accession number, registrant, and exhibit identifier. Host filings are broad and registrant-authored; CT ORDERs are narrow, SEC-authored, and meta-documentary.

Post-2019 self-executing redaction regime (Item 601(b)(10)(iv); Release No. 33-10618, March 2019). The 2019 amendments allow registrants to redact immaterial, competitively harmful information from most material contracts without filing a CTA and without an SEC order. Redactions are marked inline (commonly "[***]") with a legend, and no Commission action is created or recorded. New CT ORDER issuance has fallen sharply since this rule took effect, persisting mainly for residual contexts — Investment Company Act filings, certain Exchange Act matters outside Item 601(b)(10), and extensions or modifications of pre-2019 orders. Inline-redacted exhibits overlap with CT ORDER coverage in subject matter but contain no order; they reflect a registrant-driven process that bypasses the Commission entirely.

Other SEC orders and staff letters (no-action letters, exemptive orders, EDGAR "ORDER" form variants).

• No-action letters: staff communications, generally not on EDGAR, addressing whether enforcement action would be recommended for a specific transaction. Not formal orders and not about redaction.
• Exemptive orders (e.g., Section 36 of the Exchange Act, Section 6(c) of the Investment Company Act): formal Commission orders granting substantive relief from statutory requirements. Far broader legal effect than CT ORDERs, which are confined to disclosure scope.
• Other EDGAR "ORDER" form codes: administrative proceeding orders (enforcement/adjudication) and trading suspension orders (market integrity). All share Commission authorship; only CT ORDER concerns permitted redaction.

FOIA-related confidentiality records. Rule 406 and Rule 24b-2 confidential treatment is procedurally adjacent to FOIA Exemption 4, and both restrict public access to commercially sensitive material. The regimes apply at different points: FOIA governs SEC-held records released on request; CT ORDERs govern what registrants may withhold from EDGAR exhibits at the time of filing. FOIA logs and request records are not a substitute dataset, and the overlap is conceptual rather than data-level.

Key differences at a glance

• Authorship: CT ORDER = SEC; CTA and host filings = registrant; no-action letters = SEC staff (not the Commission).
• Trigger: CT ORDER is event-driven by a specific CTA; host filings are periodic or transactional; post-2019 inline redactions have no trigger event.
• Content: CT ORDER states scope, duration, and conditions of redaction — nothing else. It does not contain the exhibit, the legal argument, or the redacted text.
• Legal effect: narrower than exemptive orders, more formal than no-action letters, distinct from FOIA exemptions.
• Coverage horizon: dense pre-April 2019; sparse afterward, limited to non-Item 601(b)(10) regimes and order modifications.

Boundary summary

CT ORDER is the authoritative record of Commission-granted confidential treatment, mostly for the pre-2019 era and now for a narrow residual set of filings. It is not interchangeable with the CTA (the input), the host filing (the exhibit's home), inline post-2019 redactions (no order issues), other SEC orders (different subject matter and legal effect), or FOIA records (different access regime). Studying redacted contract terms typically requires joining CT ORDER records to host filings; studying the modern redaction landscape requires pairing CT ORDER coverage with an exhibit-level dataset capturing inline "[***]" redactions in 10-K, 10-Q, 8-K, S-1, and 20-F exhibits.

Who Uses This Dataset

CT ORDER filings record SEC grants and denials of confidential-treatment requests under Securities Act Rule 406 and Exchange Act Rule 24b-2. Each order names the registrant, the exhibit, the scope of protected information, the protection period, the conditions imposed, and the grant or denial outcome. Those six fields drive a small, well-defined set of professional workflows.

Securities and disclosure counsel

Used as precedent when drafting confidential-treatment applications and self-redaction memos. Counsel pull orders by contract type (supply, license, distribution, settlement) to calibrate scope and protection length against granted durations (commonly three, five, seven, or ten years) and to read denial and partial-grant text for where staff drew lines on pricing, royalty rates, milestone payments, and customer identities.

M&A and commercial-contract attorneys

Used to anticipate which deal economics can survive public filing as exhibits. Attorneys map a target's prior orders and counterparty orders to specific exhibit references and scope language, then draft confidentiality carve-outs, public-filing covenants, and disclosure schedules accordingly. Grant histories on earn-out formulas, escrow mechanics, and non-compete radii inform post-closing 8-K redaction strategy.

IP and licensing counsel

Used to model redactions in collaboration, license, and supply agreements filed as material contracts. The scope language in prior orders shows which categories — upfront payments, tiered royalties, milestone schedules, field-of-use limits, manufacturing know-how — the staff has accepted, allowing counsel to mirror granular precedent when proposing redactions.

Deal due-diligence teams

Used for redaction-expiration tracking on a target's filed exhibits. The exhibit reference plus protection period flags contracts that will become publicly visible on a known date, justifies document requests for unredacted versions, and identifies unusually long protection windows that often mark strategically important agreements.

Forensic accountants and investigations teams

Used to reconstruct redaction histories of registrants under investigation. Order timestamps, exhibit identifiers, and scope descriptions show which contractual terms the registrant chose to hide and whether protection windows align with the period of alleged misstatement, generating leads for document requests and deposition outlines.

Competitive-intelligence analysts

Used as a directory of strategically sensitive contracts. Counterparty names, exhibit numbers, and scope categories signal the importance of a relationship even when terms are redacted, and protection-period end dates predict when redacted terms will surface.

Antitrust and industrial-organization researchers

Used for empirical work on contract opacity. Scope and exhibit fields identify families of vertical, MFN, or exclusivity agreements worth deeper investigation; aggregate grant patterns serve as evidence of where firms believe disclosure of pricing or volume terms would impair market position.

Investigative journalists and FOIA researchers

Used to target FOIA requests and to time coverage to redaction expirations. Registrant identifier, exhibit reference, scope category, and protection window let reporters request unredacted versions through staff correspondence and track Commission practice on denial rates and conditions over time.

Regulatory compliance and corporate secretary teams

Used to maintain the internal calendar of redaction expirations, refile obligations, and notification conditions tied to their own granted orders. The conditions field drives compliance triggers; peer orders support benchmarking of redaction practice.

Academic finance, accounting, and legal researchers

Used for empirical disclosure research. Registrant identifiers, exhibit references, protection periods, and grant/denial outcomes support panel studies linking confidential treatment to firm characteristics, industry concentration, and price behavior around expiration. Order text supports doctrinal work on the Commission's delegated-authority practice.

Machine-learning and NLP teams

Used as training and evaluation data. The PDF-plus-metadata pairing yields labeled examples for filing-type classifiers, named-entity extraction of registrant and exhibit references, date-span extraction for protection periods, and grant-versus-denial outcome prediction. RAG systems for securities-law research index the order corpus to answer precedent questions.

In each case the value sits in the same six fields — registrant, exhibit, scope, period, conditions, outcome — read through a different workflow.

Specific Use Cases

Concrete workflows the Form CT ORDER Files Dataset supports, grounded in the per-record payload (registrant identity, rule basis, host-filing reference, exhibit list, CTR#, time-period clause, grant-or-denial disposition).

• Build a redaction-expiration calendar across a portfolio. Parse the time-period clause and exhibit list from each pre-2019 grant PDF, join to entities[].cik and ticker, and emit a per-registrant calendar of dates on which previously protected exhibit portions become publicly inspectable. Output feeds analyst alerts, FOIA timing, and re-pull jobs against the host filing referenced in the recital paragraph.

• Benchmark CTA scope and protection length by contract type. Cluster orders by SIC, host-filing form (S-1, 10-K, 10-Q, 8-K, Schedule 13E-3, N-1A), and exhibit-numbering pattern (Exhibit 10.x, Exhibit (c)(x), Exhibit (d)(x)), then summarize granted durations and scope qualifiers ("portions of", "certain information in"). Used by counsel as a precedent table when calibrating new applications or self-redaction memos.

• Train and evaluate document-AI models on CT ORDER PDFs. Use the corpus as labeled data for: form-type classification against other EDGAR PDFs, grant-vs-denial-vs-modification classification from the title line, named-entity extraction of registrant name, file number, CTR#, signer name, signer office, and exhibit references, and date-span extraction for the time-period clause. The text-typeset post-2010s subset and the OCR-required scanned-image subset together provide a realistic clean-vs-noisy split.

• Join orders to host filings to study the redacted-to-unredacted lifecycle. Resolve each recital paragraph's host-filing reference (registrant + filing date + form type) to the host filing's accession number on EDGAR, retrieve the redacted exhibit at filing time, and re-retrieve the same exhibit after the order's protection period expires. Produces matched pairs of redacted and unredacted contract text suitable for studying which terms (royalty rates, MFN clauses, milestone schedules, customer names) firms most often hide.

• Mine delegated-authority decision patterns for FOIA and administrative-law research. Aggregate the signature block across orders to build a panel of issuing offices (Office of Mergers and Acquisitions, Office of Chief Counsel, industry assistant-director offices, Division of Investment Management) and named signers, then cross-tabulate against disposition (grant, denial, modification, extension), rule basis (Rule 406 vs. Rule 24b-2), and CTR# sequence to study throughput, denial rates, and signer-level practice over time.

• Track the post-2019 residual order population. Filter to orders dated April 2019 onward and segment by host-filing form to quantify the surviving use cases — going-private exhibits under Schedule 13E-3, tender-offer exhibits, Investment Company Act filings, and extensions of pre-2019 grants. Output supports practice-area sizing for confidential-treatment counsel and contextualizes the volume drop relative to the self-executing Item 601(b)(10) regime.

• Reconstruct a registrant's confidential-treatment history for diligence or investigation. Filter the corpus by entities[].cik or fileNo, order by filedAt, and produce a chronology of every CT ORDER directed at the target along with CTR# numbering, exhibit references, host-filing dates, and protection windows. Surfaces gaps, denials, and clusters of redactions around specific transactions or alleged misstatement periods.

Dataset Access

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

This endpoint returns the dataset's metadata, the download URL for the full archive, and the list of all individual container files with per-container size, record count, last updated timestamp, and download URL. Use it to monitor which containers were updated in the most recent refresh run and to decide which containers to download incrementally. This endpoint does not require an API key.

Example response:

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          {
        

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            "datasetId": "1f13365b-9ae0-691c-81d3-9102d7c2aa96",
        

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            "datasetDownloadUrl": "https://api.sec-api.io/datasets/form-ct-order-files.zip",
        

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            "name": "Form CT ORDER Files Dataset",
        

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            "updatedAt": "2026-05-06T02:49:25.989Z",
        

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            "earliestSampleDate": "2008-05-01",
        

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            "totalRecords": 16267,
        

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            "totalSize": 217751093,
        

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            "formTypes": ["CT ORDER"],
        

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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-ct-order-files/2026/2026-05.zip",
        

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                "key": "2026/2026-05.zip",
        

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                "size": 13818783,
        

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                "records": 154,
        

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                "updatedAt": "2026-05-06T02:49:25.989Z"
        

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              }
        

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            ]
        

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          }
        

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

Downloads the complete dataset as a single ZIP archive containing every CT ORDER container (PDF filings and JSON metadata), covering all filings from the earliest sample date (2008-05-01) to the latest refresh. This endpoint requires an API key.

Download Single Container: https://api.sec-api.io/datasets/form-ct-order-files/2026/2026-05.zip?token=YOUR_API_KEY

Downloads one monthly container ZIP instead of the full archive, which is useful for incremental updates or fetching only a specific time range. Replace the year and month segments with any container key listed in the index JSON. This endpoint requires an API key.

Frequently Asked Questions

Who files a CT ORDER — the company or the SEC?

The SEC is the EDGAR filer of every CT ORDER, acting through the Division of Corporation Finance or the Division of Investment Management under delegated authority. The registrant whose exhibits the order protects is named inside the order text and inside the metadata's entities block, but is never the EDGAR filer of the CT ORDER record.

Why is the EDGAR filer CIK 9999999997?

9999999997 is the SEC's reserved filer-id prefix for confidential-treatment orders that the Commission itself posts to EDGAR. Every accession number in this dataset begins with 9999999997-, signaling that the filer of record is the SEC, not the subject registrant. To recover the registrant, read entities[].cik in metadata.json or extract the CIK from the linkToFilingDetails URL path (/Archives/edgar/data/<cik>/...).

What changed in 2019?

In March 2019 the Commission adopted Release No. 33-10618 (the FAST Act Modernization and Simplification of Regulation S-K rulemaking), which amended Item 601(b)(10) of Regulation S-K to let registrants redact immaterial, competitively harmful information from most material-contract exhibits without filing a confidential-treatment application or obtaining a Commission order. The amendments became effective in April 2019 and produced a sharp drop in CT ORDER volume; orders continue to issue mainly for filings outside the streamlined rule (such as Schedule 13E-3 going-private exhibits, Investment Company Act matters, tender-offer exhibits) and for extensions of prior orders.

What are CTR numbers?

CTR# is the SEC's monotonically incrementing internal sequence identifier for confidential-treatment requests (e.g., CTR#8492). It appears in the order PDF's subject identifier line alongside the registrant's legal name and SEC file number. The CTR# is not stored in metadata.json and must be recovered by extracting text from the PDF body.

What does the time-period clause mean?

When present, the time-period clause states the date through which confidential treatment is granted — typically expressed as through [date] and corresponding to grant durations of three, five, seven, or ten years. After that date, the protected exhibit portions become publicly inspectable. Older Rule 24b-2 grants frequently included an explicit term reflecting the pre-2019 requirement that applicants justify a finite period of protection; many post-2019 orders omit an explicit term.

How do I find the underlying redacted exhibit?

The CT ORDER does not embed the host filing or its exhibit. The recital paragraph in the PDF identifies the host filing by registrant, form type (e.g., 10-K, 8-K, S-1, Schedule 13E-3, N-1A), and filing date; combined with the registrant CIK in entities[].cik (or the CIK embedded in linkToFilingDetails), this is enough to locate the host filing's accession number on EDGAR and retrieve the specific exhibit referenced in the order's exhibits list.

What file format is the dataset distributed in?

The dataset is delivered as monthly ZIP containers organized as <YYYY>/<YYYY-MM>/<accession-number-without-hyphens>/. Each accession folder contains exactly two files: metadata.json (the EDGAR submission envelope) and the order PDF (conventionally named filename1.pdf). The dataset's only file types are PDF and JSON; CT ORDER submissions carry no XBRL, no data files, and no series-and-classes information.

How does this dataset differ from the underlying confidential-treatment application?

The CTA is the registrant's input — the legal argument, proposed redactions, and competitive-harm justification submitted under Securities Act Rule 406 or Exchange Act Rule 24b-2. The CT ORDER is the SEC's output — the disposition (grant, denial, partial grant, modification, or extension), any imposed conditions, and any time period. CTAs were historically paper-filed and are largely absent from EDGAR; this dataset contains only the Commission's orders, not the applications themselves, which are submitted to the Office of FOIA Services and held non-public.